Aquitaine Wines Privacy Policy

Introduction

This Privacy Policy explains what personal and other information is collected by Aquitaine Wines Ltd (a company registered in England and Wales, 13208400, and whose registered office is at 2 West Dunley Farm Cottages, Grittleton, Wiltshire, SN14 6PY, UK) (“Aquitaine Wines” or “we”) as part of its activities, and how we use that information.

We know how important your privacy is, and we believe it is your right to control how your personal information is used by us whether you are a Customer or Partner (Vendor, Curator or Affiliate). To make it easier for you to review those parts of the Privacy Policy which apply to you, we have divided the document into the following sections – please take the time to read Section 1 (General) and, if you are a Customer, or Partner the section that applies to you.

Section 1 – General (applicable to everyone)

Section 3 – Partner

Section 2 – Customer

In this Privacy Policy, the following expressions have the following meanings:

“Affiliate”; an entity that provides third-party PR, marketing and introduction services to customers on a referral or white label basis and remunerated via commission

“Agreement”; an agreement between (i) a Vendor and or Curator and (ii) TGBL Ltd.

“Computer”; a device used for accessing digital information including but not limited to desktops, laptops, tablets, mobile phones and other connected devices.

“Curator”; an entity that offers for resale to customers Vendor products and services, also acting as the primary service representative between Customers and Vendors

“Specialist”; an entity that offers advice, guidance or services via the Community Forum or Talent Desk.

“Customer”; an entity that acts in the capacity of a purchaser

“Optional Tools”; means (i) Data Analytics, (ii) Profile Maker (iii) such additional or alternative proprietary or third party software tools that Aquitaine Wines may launch from time to time.

“Personally Information”; (or “PI”); information from which the identity of a living individual may be determined. Examples of PI include, but not limited to, first and last name, home or other physical address, unencrypted email address, phone number or other contact information.

“Producer”; an entity that manufacturers or produces a food or drink product.

“Service(s)”; access to and use of (i) our sales channels, (ii) vendor admin panel, (iii) tablet-based apps (iv) optional vendor tools

“Partner”; an entity that sells or curates on our sites, including Producers, Curators, Vendors and Affiliates.

“Terms of Use”; Aquitaine Wines polices for site usage, including but not limited to Aquitaine Wines terms and conditions & privacy policy

“Usage Data”; non-Personal Information collected or created by the use of the Service.

“User” of “You”; anyone who interacts with our website, including but not limited to, Vendors, Curators and Customers.

“Us”, “Our” or “We”; Aquitaine Wines, our agents and our Partners.

“Vendor”; an entity that offers physical products, downloadable products, tickets or services for sale via Aquitaine Wines Ltd sales channels

“Vendor Admin Panel”; the login-protected web portal that may be accessed by Vendors to provide them with, among other things, access to Vendor account, product and order management tools

Section 1: General

This section applies to everyone who visits, or other interacts, with our Services.

At times, we need to process your personal data to help run our business and provide you with the Service. By using one of our Services you are accepting our terms and conditions of use, and you are confirming you’ve read this policy and consent to us using your information in the ways we describe. If you don’t want us to collect or process your personal information in the ways described in this policy, you should not use the Service.

We are not responsible for the content or the privacy policies of any Partner, or for the content they provide to maintain their selling profile and online store. We will intervene where we find our content and Partner policies are breached, and if no corrective action is taken we will remove the content and may suspend access to our Service.

Our Terms of Usage require all Customers to be at least 18 years of age. Those under 18 years of age and at least 16 years of age are permitted to use accounts only if the accounts are managed by someone over 18. No person under the age of 18 is permitted to purchase alcohol or alcohol-related goods. We will ask for verification the Customer is over 18 years of age for any alcohol-related Purchase and reserve the right to cancel any transaction where such proof cannot be validated. In many cases we may insist that a verifiable credit card is used for purchase to ensure the Customer is over 18 years of age.

Consent

By using the Services, you authorise Us to use your information in the United Kingdom, Ireland and any other country where We operate. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside. We will transfer personal data only to these countries to which we are permitted by law to transfer personal information, and we will take steps to ensure that your personal information continues to enjoy appropriate protections.

Information about you

When You register to use Our Services, we ask for information such as your name, e-mail address, postal address, and contact details and we then keep a secure electronic record of this information.

We will ask You questions at time of registration, and from time to time by email, that will give us information that will be used to improve your shopping experience with Us. You do not have to answer these questions, but if you do we are willing it will help us to communicate with you in a more relevant way.

If you contact Us by telephone, or via the live chat, we may record, store and use that communication for future training or business purposes. This includes, without limitation, use for the purpose of dispute resolution and/or complaints management.

We keep a record of any purchase/s made from any of the partners' stores, this enables both Partners and Ourselves to deal with any queries or problems you may have, and also to ensure any information We send to You is relevant.

We may keep a record of any e-mail correspondence You send Us, so we can track any problems or concerns with Partners or Partners products on our website.

If you would like to revise the information provided to Us as you feel it is incorrect, and/or You would like your information erased from our records, You can so do by contacting Us via email at support@AquitaineWines.com.

How we use your personal data

All information about You we collect via Our Services or through correspondence, including telephone calls, with You is used to operate and improve the service we offer you and to personalise our service.

We are committed to using your personal information only for:

1. Passing on your orders to your chosen Partner so they can supply goods and services to you and for customer administration. Our Partners may use subcontractors to process and provide your orders to you, including to assist with delivery and fulfilment.
2. Planning and managing Our business activities, including analysis of customers' shopping habits, tracking and reporting on advertisements and push notifications as well as product and style preferences of our customers.
3. Technical administration of our website.
4. Research.
5. Providing You with information about the services we offer.
6. Informing You of offers, news and products from our Partners or Ourselves.
7. To verify Your identity, Your Age (for purposes of Alcohol Sales legislation), or Your address using your credit card account, the electoral roll or credit reference agency

During the registration process you are given the opportunity to select some of the ways in which we may use your details.

These are the circumstances in which we may share some of your data with others:

1. When we instruct agents, contractors or third-party service providers to provide business operations support. This may include advertising and marketing advice and support, financial services and technology services. In all cases, such third parties are under contract with us that includes a restricted privacy clauses, dictating that such information solely be used in connection with the services they perform for us and not for their own benefit.
2. In the unlikely event that Our business assets are ever sold to or purchased by another company, then our data records shall be deemed a part of Our business. We will notify you at least thirty (30) days in advance of any such event and we will use reasonable endeavours to ensure that the new combined entity will follow the practices disclosed in this Privacy Policy.
3. We may provide limited data, only the minimum necessary data to fulfil their function, to outside research companies whom We may ask to contact You directly for your opinions on our service as well as our Partners' products and services.
4. If We are requested by the police or a regulatory or government authority investigating illegal activities to provide information concerning your activities whilst using the network, we shall do so.
5. If an Affiliate, or a Customer recommends You, as part of a referral scheme, we shall notify them that you are already a shopper with Aquitaine Wines. We will not share any of your purchase or other details with that customer.

How we protect your information

Information you provide to us may be transferred using Our Content Management Systems (CMS) (resulting in the temporary storage of your information on servers in different countries throughout the world) before being transferred to, and stored in, servers located in the EU and/or USA. By submitting any information to us, you agree to such transfer and storage, including (without limitation) storage in the USA and/or the EU.

We store your information on secure, firewall-protected servers that are located in secure facilities. These technology and security features, as well as strict internal guidelines, are designed to safeguard the privacy of your personal information from unauthorised access or improper use. We will continue to enhance security as new technology becomes available.

Access to your personal information is only granted to Aquitaine Wines and our Partners, never to third parties, and only where necessitated to carry out their business. Backups are run to reduce the risk of loss of information, and our Internet Servers are housed in secure facilities.

We have security measures in place including firewalls, proxy servers, aliasing and encryption to protect our customer database and access to this database is restricted internally.

While we take the steps described above to ensure that your information is secure on our system, no data transmission over the Internet can be guaranteed to be 100% secure. For your safety, we also employ independently verifiable Secure Socket Layer (SSL) encryption technology to protect in transit information across all online sales channels. All financial data for purchases on our Services are encrypted, and at no time are any financial details are stored on our Services. As a result, although we cannot guarantee 100% the security of any information you transmit to us, and you do so at your own risk, we have taken reasonable measures to protect such data.

How we use cookies on our website

A cookie is a small text file that is stored on a user’s Computer to improve user experience and for record-keeping purposes. We employ both session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies via your browser’s ‘clear cookie’ functionality. Unless you have adjusted your browser privacy setting to restrict cookies, We will use cookies on your Computer on visiting our Services.

Persistent cookies enable us to track and target your interests to enhance your experience while using our Services. For example, we use this data to understand how you interact with our website so we can make improvements to the information and design of our website. By agreeing to the terms of this Privacy Policy, you consent to the cookies referenced above being used on your computer or other device.

Some third-party applications and services used on our site also employ cookies, for instance Social Media, If you use the buttons that allow you to share products and content with your friends via social networks like Twitter and Facebook, these companies may set a cookie on your computer memory. Find out more about these here:

https://www.facebook.com/about/privacy/

http://twitter.com/privacy

http://www.google.com/intl/en-GB/policies/privacy/

Cookies we use with our Services

Managing cookies:

If cookies aren't enabled on Your computer, it will mean that Your shopping experience on Our website will be limited to browsing and researching; you won't be able to add products to your basket or buy them. You can set Your browser cookie policy to do this. Each browser is different, so check the 'Help' menu of your browser (or your mobile phone's handset manual) to learn how to change your cookie preferences but here are links to the most popular: -

Google Chrome

Internet Explorer

Mozilla Firefox

Safari

Opera

Google Analytics Opt Out

Managing your orders

We may monitor and review communications between you and our partners on our CMS. This is solely to ensure your orders and communications are managed appropriately by our Partners and our customer service team, and all communications are in accordance with the terms and conditions that we have in place with our Partners.

Our Partners’ privacy policies

Our Partners are bound by the same legislation as us, and if they gather or keep your information they must give you all relevant information about their policy, as well as giving you the opportunity to opt in or out of certain ways in which they might use that information.

We are however not responsible for our Partners policies, and do not warrant or guarantee that such Partner policies, or of any other companies that your personal information is passed to in accordance with this Privacy Policy, comply with data protection legislation. We are not responsible for any damages which You or others may suffer due to the loss of confidentiality of such information. When you place an order with any Partner, any personal details you submit at registration must by necessity be forwarded along with the order, so you can verify their privacy policy directly with them if you wish.

What we share with third parties

We use third parties’ analytics technologies which involve cookies being employed by our website and the collection of non-Personal Information about you, so we can understand how you use our website. By agreeing to the terms of this Privacy Policy, you consent to the cookies referenced above being dropped onto your computer or other device. We do not, and will not, provide your Personal Information to any third party outside of Our operations.

How you can help us protect your information

Please keep in mind that whenever you voluntarily disclose personal information online in non-protected environments, examples being message boards, through email, feedback and ratings, or in chat areas, that the information can be collected and used by others. If you post personal information online that is accessible to the public, you may receive unsolicited messages from unsolicited parties in return. If you are using a shared computer it is always advisable to close your browser window when you have finished your session to ensure others cannot access your personal information and correspondence. We cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. Once we receive your transmission, however, we endeavour to ensure that the data is secure on our systems.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time, so please review it frequently.

Contacting Aquitaine Wines Ltd

If you have any questions about this Privacy Policy, our practices, or your dealings with Us, you can contact us via email at support@AquitaineWines.com.

You have certain rights under the Data Protection Act 1998, including the right to be told what personal information we hold about you on our database. Should you wish to exercise that right, please contact us via the same email address with the subject “Data Protection Act Request”. Please note that under English law we are entitled to charge £10 for providing this information.

You have certain rights under the Data Protection Act 1998, including the right to be told what personal information we hold about you on our database. Should you wish to exercise that right, please contact us via the same email address with the subject “Data Protection Act Request”. Please note that under English law we are entitled to charge £10 for providing this information.

Should you wish to close your account and for use to delete all personal information you must in the first instance contact us via email at support@AquitaineWines.com.

Data Protection Service

You can obtain further information about data protection and privacy laws by visiting the Information Commissioner’s web site at: https://ico.org.uk

Section 2 – Customers

We do not intentionally capture any Personal Information. Regarding information which is not Personal Information:

We store Customers’ IP addresses, from which we can determine a Customer’s approximate geographical location (e.g. country or region). We need this information to optimize the links that are created/monetized to suit the geography of the Customer, and to provide aggregate reporting to Partners on the location of Customers using Our Services. We also use IP addresses as part of our efforts to reduce fraud and identify non-human browsing patterns.

We store information about the device that a Customer uses to access Services within our network, such as the browser type, browser version, and type of device. This helps us ensure we can diagnose and fix browser compatibility issues more swiftly, optimize our service to suit the preferred browsing environments, and provide aggregate reporting to Partners and Affiliates.

We store anonymous information, using cookies and device identifiers, about the websites within our network that Customers visit, which of our links Customers click on, and whether Customers make a purchase. This enables us to provide Customers with relevant and useful links and advertising to products and/or services in which they are likely to be interested, and to Partners and Affiliates from whom they are likely to want to buy.

We also store information about the Affiliate, i.e. the website page from which the Customer linked to Our site.

To assist Partners and Affiliates We collect information on visits and sales on Our sites, including but not limited to order value, products bought, and order identifiers. These are used to help Partners and Affiliates make better marketing and content creation decisions.

We use cookies to collect the information we need to optimise the product/Merchant links we monetize/create, and improve the service we provide. Cookies also enable us to carry out audience segmentation, i.e. we divide Customers into groups based upon defined criteria such as product usage, demographics, communication behaviour and media use. We synchronise anonymous cookie identifiers with third parties to enrich the Service and offer personalized experiences across the web. As you browse Our Services, cookies will be placed on your Computer so that we can understand what you are interested in. These anonymous profiles allow for the customization of websites and targeting of content, including but not limited to advertising. The techniques used do not collect any Personal Information.

For referral fees and commissions to be paid by Partners to Affiliates We work with Affiliate networks and other ad networks that manage the relationships between Us, Our Partners and Our Affiliates. The Affiliate and ad networks that we work with also use their own cookies to track if a sale has occurred, as most of these parties will only pay or be paid when a referral has been successful, i.e. a sale was completed. We do not have control over or access to these cookies and they are dropped and controlled by the affiliate and ad networks.

Section 3 - Partners

This section describes what information is collected by Us from Partners, and how that information is used by Us.

What information we collect from Merchants

When a Partner signs up to use Our Service, we collect and store various pieces of Personally Identifiable Information, including, but limited to:

• Contact Name
• Email address
• Telephone number
• Website information
• VAT Information
• AWRS information
• Company registration number
• Registered office address
• Trading address

We also collect and store information about when and how a Partner uses the Services we provide, including system usage reports and an audit trail for sensitive information. We also make regular backups of data that is stored for a period of up to 6 years.

How we use Partner information

We use this Partner information to perform our obligations under the Agreement, including:

• To assess the suitability of the Partner for the Service
• To contact the Partner to help them with registration, use and optimisation of the Service
• To communicate with the Partner matters related to Our Services
• To provide Partners with order and billing history information
• To improve the Services, we provide to Partners based on how Partners use Our service and the tools which We provide to them.
• To introduce Affiliates and Specialists who may wish to enter agreements with the Partner.

Updating Merchant information

Partners can edit any of their personal information within the Vendor Admin Panel. It is the Partners’ responsibility to:

• Protect against unauthorised access of their details, Vendor account and the Vendor Admin Portal
• To log-off from the Vendor Admin Portal not using it
• To keep all password secret.

Do Partners need to update their own privacy policies?

It is the responsibility of Partners to ensure that its privacy policy, ‘About Us’ or other relevant website section includes information concerning its the use of cookies, and that the Partner obtains each Customers consent to the privacy policy. The Partner should share full details about cookies employed. Partners should also provide a link for Customers with information regarding how they can disable the use of cookies.

If the Partner is based in the European Union, or has customers predominantly based in the European Union, the Partner must also seek the consent of the Customer before cookies are dropped via their site. Partners can decide how to obtain consent, but We suggest that Customers are requested to opt-in to the terms of the Partner privacy policy the first time they arrive on the Partner site. After initial consent, has been given by a Customer it need not be provided again, unless the purpose of cookies dropped via the Partner sites is changed. If We make relevant changes to Our cookies, we will notify you accordingly.

For U.S. properties, the Publisher must insert a link to the DAA opt-out program (currently available at http://www.aboutads.info/choices ) and the NAI opt-out program (currently available at http://www.networkadvertising.org/choices/ ).

For EU/EEA properties, the Publisher must insert a link to the EDAA opt-out program (currently available at http://www.youronlinechoices.eu/ ).

For properties in other regions, if the above rules are not sufficient for compliance with local legislation or regulation, please provide a link to Our Privacy Policy.

What we share with third parties

We will keep your Personal Information private, and will never sell, rent or otherwise disclose any of your PI, including your email address, to any third party without your prior and explicit consent. However, we may disclose your personal data to third parties if:

• We identify an Affiliate or Customer with which a Partner could have a commercial relationship, to make introductions.
• We sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• We are under a duty to disclose or share your personal data to comply with the requirements of any court, tribunal or governmental authority with competent jurisdiction or other legal obligation, or to enforce or apply Our Terms and Conditions or to protect the rights, property, or safety of Aquitaine Wines Ltd, our customers, or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.

Policy last updated 12th February 2021.