Vin-X Limited (‘Vin-X’) is a data controller, in accordance with the EU General Data Protection Regulation 2018 and is committed to protecting your personal data and working in accordance with all relevant data protection legislation.
This Privacy Notice explains how Vin-X processes and uses the personal data we collect from our clients, contacts and past, current and future suppliers and supporters. Personal data is used to provide relevant market information and the fine wine portfolio management service we have agreed to provide for the five-year period included in our management fee. 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.
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.
What data do we hold?
Vin-X may hold data relating to you from a number of sources. The majority of the data we hold on you has been provided by you during the period of time that you have been a client, registered to receive our marketing information or since you attended an event 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
- Payment information – 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 preferences – to help us engage with you in the ways most relevant to you
- Family details – during our account management we may have collected information about your marital status and details of your spouse and other family members which may have been recorded 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:
- 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.
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 and to offer wine and other services including storage, insurance, events and club services. Therefore, your information may be used for the following purposes:
- To allow your Vin-X Portfolio Manager to manage your account and optimise your wine portfolio performance
- To provide you with our Monthly Market Report, Newsletter and specialist reports and other useful investor information
- To provide Certificates of Ownership of your fine wine
- To manage the transfer, storage and insurance of your fine wine with the storage facility
- To assist you with the sale of your wine when you wish
- To introduce new fine wine investment opportunities to you that we feel are suitable for you
- To invite you to events
- To offer the opportunity to join Vin-X member clubs
- To provide you with special offers and promotions
- 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.
These activities may include an element of direct marketing of our products and services.
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.
How will we share your data?
We may have to share some of the data you provide to us with our strategic partners who provide essential services including Vin-X consultants, our storage and insurance partner, and Liv-ex should client wines be sold through the exchange. Data may also be disclosed to other external organisations to facilitate payment for wine such as Lloyds Bank plc, Cardnet, SagePay. Suppliers of essential services such as IT systems support provided by 3aIT Limited and others including logistics supply for the delivery of wine, will all have an agreement in place with Vin-X which will include confidentiality terms and data protection.
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.
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.
Your rights and preferences
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 email@example.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.
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 May 2018.
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 firstname.lastname@example.org. You can also contact the DPO 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 .