Privacy Policy

HomePrivacy Policy

We wanted to let you know that we have updated our Privacy Policy in line with new data protection laws, which come into effect on 25 May 2018. We take our data privacy responsibilities very seriously at Wines of Hungary UK, and we want you to understand and feel confident about how we collect, store and handle your personal data. Our new Privacy Policy explains this, and sets out the rights you have in relation to your personal data. If you’d like to find out more you can read our Privacy Policy, or visit our website.

PRIVACY AND DATA SECURITY

Privacy Policy

INTRODUCTION

 

Welcome to the Wines of Hungary UK Privacy Policy.

Wines of Hungary respects your privacy and is committed to protecting your personal data. This Privacy Policy will tell you how we look after your personal data when you visit our website and inform you of your privacy rights and how the law protects you.

Please use the Glossary at the end of this Privacy Policy to understand the meaning of some of the terms used in it. Our Cookies Policy is set out below, at the end of this Privacy Policy.

 

  1. IMPORTANT INFORMATION AND WHO WE ARE

 

PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy aims to give you information on how Wines of Hungary collects and processes your personal data through your use of this website, including any data you may provide through the website when you sign up to receive our marketing material. This website is not intended for people under the legal drinking age and we do not knowingly collect data relating to them. It is important that you read this Privacy Policy together with any other privacy notice on our website from time to time so that you are fully aware of how and why we are using your data.

CONTROLLER

Wines of Hungary UK is the controller and responsible for your personal data (collectively referred to as, “we”, “us” or “our” in this Privacy Policy).

 

CONTACT DETAILS

Our full details are: Full name of legal entity: Wine Communications, a partnership. Wines of Hungary UK operates, in the United Kingdom.

Postal address: Wines of Hungary UK, 48, Whittington Rd, Brentwood, CM13 1JX.

You can also contact us through our customer contact page.

 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk). In the UK, please read: https://ico.org.uk/for-the-public/raising-concerns/ for details of how to do this. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

 

We may need to update this Policy at any time and without notice and where we do this we will notify you by including pop up boxes on the website and/or emailing our customers. This Policy was last updated on 16 May 2018.

 

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us and periodically review your account settings on our website.

 

THIRD-PARTY LINKS

 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Policy of every website you visit.

 

  1. THE DATA WE COLLECT ABOUT YOU

 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

– Identity Data includes first name and last name.

– Contact Data means the data we use to contact you including your address, delivery address, email address and telephone number.

– Technical Data means details about the device(s) you use to access our website including your internet protocol (IP) address, browser type and version, location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

  • Profile Data includes your username (email address) and password, your login data
  • Usage Data includes information about how you use our website. This includes your browsing patterns and information such as how long you might spend on one of our webpages and what you look at and for on our website, the click stream to and from our website, page response times and page interaction information such as scrolling, clicks and mouseovers.

– Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

 

We also collect, use and share aggregated and/or anonymised data (“Aggregated Data”) such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

 

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, where you do not provide suitable delivery instructions to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

 

We use different methods to collect data from and about you including through:

– Direct interactions. You may give us your Identity Data, Contact Data and Marketing and Communications Data by using our website, filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you

  • purchase a product or service (including gift cards) through our website;
  • create an account on our website;
  • request marketing to be sent to you;
  • enter a competition; or
  • give us some feedback.

– Automated technologies or interactions. As you interact with our website, we may automatically collect Usage Data and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookies Policy for further details.

 

  1. THIRD PARTY SOURCES OF DATA/DATA SHARING:

Will never share this with a third party under any circumstances apart from as explained below. The lawful bases for sharing and processing this data is set out in the table below and please refer to the External Third Parties listed in the Glossary for further information.

 

  1. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data to contact you once a month with wine related content and occasionally event updates. We will also use your data where we need to comply with a legal or regulatory obligation.

See the Glossary at the end of this Privacy Policy to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent at any time by opting out or emailing us at info@winehungary.co.ukto be removed from our mailing list. We will only ever send emails to recipients with a legitimate interest in the content.  We always provide an unsubscribe link in each and every emailcommunication.

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. We do not conduct any automated decision making. We do not conduct any online behavioural tracking.

 

MARKETING

We only send electronic marketing – such as email marketing. We only share certain data with third party social media platforms in order to show you targeted ads when you visit them. We do this by:

– the use of cookies which capture your visits to our website. Please refer to our Cookies Policy for more information; and

– we may also provide these platforms with your email address to create ‘audiences’ of users fitting within a certain demographic/category so that we can target our marketing. Please check the social media platforms’ terms for more details of these services. This is in our legitimate interests of sending you direct marketing. See ‘Opting out’ below for details of how you can adjust your marketing preferences. Our Cookies Policy also explains how you can adjust your cookies preferences.

 

OPTING OUT

You can ask us to stop sending you marketing messages at any time by emailing us at info@winehungary.co.uk, or by following the opt-out links on any marketing message sent to you or by contacting us at any time via our contact page.

If you opt out of receiving email marketing from us, we will no longer share your email address with social media platforms (see ‘External Third Parties’ below). However, you may continue to see our ads through them, due to their general demographic targeting. Please check the social media platforms for more detail of how to opt out from seeing ads.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, or related correspondence, and we will continue to process such data in accordance with this Privacy Policy and only ever as permitted by law.

 

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.

 

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

  1. DISCLOSURES OF YOUR PERSONAL DATA

We require all third parties to respect the security of your personal data and to treat it in accordance with the law and they may only use your data for the purposes we specify in our contract with them. We will always work with them to protect your privacy.

 

  1. INTERNATIONAL TRANSFERS

Some of our External Third Parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

  1. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

You acknowledge that the Internet is not a completely secure medium for communication and, accordingly, we cannot guarantee the security of any information you send to us (or we send to you) via the Internet. We are not responsible for any damages which you, or others, may suffer as a result of the loss of confidentiality of such information.

 

  1. DATA RETENTION

 

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data: see ‘Your Legal Rights’ below for further information.

 

  1. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under UK data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of these rights, please Contact Us.

 

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

  1. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting Us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

THIRD PARTIES

EXTERNAL THIRD PARTIES

Email service providers – in order to send you relevant content, we share your details with our email service providers.

Social Media Platforms – We may make your name and email address available to companies in order to market our services to you through other platforms on the internet (e.g. Facebook). See the ‘Marketing’ section of this Privacy Policy above.

Analytics tools – we use analytics tools to track the way that users interact with our website.

Profiling tools – we use profiling tools to understand how you engage with our website and show you content we think will be most relevant to you, based on our understanding of your interests and preferences.

 

Cookie Policy

By visiting this website with your browser settings adjusted to allow cookies, you are consenting to Wines of Hungary UK using cookies for the purposes outlined below in order to provide you with a fully functional shopping experience.

This site uses cookies – small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymised tracking data to third party applications like Google Analytics. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser.

What is a cookie?

A cookie is a small text file which is downloaded and stored on your computer or mobile device by websites that you visit. Where cookie technology is not available, an anonymous identifier may be used. An anonymous identifier is a random string of characters used for the same purposes as a cookie.

Your browser accesses the cookie file only when you visit the website that generated it.

The information stored within any given cookie can only be accessed by the website that created it and cookies are limited to communicating only the information that you have disclosed to the site.

 

We use the following types of cookie:

Strictly necessary cookies. These are cookies that are required for the operation of our website.    Performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

The list below details the cookies used on Wines of Hungary UK. We have outlined who sets these cookies and their purpose.

 

Strictly necessary

Wines of Hungary UK uses cookies to enable some of the basic functionality that is required for you to browse on our website. The information collected through these cookies is only used for this purpose and is never shared or sold on to third parties.

Performance

Google Adwords, Facebook, Pinterest, use cookies (or, if applicable, anonymous identifiers) to track our own paid advertising activity. We use the information collected by these cookies to help us determine where our ads will be most effective online. Each individual advertiser uses its own tracking cookies and the data taken is not confidential data or interchangeable.

 Google Analytics (including Universal Analytics and Google Analytics for Display Advertisers)      Google Analytics use cookies (or, if applicable, anonymous identifiers) to collect data that helps us understand how people are using the site. We use this information to identify how and where we can improve the customer experience, and to help us determine where our ads will be most effective online. The data collected through these cookies is anonymous, does not collect specific customer data and is never shared with other third parties, other than Double Click Campaign Manager, which is a fully owned Google product.

Social Media plugins

Sites such as Facebook and Pinterest, serve cookies in order to be able to share and discuss Wines of Hungary UK content on social networks.

 

Duration of cookies:

Session (or Transient) Cookies

Session cookies are stored in your computer’s memory for the length of your browsing session. They become inaccessible after the session has been inactive for a time and are automatically deleted from your computer when the browser is closed. They allow you to move from page to page without having to log-in repeatedly.

Persistent (or Permanent) Cookies

Persistent cookies are stored in your computer memory and are not deleted when the browser is closed. They are used to keep your preferences for the website, so they will be remembered for next time you visit the website. They are also used to collect information about the numbers of visitors, the average time spent on a particular page and analyse shopping behaviour on the website. This information is used to find out how well the website works and where it can be improved.

Flash Cookies (or Locally Shared Objects)

You probably have Adobe Flash installed on your computer. Websites that contain Flash can also store small files on your computer that are used in the same way as cookies.

Flash cookies can also back up the data that is stored in other cookies. When you delete cookies, your Flash cookies are not affected. So a website may still recognise you if it backed up the deleted cookie information on a Flash cookie.

Sharing with social networks

If you use the buttons that allow you to share products and content with your friends via social networks like Twitter and Facebook, these companies may set a cookie on your computer memory. Find out more about these here:

https://www.facebook.com/about/privacy/
http://twitter.com/privacy
http://www.google.com/intl/en-GB/policies/privacy/

Managing cookies:

If cookies aren’t enabled on your computer, it will mean that your shopping experience on our website will be limited to browsing and researching; you won’t be able to add products to your basket or buy them. To enable and manage cookies, you can use your browser to do this. Each browser is different, so check the ‘Help’ menu of your particular browser (or your mobile phone’s handset manual) to learn how to change your cookie preferences.

 Google Chrome

 Internet Explorer

Mozilla Firefox

Safarihttps://support.apple.com/en-gb/HT201265

Operahttps://www.opera.com/help/tutorials/security/privacy/

Google Analytics Opt Out