The privacy of your personal information is important to us, this document sets out the information we will hold on your and how we will use it.
What information we collect relating to you and individuals connected to your business
We’ll only collect your information and information relating to individuals connected to your business, in line with relevant regulations and law. We may collect it from a range of sources. We may also collect information about you and individuals connected to your business when you or they interact with us, e.g. visit our websites, call us or visit one of our tastings, or email us.
This notice (Privacy Notice) applies to information held about you and individuals connected to your business by Vindependents employees as data controllers, as described below. It explains what information we collect about you and individuals who are connected to your business, how we’ll use that information, who we’ll share it with, the circumstances when we’ll share it, and what steps we’ll take to make sure it stays private and secure.
It continues to apply even if your membership with us ends. It should also be read alongside your membership terms and conditions. This Privacy Notice covers business relationships you have with us, including membership, share options and board membership.
Sometimes we may need to provide you with separate or further information about specific products and services.
Wherever we’ve said ‘you’ or ‘your’, this means you, any authorised person in your business, or deals with us for you and other related people (including authorised signatories and partners).
Parts of this notice relate only to individuals, and we have highlighted this where relevant. This includes individuals whose business does not have a separate legal identity (e.g. sole traders) and individuals connected to your business.
An individual connected to your business could be any guarantor, a director, officer or employee of a company, partners or members of a partnership, any substantial owner, controlling person, or beneficial owner, account holder of a designated account, recipient of a designated payment, your attorney or representative (e.g. authorised signatories), agent or nominee, or any other persons or entities with whom you have a relationship that’s relevant to your relationship with us.
You must ensure that any relevant individuals are made aware of this notice and the individual rights and information it sets out, prior to providing their information to us or our obtaining their information from another source. If you, or anyone else on your behalf, has provided or provides information on an individual connected to your business to us, you or they must first ensure that you or they have the authority to do so.
When we say ‘we’, we mean Vindependents t/a Tamar Selections which act as a data controller in respect of your personal data. Unless otherwise stated below, the data controller for the purposes of this notice will be Vindependents.
What information we collect relating to you and individuals connected to your business
We’ll only collect your information and information relating to individuals connected to your business, in line with relevant regulations and law. We may collect it from a range of sources and it may relate to any of our products or services. We may also collect information about you and individuals connected to your business when you or they interact with us, e.g. visit our websites or email us, call us or visit one of our tastings. Some of this information will come directly from you and individuals connected to your business.
It can also come from your solicitors, other intermediary, or other sources you’ve asked us to obtain information from. We might also get some of it from publicly available sources. The information we collect may include: Information relating to you and individuals connected to your business that you provide to us, or which others provided to us on your behalf e.g.:
- where you’re an individual, personal details (e.g. names). We’ll also collect this information about individuals connected to your business;
- contact details (e.g. address, email address, position in company, landline and mobile numbers);
- market research (e.g. information and opinions expressed when participating in feedback);
- user login data (e.g. login credentials for website member areas);
- other information about you and individuals connected to your business that you’ve provided to us by filling in forms or by communicating with us, whether face-to-face, by phone, email, online, or otherwise. Information we collect or generate about you and individuals connected to your business, e.g. :
- geographic information (e.g. about where you and the individuals connected to your business trade);
- marketing and sales information
- cookies and similar technologies we use to recognise you and individuals connected to your business, remember preferences and tailor the content we provide. (our current website doesn’t record cookies)
- risk rating information (e.g. credit risk rating, transactional behaviour and underwriting information);
- records of correspondence and other communications between you and your representatives and us, including email, instant messages, text and social media communications;
- information that we need to support our regulatory obligations.
Information we collect from other sources relating to you and individuals connected to your business, e.g.:
- information you’ve asked us to collect for you (e.g. credit references);
- information from third party providers (e.g. information that helps us to combat fraud or that relates to social interactions (eg credit checking)
How we’ll use your information and information relating to individuals connected to your business
We’ll only use information on you and individuals connected to your business where we have consent or we have another lawful reason for using it. These reasons include where we:
- need to pursue our legitimate interests;
- need to process the information to carry out an agreement we have with you;
- need to process the information to comply with a legal obligation;
- believe the use of information as described is in the public interest (e.g. for the purpose of preventing or detecting crime).
The reasons we use your information and information relating to individuals connected to your business include:
- delivering our services;
- carrying out your instructions
- managing our relationship with you, including (unless you tell us otherwise) telling you about products and services we think may be relevant for you;
- understanding how you use your membership and benefits;
- undertaking risk management;
- undertaking service improvement;
- protecting our legal rights and complying with our legal obligations;
- corresponding with solicitors, valuers, and third party intermediaries;
How we make decisions about you
We will not make automated decisions about you.
Marketing and market research
We may use your information and information relating to individuals connected to your business to provide information our products, and also products and services from our partners and other relevant third parties.
We may send marketing messages by post, email, telephone, text or secure messages. If you or individuals connected to your business wish to change how marketing messages are sent or wish to stop receiving these, please contact us in the usual way.
It may take us a short period of time to update our systems and records to reflect requests to stop receiving marketing messages, during which time you and individuals connected to your business may continue to receive marketing messages. Even if you tell us not to send marketing messages, we’ll continue to use contact details to provide important information, such as changes to your terms and conditions or if we need to tell you, or individuals connected to your business, something to comply with our regulatory obligations.
Who we might share information with
We may share your information and information relating to individuals connected to your business with others where lawful to do so including where we or they:
- need to in order to provide you with products or services you’ve requested (e.g. fulfilling a delivery request);
- have a public or legal duty to do
- need to in connection with regulatory reporting, litigation or asserting or defending legal rights and interests;
- have a legitimate business reason for doing so (e.g. to manage risk, enable another company to provide you with services you’ve requested;
- have asked you or the individuals connected to your business for your permission to share it, and you (or they) have agreed.
We may share your information and information relating to individuals connected to your business for these purposes with others, including:
- other Vindependents members;
- our suppliers;
Sharing aggregated or anonymised information
We may share aggregated or anonymised information within and outside of Vindependents with partners such as trade press and suppliers. Neither you nor individuals connected to your business will be able to be identified from this information (e.g. we may share information about general spending trends among members to assist in research).
How long we’ll keep information
We’ll keep information in line with our data retention policy. For example, we’ll normally keep your core financial data for a period of seven years from the end of our relationship with you. This enables us to comply with legal and regulatory requirements or use it where we need to for our legitimate purposes.
We may need to retain information for a longer period where we need the information to comply with regulatory or legal requirements or where we may need it for our legitimate purposes.
If we don’t need to retain information for this period of time, we may destroy, delete or anonymise it more promptly. Where you receive products and services from third parties (e.g. GlobaPay) who Vindependents have introduced you to, those third parties may keep your information, and information relating to individuals connected to your business, in line with additional terms and conditions that apply to their product and services.
Transferring information overseas
Your information and information relating to individuals connected to your business may be transferred to and stored in locations outside the European Economic Area (EEA), including countries that may not have the same level of protection for personal information. When we do this, we’ll ensure it has an appropriate level of protection and that the transfer is lawful.
We may need to transfer information in this way to carry out our contract with you, or to arrange visits from overseas wine representatives.
Credit reference checks
We may perform credit checks on your business with one or more credit reference agencies.
We may use this information to:
- assess if we can offer you credit;
- manage your account;
- trace and recover debts;
We’ll continue to exchange information about you with CRAs while you have a relationship with us.
To comply with the law and for our own legitimate interest to enable us to assess and manage risk, we can share details about your financial situation and financial history, and the financial situation with other wine merchants who you have requested we give a credit reference to.
This includes information:
- if you owe us money;
- if you haven’t kept up with your payments or paid off what you owe us or if you’ve agreed and stuck to a repayment plan.