Privacy Policy

Last Updated: 03/06/2025

1. Introduction

Welcome to emberandvine.co.uk (the "Website"). We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our Website and use our services (collectively, the "Services"). Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the Website or use our Services.

2. About Us (Data Controller)

Ember & Vine ("we," "us," or "our") is the controller responsible for your personal data.

• Company Name: Ember and Vine
• Contact Email for Data Protection Queries: info@emberandvine.co.uk

3. What Personal Data We Collect

We may collect and process the following types of personal data about you:

• Identity Data: Includes first name, last name, username or similar identifier, title.
• Contact Data: Includes billing address, delivery address, email address, and telephone numbers.
• Financial Data: Includes payment card details [Specify if you collect/process this directly or through a third-party payment processor. If using a third party, name them].
• Transaction Data: Includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data: Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.
• Profile Data: Includes your username and password [if you have user accounts], purchases or orders made by you, your interests, preferences, feedback, and survey responses.
• Usage Data: Includes information about how you use our Website, products, and Services.
• Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

4. How We Collect Your Personal Data

We use different methods to collect data from and about you including through:

• Direct interactions: You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you: 
  • Create an account on our Website;
  • Subscribe to our service or publications;
  • Request marketing to be sent to you;
  • Enter a competition, promotion, or survey;
  • Give us feedback or contact us;
  • Purchase our products or services.
• Automated technologies or interactions: As you interact with our Website, we will automatically collect Technical Data about your equipment, Browse actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. Please see our Cookie Policy [Link to your Cookie Policy] for further details.
• Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below: 
  • Technical Data from analytics providers such as Google;
  • Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services [Specify providers if applicable];
  • Identity and Contact Data from data brokers or aggregators [Specify if applicable];
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
  • [Specify other third-party sources]

5. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• To perform a contract: Where we need to perform the contract we are about to enter into or have entered into with you (e.g., to provide you with goods or services).
• Legitimate interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (e.g., to improve our services, for fraud prevention).
• Legal obligation: Where we need to comply with a legal obligation.
• Consent: Where you have provided your consent for us to do so (e.g., for direct marketing).

Purposes for which we will use your personal data:

• To register you as a new customer: 
  • Lawful basis: Performance of a contract with you.
• To process and deliver your order including managing payments, fees, and charges, and collecting money owed to us: 
  • Lawful basis: Performance of a contract with you; Necessary for our legitimate interests (to recover debts due to us).
• To manage our relationship with you (e.g., notifying you about changes to our terms or privacy policy, asking you to leave a review): 
  • Lawful basis: Performance of a contract with you; Necessary to comply with a legal obligation; Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
• To enable you to partake in a prize draw, competition, or complete a survey:
  • Lawful basis: Performance of a contract with you; Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
• To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data): 
  • Lawful basis: Necessary to comply with a legal obligation; Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud).
• To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you: 
  • Lawful basis: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy); Consent (for certain types of advertising or cookies).
• To use data analytics to improve our Website, products/services, marketing, customer relationships, and experiences: 
  • Lawful basis: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy); Consent (for certain types of analytics cookies).
• To make suggestions and recommendations to you about goods or services that may be of interest to you: 
  • Lawful basis: Necessary for our legitimate interests (to develop our products/services and grow our business); Consent (for direct marketing communications).

Marketing:

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can ask us or third parties to stop sending you marketing messages at any time by [Explain how users can opt-out, e.g., following the opt-out links on any marketing message sent to you or by contacting us].

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

6. Disclosure of Your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in the table in section 5 above:

• Internal Third Parties: [Specify if other companies in your group act as joint controllers or processors].
• External Third Parties: 
  • Service providers acting as processors who provide [Specify services, e.g., IT and system administration services, payment processing, delivery services, marketing services].
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers who provide [Specify services, e.g., consultancy, banking, legal, insurance, and accounting services].
  • HM Revenue & Customs, regulators, and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • [Specify other third parties, e.g., fraud prevention agencies, analytics providers, marketing partners].
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

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.

7. International Transfers

Some of our external third parties may be based outside the United Kingdom (UK) so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• 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 UK.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK (e.g., Standard Contractual Clauses or an International Data Transfer Agreement).

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

8. Data Security

We have put in place 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. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

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

9. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal 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, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

[You may want to specify retention periods for different types of data, e.g., "By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes."]

In some circumstances you can ask us to delete your data: see "Your Legal Rights" below for further information.

10. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data (commonly known as a "data subject access request").
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party).
• Request restriction of processing of your personal data.
• Request the transfer of your personal data to you or to a third party.
• Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact us at [Insert Email Address].

You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Cookies

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy [Link to your Cookie Policy].

12. Changes to This Privacy Policy

We keep our Privacy Policy under regular review. This version was last updated on [Date]. Any changes we may make to our Privacy 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 Privacy Policy.

13. How to Contact Us

If you have any questions about this Privacy Policy or our privacy practices, or if you wish to exercise any of your legal rights, please contact us using the details set out below:

• Email Address: [Insert Email Address]
• Postal Address: [Insert Postal Address]

14. Complaints

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