We are Noble Cask Wine Limited, a company registered in England and Wales and with its registered office at 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ (we might refer to ourselves as "Noble Cask Wine", "we", "our", "the Company"or "us"). This is the Privacy Policy ("Policy") of our managed investment services, retail services and the website hosted at www.noblecaskwine.com ("our Site") (together the "Services").
We are committed to handling personal information responsibly and in accordance with applicable data protection laws, including the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018.
For the purposes of data protection law, Noble Cask Wine Limited is the data controller of your personal information.
1. What information do we collect from you?
Some of the information we collect is classified as "personal data" under the GDPR as it is information relating to an individual such as a sole trader, a partnership, a company director, a beneficial owner, a trustee, a professional contact etc.
To use our Services, you will need to register for an account ("Account") with us through the account opening request form available on our Site (we call this your "Account Opening Form") as part of the onboarding process. You will need to be at least 18 years of age to create an Account and to use our Services.
The Company may collect and process the following types of personal data in connection with the services:
- Your name and sometimes your signature;
- Your date of birth;
- Your contact details such as your residential address, billing address, delivery address, email and telephone number;
- Your bank details and /or your card payment details;
- Information about your investment style, risk appetite and investment length so we can build your investment portfolio and furnish you with appropriate investment recommendations;
- Information about your financial background (i.e. your net worth, income, or job position) when you complete our online investment questionnaire;
- Copies of documents you provide to prove your age or identity (including your passport and driver's license). This will include details of your facial image, and if your passport it will include your place of birth, gender and nationality;
- Your IP address, location data, cookie & social identifiers (including for example gender and age range) and when you visit our website, the URL's of the webpages you have reviewed;
- Records of any correspondence and communication if you contact us, including information you supply if you report a problem with our Site or Services to us. This covers information we learn about you from: letters, emails, texts & other digital messaging, calls, face-to-face conversations you have with us.
- If you sign up for ongoing insights, newsletters, download reports or other promotional material from us, we will collect your contact information and marketing preferences.
2. How will we use this information?
We use personal data held about you in the following ways:
Information you give to us:
We will use this information to:
- Set up your Account and fulfil any orders you make with us, including: administering your account with us; verifying and carrying out payments that you make through our Site; and notifying you about changes to our Services.
- Manage your Account moving forward;
- In some circumstances to set preferences and make decisions about you and your account
- Provide you with information about our products and Services we feel may interest you, if you have given your consent to receiving marketing material from us at the point we collected your information, where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications.
- Ensure in our legitimate interest that: content from our Site is easy for you to read and understand on your devices; and we answer any questions you have and give you any information that you request.
Information we collect about you from your use of our Services:
We will use some information, in our legitimate interest, to help us:
- to run our Site and our Services and to help us spot problems;
- to understand how people use our Site so we can improve them;
- to keep our Site safe and secure;
- to make sure any advertising we send or show to you is relevant to you; and
- to allow you to participate in any interactive features of our service, when you choose to do so.
Information we collect about you from your use of our Services:
- Where permitted in our legitimate interest or with your prior consent, we will use your personal information for marketing analysis and to provide you with promotional update communications about our products.
- You can object to further marketing at any time by checking and updating your contact details within your account, or selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by sending us an email at info@noblecaskwine.com.
3. Sharing your information with others
To provide our Services, we work with the following carefully selected third parties. To do this, we may share your information with these third parties:
- the third parties responsible for arranging and fulfilling delivery of your wine order to our storage facility or to you (specifically your name and delivery address);
- any service providers hired to provide administrative, communication, wine storage, delivery, payment processing or insurance services; any group companies for business purposes;
- any affiliated companies; and
- any professional advisers
We may disclose your personal information to service providers who process data on our behalf in the course of providing services to the Company, including:
- Warehousing and delivery services who may contact you regarding the status of your delivery;
- Our customer relationship management service provider, direct marketing companies and mailing houses who help us manage our electronic and mailed communications;
- IT companies who support our website and other business systems;
- Banks and payment processors;
- Identification verification services to prevent or detect crime in compliance with current regulations;
- Data cleansing service providers to ensure your data is accurate;
- Third party debt collection agencies.
In some contexts, we may disclose the personal data to the following third parties:
- the Company's legal adviser for the purposes of providing legal advice to the Company;
- the Company's auditor for the purpose of providing audit services to the Company;
- HM Revenue & Customs and other regulatory bodies if we are under a duty to disclose or share your personal data in order to comply with any legal obligation.
We may also pass on your details to our wine producers & suppliers so they may invite you to events from time to time if you consent to this.
4. How long will you retain and store my data for?
Personal data is stored for varying lengths of time depending on the nature and purpose for which it was collected.
To determine the appropriate retention period for your 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 and whether we can achieve the purpose of the processing through other means.
Our retention of your personal data - and the criteria we apply to determine how long it is necessary for us to retain your personal data - is kept under review. In any case personal data will be retained for only as long as is necessary for the purpose for which it was collected subject to any statutory minimum periods.
For further information about this, please contact us at info@noblecaskwine.com.
5. How do we protect your information?
- All information you provide to us is stored on our secure servers.
- Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
- Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
- Our Site may, from time to time, contain links to external Sites. We are not responsible
for the privacy policies or the content of such Sites.
6. What are your rights?
In certain circumstances, under the GDPR, you will have the right to:
- request access to your personal data;
- request rectification of your personal data if it is inaccurate or incomplete;
- restrict the processing of your personal data (for example, if you want the Company to establish its accuracy or the reason for processing it);
- object to your personal data being processed;
- lodge a complaint with a supervisory authority (e.g., the Information Commissioner's Office in the UK by contacting them at https://ico.org.uk/concerns/ or by post at Wycliffe House, Water Lane, Wilmslow SK9 5AF);
- withdraw your consent to the processing, in the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose. Once the Company have received notification that you have withdrawn your consent, they will no longer process your information for the purpose or purposes you originally agreed to, unless they have another legitimate basis for doing so in law. Please note that the withdrawal of your consent will not affect the lawfulness of any processing of personal data based on your consent before it is withdrawal
7. Payment processing
Payment details you provide will be kept securely. We use a third party to process your payments and information which you supply to Stripe is not within our control and subject to Stripe's privacy policy here: https://stripe.com/gb/privacy
8. Changes to this policy
The Company reserves the right to update this Policy and any other relevant policies or procedures at any time. Any substantial changes that we may make to this Policy in the future will be provided to you by post or email depending on your preferred method of contact and posted on this page. The Company may also notify you in other ways from time to time about the processing of your personal data.
9. Contact Us
If you would like to contact us to access, rectify or request deletion of your personal data, object to the processing of your personal data, withdraw your consent to processing or make a complaint (if applicable), please contact the Company in writing by emailing us at info@noblecaskwine.com or to the following address
71-75 Shelton Street
London, WC2H 9JQ
United Kingdom
10. Marketing and Communication
You can unsubscribe or amend your preferences on how we communicate with you at any time using the following methods:
Email us directly at info@noblecaskwine.com
You can also unsubscribe from email communications by clicking the unsubscribe link at the foot of the email or alternatively you can change your preferences by clicking the update marketing preference link.
Please note that by unsubscribing from email communication, you will not receive any further marketing emails from Noble Cask Wine, including the ones from your designated sales representative if you have one.
