PRIVACY POLICY

This is the Privacy Policy of the website located at www.masterwineonline.com, its affiliate sites, subdomains, mobile versions, and any associated applications (collectively, the “Website”). MasterWineOnline.com (“we,” “us,” “our”) is the individual responsible for the management of jointly used personal data. We are the Controller in respect of your personal data.
Full name: Jennifer Simonetti-Bryan
Contact details: [Jennifer@masterwineonline.com]

1. Personal Data

We collect the following personal data:
1.1 User-provided Information. When you use our Website or make a purchase through it you may provide, and we may collect personal data. Examples include name, email address, mailing address, mobile phone number, and credit card or other billing information.
1.2 Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
1.3 Information we receive from other sources. We may also work closely with third parties (such as, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

2. Purposes of Collection of Personal Data

We are collecting your personal data for the following purpose(s):
2.1 managing the Website and access to it so that it is presented in the most effective way for you and your computer;
2.2 dealing with orders and accounts for the supply of our goods and services;
2.3 planning and managing our business activities, including analysing users’
preferences;
2.4 2.5
research;
providing you with information about the products and services we offer;
2.6 providing you with information about specially selected third party products and services (if you consent to receive such information);
2.7 notifying you of any changes to our products and services;
2.8 providing you with password reminders or to notify you that a particular service has
been suspended for maintenance; and
2.9 processing and dealing with any complaints or enquiries made by you.

3. Processing Personal Data

The legal bases for processing your personal data are that:
3.1 processing is necessary for the performance of a contract to which you are a party;
3.2 processing is necessary for compliance with a legal obligation to which we are
subject; and
3.3 processing is necessary for the purposes of the legitimate interests pursued by us, which include processing for direct marketing purposes, processing for the purposes of preventing fraud, and processing for the purposes of ensuring network and information security, including preventing unauthorised access to electronic communications networks and malicious code distribution and stopping ‘denial of service’ attacks and damage to computer and electronic communication systems.

4. Recipient of Personal Data

The recipients or categories of recipients of your personal data are:
4.1 Business partners, subcontractors and other third parties who assist us in the services we provide to you by, for example, hosting our Website or sending emails on our behalf, and with retail partners on the Website. In these instances, we provide them with only the information that they will need to perform their function. We require these third parties to comply with our instructions and requires them not to use any personal data for their own business purposes;
4.2 Any potential purchaser of our business; or
4.3 Legal or regulatory authorities we are under a duty to disclose or share personal data
about you in order to comply with any legal obligation.

5. Location

We are based in the United States and as a result we will transfer, store and hold your data in the United States.

6. Retention

6.1 We will hold personal data about you on our systems for as long as is necessary for the relevant service, or as long as is set out in any relevant contract you hold with us, subject to any applicable laws and/or regulations. In the case that you wish to cancel your registration as a member of the Website once an account is deleted, people cannot use the personal data about you other than for administrative purposes, but it stays on the system for a period of one year for administration purposes before being deleted.
6.2 Where you contribute to the Website, we will generally only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted.

7. Your Requests Regarding Personal Data

You have the right to request from us access to and rectification or erasure of personal data or to restriction of processing concerning you or to object to our processing of the data as well as the right to data portability.

8. Consent

If we are relying on your consent to process data, you may withdraw your consent at any time by notice to us.

9. Complaints

You have the right to complain to the applicable governmental office, such as the UK Information Commissioner’s Office, about the manner in which or otherwise in respect of the manner in which we process your personal data.

10. No Requirement to Provide Personal Data

Your provision of personal data to us is not a contractual or legal requirement. However, if you do not supply your personal data to us, we would be unable to provide you with information, products and services that you requested from us.