Please read this company privacy policy carefully as it explains how we collect, use, store and share the information we collect about you, how you can exercise your rights in respect of that information and procedures that we have in place to safeguard your privacy.
WHO WE ARE
Carvers Hill Estate Ltd is a company registered in England under company no. 12695776 with registered office at Unit 10 Park Plaza, Battlefield Enterprise Park, Shrewsbury, SY1 3AF (“we” and “us“).
We understand that privacy is important to you and are committed to ensuring that your privacy is protected. We comply with the General Data Protection Regulation and other applicable data protection rules (including (a) the Data Protection Act 2018 and (b) marketing and cookies laws) (together with associated guidance) (“Data Protection Laws“).
We are responsible as a ‘controller’ of the personal information of those who visit our website, and the ‘processor’ of the data of our customer, suppliers and employees for the purposes of those laws.
WHAT DOES THIS POLICY COVER
This policy sets out the principles governing how we use your personal data. It also applies to your use of our website www.carvershillestate.com and you are deemed to have agreed to be bound by it upon your first use of the website.
Please note: this policy does not cover links to other websites. We are not responsible for the privacy policies and practices (including use of cookies) of other websites even if you accessed the third-party website using links from our Website. We recommend that you check the policy of each website you visit and contact the owner or operator of such website if you have concerns or questions.
HOW WE COLLECT INFORMATION
Most of the personal information we process is provided to us directly by you, either via our website, or through correspondence via email, phone or post. We also collect data via automated means, such as when you visit our website or use our app. We use cookies on our website to provide the best possible experience (See “Cookies” below).
We collect personal information from you when you:
- Make an enquiry or purchase our products and services
- Access our website
- Attend a wine tour, event or private dinner or login to our guest WiFi
- Register to receive our newsletter or blog updates
- Provide feedback on our products or services or complete a survey or market research questionnaire
- If you visit our shop, event space or offices, your image may be recorded on CCTV, which is in operation for the safety of our staff and customers
Finally, we also receive personal information indirectly, from the following sources in the following scenarios:
- When processing gift requests from customers where you are the recipient
- When you are referred to us via a referral scheme
- From 3rd parties who we have partnered with to deliver a product or service
- Personal identifiers or contact information from publicly available sources or data brokers
WHAT INFORMATION DO WE COLLECT
The personal information we collect depends on your particular activities and interaction with us. We aim to keep the amount of data we collect to a minimum limited to the following categories:
- Personal Identifiers and contact information, such as title, name, addresses, phone numbers and email addresses
- Transactional data, such as your order or accommodation booking history, your attendance at any of our events or the quantity and value of the wines you have stored with us
- Marketing and communications data, such as your preferences around how you want to hear from us and your product and service interests, as well as details of when you open marketing emails, and which links you access
- Feedback information, such as how you rated our products or customer service, or your responses to surveys and market research
- Dietary information
- Social identifiers, such as age, gender, socio-economic status
- Functional data such as registration and system data, as well as additional usage data
- Payment information and bank details
- Name, entry and exit dates and times and CCTV images from when you physically visit our site
You can browse our website anonymously and we will not collect your data. If you register with us or have an account with us we may collect the following :
- Technical information, including online identifiers, such as IP Address, browser type and version, time zone and location and operating system
- Information about your visit, such as times and location of log on or access, duration of sessions, clickstream and similar usage or system data
Please see our cookies policy for further information.
HOW WE USE YOUR INFORMATION
The UK General Data Protection Regulation (UK-GDPR) requires that we always have a lawful basis before processing your personal information. Therefore, we will only process your data if we have a contractual or legal obligation, a legitimate interest or where we have your consent.
We use the information you give us in order to :
- Fulfil contracts, orders, accommodation bookings, event bookings and collect payment
- Resolve customer queries and complaints, monitor quality, and provide training to our staff
- Send you service-related emails relating to your membership, the events or accommodation you have booked with us, wine you have stored with us or how your account may be used or managed
- Improve your experience of our products and services and for product development
- Detect and prevent faults, breaches of our network security, the law, or our contract terms
- Send you marketing communications, primarily via email but from time to time also by phone or post. If you wish to stop receiving some, or all, of our marketing communications, you can unsubscribe by following the instructions included in the footer of our emails or contact enquiries@carvershillestate.com
- Contact you to obtain feedback or perform market research
SECURITY AND HOW WE STORE YOUR INFORMATION
The security of your personal information is essential to us, and to protect your data we take a number of important measures including the following:
- Limiting access to your personal data to those employees, agents, contractors, and other trusted third parties such as logistics partners with a legitimate need to know, and ensuring that they are subject to duties of confidentiality
- We store the personal data you provide on cloud-based computer systems that have restricted user access and are in controlled facilities. Where possible, we avoid storing paper records of personal data
- Procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s where we are legally required to do so
- We use reasonable endeavours to install and have appropriate security measures in place in our systems and facilities to protect against the loss, misuse, or alteration of information that we have collected from you
We may transfer personal information to countries other than the country in which the data was originally collected (for example, outside the UK/ EEA) to provide you with our services. These countries may not have the same data protection laws as the country in which you initially provided the information and may not provide the same level of protection.
However, the Internet and email are not secure. Your communications may route through a number of countries before being delivered, may be intercepted by third parties and may not always reach the intended recipient – this is the nature of the World Wide Web/Internet. We cannot accept responsibility for any such unauthorised access or loss of personal information that is beyond our control.
You are responsible for protecting your password and username and must not share it with, or disclose it, to anyone.
We will store your personal information relating to transactional activities (like orders, bookings, stock movements etc) for a minimum of six years plus the current financial year after your last transaction with us. This is because HMRC requires wine businesses such as ours to keep all business records concerning excise goods for this time period.
We may keep records of transactions for longer periods, but we will ensure that the data is anonymised.
We keep data relating to marketing and our newsletter until you ask us to remove it.
Entry and exit logs are kept for 3 years, CCTV images are kept for between 10 and 20 days unless connected to an investigation, in which case they will be maintained for the duration of the investigation.
SHARING YOUR PERSONAL INFORMATION
We do not share your personal data with third parties except as provided in this privacy policy. We will not sell or rent it to third parties, nor will we share it with third parties for marketing purposes. We will only disclose your information:
- to our professional advisors (including without limitation tax, legal or other corporate advisors who provide professional services to us)
- to other trusted third party suppliers, business partners and sub-contractors with a legitimate need to know for business administration, support, processing, services, or IT purposes
- to analytics or search engines, that enable us to optimise and improve your Website experience
- to our regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, the police and any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters etc
- HMRC or other tax bodies or agencies to comply with our legal and regulatory obligations
We will disclose your personal information to third parties:
- in the event that we consider selling or buying any business or assets, in which case we will disclose your personal data to any prospective sellers or buyers of such business or assets
- in the event of any insolvency situation (e.g. the administration or liquidation) of Carvers Hill Estate Ltd
- if we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets
- in order to enforce or apply our terms and conditions
- to protect the rights, property, or safety of us, our staff, our customers, or others. This includes exchanging information with other companies and organisations (including without limitation HMRC, the local police or other local law enforcement agencies) for the purposes of staff and customer safety, crime prevention, fraud protection and credit risk reduction
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.
YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
Under the data protection legislation applicable in the UK you have a number of important rights to :
- access the personal information we hold about you
- require us to rectify any inaccurate personal information we hold about you
- ask us to delete the personal information we hold about you. This right will only apply where (for example): we no longer need to use the personal information to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data
- In certain circumstances, a right to restrict our processing of the personal information we hold about you. This right will only apply where (for example): you dispute the accuracy of the personal information held by us; or where you would have the right to ask us to delete the personal information but would prefer that our processing is restricted instead; or where we no longer need to use the personal information to achieve the purpose we collected it for, but you need the data for the purposes of establishing, exercising or defending legal claims
- In certain circumstances, a right to receive the personal information you have given us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal information to another organisation, at your request
- object to our processing of the personal information we hold about you where our lawful basis is for the purpose of our legitimate interests, unless we are able to demonstrate, on balance, legitimate grounds for continuing to process the personal information which override your rights or which are for the establishment, exercise or defence of legal claims
- for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you. We do not carry out any automated processing or profiling
- to withdraw your consent, where we are relying on it to use your personal information (for example, to provide you with brochures and newsletters)
COOKIES POLICY
“Cookies” are small files that reside on your computer’s hard drive, generally contain an anonymous unique identifier and are accessible only by the website that placed them there and not any other sites.
We may set and access Cookies on your computer. In addition, we may gather certain information about you, including details of your operating system, browser version, domain name and IP address, and the details of any website you linked from to the Website. We do this to help recognise you and your device to enable us to provide the services available on the Website and to monitor and improve the Website.
You can choose to enable or disable Cookies in your web browser. By default, your browser will accept Cookies, however this can be altered. In addition, you may delete Cookies that have already been placed on your hard drive. For further details please consult the help menu in your browser. Disabling or deleting Cookies may prevent you from using the full range of services available on the Website.
For further information on Cookies generally, visit www.aboutcookies.org or www.allaboutcookies.org.
HOW YOU CAN CONTACT US
We welcome your views about our website and this policy. If you would like to contact us with any queries or comments, request further information or exercise any of your available rights set out above, please get in touch with us in one of the following ways:
By Email : enquiries@carvershillestate.com
By Phone : 01672 551700
By Post : Write to us at
Carvers Hill Estate Ltd, Carvers Hill, Shalbourne, Marlborough, Wiltshire, SN8 3PS
HOW YOU CAN MAKE A COMPLAINT
We encourage you to contact us first if you have any queries, comments or concerns about the way we handle your personal information. However, if you are not satisfied with our handling of any request by you in relation to your rights or concerns, you also have the right to make a complaint to our supervisory authority, which is the UK’s Information Commissioner’s Office. Their address is: First Contact Team, Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.
CHANGES TO THIS POLICY
Any changes to this policy in the future will be posted on this page, and where appropriate, notified to you by email. We will also post a notice on the Website landing page and on appropriate pages on the Website. Please check back frequently to see any updates or changes to this policy.
Last updated: April 2024