This policy applies to information held about clients and prospective clients, suppliers and prospective suppliers, contacts and all other persons about whom Tutto Wines Limited holds information. By ‘information,’ we mean personal information about you that we collect, use, share and store.
In this policy, “we,” “us,” and “our” means Tutto Wines Limited, trading as Tutto Wines and “you” means the individual to whom the information relates.
What we collect
• your name;
• your contact information such as your address, email address and telephone number;
• information about you that you give us in person at our events or by corresponding with us by phone, e-mail or otherwise; and
• information in relation to your purchase of our wines
How we collect information about you
• collecting information you give to us when you purchase any wines or visit us at events
• your use of the forms on our website.
What we do with the information we gather
We use your information to:
• provide information about our wines to you;
• keep you informed about wines, wine makers and events that we think you may find interesting;
• carry out our obligations arising from any agreements entered into between you and us;
• communicate with you;
• administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• keep our site safe and secure;
• comply with legal and regulatory obligations; and
• for security and to check your identity.
Legal basis for processing
Our processing of your personal information is necessary:
• for the performance of contracts to which you will be a party to and in order to take steps at your request prior to you entering into those contracts;
• for the purposes of legitimate interests pursued by us; or
• in order to comply with a legal obligation to which we are subject.
In relation to any processing of special categories of personal data, we will generally rely on obtaining specific consent from you at the time unless there is otherwise a legal requirement for us to process such information.
Where our processing is based on the legitimate interest grounds described above, those legitimate interests are: (i) collecting personal information to provide you with a smooth and efficient client experience; (ii) to make sure you receive updated information on Tutto Wines’ business activities; (iii) to provide the services you have requested; and (iv) for our own marketing and research.
Sharing your information
Except as expressly set out in this policy we will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.
The personal information you provide to us may be shared with third party companies, agents, contractors, service providers or affiliated companies if this is necessary to provide you with our wines, respond to your inquiries or for any of the purposes described in this policy.
We may also share your personal information with:
• law enforcement agencies, other governmental agencies or third parties if we are required by law to do so; and
• other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.
Transferring Your Information outside Europe
Your personal information may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) and may also be processed by staff operating outside the EEA who work for us, or for one of our service providers.
When we, or our permitted third parties, transfer your information outside the European Economic Area, we or they will impose obligations on the recipients of that data to protect your information to the standard required in the European Economic Area or otherwise require the recipient to subscribe to international frameworks intended to enable secure data sharing. In the case of transfers by us, we may also transfer your information where: (i) the transfer is to a country deemed to provide adequate protection of your information by the European Commission; or (ii) where you have consented to the transfer.
At any time, you have the right:
• to request access to or a copy of any personal data which we hold about you;
• to rectification of your personal data, if you consider that the information we are holding is inaccurate;
• to ask us to delete your personal data, if you consider that we do not have the right to hold it;
• to withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
• to ask us to stop or start sending you marketing messages as described below in the marketing section;
• to restrict processing of your personal data;
• to data portability (moving some of your personal data elsewhere) in certain circumstances;
• to object to your personal data being processed in certain circumstances; and
• to not be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.
Any request from you for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with data protection legislation. We will comply with our legal obligations as regards your rights as a data subject.
We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change by sending an email to firstname.lastname@example.org
Where you are one of our clients or have otherwise agreed to be contacted for marketing we may use your personal information to send you information about Tutto Wines, our producers, their wines and events. You can unsubscribe from receiving them at any time, details of how to unsubscribe will be included on each electronic mailing we send you.
You also have the option of “unsubscribing” from our mailing list at any time thereby disabling any further such e-mail or other communication from being sent to you by emailing email@example.com
We will action any opt out request from you without delay.
How long will we keep your information?
We will only keep the information we collect about you for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. This will involve us periodically reviewing our files to check that information is accurate, up-to-date and still required.
Where we are permitted to send you direct marketing communications we may retain your contact information necessary for this purpose, for as long as you do not unsubscribe from receiving the same from us. If you opt out from marketing, we will retain your information to enable us to respect your wishes to not be contacted for marketing purposes.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. You should be aware, however, that the transmission of information via the internet is not completely secure and therefore we do not guarantee the security of data you transmit to our website or via email.
Links to Other Sites
Questions, comments and requests regarding this policy are welcomed and should be addressed to firstname.lastname@example.org.
We can be contacted at our physical addresses and emails listed below and will try to respond as quickly as possible:
Tutto Wines Limited
303 Hoxton Street
London N1 5JX
If you are a UK resident and have any concerns about our use of your information, you also have the right (as a UK resident) to make a complaint to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK, via their helpline on +44 (0)303 123 1113.
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We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
We do not knowingly collect or solicit information from person under the age of 18 and we do not knowingly provide access to our website or market our services to anyone under the age of 18. No one under the age of 18 should submit any personal information to us and/or our website.
Changes to this policy
Any changes we make to our policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our policy.