Privacy Policy

Welcome to the Enotria&Coe privacy policy.

Enotria&Coe respects your privacy and is committed to protecting your personal data.

The information set out in this privacy policy aims to inform you as to how we collect and look after your personal data when you visit our website https://www.enotriacoe.com, when you purchase wines, spirits or other products and services from us (through our website or by getting in contact with us directly), when you open a customer account and/or register with us, when you otherwise contact us and when we deliver you the products and services you have ordered from us. It will also tell you about your privacy rights and how the law protects you.

References to "you" or "your" are to you as an individual using our website or otherwise contacting Enotria&Coe (either on behalf of yourself, your business or another individual or organisation).

THE CONTENT

THE CONTENT
IMPORTANT INFORMATION
WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
IF YOU FAIL TO PROVIDE PERSONAL DATA
HOW WE COLLECT YOUR PERSONAL DATA
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS
CONTACT DETAILS AND COMPLAINTS

IMPORTANT INFORMATION

It is important that you read this privacy policy together with our Terms and Conditions -  www.enotriacoe.com/terms-and-conditions and any other privacy policy or fair processing notice we may provide on specific occasions (such as events or tastings) when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.
Please note that Enotria&Coe may update and amend this privacy policy from time to time and any changes will be posted on our website. This version was last updated in May 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. 
Our 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.
By accessing and continuing to use the Enotria&Coe website, you accept the terms of this privacy policy.

WHO WE ARE

Enotria&Coe is a trading name of Enotria Winecellars Limited and is a company incorporated in England and Wales with company number 01071904. Our registered office is 23 Cumberland Avenue, London, NW10 7RX and is referred to as "Enotria&Coe", “we”, “us” or “our” in this privacy policy
Enotria&Coe is a specialist wholesaler in wine, spirits and related products. We operate this website, alongside warehousing and distribution facilities and managing delivery services, to provide our products and services to our business customers and to operate customer accounts for these businesses. We also support our business customers with face-to-face product training (which we give to their staff and sometimes their consumers) and by helping them with their own events. As such, we do need certain personal information to be able to deliver our products and services and to operate our customer accounts.    
Enotria&Coe is a controller and we are responsible for your personal data. We are bound by applicable data protection laws in respect of the handling and collection of your personal data and are in the process of becoming registered as a data controller in England and Wales, with the Information Commissioner's Office (ICO).
If you have any questions about this privacy policy, including any requests to exercise your legal rights as set out in the 'LEGAL RIGHTS' section, please contact us using the contact details in the 'CONTACT' section.

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) or data relating to a corporate entity.

If you visit our website, or contact us about employment opportunities or to enquire about our products and services or are a customer making contact with us via our website or by telephone or email, we may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

  • Identity Data includes first name, last name, title and date of birth.

  • Contact Data includes home or business address, billing and delivery address(es), place of work, email address(es) and telephone number(s).

  • Financial Data includes our customers' card holder details (CHD), bank account details (bank name, account name, number, address and sort code) and credit references and checks.

  • Transaction Data includes details about order history, payment instructions, payment patterns (including details related to certain subscription payments) made by you.

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, use of cookies or other devices to store and sometimes track information about you (more details on our use of cookies is set out in the 'Cookies' section) and other technology on the devices you use to access this website or our software.

  • Profile Data includes your username and password, purchases and orders made by you, any membership or event history, account preferences, feedback and survey responses.

  • Usage Data includes information about how you use our website and/or software.

  • Marketing and Communications Data includes your preferences in receiving marketing from us, or from our clients or other third parties and your communication preferences.

Aggregated Data. We also collect, use and share 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 software 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.

Special Categories of Personal Data. We do not actively collect any special categories of personal data about you. This includes details about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health, sex life or sexual orientation. However, we may process certain special categories of personal data when you include such information in your CV which you (or a third party) send to us when making contact with us about employment opportunities with us.

Children. Our website is not intended for children and in this respect we do not knowingly collect data relating to children.

We do not actively collect any information about criminal convictions and offences.

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, to provide you with our products or services or open up a customer account). In this case, we may have to suspend or cancel a product or service you have with us but we will notify you if this is the case at the time.

HOW WE COLLECT YOUR PERSONAL DATA

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

  • Direct interactions. You may give us your Identity, Contact, Profile, Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:

    • ­ purchase any of our products or services by making contact with us via our website, via email or by telephone;

    • ­ set up a customer account with us (as an individual, as a sole trader or on behalf of a corporate entity);

    • ­ meet with one of our members of staff to discuss our products and services or otherwise contact us;

    • ­ make contact with our sales and support teams via email or telephone;

    • ­ request marketing and publications to be sent to you;

    • ­ subscribe to our newsletter;

    • ­ enter a competition, promotion or survey;

    • ­ email us about your interest in a job with us; or

    • ­ give us some feedback.

  • Automated technologies or interactions. As you interact with our website or software we may automatically collect Technical or Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see the 'Cookies' section.

  • Third parties or publicly available sources. We may receive personal data about you from various other third parties and public sources as set out below:

    • ­ Identity and Contact Data from individuals recommending, in a business-to-business context, that we make contact with you to introduce our products and services to you;

    • ­ Financial Data from credit reference agencies (such as Experian);

    • ­ Identity, Contact (and possibly Special Categories of Personal) Data from recruitment professionals who send us your CV; and

    • ­ Technical and Usage Data from analytics providers, such as Google, based outside the EU.

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 in the following circumstances:

  • Performance of Contract means processing your personal 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.

  • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best product/service and 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 contact us for further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities (please see the 'CONTACT' section).

  • Consent means where we have obtained your agreement to process your personal data. Consent must be freely given, specific, informed and be an unambiguous indication of your wishes for us to process your personal data (this may be collected by you ticking a box). Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending our newsletters and/or marketing material to you via email, post, phone, text message and social media. You have the right to withdraw consent to newsletters and/or marketing at any time by contacting us (please see the 'Opting Out / Unsubscribing', the 'Withdraw consent at any time' and the 'CONTACT' sections).

  • 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.

We have set out below, in a table format, a description of all the ways we plan to 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.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose / Activity

Type of Data

Lawful basis for processing including basis of legitimate interest

To process and deliver product orders and provide our services to you

Identity Data

Contact Data

Financial Data

Transaction Data

Marketing and Communications

Performance of a contract

Necessary for our legitimate interests (to provide our products and service to you)

To register you as a new customer, including running credit and other reference checks to ensure that we can give you credit and providing relevant details about benefits of the customer account

Identify Data

Contact Data

Financial Data

Transaction Data

Profile Data

Marketing and Communications Data

Performance of a contract

Necessary for our legitimate interests (to provide our products and service to you)

Necessary to comply with a legal obligation

To carry out our obligations arising from any contracts entered into between you and us

Identity Data

Contact Data

Financial Data

Transaction Data

Profile Data

Performance of a contract

Necessary for our legitimate interests (to provide our products and service to you)

Necessary to comply with a legal obligation

To manage our relationship with you or our client which will include:

- notifying you about changes to our terms and conditions or privacy policy; or

- asking you to provide a review or take a survey

Identity Data

Contact Data

Profile Data

Marketing and Communications Data

Performance of a contract

Necessary for our legitimate interests (to keep our records updated and to study how clients and their customers use our products and services)

Necessary to comply with a legal obligation

To receive and respond to enquiries from you about our products and/or services

Identity Data

Contact Data

Marketing and Communications Data

Necessary for our legitimate interests (to engage with stakeholders and to facilitate the growth of our business)

 

To receive and respond to sales, customer support and delivery related questions raised by you

Identity Data

Contact Data

Financial Data

Transaction Data

Technical Data

Profile Data

Usage Data

Marketing and Communications Data

Necessary for our legitimate interests (to be able to provide our clients and their customers with excellent customer service)

 

To enable you to complete a survey

Identity Data

Contact Data

Profile Data

Usage Data

Marketing and Communications Data

Necessary for our legitimate interests (to study how our clients and their customers use our software, to develop it and improve our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Identity Data

Contact Data

Technical Data

Usage Data

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

Necessary to comply with a legal obligation

To use data analytics to improve our website, software, marketing, customer relationships and experiences

Technical Data

Usage Data

Profile Data

Necessary for our legitimate interests (to define types of clients our services, to keep our website and software updated and relevant, to develop our business and to inform our marketing strategy

To make suggestions and recommendations to you about our products and services that may be of interest to you

Identity Data

Contact Data

Technical Data

Usage Data

Profile Data

Marketing and Communications Data

Necessary for our legitimate interests (to develop our products and services and grow our business)

Consent

To receive information about you from you or other third parties for the purposes of recruitment

Identity Data

Contact Data

Special Categories of Personal Data

Performance of a contract

Necessary for our legitimate interests (in finding and hiring the right people to help grow our business)

Consent

 

  • Prospecting. In a business-to-business context we may make contact with you to provide or seek information in connection with our products and/or services. The legal basis we rely on for making contact with you and processing your personal data is our shared legitimate interests in doing business together. When we make contact with you, you can exercise your right to object to such contact from us (please see the 'Object to processing' section).

  • Marketing.  We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

    • ­Unsubscribe link displayed on every email newsletter and marketing communication.

Marketing from Us

If you provide your express, opt-in consent, we may use your Identity, Contact, Technical, Usage and/or Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You may receive marketing communications from us after you have requested information from us or opened a customer account and, in each case, you have opted-in to receiving that marketing.

You can withdraw your consent at any time.

In some limited circumstances, we may contact you about similar products and/or services where you have purchased products or services from us and you have not opted-out of receiving this information. The legal basis on which we process personal data for these purposes is our legitimate interest to develop our products and services and grow our business.

You can ask us to stop sending you marketing communications at any time (please see the 'Opting Out / Unsubscribing' section).

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any company outside Enotria&Coe for marketing purposes. We have made it clear to our clients that they must do the same. If you think any of our clients are not operating in accordance with this policy, please let us know.

Opting Out / Unsubscribing

You can ask us or our clients to stop sending you marketing messages at any time by emailing us at gdpr@enotriacoe.com or by following the opt-out / unsubscribe links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, you may still receive messages for other purposes (such as providing the services to you).

  • Cookies. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. By continuing to browse the website, users are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of their computer. We only use (and store) non-essential cookies on your computer's browser or hard drive if you provide your consent.

Cookie

Purpose

Expiration Time

_ga

Used to distinguish users.

2 years

_gid

Used to distinguish users.

24 hours

_gat

Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_<property-id>.

1 minute

AMP_TOKEN

Contains a token that can be used to retrieve a Client ID from  AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.

30 seconds to 1 year

_gac_<property-id>

Contains campaign related information for the user. If you have linked your Google Analytics and AdWords accounts, AdWords website conversion tags will read this cookie unless you opt-out. Learn more.

90 days

__utma

Used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated every time data is sent to Google Analytics.

2 years from set/update

__utmt

Used to throttle request rate.

10 minutes

__utmb

Used to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exists. The cookie is updated every time data is sent to Google Analytics.

30 mins from set/update

__utmc

Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit.

End of browser session

__utmz

Stores the traffic source or campaign that explains how the user reached your site. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics.

6 months from set/update

__utmv

Used to store visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor level custom variable. This cookie was also used for the deprecated _setVar method. The cookie is updated every time data is sent to Google Analytics.

2 years from set/update


Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you disable or refuse cookies when browsing our website, please note that some parts of our website may become inaccessible or not function properly.

Except for essential cookies, all cookies will expire as outlined under the expiration column in the table above.

  • 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, you can contact us (please see the 'CONTACT' section).

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.

DISCLOSURES OF YOUR PERSONAL DATA

For the purposes set out in the 'HOW WE USE YOUR PERSONAL DATA' section we may have to share your personal data with the following parties:

  • Internal Third Parties such as other companies within the Enotria&Coe group, which includes subsidiaries and the ultimate Enotria&Coe holding company and its subsidiaries.

  • External Third Parties such as:

    • Service providers and developers based in (and outside) the UK who provide IT and system administration (including email, payment software and hosting) services.

    • Specialist suppliers for the dispatch and delivery of our products.

    • Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, legal, banking, accounting insurance and services.

    • HM Revenue & Customs, regulators, law enforcement bodies, police and other authorities based in the UK who require reporting of processing activities in certain circumstances (such as criminal activity, suspected or actual fraud or tax evasion).

    • Marketing and PR providers where you have agreed to a publication or article with us.

  • Specific Third Parties such as:

    • MailChimp a marketing automation platform based in the USA and who provide us with products and services that help us to run our email marketing programmes.

    • Sage Pay a payment gateway provider based in Europe who help us to provide secure financial transactions with our customers.

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

We do not process your personal data in any country outside the European Union (EU).

However, certain third parties are based outside of the EU, so their processing of your personal data will involve a transfer of data outside the EU.

Whenever we transfer your personal data out of the EU, 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.

  • 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.

  • 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 Europe and the US.

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

DATA SECURITY

We have put in place appropriate security measures (including SSL technology) 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.

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.

We will generally retain our clients' data for a period of 7 (seven)  years after a contract has ended, to ensure that we are able to assist you should you have any questions or feedback in relation to our products or services or to protect, or defend our legal rights, or for tax purposes.

Where you are a customer of one of our clients and your personal data is processed via our software, we refer you to the relevant client's retention policy. Your rights in respect of that client are also set out below (please see the 'YOUR LEGAL RIGHTS' section). Subject to you exercising your rights with the relevant client, we store the client's data, which may include your personal data, in accordance with the 'We will only retain your personal data for as long as necessary' section and the relevant client's instructions. On termination of any client arrangement, the client's data, including any of your personal data, are securely exported to our client and then permanently deleted from our software by us.

We have processed your personal data to provide you with marketing communications with consent, we may contact you at least every 12 (twelve) months to ensure you are happy to continue receiving such communications. If you tell us that you no longer wish to receive such communications, your personal data will be removed from our marketing lists (but will be added to a "do not contact" list).

Where we have processed your data for any other reason (such as where you have contacted us with a question in connection with services or in relation to recruitment), subject to the 'We will generally retain our clients' data for a period of 7 (seven) years after a contract has ended' section, we will retain your data for 12 (twelve) months.

In some circumstances you can ask us to delete your data; please see the 'Request erasure of your personal data' section for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS  

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are detailed below:

  • 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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • 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 withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us directly (please see the 'CONTACT' section).

  • No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

  • What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

  • 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.

CONTACT DETAILS AND COMPLAINTS

Our full details are:

Full name of legal entity:        Enotria Winecellars Limited

Contact person:                      [HR Director]  

Email address:                        [gdpr@enotriacoe.com]

Postal address:                       23 Cumberland Avenue, London, NW10 7RX

Telephone number:                 +44 (0)20 8961 5161

You have the right to make a complaint at any time to the ICO, the UK supervisory authority 

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