Policy key definitions:
“I”, “our”, “us”, or “we” refer to the business, London Barrelhouse Limited.
“you”, “the user” refer to the person(s) using this website.
GDPR means General Data Protection Act.
PECR means Privacy & Electronic Communications Regulation.
ICO means Information Commissioner’s Office.
Cookies mean small files stored on a users computer or device.
Key principles of GDPR:
Processing of your personal data
Under the GDPR (General Data Protection Regulation) we control and / or process any personal information about you electronically using the following lawful bases.
We are registered with the ICO under the Data Protection Register, our registration number is: ZA517235.
What data do we hold?
London Barrelhouse may hold data relating to you from a number of sources. The majority of the data we hold on you has been provided by you during the period of time that you have been a client, registered to receive our marketing information or since you attended an event or engaged with us in any other way.
Our records may include:
- Contact details – your postal address, email address details, telephone number, mobile telephone number – we update these details when you advise us that they have changed
- Your wine & whisky assets – the details of the wines that you have acquired from us and that we sell for you and the associated prices, your wine storage and insurance information including any storage and insurance that you have organised independent of London Barrelhouse but you have notified us of.
- Payment details– any card and bank details we have processed during the course of business with London Barrelhouse are securely managed in accordance with PCI/DSS
- Company Corporate Events – we may have a record of you attending a London Barrelhouse event.
- Personal details – during our account opening process we may have collected information about your marital status and details of your spouse and other family members which help us to deliver a more bespoke service.
Sharing your information
We may have to share some of the data you provide to us with our strategic partners who provide essential services to London Barrelhouse in order to deliver its services. Data may also be disclosed to other external organisations to facilitate payment for wine & whisky assets.
Data is only shared with external parties whose involvement is required to deliver London Barrelhouse’s business services. London Barrelhouse does NOT sell data to third parties or allow third parties to sell data where data is shared with them for throughput processes.
How do we protect your data?
Your data is securely held by London Barrelhouse which is only accessible to a limited number of authorised London Barrelhouse personnel, who are all bound by London Barrelhouse’s data protection policy.
London Barrelhouse ensures that appropriate data sharing agreements are in place prior to sharing your personal data with any partners.
If, as determined by us, the lawful basis upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant.
Your individual rights
Under the GDPR your rights are as follows:
- the right to be informed;
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to data portability;
- the right to object; and
- the right not to be subject to automated decision-making including profiling.
You also have the right to complain to the ICO via www.ico.org.uk if you feel there is a problem with the way we are handling your data.
We handle subject access requests in accordance with the GDPR.
Data security and protection
We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement.
Fair & Transparent Privacy Explained
We have provided some further explanations about user privacy and the way we use this website to help promote a transparent and honest user privacy methodology.
Email marketing messages & subscription
Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the “Processing of your personal data” above. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third party service provider of software applications that allows marketers to send out email marketing campaigns to a list of users.
Email marketing messages that we send may contain tracking beacons, tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.
Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time.
This Privacy Notice will be kept under review. Any changes will be updated on our website and communicated as appropriate. This Privacy Notice was last updated in May 2019.
Should you have any queries in relation to London Barrelhouse and our management of personal data please contact enquiries@LondonBarrelhouse.com. You can also contact the DPO if you have any questions or concerns about our processing of your personal data. You have the right to lodge a complaint with the Information Commissioner’s Office at www.ico.org.uk/concerns .