Privacy and Cookies

  • This is the Privacy Notice of Accolade Wines Limited (company number 137407) whose registered office is at Thomas Hardy House, 2 Heath Road, Weybridge, Surrey, KT13 8TB (“Accolade Wines”).
  • Accolade Wines has a commitment to privacy in accordance with the applicable privacy laws in the countries in which we operate, and are committed to protecting and maintaining your privacy. We understand that when interacting with us the privacy and confidentiality of your personal information is important to you. That is why we are committed to safeguarding your personal information.
  • This Privacy Notice relates to any personal information that identifies “you” meaning our customers and individuals who browse our website or use our apps. The types of personal information Accolade Wines collects will vary depending on the nature of your dealings with Accolade Wines. We refer to this personal information throughout this Privacy Notice as “personal data” and paragraph 3 below sets out further detail of what this includes.
  • This Privacy Notice describes the types of personal data we may collect, and how we collect and process this personal data.
  • Please read this Privacy Notice to understand how we may use your personal data. This Privacy Notice may vary from time to time so please check it regularly. This version was last updated October 2020.

1. DATA CONTROLLER

For the UK and EU the data controller will be: Accolade Wines Limited (company number 137407) Thomas Hardy House, 2 Heath Road, Weybridge, Surrey KT13 8TB.

2. OUR CONTACT DETAILS

For the UK and EU our contact details are set out below and if you wish to exercise your rights in respect of your personal data held by us, or to complain about a possible breach of privacy or for any other enquiries these should be directed to the Data Protection Manager using the following details:

By Email: privacy@accoladewines.com

or

By Post: FAO the Data Protection Manager, Accolade Wines Limited, Thomas Hardy House, 2 Heath Road, Weybridge, Surrey, KT13 8TB

3. WHAT PERSONAL DATA DO WE COLLECT?

The categories of personal data about you which we may collect are:

(a) Individual Data which includes personal data which relates to your identity, such as your first name, middle name, last name, username or similar identifier, marital status, title, date of birth and gender, and your billing address, delivery address, email address and telephone numbers which you provide to us in person, via our website, email, apps or by telephone;

(b) Account and Profile Data which includes personal data which relates to your account with us or profile on our website or apps, such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;

(c) Economic and Financial Data which includes personal data which relates to your finances, such as your payment card details;

(d) Sales Data which includes personal data which relates to the transactions you have conducted with us, such as details about payments to and from you, details of subscriptions to our services or publications and other details of products and services you have purchased from us;

(e) Information Technology Data which includes personal data which relates to your use of our website or apps, such as your IP address, login data, and traffic data;

(f) Audio and Visual Data which includes personal data which is gathered using our CCTV or other recording systems at our shops and locations in the form of images, video footage and sound recordings;

(f) Advertising and Marketing Data which includes personal data which relates to your marketing preferences, such as information about your preferences in receiving marketing materials from us and our third parties and your communication preferences as well as your personal interests (where you provide this to us); and

(g) Market Research Data which includes personal data which is gathered for the purposes of market research.

We may also create personal data about you, for example, if you contact us by telephone to make a complaint, for example about our services or goods, then we may make a written record of key details of the conversation so that we can take steps to address the complaint.

We also obtain and use certain aggregated data such as statistical or demographic data to improve the functionality of our sites and improve our customer service and experience (“Aggregated Data”). Aggregated Data may be derived from your personal data but will not be linked to or reveal your identity. For example, we may aggregate your operational data to calculate the percentage of users accessing a specific feature on our website or apps.

4. HOW WE COLLECT YOUR PERSONAL DATA

We collect your personal data from the following sources:

(a) Directly from you, either in person (at our locations or otherwise), via our website, via email or by telephone. This could include personal data which you provide when you:

  • apply for our products or services;
  • create an account on our website or apps;
  • become a member of one of our wine clubs;
  • engage with us on social media;
  • install or download one of our apps;
  • contact us with a query or complaint;
  • subscribe to our services or publications;
  • request information on our services or products or for other marketing to be sent to you;
  • enter into a competition or promotion;
  • complete a survey from us or give us feedback; and
  • when you visit any of Accolade Wines premises.

(b) Automated technologies, such as CCTV or other recording systems (in the event this is over the telephone we will notify you beforehand), cookies, server logs and other similar technologies. Please see Annex A for further details on personal data gathered using cookies. Audio and Visual Data may be collected on you for security purposes if you attend any of our premises.

(c) Third parties, such as:

  • analytics providers;
  • providers of technical, payment and delivery services; and
  • data brokers or aggregators.

(d) Publicly available sources or “trusted” sources, such as:

  • Tax authorities and credit and default reference agencies; and
  • Banks and other financial institutions.

5. HOW WE USE YOUR PERSONAL DATA & OUR BASIS FOR USING IT

(a)Where we are relying on a basis other than consent

We may rely on one or more of the following legal bases when processing your personal data for the purposes set out below. Where we process your personal data to meet our legitimate interests, we have identified what our legitimate interests are and put in place robust safeguards to ensure that these legitimate interests in carrying out the processing are not overridden by your interests, fundamental rights or freedoms.

Purposes for which we process your personal data

Type of personal data used (see above for more details)

The lawful basis on which we can do this

To register you as a new customer or a member of an Accolade wine club.
  • Individual Data;
  • Economic and Financial Data;
  • Account and Profile Data.

The processing is necessary:

  • to take steps at your request prior to entering into a contract; and
  • to perform a contract with you.

To process and perform any order placed by you, including:

· payments, fees and charges;

· collecting and

recovering money owed.
  • Individual Data;
  • Economic and
  • Financial Data;
  • Sales Data.

 

The processing is necessary:

  • to perform any contract entered into with you; and
  • for our legitimate interests (to recover debts due to us).

In order to comply with our own legal obligations, e.g. health and safety legislation, or to assist in an investigation (for example if there was an incident at our premises).
  • Individual Data;
  • Audio and Visual
  • Data;
  • Health Data.

The processing is necessary:

  • for us to comply with the law and social protection law; and
  • in the case of a health and safety incident recorded at any of our premises or in order to protect the vital interests of you or another.

In order to use your personal data in life or death situations and there is no time to gain your consent.
  • Individual Data;
  • Health Data.

The processing is necessary for us to:

  • comply with the law,
  • social protection law and
  • in order to protect the vital interests of you or another individual.

In order to manage our relationship with you including:

 

· to send you important notices such as communications about changes to our terms and conditions and policies (including this Privacy Notice);

· to provide you with important information about products or services you have ordered from us (e.g. a change of time or location due to unforeseen circumstances);

· to send you information you have requested;

· wine club membership;

· to deal with your enquiries; and

· to ask you to leave a review or feedback on us.
  • Individual Data;
  • Sales Data;
  • Account and Profile Data; and
  • Advertising and Marketing Data.

The processing is necessary:

  • to perform any contract entered into with you;
  • to comply with the law; and
  • for our legitimate interests in the management and

operation of our business, to keep our records updated and to study how customers use our products/services.

 

In order to administer and protect our business, deal with any misuse including of our website or apps and to comply with our security policies at our premises.
  • Individual Data;
  • Sales Data;
  • Information and Technology Data; and
  • Advertising and Marketing Data.

The processing is necessary for our legitimate interest in provision of administration and IT services, network security and prevent fraud.

In order to make suggestions and recommendations to you about goods or services that may be of interest to you, deliver relevant website or app content and advertisements to you and to measure or understand the effectiveness of our advertising.
  • Individual Data;
  • Sales Data;
  • Information and Technology Data; and
  • Advertising and Marketing Data.

The processing is necessary for our legitimate interests (to study how customers use our products/services, to develop our products and services and ensure our marketing is relevant to you, to grow our business and to inform our marketing strategy).

For internal purposes to use data analytics, to identify usage trends, determine and measure the effectiveness of promotional campaigns and advertising and to improve our website, apps products/services, marketing, customer relationships and experiences.
  • Individual Data;
  • Information and Technology Data;
  • Advertising and
  • Marketing Data;
  • Market Research Data.

The processing is necessary for our legitimate interests in defining types of customers for our products and services, to keep our website and apps updated and relevant, to develop our business and to inform our marketing strategy.

To communicate with you about, and administer your participation in, special, events, programs, promotions, any prize draws or competitions.
  • Individual Data;
  • Account and Profile
  • Data;
  • Sales Data;
  • Information and Technology Data;
  • Advertising and Marketing Data.

The processing is necessary for performance of a contract with you.

To sell, make ready for sale or dispose of our business in whole or in part including for intragroup activities, investment, financing or to any potential buyer or their advisers.
  • Individual Data; Account and Profile Data;
  • Sales Data;
  • Information and Technology Data;
  • Advertising and
  • Marketing Data;
  • Economic and Financial Data.

The processing is necessary for our legitimate interests in the sale or disposal of our business or assets and in the context of a business reorganization or group restructuring exercise.

In order to enforce or apply our terms of use, terms and conditions of supply and other agreements with third parties.
  • Individual Data; Account and Profile Data;
  • Sales Data; and
  • Economic and Financial Data.

The processing is necessary for our legitimate interests in protecting our business and property and recovering debts owed to us.

 

(b) Where we may rely on consent

We would like to use your personal data for a variety of different purposes. For certain of these purposes it is appropriate for us to obtain your prior consent. The legal basis of consent is only used by us in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way.

Where we rely on consent you may at any time withdraw the specific consent you give to our processing your personal data by logging into your account and managing your preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

6. WHO RECEIVES YOUR PERSONAL DATA

We may disclose your personal data to:

  • our group companies and affiliates or third party data processers who may process data on our behalf to enable us to carry out our usual business practices. Any such disclosure will only be so that we can process your personal data for the purposes set out in this Privacy Notice;
  • HMRC, legal and other regulatory authorities, including those who request your personal data or to report any potential or actual breach of applicable law or regulation;
  • external professional advisers such as accountants, auditors, bankers, insurers and lawyers;
  • law enforcement agencies, courts or other relevant party, to the extent necessary for the establishment, exercise or defence of legal rights;
  • third parties where necessary for the purposes of prevention, investigation, detection or prosecution of criminal offences, including but not limited to fraud prevention, or the execution of criminal penalties;
  • third parties which are considering or have decided to acquire some or all of our assets or shares, merge with us or to whom we may transfer our business (including in the event of a reorganisation, dissolution or liquidation); or
  • third parties operating plugins or content (such as Facebook, Twitter, Instagram) on our website or apps which you choose to interact with.

7. INTERNATIONAL TRANSFERS OF PERSONAL DATA

It is possible that personal data we collect from you may be transferred, stored and/or processed outside the European Economic Area and the United Kingdom. In connection with such transfers these are made on the following bases including:

  • the EU Model Clauses between us and the recipient and a copy can be obtained by using the contact details set out in paragraph 2; or
  • where the European Commission (or the UK Government, as appropriate) has decided that the relevant non-EU country ensures an adequate level of protection by means of an adequacy decision; or
  • Another reason applies so for example the transfer is necessary for legal claims, to protect the vital interests of an individual or necessary for the performance of a contract, public interest or with consent.

8. HOW LONG WE WILL STORE YOUR PERSONAL DATA FOR

We will store your personal data for the time period which is appropriate and in accordance with our data retention criteria set out below. We keep the length of time that we hold your personal data for under regular review. These reviews take place annually. The criteria include:

  • the purpose for which the personal data is used;
  • our legal obligations and other legal requirements; and
  • the type and amount of data and whether it is special data.

9. CONTRACTUAL OR STATUTORY REQUIREMENTS ON YOU TO PROVIDE PERSONAL DATA

(a) In certain circumstances the provision of personal data by you is a requirement: to comply with the law or a contract or necessary to enter into a contract.

(b)It is your choice as to whether you provide us with your personal data necessary to enter into a contract or as part of a contractual requirement. If you do not provide your personal data then the consequences of such failure could mean, for example, that we may not be able to perform to the level you expect under our contract with you.

10. ACCURACY OF YOUR PERSONAL DATA

It is important that the personal data we hold about you is accurate and current and we take all reasonable precautions to ensure that this is the case but we do not undertake to check or verify the accuracy of personal data provided by you. Please keep us informed if your personal data changes during your relationship with us by emailing us on privacy@accoladewines.com.

11. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

In addition to your ability to withdraw any consent you may have given to our processing your personal data, you have a number of rights in connection with the processing of your personal data, including:

  • the right to request access to your personal data that we process;
  • the right to request rectification of any inaccuracies in your personal data or, taking into account the purposes of our processing, to request that incomplete data is completed;
  • the right to request, on legitimate grounds (as specified in law) erasure or restriction in the processing of your personal data that we process or control;
  • the right to object, on legitimate grounds as specified in law, to the processing of your personal data;
  • the right to receive your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller; and
  • the right to lodge complaints regarding the processing of your personal data with the Information Commissioner’s Office or other relevant supervisory body. Please see https://ico.org.uk/concerns/ for how to do this.

If you would like to exercise any of the rights set out above, please contact us using the contact details set out in paragraph 2 above.

12. LINKS TO OTHER WEBSITES OR APPS

This policy only applies to Accolade Wines.

Our Echo Falls site uses a third-party platform called Adimo to create the “Where to Buy” feature on the Echo Falls websites. This is a separate plugin to the Echo Falls website and carries with it its own Privacy Policy and Terms of Use.

If you link to another website or app, you should remember to read and understand that website’s privacy policy as well. We are not responsible for any use of your personal data that is made by unconnected third party websites or apps.

Annex A: Cookies and Accolade Wines Websites

Accolade Wines, in common with many website providers, may use standard technology called cookies on its websites. Cookies are small data files that are downloaded onto your computer when you visit a particular website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. This can allow websites to recognise devices throughout the duration of a user’s visit or browsing session. These cookies are known as session cookies.

In some cases cookies persist across multiple browsing sessions, enabling the website to remember user preferences from previous visits. These cookies are known as preference cookies. Both session cookies and preference cookies reduce the requirement for the user to continually identify themselves on their journey through a website. For example, cookies may be used on this website to remember that the user has verified their date of birth, or to remember the details and the choices from submitted forms.

Some third party cookies may be placed on devices used to browse this website. These will typically be social media cookies, used by websites such as Facebook, to aid with the integration between any social media elements that the user may interact with and their social media profiles. Analytic cookies may also be placed to log visit statistics and anonymously track the way users browse this website.

This site has a Google Ads Tag installed, which we use for marketing retargeting purposes on Google’s Ads Network. Which allows you to be shown relevant advertising of our products on sites or advertising spaces that Google operate on. More information here: About Google Ads

Some areas of this website may invite users to participate, by adding comments or by rating items. This functionality works by incorporating a content management system. These content management systems may require content management cookies to be placed on the browsing device.

If you agree to our use of cookies, you can disable cookies by turning them off in your browser, however some areas of the website may not function properly if you do so. With the exception of essential cookies, which will be placed as soon you visit our site, our system will not issue any cookies without your consent. For more information on cookies and how to use them or block them visit www.allaboutcookies.org.

 

Necessary

Cookie Name

Expiry

Purpose

SHOP_SESSION_TOKEN

6 days

Necessary for the shopping cart functionality on the website.

XSRF-TOKEN

Session

Necessary for the shopping cart functionality on the website.

rc::c

Session

Used by Google Recaptcha to distinguish between humans and bots.

cart-quantity

Persistent

Used to track current cart quantity

lastVisitedCategory

Session

Used to track the users most recently visited category.

productsView

Session

Used to track the users preference for product view mode.

 

 

Statistics

Cookie Name

Expiry

Purpose

_dc_gtm_UA-#

1 day

Used for analytics purposes.

_ga

2 years

Used for analytics purposes.

_gid

1 day

Used for analytics purposes.

fornax_anonymousId

2 years

Used for analytics purposes.

STORE_VISITOR

Session

Used to track the current users visits.

 

 

Marketing

Cookie Name

Expiry

Purpose

_fbp

3 months

Used by Facebook to deliver a series of advertisement products on Facebook

index.php

Session

Used to determine the content of the shopping basket and provide related products/advertisements based on that information.