Octavian Wine Services Limited is committed to ensuring that your privacy is protected and 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“). This policy explains how we 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. Please contact us by email on dpo@octavian.co.uk if you have any questions, comments or concerns about this policy or how we handle your personal information.

This website (the “Website“) is run by Octavian Wine Services Limited (company no. 07768056 with registered office at Octavian Eastlays, Gastard, Corsham, Wiltshire, SN13 9PP) (“we” and “us“).

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.

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.

The information we collect and how we use it
Under Data Protection Laws, we are required to explain what information we collect from you and, how and why we use your personal information. We are also required to have a “lawful basis” on which to process your personal information. This is summarised in the table below.

From you via our Website or when you call us.Name, title, address, postcode, phone number, fax number, email address, residency details (i.e. whether you are a resident inside or outside of the UK), credit card or bank account details,  details of authorised person(s) on the account, market value of your stockholding and number of cases.

In addition to the above, we also collect information you volunteer to us when you email or call us. Calls are recorded for training, monitoring and account management purposes.

We require this information in order to set up, maintain and manage your account and in order to comply with our statutory and regulatory obligations. A failure to provide this information will therefore unfortunately mean you will not be able to open an account and receive our services.

To process your request to open an account with us and for ongoing management of your account.

The lawful basis on which we process this information is (a) to take steps at your request to enter a contract with you and for the ongoing performance of such contract or (b) to comply with our legal obligations (specifically in respect of HMRC/ taxation rules).

For the duration you hold an account with us and for 6 years following the closure of your account.
From you when you physically visit our site(s).Name, entry and exit dates and times and CCTV images.To keep our site(s) safe and secure and to allow you access where you hold an account with us.

The lawful basis on which we process this information is (a) for the ongoing performance of our contract with you or (b) it is in our legitimate interests to maintain site(s) safety and security.

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.
From you when you request a brochure, information pack or guide via our Website.Name, address, postcode, email, telephone number.To fulfil your request.

The lawful basis on which we process this information is consent.

Until we have fulfilled your request.
From you when you subscribe to our newsletter via our Website.Name, address, postcode, email, telephone number, newsletter subscription preferences.To fulfil your request.

The lawful basis on which we process this information is consent.

Until you unsubscribe from our newsletter.
From you when you use the “Contact Us” function on our Website or call us by telephone.Name, address, postcode, email, telephone number, communication preference (by email or phone).To fulfil your request.

The lawful basis on which we process this information is that it is in our legitimate interests to look after you as a customer and respond to your enquiry or request.

Once we accept or return your call/ email (as indicated by you) depending on the nature of your request, our lawful basis may change to one of those set out above if your request falls into the corresponding category.

Either:

(a) until we have dealt with your request;

(b) for 6 years, where your request is a complaint; or

(c) in accordance with the other timescales set out above if your request subsequently falls into another category (e.g. to open an account).

From your use of our Website.Browsing Information about you, including your device (mobile, tablet, desktop, including location and your IP address.To help us analyse how you use the Website so that we can improve our online experience.

The lawful basis on which we process this information is that it is in our legitimate interests to monitor and analyse our Website and customer offering.

Please see our cookies policy for further information about what information may be automatically collected when you visit our Website www.octavian.co.uk.

Please see our cookies policy for further information.
Sole trader/ business contact information.Personal information, including but not limited to your name, postal address, email address, phone number and any other information collected during the business relationship.As a sole trader, we will need to process your personal information in order to perform the contract we have with you as an individual.

If you are an individual representative of a business who has a relationship with us, it is in our legitimate interests to process your information in the course of our relationship with the business you represent/ work for to enable us to manage our contracts and business relationships effectively.

For the duration of our agreement with you or the company you represent, and a period of 6 years thereafter).

 

We have determined, acting reasonably and considering the circumstances, that we are able to rely on “legitimate interests” as the lawful basis on which to process your personal information (where stated as such above).  We have reached this decision by carrying out a balancing exercise to make sure your rights as an individual aren’t impacted. As a result of our balancing test, is detailed below.

We consider that it is reasonable for us to process your information for the purposes of our legitimate interests outlined above as (a) we process your information only so far as is necessary for such purpose and (b) it can be reasonably expected for us to process your information in this way. 

Security
We may transfer personal information to countries other than the country in which the data was originally collected (for example, outside the UK/ EEA) in order 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.

We have in place appropriate policies, rules and technical and organisational measures to protect your personal information from unauthorised or unlawful processing, and against accidental loss, destruction or damage.

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.

Sharing your personal information
We will only disclose your information to:

  • to our professional advisors (including without limitation tax, legal or other corporate advisors who provide professional services to us);
  • to other third party suppliers, business partners and sub-contractors for business administration, support, processing, services, or IT purposes;
  • analytics or search engines, that enable us to optimise and improve your Website experience;
  • 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 Octavian Wine Services Limited;
  • 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; and
  • 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: 

NUMBERDESCRIPTION OF RIGHT
Right 1A right to access the personal information we hold about you.
Right 2A right to require us to rectify any inaccurate personal information we hold about you.
Right 3A right to 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 line with Right 6 below).
Right 4In 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.
Right 5In 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.
Right 6A right to 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.
Right 7A right 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.
Right 8A right to withdraw your consent, where we are relying on it to use your personal information (for example, to provide you with brochures and newsletters).

 

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 email us at: dpo@octavian.co.uk or write to us at: Octavian, Eastlays, Gastard, Nr Corsham, Wiltshire, SN13 9PP.

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.