Vin-X Privacy Policy

Vin-X Limited Privacy Policy

Vin-X Limited (‘Vin-X’) is a data controller, in accordance with the Data Protection Act 2018 (“DPA”), the retained EU General Data Protection Regulations as set out in the DPA (“UK GDPR”) and the Privacy and Electronic Communications Regulations 2003 (“PECR”). The DPA, UK GDPR and PECR shall collectively be referred to as “Data Protection Legislation”. Vin-X is committed to protecting your personal data and working in accordance with all relevant Data Protection Legislation.

This Privacy Policy explains how Vin-X processes and uses the personal data we collect from our clients, contacts and past, current and future suppliers. Personal data is used to provide relevant market information and the fine wine portfolio management service we agree to provide to our clients. We also provide a news and information service for individuals who have registered an interest in receiving information on the fine wine market and alternative investments, which is delivered by electronic direct mail and by telephone by Vin-X representatives, in accordance with this Privacy Policy.

We take your privacy seriously and will only use your personal information to administer your fine wine account with us and to provide the products, services and fine wine market information that you have requested from us. The website and our services are not intended for children and we do not knowingly collect data relating to children.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us using the following details:

Full name of legal entity: Vin-X Limited

Email address: dataprotection@vin-x.com

Postal address: Barclays House, 51 Bishopric, Horsham, West Sussex, RH12 1QJ

Telephone number: 0203 384 2260

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

What data do we hold?

Personal data, or personal information, means any information about a living individual from which that person can be identified. Vin-X may collect, use and hold personal data relating to you from a number of sources. The majority of the data we hold about you has been provided by you during the period of time that you have been a client, registered to receive our marketing information or by attending one of our events or engaged with us in any other way.

Our records may include:

Contact details – your postal address, email address details, telephone number, mobile telephone number – we update these details when you advise us that they have changed
Your wine portfolio information – the details of the wines that you have acquired from us and that we sell for you and the associated prices, your wine storage and insurance information including any storage and insurance that you have organised independent of Vin-X but you have notified us of. Wine delivery details if you have organised this with us
Financial information – includes bank account, payment and limited financial information about your level of investment (including a client’s appetite for investment), any card and bank details we have processed during the course of business with Vin-X are securely managed in accordance with PCI/DSS
Events – we may have a record of you attending a Vin-X event
Personal details – for event management purposes we may have a record of your dietary preferences or disability information
Your marketing and communication preferences – to help us engage with you in the ways most relevant to you
Marketing Data – allow us to personalise content and advertising, to provide social media features and to analyse our website traffic

Family details – during our account management we may have collected certain personal information provided by you to help us to deliver a more personal service. We may also augment the data you provide with data which is publicly available, for example we may record:

Your career details and other achievements
Your interests (wine, sport, art, classic cars, vintage watches, other)
Your philanthropy, including donations and support to charities and other organisations

We are required to ensure that data we hold about you is as accurate as possible, therefore we may update your details based on reliable publicly available sources, which may include:

Social media platforms, such as LinkedIn, Facebook and Twitter
Reliable news and press reports
Companies House, company websites and other business-related resources
The Charity Commission and other websites relating to charitable trusts and foundations
The Sunday Times Rich List

In order to deliver a comprehensive service and to support our ongoing relationship we will retain your data unless you request otherwise. It is important that the personal data that we hold about you is accurate and current. Please keep us informed if any personal data we hold about you changes during your relationship with us.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.

How do we use your data?

Vin-X uses your data primarily to deliver its specialist fine wine portfolio management service, to provide information about the fine wine market and other factors which may influence the performance of your fine wine portfolio. It is also used to offer wine and other services including storage, insurance, events and club services. Your information may be used for the following purposes:

To allow Vin-X to manage your account and optimise your wine portfolio performance, our processing being in order to perform our contract with you
To provide you with our Monthly Market Report, Newsletter and specialist reports and other useful investor information, as part of our contract with you or as requested and send as a direct communication with you at your request
To provide Certificates for your fine wine, as part of our contract with you
To manage the transfer, storage and insurance of your fine wine with the storage facility, as part of our contract with you
To assist you with the sale of your wine when you wish, as part of our contract with you
To introduce new fine wine investment opportunities to you that we feel are suitable for you, as necessary for our legitimate interests
To invite you to events which we think may be of interest to you, as necessary for our legitimate interests
To offer the opportunity to join Vin-X member clubs, as necessary for our legitimate interests
To provide you with special offers and promotions, as necessary for our legitimate interests
To provide general information on the fine wine market, explaining the fundamentals of investing in fine wine and providing ongoing news and information relevant to investors and collectors or people considering creating a fine wine portfolio, as necessary for our legitimate interests
To ask you to review our service via UK-based Customer Service Survey Companies, as necessary for our legitimate interests
To understand you digital journey, personalise content and ads and analyse our traffic to give you the best digital experience, as necessary for our legitimate interests

These activities may include an element of direct marketing of our products and services, which we do as set out in this Privacy Policy.

Communications may be sent to you by post, telephone, email, text or other electronic means (for example through social media) depending on the communication preferences you have shared with us.

Vin-X may also use third party platforms for marketing and performance purposes:

Performance measurement and reviews:

We may share your data with a UK-based Customer Service Survey company, Feefo, who may contact you occasionally to determine your level of customer satisfaction. We share your name, email address and the service you purchased (as obtained for your Vin-X account) with Feefo, who will send you an email on our behalf asking you to complete a review. Our legal basis for doing this is our legitimate interest in asking for feedback in order to improve our products and services.

2. Digital Marketing, Marketing Data and Marketing communications:

We collect data when you visit our website, including traffic data, social media trends and user behaviour. We do this to personalise content and ads, to provide social media features and to analyse our traffic. To learn more about cookies, please click here.

If you have requested to receive such marketing information from us by opting-in (you may withdraw your consent at any time), we may contact you by post or email. We will only use your contact details to send you marketing communications (as obtained for your Vin-X account). Our legal basis for doing this is our legitimate interest in informing you about relevant news, promotions and events. If you do not wish to receive marketing communications from us, please inform us by using the unsubscribe link inside the email, by sending an email to marketing@vin-x.com, or by informing your Vin-X Portfolio Manager.

3. Profiling

We may use and compile data for profiling purposes. Profiling is a processing of personal data which evaluates, analyses and predicts your interests and behaviours.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of other transactions (for example the purchase and storage of wines).

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 it 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 we will explain the legal basis which allows us to do so.

Please note that 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.

Disclosures of Your Personal Data

Data is only shared with external parties whose involvement is required to deliver Vin-X’s business services. Vin-X does NOT sell data to third parties or allow third parties to sell data where data is shared with them.

We may share your personal data with the parties set out below for the purposes set out above.

External Third Parties (including, but not limited to, Feefo, Mailchimp), including those who provide our IT systems and various services on our behalf.
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.

International Transfers

We do not transfer your personal data outside the UK.

Some of our external third parties are based outside the 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; or
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.

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

How do we protect your data?

Your data is securely held on the Vin-X database which is only accessible to a limited number of authorised Vin-X personnel and consultants, who are all cognisant of Vin-X’s data protection policy.

Vin-X ensures that appropriate data sharing agreements are in place prior to sharing your personal data with any partners.

Data Retention

We keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers, as part of general record keeping activities.

In some circumstances you can ask us to delete your data: see ‘your rights and preferences’ below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your rights and preferences

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to 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.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object 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 also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request transfer of your personal data to you or to 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. 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.
Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you 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.

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

No fee usually required

You will not 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.

What we may need from you

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.

Time limit to respond

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.

Vin-X may contact you from time to time by post, telephone, email or other electronic means as you have previously consented. If you wish to change the way in which we communicate with you, please contact the Vin-X Administration team at 0203 384 2260 or by email at info@vin-x.com.

When contacting us please provide your name, your Client Account reference number and please specify which specific form of communication you would like to receive and any you may wish to opt out from.

If you ask us to delete your data, we will maintain a skeleton record comprising your name, client account number and postcode to ensure that we do not inadvertently contact you in future. We may also need to retain some financial records for statutory purposes.

Other information

The legal basis for processing your personal data for the purposes described above is that it is necessary for the delivery of our legitimate interests to provide a specialist fine wine portfolio management and information service for individuals, companies, charities and other organisations.

This Privacy Notice will be kept under review. Any changes will be updated on our website and communicated as appropriate. This Privacy Notice was last updated in December 2022.

Vin-X clients and contacts who have received communications from us have the right to:

Ask us to see, correct or delete the data we hold about them
Object to specific data uses, as described above
Object to receiving communications and direct marketing.

Should you have any queries in relation to Vin-X and our management of personal data please contact dataprotection@vin-x.com. You can also contact us if you have any questions or concerns about our processing of your personal data. You have the right to lodge a complaint with the Information Commissioner’s Office at www.ico.org.uk/concerns