Privacy Policy

1 Who is responsible for your personal information?

VintWire is an independent UK business operated by a sole trader.

For the purposes of UK data protection law, the operator of VintWire is the data controller responsible for personal information collected and processed through the VintWire website and services. The operator determines the purposes for which personal information is used and the means by which it is processed.

Privacy and data protection matters are handled directly by the operator of VintWire.

2 Information VintWire may collect

The information VintWire collects depends on how you use the website and services.

Account information

If you create a VintWire account, information processed may include:

• your email address;
• username and authentication information;
• your chosen display name;
• account creation and update dates;
• account and membership status; and
• information necessary to administer and secure your account.

Passwords are handled through Django's authentication system. VintWire does not store your password in readable plain text.

Membership and subscription information

If you use a VintWire membership or paid subscription, VintWire may process information including:

• your membership tier;
• subscription status;
• subscription start and end dates;
• billing email address;
• billing provider;
• identifiers supplied by the payment provider;
• billing period information; and
• whether a subscription is due to cancel.

Where payment processing is provided by a third-party payment provider, payment-card or bank details may be collected and processed directly by that provider rather than by VintWire.

VintWire's own systems are designed to store the information required to identify and administer the subscription rather than full payment-card details.

Watchlists, wishlists, saved searches and alerts

When you use VintWire's personalised market features, VintWire may store information about your use of those features, including:

• wines and vintages added to your watchlist;
• wines and vintages added to your wishlist;
• whether you have requested availability notifications;
• searches you choose to save;
• search filters associated with saved searches;
• wines and markets for which you create alerts;
• alert types and price thresholds;
• price-change thresholds;
• whether an alert is active;
• when an alert was last triggered; and
• your notification and alert-delivery preferences.

This information is used to provide the features you have requested and personalise your VintWire account.

Notifications and market-alert activity

VintWire may create records when an alert or other market condition relevant to your account is triggered.

These records may include information about the relevant wine, vintage, merchant, offer, price movement, time of the event and whether a notification was presented or dismissed.

Email and notification preferences

VintWire may store your preferences for service emails and notifications, including instant alerts and daily or weekly digests.

These service notifications are treated separately from consent to receive general VintWire marketing or newsletter emails.

VintWire Mailer and marketing communications

If you choose to join the VintWire Mailer or otherwise expressly request marketing emails from VintWire, VintWire may process:

• your email address;
• whether marketing consent is currently active;
• the date and time consent was provided;
• the source through which consent was provided;
• the date and time consent was withdrawn;
• relevant email-service-provider identifiers and status information; and
• information required to administer your subscription and unsubscribe requests.

Creating a VintWire account does not by itself constitute consent to receive the VintWire Mailer.

Where an account-registration form offers the option to join the VintWire Mailer, joining is optional and separate from registration.

If you join the Mailer before creating an account and subsequently create an account using the same email address, VintWire may associate the existing subscription with your account. Doing so does not change the consent status or create new marketing consent.

You may unsubscribe from marketing communications at any time.

Email delivery and engagement information

Where email-delivery technology provides this functionality, VintWire may process information about the delivery and interaction with emails sent through its services.

This may include whether an email was:

• queued;
• sent;
• delivered;
• opened;
• clicked;
• bounced; or
• unsuccessful.

VintWire may also retain relevant message identifiers and timestamps.

This information may be used to operate and troubleshoot email services, maintain delivery records, understand whether requested notifications are functioning correctly and, where appropriate, understand engagement with VintWire communications.

Where technologies such as tracking pixels or similar storage or access technologies require consent under applicable law, VintWire will use them in accordance with the choices available through its cookie and privacy controls.

Contacting VintWire

If you contact VintWire through a contact form or by email, VintWire may process information including:

• your name;
• email address;
• subject;
• message;
• the reason or category for contacting VintWire;
• merchant or business name, where relevant;
• website or other URLs you choose to provide; and
• correspondence between you and VintWire.

If you are logged in when making an enquiry, the submission may also be associated with your VintWire account.

Technical and website information

When you access VintWire, certain technical information may be processed as part of operating and securing the website.

Depending on the technologies in use, this may include:

• IP address;
• browser and device information;
• request and server-log information;
• session information;
• security information; and
• cookie or consent preferences.

Some of this information may be processed automatically by VintWire's hosting, security or infrastructure providers.

3 How VintWire uses personal information

VintWire may use personal information to:

• create and administer VintWire accounts;
• authenticate users and maintain website security;
• provide member-only or subscription features;
• operate watchlists, wishlists and saved searches;
• monitor market conditions for alerts requested by users;
• provide notifications and email alerts;
• administer subscriptions and membership entitlements;
• process and administer billing relationships;
• respond to questions, requests and contact submissions;
• provide the VintWire Mailer where a person has chosen to receive it;
• maintain records of marketing consent and withdrawal;
• operate, maintain, troubleshoot and improve the website;
• understand and improve the performance of VintWire services;
• prevent misuse, fraud or security incidents;
• maintain appropriate business and compliance records; and
• comply with applicable legal obligations.

4 Lawful bases for processing

UK data protection law requires VintWire to have a lawful basis for processing personal information. The appropriate basis depends on why the information is being used.

Contract

VintWire may process personal information where this is necessary to provide a service you have requested or to take steps at your request before entering into a contract.

This may apply, for example, to operating your account, providing membership functionality and administering paid subscriptions.

Legitimate interests

VintWire may process information where necessary for legitimate business interests, provided those interests are not overridden by your rights and interests.

These interests may include:

• operating and improving VintWire;
• securing the website and user accounts;
• responding to enquiries;
• maintaining appropriate records;
• understanding the operation and reliability of VintWire services;
• preventing misuse or fraud; and
• administering services requested by users.

Where VintWire relies on legitimate interests, it will consider the nature of the processing, its necessity and its potential impact on individuals.

Consent

VintWire relies on consent where required, including for the VintWire Mailer where consent is the applicable basis and for certain optional cookies, advertising, analytics or similar technologies where applicable law requires consent.

You can withdraw consent at any time. Withdrawal does not make processing carried out before withdrawal unlawful.

Legal obligation

VintWire may process and retain information where necessary to comply with a legal obligation, including applicable tax, accounting, regulatory or data protection requirements.

5 Marketing communications

VintWire does not treat creation of an account as automatic agreement to receive marketing emails.

Where VintWire asks you to consent to marketing email, the choice will be presented separately from account registration or other services.

VintWire maintains records of marketing consent so that it can demonstrate when and through which VintWire service consent was provided.

Every marketing email will provide an appropriate method for withdrawing from further marketing communications.

VintWire may retain sufficient information about an unsubscribe request to ensure that the person's marketing preference continues to be respected.

6 Cookies and similar technologies

VintWire uses or may use cookies and similar technologies to operate the website, maintain sessions, provide security, remember choices and, where enabled, measure website usage or advertising performance.

Some technologies are strictly necessary for the website to function and do not depend on optional advertising or analytics consent. Other technologies may be optional.

Where consent is required, VintWire will provide controls enabling you to make choices about optional technologies.

VintWire may use Google measurement or advertising services in the future or where such services are shown as active in VintWire's cookie controls. Optional Google analytics or advertising functionality will be configured in accordance with the consent choices made available on the website.

More detailed and current information about the technologies actually in use will be provided in VintWire's Cookie Policy and cookie-preference controls.

7 Affiliate and outbound merchant links

VintWire provides links to third-party wine merchants and other external services.

VintWire may record information about an outbound link being selected in order to:

• operate affiliate relationships;
• attribute traffic to VintWire;
• understand which VintWire features are being used;
• administer commercial arrangements; and
• prevent misuse or investigate technical problems.

Depending on the implementation in use, such records may include the offer or merchant selected, the page or feature from which the link was selected, the date and time, and, for authenticated services where appropriate, the associated VintWire account.

When you leave VintWire and visit a third-party website, that third party's own privacy and cookie practices apply. VintWire does not control how an independent merchant processes information on its own website.

8 Who VintWire may share information with

VintWire does not sell your personal information.

Personal information may be disclosed to service providers where reasonably necessary to operate VintWire.

Depending on the services in use, these may include providers of:

• website hosting and infrastructure;
• database and cloud services;
• email delivery;
• payment processing;
• security and technical services;
• website analytics;
• advertising measurement;
• professional advice; and
• other services necessary to operate VintWire.

These providers may process information on VintWire's behalf or, in some circumstances, act as independent controllers for their own processing.

VintWire may also disclose information where required by law, regulation, court order or another lawful authority, or where reasonably necessary to establish, exercise or defend legal rights.

As VintWire's third-party services are finalised, relevant providers will be identified more specifically where appropriate.

9 International transfers

Some service providers used by VintWire may process personal information outside the United Kingdom.

Where personal information is transferred internationally, VintWire will take appropriate steps required by UK data protection law to ensure that the information receives an appropriate level of protection.

Depending on the destination and provider, these measures may include UK adequacy regulations or appropriate contractual safeguards.

More specific information about relevant international transfers can be requested by contacting hello@vintwire.co.uk.

10 How long VintWire keeps information

VintWire keeps personal information only for as long as reasonably necessary for the purposes for which it was collected, including applicable legal, accounting, security and record-keeping requirements.

Retention periods vary according to the type of information and why it is held.

For example:

• active account information may be retained while the account remains open;
• watchlists, wishlists, alerts and saved searches may be retained while required to provide those account features;
• subscription and billing records may be retained where necessary for contractual, accounting, tax or legal purposes;
• contact correspondence may be retained for an appropriate period depending on the nature of the enquiry;
• marketing-consent and withdrawal records may be retained where necessary to demonstrate consent and respect future opt-out preferences;
• security and technical records may be retained for an appropriate period for security, troubleshooting and fraud-prevention purposes; and
• some information may be retained after an account closes where VintWire has a legal obligation or legitimate need to retain it.

VintWire will periodically review retention and remove or anonymise information when there is no longer an appropriate reason to retain it.

11 Security

VintWire takes reasonable technical and organisational measures designed to protect personal information from unauthorised access, loss, misuse, alteration or disclosure.

These measures may include access controls, authentication mechanisms, secure hosting and database arrangements, appropriate application security measures and restrictions on administrative access.

No internet service can guarantee absolute security, but VintWire will review and improve its safeguards as the service develops.

12 Your data protection rights

Depending on the circumstances, UK data protection law gives you rights in relation to your personal information.

These may include the right to:

• be informed about how your information is used;
• request access to personal information held about you;
• ask for inaccurate or incomplete information to be corrected;
• ask for personal information to be erased in certain circumstances;
• request restriction of processing in certain circumstances;
• object to certain processing;
• receive certain information in a portable format where the right to data portability applies; and
• withdraw consent where processing is based on consent.

These rights are not absolute and may depend on the circumstances and lawful basis for processing.

13 Complaints

If you have concerns about how VintWire handles your personal information, please contact hello@vintwire.co.uk so that the matter can be investigated.

You also have the right to raise a concern with the UK's data protection regulator, the Information Commissioner's Office (ICO).

Information about your data protection rights and making a complaint is available from the ICO.

14 Third-party websites

VintWire contains links to websites operated by wine merchants and other third parties.

This Privacy Policy applies to processing carried out by VintWire. It does not govern independent websites operated by third parties.

You should review the privacy information provided by the relevant third party when visiting another website.

15 Children

VintWire is a wine-market information service and is not designed or intended for children.

VintWire does not knowingly seek to collect personal information from children through its membership, marketing or personalised market services.

If VintWire becomes aware that personal information has been collected in circumstances where it should not have been, appropriate steps will be taken to address it.

16 Changes to this Privacy Policy

VintWire may update this Privacy Policy as the service develops, when new functionality or service providers are introduced, or where legal or regulatory requirements change.

The current version will be published on this page and the “Last updated” date will be amended when material changes are made.

Where a change materially affects how existing personal information is used, VintWire will take additional steps to inform affected users where appropriate.