WHO WE ARE
- What types of personal data we collect;
- How we collect personal data;
- The purposes we collect personal data for, including how we use it to make our products better and to offer better services and experiences to our consumers;
- The circumstances in which we may share it with other organisations that support our operations, including the types of organisations involved;
- Where we store your personal data;
- How long we keep personal data for; and
- The rights and choices you have with regards to your personal data.
WHAT TYPES OF DATA DO WE COLLECT ABOUT OUR CONSUMERS?
- Your name, age/date of birth (including for age verification and due diligence purposes) and home location(s);
- Your contact details: postal addresses including billing and delivery addresses, contact telephone numbers and email address;
- Details about payments to and from you and other details of purchases, orders made by you, including your purchase history and ballots you have submitted for the purchase of Volpe & Castello’s products;
- When you make a purchase or place an order with us, your payment card details;
- Details of any event or experience bookings you have made, including details you have provided or we may have collected from you in connection with your attendance at any events or experiences we have arranged with you (such as any accessibility or dietary requirements or other interests related to the event or experience);
- If we are required to carry out due diligence, details of any criminal convictions or sanctions, illegal activity, adverse media or whether you are a politically exposed person, which is publicly available;
- Your 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 the website (Technical Data);
- Information about how you use our website, products and services (Usage Data);
- Your correspondence and communications with Volpe & Castello.
- Personal data, which you have maybe shared via a public platform (such as on Volpe & Castello’s Facebook or Instagram feed);
- Your preferences in receiving marketing from us and our third parties and your communication preferences;
- Your image may be captured on CCTV when you visit the Volpe & Castello bonded warehouses;
- Information which may be collected or generated by our customer engagement personnel and/or representatives, or when you participate in an online experience, such as:
- preferences regarding our products and offerings including any "wish list" items regarding preferred Volpe & Castello products and experiences and how you share your experiences and passion for Volpe & Castello with others;
- lifestyle preferences and interests such as preferred travel destinations, preferred restaurants / cuisines and whisky and drink preferences / collection;
- social indicators such as your profession and connections;
- engagement data such as when you open or click on our emails, how long you have been a consumer of Volpe & Castello, and how you interact with our personnel /representatives;
- communication channel preferences (e.g. social media handles and app-based messaging) such as LinkedIn, Facebook, Twitter, WeChat and WhatsApp;
- your behaviours insofar as they impact the Volpe & Castello brand, including compliance with our terms and conditions of sale and behaviour at events and online;
- Information about any experiences, gifts, special invitations or benefits made available to you;
- Your feedback and survey responses; and
- Online browsing activities on the Volpe & Castello website.
Other than the data listed above, 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, biometric data).
Where we need to collect personal data by law, 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 (e.g. to provide you with goods or services). In this case, we may have to cancel a purchase or experience you have with us but we will notify you if this is the case at the time.
HOW DO WE COLLECT YOUR PERSONAL DATA?
We collect your personal data by different methods, including:
- Direct interactions: This includes personal data you provide when;
- You subscribe to receive our newsletter;
- You create an account on our website or participate in one of our online experiences;
- You make an online purchase or place an order online for a Volpe & Castello product or merchandise;
- You enter a ballot or competition related to Volpe & Castello or one of Volpe & Castello’s products;
- You attend one of our events, visit one of our sites (e.g. our bonded warehouse) or you avail of one of our experiences (e.g. whisky tastings, dinning and food, and other bespoke or exclusive experiences);
- You interact with one of our Private Client Relationship Managers (PCRMs or other representatives;
- You communicate with us through telephone, text messaging, or other app-based or social media direct messaging;
- You provide your information to us at one of our boutiques or retail outlets such as at airports; and
- You contact us, for whatever reason.
- Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We may also gather statistical information on emails sent to you (e.g. opens, clicks, delivery rates, unsubscribes and forwards). This helps us to assess and improve email performance and our engagement with you. We collect this personal data by using cookies, pixels and other similar technologies.
- Third party sources of information: We may obtain information about you from the following third party sources:
- Where you interact with a third party acting on our behalf (e.g. a representative of one of our distributors, joint venture partners or airport boutique operators);
- Our professional advisors (e.g. lawyers, accountants and bankers);
- Publicly available sources (e.g. how you share your experiences and passion for Volpe & Castello with others on social media); and
- Where we carry out customer due diligence, we use a third party due diligence screening provider who searches publicly available information.
- Technical Data: We also collect Technical Data from the following third parties:
- Analytics providers (such as Google based outside the UK and/or EU);
- Advertising networks;
- Search information providers; and
- Due diligence screening providers.
HOW DO WE USE YOUR PERSONAL DATA?
Volpe & Castello (and trusted partners and service providers acting on our behalf) use your personal data:
- To provide you with information, products or services that you request from us, or which we feel may interest you. This is only done when you’ve given your consent to be contacted by us, or where we are permitted to contact you in accordance with data protection law (such as where you have not opted-out of receiving such information from us at the time of making a purchase from us);
- We may send you personalised communications based on your preferences, and engagement with Volpe & Castello’s products, services or experiences;
- To verify your identity and your age;
- Where you make a purchase above a certain value or we have or are building a relationship with you, carry out due diligence checks using our third-party due diligence system;
- For crime and fraud prevention, detection and related purposes;
- To enable Volpe & Castello to manage any customer service interactions with you;
- To ensure compliance with our terms and conditions of sale and protection of Volpe & Castello brand and products;
- To ensure that our web content is presented in the most efficient way for you and your computer;
- To allow you to participate in interactive features on our website, when you choose to do so; and
- Where we have a legal right or duty to use or disclose your information (e.g. in relation to an investigation by a public authority or in a legal dispute).
We may also combine your personal data collected through various sources, including information collected through our website and services, and develop a profile that will be used for the purposes above.
OUR LEGITIMATE INTERESTS
The normal legal basis for processing consumer data, is that it is necessary for the legitimate interests of Volpe & Castello, including:
- selling and supplying goods and services to our consumers;
- protecting consumers, employees and other individuals and maintaining their safety, health and welfare;
- promoting, marketing and advertising our products, services, events, experiences and brand partnerships;
- understanding our consumers’ behaviour, activities, preferences, and needs, including through the use of profiling;
- ensuring compliance with our terms and conditions, including our Terms and Conditions of Sale, such as investigating any breaches, which may involve the use of personal data collected directly or indirectly (e.g. from public information available on social media);
- improving existing products and developing new products;
- providing experiences, special invitations and other benefits to our most-valued consumers;
- protecting the Volpe & Castello brand, which may involve noting negative consumer behaviour towards our brand;
- handling consumer contacts, queries, complaints, or disputes; and
- preventing, investigating and detecting crime, fraud, or anti-social behaviour and prosecuting offenders.
Where we process your personal data in pursuit of our legitimate interests, you have the right to object to us using your personal data for the above purposes. If you wish to object to any of the above processing, please contact us at [email protected]. If we agree and comply with your objection, this may affect our ability to undertake the tasks above for your benefit.
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 require any further information on how the processing for the new purpose is compatible with the original purpose, please contact us using the details below.
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.
WHAT ARE YOUR RIGHTS?
You have a number of rights under the Data Protection Laws in relation to the way we process your personal data, namely:
- to access your data (commonly known as a "data subject access request") – this enables you to receive access the personal data we hold about you and to receive confirmation of how we are processing it;
- to have your data rectified if it is inaccurate or incomplete – 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;
- in certain circumstances, to have your data deleted or removed – 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. Please 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;
- in certain circumstances, to restrict the processing of your 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 don’t 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; or
- you have objected to our use of your data (see below) but we need to verify whether we have overriding legitimate grounds to use it,
- a right of data portability, namely to obtain and reuse your data for your own purposes across different services. 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 personal data which you initially provided consent for us to use or where we used the data to perform a contract with you;
- to object to the processing of your 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;
- not to be subject to automated decision-making (including profiling), where it produces a legal effect or a similarly significant effect on you;
- to withdraw your 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; and
- to claim compensation for damages caused by a breach of the Data Protection Laws.
If you wish to exercise any of these rights, please contact [email protected] or the Volpe & Castello representative with whom you normally deal.
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
To effectively fulfil our obligations to you, and to provide you with marketing and certain experiences, special invitations and benefits, we use a number of trusted and reliable third parties to carry out functions, which involve the processing of your personal data. These include:
- vendors who will process your personal data on our behalf and under our written instructions to carry out their services during the course of our business, such as IT service providers, financial institutions, customer relationship management vendors marketing service providers, and other cloud-based solutions providers that are used by Volpe & Castello in the conduct of its business. We contract with such vendors to ensure that they only process your personal data under our instructions and ensure the security and confidentiality of your personal data by implementing the appropriate technical and organisational measures for such processing;
- vendors that process your personal data in order to assist us to better understand our consumers and how we can improve our consumer engagement, such as HubSpot and Lightspeed;
- when you order products or services from our online shop, we will share your details with our fulfilment partners who will process your orders as set out in our Terms and Conditions;
- where you make a purchase above a certain value or we have or are building a relationship with you, we will share your name and date of birth with our due diligence service provider to carry out due diligence checks;
- marketing service providers that administer services on our behalf, such as sending communications to our consumers, administering any promotions or ballots which we run;
- translation service providers that administer services on our behalf, such as translating communications received and sent in different languages;
- other agencies and fulfilment partners to administer events, competitions. experiences, brand programmes and other special invitations and benefits.
- our professional advisors (e.g. lawyers, accountants and bankers); and
- Volpe & Castello’s third party distributors, joint venture partners, or boutique operators.
We may provide information to others (such as governmental or law enforcement agencies) in the good faith belief that such action is necessary to: (i) enforce or apply our terms and conditions of sale; (ii) comply with any legal claims raised against Volpe & Castello; (iii) protect the rights, property or safety of Volpe & Castello; or (iv) protect the rights, property or safety of the public.
In accordance with applicable law if Volpe & Castello becomes involved in a merger, consolidation, acquisition, change in control, bankruptcy, reorganisation, liquidation or other transaction involving the sale of some or all of our business or assets, user information, including personal data collected from you through your use of our website, could be included in the transferred business or assets. Should such an event occur, we will use reasonable means to notify you, either through email and/or a prominent notice on our website.
WHERE DO WE STORE YOUR PERSONAL DATA?
We may transfer your personal data outside the United Kingdom and European Economic Area. This is primarily to allow us to:
- receive consultancy, marketing and IT services (e.g. cloud storage services, database development and management services, email/webmail services and customer relationship management services) from vendors located in other jurisdictions, such as Hong Kong.
Where your personal data is transferred outside of the UK and/or EEA, we will ensure your personal data is afforded an adequate level of data protections (as required by data protection laws), including:
- by transferring the data to a country that the UK authorities or European Commission have deemed as providing an adequate level of data protection (an "adequacy decision");
- by implementing an appropriate international transfer mechanism under data protection law, such as standard contractual clauses or a data transfer agreement / addendum approved for this purpose by the UK authorities or European Commission;
- by relying on a "transfer derogation" under data protection law (e.g. where the transfer is based on your explicit consent, or is necessary to perform a contract with you); or
- where we are otherwise permitted to make the transfer under data protection law.
Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the UK and/or EEA.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
Different retention periods will apply to different types of data. To determine the appropriate retention period for personal data, we consider any ongoing relationship we have with you, the likelihood you may want to make a further purchase from us in the future, 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.
When we no longer need to use your personal data, we will remove it from our systems and records, and or take steps to anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations we are subject to).
In certain circumstances, you can ask us to delete or remove your data.
We may also use your personal data collected by recording phone calls and retaining a transcript of our live chats with you through our website (including where these are handled by Volpe & Castello’s third party technical services partner, Customer Experience People) for the following purposes:
- Account management;
- Prevention, detection, investigation and prosecution of fraud;
- Complaint handling and resolution;
- Measuring the quality of the call;
- Internal training on call handling.
We have a legitimate interest in retaining calls and live chats in order to offer our consumers a good service and to protect our business. If you object to the call recording, you may choose to end the call when you are informed that calls may be recorded. If you use our live chat function to get in touch with us, you will be informed that we will keep a record of the discussion at the start of the chat and you will be able to end the chat at any time. You will have the option to contact us through alternative means. All calls and live chat records will be retained for a period of one year.
If you have any questions or concerns about the way in which your Personal Data is processed, please contact [email protected].
In the UK, you have the right to complain about data protection matters to the Information Commissioner’s Office (ICO).
The ICO is the UK's independent body set up to uphold information rights. You can find out more about the ICO on its website (https://ico.org.uk/). The ICO can be contacted by calling 0303 123 1113.
You can also lodge a complaint with a data protection regulator in the EEA member state in which you are based.
We would however appreciate the chance to discuss and work with you to address your concerns before you approach any regulator, so please contact us in the first instance.