Privacy Policy

1. About this privacy notice

1.1 Whisky- Online.com Limited (We) are dedicated to protecting your personal data. This privacy notice (together with our Website Terms of Use and any other documents referred to on it) will inform you of our processing practices in relation to your personal data, and will outline your privacy rights, and how the law protects you.  

1.2 Please read this privacy notice carefully as to fully understand your privacy rights, and our practices in processing your data.  

1.3 This privacy notice was last updated on [19 December 2018].

1.4 If you have any queries about this privacy notice, or our processing practices, please contact us on info@whisky-online.com.

2. INFORMATION ABOUT US AND HOW TO CONTACT US

2.1 We are Whisky-Online.com Limited a company registered in England and Wales. Our company registration number is 05974614 and our registered office is at Units 1-3 Concorde House, Charnley Road, Blackpool, Lancashire, United Kingdom, FY1 4PE.

2.2 You can contact us by phone on 01253 620376 or by email to info@whisky-online.com.

2.3 We may contact you by telephone or in writing to the email address provided in your Whisky Online account.

3. What data we collect about you

    1. We will collect and process the following data about you:

      1. Information you give us

        1. Identity and contact information. This includes your name, address, username, date of birth, gender, copies of your identification documentation, email address and telephone number.

        2. Financial information. This includes your credit card details and details of any other payment method details used by you.

        3. Profile information. This includes your username, password, order history, sale history, bidding history and feedback given on our site.

        4. Transaction information. This includes details of payments made to and from you, details of products you have purchased or sold on our site.

        5. Marketing and communication information. This includes any preferences in receiving marketing from us and any third parties, and your communication preferences.

      2. Information we collect about you

        1. Technical information. This includes your Internet Protocol (IP) address used to connect your computer to the Internet, you login information, browser type and version, time zone setting, browser plug-in types and versions, operating systems and platforms.

        2. Information about your visit. This includes the full Uniform Resources Locator (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interactions information (such as scrolling, clicks, and mouse- overs methods used to browse away from the page.

  1. how we collect data about you

    1. Visitors to our websites. We use a third party service to collect standard internet log information and details of visitor behaviour patterns. We collect this information to establish how many of our visitors are using particulars areas of our website. The information collected will only be used in a way that shall not identify you. We do not allow our third party service to identify you if you have visited our website.

    2. Cookies. When you visit our website, your data may be gathered through the use of cookies. Cookies are small files which are downloaded onto your computer when you visit our website. The cookie allows us to gather data which will help us improve our site and service.

You may reject cookies from our website by altering the settings on your browser. If you choose to reject cookies from our site, you may be able to access some areas of our site.

Any third party may advertisement may also incorporate cookies for which we have no control.

For more information about the cookies we use, please see our Cookie Policy.

  1. Online accounts and purchases. When you register for an online account or place an order, we will request personal data from you. The personal data will be used to verify for your identity for setting up your account or processing your order. This information will be used when you interact with us through our website.

Your personal data will be kept for a period of 12 months from the date that you last logged into your account.

    1. Direct interactions. We may collect personal data from direct interactions with you. This may include:

      1. personal data collected when we visit you to value a proposed lot;

      2. any information supplied by you when you directly interact with us. This may include through correspondence, telephone calls and any other direct interactions; and

      3. [ANY OTHER DIRECT INTERACTIONS].

  1. how we use your personal data

    1. Marketing. We may use your personal data for marketing purposes. This may include:

      1. supplying information to you from us relating to the goods we offer, which may be of interest to you; or

      2. using or permitting third parties to use your personal data, so that they may supply to you with information of goods that may be of interest to you, where you have given consent.

You may withhold your consent when providing your details to us. If you have given consent but you wish to revoke your consent, you may revoke your consent at any time by [giving notice].  

  1. Disclosure to third parties. We may share your personal data with third parties. This may include:

    1. logistics providers organising the delivery of your goods;

    2. service providers who provide IT and service administration support;

    3. professional advisors including legal advisors, bankers, auditors, insurers who provide consultancy, banking, legal, insurance and accounting services;

    4. HM Revenue and Customs, regulators and other authorities where required by law;

    5. third parties, to who we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change in the ownership or structure of our business occurs, then any new owners may use your personal data in the same way as set out in this privacy notice.

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.

  1. Transfers. Some of our third parties may be based outside of the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data to a third party outside of the EEA, we ensure that a similar degree of protection is afforded by ensuring that at least one of the following safeguards is implemented:

  1. 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;

  2. where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection as it is afforded in the EEA; or

  3. 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 EEA.

  1. 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 if 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, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Please note, 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.

  1. how we store your personal data

    1. Data security. We have put in place in appropriate security measures 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

    2. Data breaches. We have put in places procedures to deal with any suspected personal data breach. We will notify you and any applicable regulator of a breach where we are legally required to do so.

    3. How long we store your data. By law, we have to keep basic information about you as our customers (including Contact, Identity, Financial and Transaction Data) for six years after you cease to be a customer. This is for tax purposes.

We will also keep your purchase history for the duration of any warranty period applicable to the goods or services purchased, which may be in excess of the period stated above.  

  1. your legal rights

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

    2. Request to access 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.

    3. Request correction of the personal data we hold about you. This enable you to have any incomplete or inaccurate data we have about you corrected, though we may need to verify the accuracy of the new data you provide to us

    4. 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. Take note that we may not always be able to comply with your request for erasure of your personal data, for specific legal reasons which will be notified to you, if applicable at the time of your request.

    5. Objection 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 may object to our processing of your personal data. You also have the right to object where we are processing your personal data for direct marketing purposes. In some circumstances we may demonstrate that we have compelling legitimate grounds to process your data which overrides your rights and freedoms.

    6. Request restriction of processing your personal data. This allows you to ask us to suspend the processing of your personal data in the following situations:

      1. if you want us to establish the data’s accuracy;

      2. where our use of the data is unlawful but you do not want us to erase it;

      3. 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

      4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

    7. Request the transfer of your personal data to you or 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. Please 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.

    8. Withdraw consent at any time. Where we are relying on consent to process your personal data you may withdraw this consent at any time. However, this will not affect the lawfulness of any processing carried out before your 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.

    9. How to exercise your rights. If you wish to exercise any of the rights set out above, please contact us.

    10. You will not have to pay a fee to access your personal data (or to exercise any of your 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.

    11. 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.

    12. 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 numerous requests. In this case, we will notify you and keep you updated.

  2. your right to complain to the information commissioner’s office  

    1. You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would appreciate the opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance.