PLEASE READ THIS POLICY CAREFULLY. IF YOU DO NOT ACCEPT THESE TERMS, YOU ARE ADVISED NOT TO USE THE WEBSITE
This Privacy Policy was last updated: 20th June 2019
Use of this website https://digby-fine-english.com constitutes your legal agreement to the terms within this Privacy Policy and your acceptance of the policy is deemed to occur upon your first use of the website.
Digby Fine English may change this policy from time to time by updating this page. On each visit to the website you should refer to this page to ensure that you are aware of and accept any changes.
Digby Fine English recognises the trust you place in us when you share personal information with us. We are committed to being open, honest and transparent with our use of personal data.
This Privacy Policy provides you with details of the personal information we collect when we engage with you, how we will use and look after your personal information, your privacy rights and how the law protects you. We will take all reasonable steps to ensure that personal information is safeguarded and kept in accordance with data protection law.
By providing us with your data, you warrant that you are over 18 years of age.
Digby Fine English is a trading name of Digby Wine Ltd, registered in England and Wales under company registration number 08020752. Our registered office address is 1 Berkley Street, Mayfair, London W17 8DJ and for correspondence purposes the postal address is 55-57 High Street, Arundel BN18 9AJ.
Where we manage personal data, we identify as a Data Controller and recognise and act on our obligations under applicable data protection law.
For any issues relating to data protection the person responsible is Jason Humphries. You can contact us in relation to data protection matters by email to cheers@digbyfineenglish.com
Personal information is any information relating to an identified or identifiable individual. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal information about you when we engage with you. This may include>:
Whether you browse as a guest or register with us, we will collect different types of information about you:
Customer Create Account, Sign In and Registration for the Kenelm Clu
We will collect your first and last name, email and set a password, so that we can register you and respond to your communications with details of our products and services. Data will be held on the grounds of being legitimate to our business interests.
If you make purchases from the website, we will process details of the items you purchase and delivery address in order to fulfil a contractual obligation to you.
Emails
We retain copies of emails sent to us and any personal data will be held in accordance with this Privacy Policy on the basis of being legitimate to our business interests.
Subscription to our Newsletters
If you subscribe to our newsletter via the website, we will keep details of your name and email for this purpose on the lawful basis of your consent. You will be able to unsubscribe from receiving these by clicking on a link for that purpose at the bottom of our e-mail with the newsletter.
We use MailChimp for newsletter emails see (https://mailchimp.com/legal/)
Telephone calls
Calls to us may be recorded and any data relating to the call may be retained by us. The data will be held on the basis of being for our legitimate business needs or in order to fulfil our contractual obligations if you are a client of ours.
Other direct interactions
You may give us your data by filling in forms or by corresponding with us face-to-face, by post, or through social media. This includes personal data you provide when you: sign up to receive our free consultation; make enquiries or request information be sent to you; order our services; ask for information to be sent to you; engage with us on social media; enter a competition, promotion or survey; contact us direct; or leave comments or reviews on our services.
We use social media to engage with users and link to our Facebook, Instagram and Twitter pages. We do not keep any specific data that identifies you as an individual user but hold details of our followers on these platforms. You should refer to the Privacy Policies of these channels to understand how they treat your data in relation to linking to our site.
Facebook: https://www.facebook.com/privacy/explanation
Instagram: https://wellbeing.instagram.com/safety
Twitter: https://twitter.co.uk/privacy
If you send us a direct message via social media, the details may be retained by us only as relevant to any ongoing contract or to further our legitimate business interests or as required for legal purposes. The third-party provider may also retain details in accordance with their Privacy Policy.
When you visit our website, we do not attempt to identify you as an individual user, however we will process certain information about your interactions on the website through the use of cookies, details of which are explained in our Cookie Policy.
Cookies
This website, https://digby-fine-english.com, uses cookies to track users’ interactions on the website and improve functionality as outlined below. You are advised to read this policy carefully. If you do not accept these terms, please do not use the website.
What are Cookies?
Cookies are small files saved to the user’s computer hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server, to provide the user with a tailored experience when navigating the website. Session cookies may be used to validate your access to different parts of the website.
Disabling Cookies
If you are uncomfortable with the use of cookies, you can disable cookies on your device by changing the settings in the preferences or options menu in your browser. You can set your browser to reject or block cookies or to tell you when a website tries to put a cookie on your device. You can also delete any cookies that are already stored on your device. However, please be aware that if you do delete and block all cookies from our website, parts of the site my not fully function.
How we use Cookies
The website uses cookies to help us identify and track visitors, their usage of the website, and their website access preferences. Cookies are a used to identify and distinguish you from other users on the website.
Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer or device. This complies with UK and EU legislation which requires that explicit consent is given by users before reading files are left, or applied, on a user’s computer or device.
Widgets
We use widgets which are small standalone applications from a third-party that can be embedded and used to display certain features on a particular web page. These are provided by Adobe Spark to enable us to process bookings for our taster room and to facilitate Club bookings by registered customers. You should refer to the Privacy Policy at https://www.adobe.com/privacy.html for details of how Adobe processes personal data.
Pixel tags
We also use pixel tags (also known as web beacons) which are small strings of html or JavaScript code that provide a method for delivering a graphic image on a web page. Pixel tags may be used to obtain information about the computer or device being used to view a particular web page such as the IP address of the computer or device to which the pixel tag is sent, the time it was sent, the computer or device’s operating system and browser type, and similar information.
Consent
If you accept the use of cookies on this website, you consent to the processing of data about you by us as described in our Privacy Policy. You have the right to withdraw your consent at any time by sending an email to cheers@digbyfineenglish.com
For cookies provided by third parties you are referred to their respective Privacy and Cookies Policies.
Types of Cookies
The types of Cookies we use are:
Strictly necessary cookies
Strictly necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
Analytical/performance cookies
These help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
Functionality cookies
These are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.
Targeting cookies
This information to make our site and the advertising displayed more relevant to your interests. We may also share this information with third parties for this purpose.
For information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work
You can opt out of targeted advertising by using the links below:
You can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/
How long will Cookies remain on my device?
Cookies can be placed for a user’s session and will disappear as soon as the browser software is closed or the computer is turned off, or cookies may be persistent and will remain on the device until they expire or are deleted.
Analytics
Digby Fine English uses tracking software provided by third parties to monitor its visitors, and to better understand how they use the site. Cookies track a visitors’ usage by saving a cookie to the user’s hard drive which will track and monitor engagement and usage of the website. The cookie will not store, save or collect personal information.
For details of the providers we use for analytical purposes please see the below list with links to the respective privacy policies:
Google: http://www.google.co.uk/privacy.html
Twitter: https://twitter.com/en/privacy
Zoho Page Sense: https://www.zoho.com/privacy.html
Users may opt-out from having their data collected by disabling the tracking.
Cookies used on the website
Please note that although we endeavour to keep this list current, the cookies used may change from time to time.
| COOKIE | PROVIDER | TYPE | USE | RETENTION PERIOD |
|---|---|---|---|---|
| NECESSARY | ||||
| __cfduid | boldapps.net | HTTP | Used to identify trusted web traffic. | 1 year |
| __cfduid | digby-fine-english.com | HTTP | Used to identify trusted web traffic. | 1 year |
| __cfduid | geoiplookup.io | HTTP | Used to identify trusted web traffic. | 1 year |
| AWSELB | api.bookthatapp.com | HTTP | Used to identify trusted web traffic. | Session |
| AWSELB | bookthatapp.com | HTTP | Used to distribute traffic to the website. | Session |
| AWSELB | digbyfineenglish2.bookthatapp.com | HTTP | Used to distribute traffic to the website. | Session |
| cart | digby-fine-english.com | HTTP | Necessary for the shopping cart functionality on the website. | 13 days |
| cart_currency | digby-fine-english.com | HTTP | Necessary for the secure checkout and payment function. | 13 days |
| cart_sig | digby-fine-english.com | HTTP | Necessary for the secure checkout and payment function. | 13 days |
| cookietest | digby-fine-english.com | HTTP | Used to determine if the visitor has accepted the cookie consent box. | Session |
| secure_customer_sig | digby-fine-english.com | HTTP | Used to store customer credentials securely when processing a purchase. | 20 years |
| STATISTICS | ||||
| _ga | digby-fine-english.com | HTTP | Registers a unique ID that is used to generate statistical data. | 2 years |
| _gat | digby-fine-english.com | HTTP | Used by Google Analytics to throttle request rate. | 1 day |
| _gid | digby-fine-english.com | HTTP | Registers a unique ID. | 1 day |
| collect | google-analytics.com | Pixel | Used to send data to Google Analytics about the visitor’s device and behaviour. | Session |
| MARKETING | ||||
| __widgetsettings | twitter.com | HTML | No details available. | Persistent |
| _fbp | digby-fine-english.com | HTTP | Used by Facebook to deliver a series of adverts. | 3 months |
| _landing_page | digby-fine-english.com | HTTP | Stores visitors’ navigation by registering landing page. | 13 days |
| _orig_referrer | digby-fine-english.com | HTTP | Becomes an ID string with information on a specific visitor. | 13 days |
| _s | digby-fine-english.com | HTTP | Used to optimize the website and make adverts more relevant. | 1 day |
| _y | digby-fine-english.com | HTTP | Collects data on visitors’ behaviour and interaction. | 2 years |
| fr | facebook.com | HTTP | Used by Facebook to deliver a series of adverts. | 3 months |
| local_storage_support_test | twitter.com | HTML | This function allows the web site to load faster by pre-loading certain procedures. | Persistent |
| r/collect | facebook.com | Pixel | Used to send data to Google Analytics about the visitor’s device and behaviour. | Session |
| RO_json_recurring_cart_settings___# | twitter.com | HTML | No details available. | Persistent |
| RO_json_translations___# | digby-fine-english.com | HTML | No details available. | Persistent |
| RO_text_css___# | digby-fine-english.com | HTML | No details available. | Persistent |
| tr | facebook.com | Pixel | Used by Facebook to deliver a series of adverts. | Session |
| UNCLASSIFIED | ||||
| 0c3072a8e7 | pagesense-collect.zoho.com | HTTP | No details available. | Session |
| cart_ts | digby-fine-english.com | HTTP | No details available. | 13 days |
| popup | digby-fine-english.com | HTTP | No details available. | 6 days |
| psimg.gif | pagesense-collect.zoho.com | Pixel | No details available. | Session |
| zabHMBucket | digby-fine-english.com | HTTP | No details available. | 1 year |
| zabUserId | digby-fine-english.com | HTTP | No details available. | 1 year |
| zabVisitId | digby-fine-english.com | HTTP | No details available. | Session |
| zfccn | pagesense-collect.zoho.com | HTTP | No details available. | Session |
Important Information
Questions and queries
If you have any concerns about how we handle your data, you can contact the person responsible for data protection by email to cheers@digbyfineenglish.com
Changes to this policy
We reserve the right to change this Cookies Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. You will be deemed to have accepted any changes to the terms of this Cookies Policy on your next visit of the website following the amendment.
Complaints
If you wish to raise a concern about the use of your data, you can contact us by email to cheers@digbyfineenglish.com. Alternatively, you can formally raise a concern or complaint to the Information Commissioner’s Office (ICO) directly on 0303 123 1113, or see the options for reporting issues on https://ico.org.uk/concerns/
Further information
Guidelines for the processing and handling of data is available from the Information Commissioner’s Office, the UK supervisory authority on data protection, see www.ico.org.uk
Information is also available at www.ec.europa.eu/ipg/basics/legal/cookies/index_en.htmla>
We do not generally 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.
We do not market this website at those under 18 years old. Consistent with the GDPR we will never knowingly request personally identifiable information from anyone under the age of 18 years old.
We will take appropriate steps to delete any personal data of individuals less than 18 years of age that has been collected on our website upon learning of the existence of such data.
From time to time, we may need to obtain information from third parties about you. This will only apply where it is necessary to provide our services and as permitted by law.
We may receive personal data relating to: your identity and contact data from data partners; and data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites.
UK data protection law requires us to have a “legal basis” for processing personal data. The legal bases we rely on are:
We may use the personal data we collect from you as outlined in this table:
| Use of personal data | Type of data | Legal basis |
|---|---|---|
| To register you on our website |
|
Performance of a contract or to take steps to enter into a contract |
| To provide, manage and personalise our services to you, respond to communications |
|
Where necessary for the perform of our agreement or to take steps to enter into an agreement It is in our legitimate interests to make sure that our customer accounts are well-managed, and to provide a high standard of service |
| To process payments for our services |
|
Performance of a contract Necessary to comply with a legal obligation |
| To administer and improve the website | (e) Technical (h) Usage |
It is in our legitimate interests to develop and improve our products and services, so that we can continue to provide products and services that our customers want to use, and to make sure we continue to be competitive |
| To send email notifications which have been specifically requested |
|
It is in our legitimate interests to give you information about our products and services that you may be interested in |
| To send marketing communications, where expressly agreed eg newsletters; |
|
In the case of electronic marketing we have your consent to do so. |
| To provide third parties with statistical information about our users | (e) Technical (h) Usage |
It is in our legitimate interests to better understand how our customers use our products and what changes we could make to improve them |
| To ask for feedback, a testimonial or review |
|
It is in our legitimate interests to better understand how our customers use our products and what changes we could make to improve them |
| To deal with enquiries and complaints made by or about you relating to the website |
(e) Technical |
It is in our legitimate interests to make sure that our customer accounts are well-managed, so that our customers are provided with a high standard of service |
| To recover debt and exercise other rights we have under any agreement with you, as well as to protect ourselves against harm to our rights and interests in property | (a) Identity (b) Contact (c) Financial (d) Transaction |
Where necessary to perform a contract or to take steps to enter into an agreement with you Where the law requires this It is in our legitimate interests to make sure that our business is run prudently and we can recover the debts owed to us, as well as making sure our assets are protected |
Users contacting this website and/or its owners do so at their own discretion and provide any such personal data requested at their own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use.
When we use our legitimate interests as the legal basis for processing your personal information, we will consider and balance any potential impact on you and your rights before we process your personal data. We will only then proceed where we believe our interests are not overridden by the impact on you. Our legitimate interests include the management of our business operations.
Disclosure
We don’t share, sell, or distribute your data to third parties, except as contractually agreed with you or as provided in this Privacy Policy. We may disclose your personal information if we are required to do so by law, in connection with any legal proceedings, and in order to establish, exercise or defend our legal rights, or if otherwise legally permitted.
Data Processors
We may use Data Processors who act on our instruction in relation to the management of your data and they must adhere to all data protection laws and regulations. We will ensure that any Data Processors used only operate on our written instructions and comply with their obligations under the GDPR. You will be informed of any other Data Controllers who have access to your data and who may determine processing activities separately to us, or as a Joint Data Controller.
Marketing
We may carry out direct marketing by email, phone, text or post.
We will ask for your consent to receiving marketing communications (including newsletters) when you register on the website and you have the option not to give consent and to withdraw consent given at any time. You may withdraw your consent for us to contact you by email to cheers@digbyfineenglish.com. We may continue to contact you for non-marketing purposes if there is another lawful basis to do so.
Non-personally identifiable information may be provided to other third parties for marketing, advertising or other uses.
Users of the website are advised to adopt a policy of caution before clicking on any external web links. Clicking an external link will take the user away from our website. Once you leave our website or are redirected to a third-party website, plug-in or application, you are no longer governed by this Privacy Policy or our website’s terms and conditions. We cannot guarantee or verify the contents of any externally linked website and users click on external links at their own risk. Digby Fine English and its owners cannot be held liable for any damages, or the consequences of visiting any external links.
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are subject to our terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate and/or engage with them with due care and caution in regard to their own privacy and personal details. This website nor its owners will not ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.
Digby Fine English uses social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised that before using such social sharing buttons, that they do so at their own discretion, and should consider that the social media platform may track and save requests to share a web page, through the users’ social media platform account.
We may disclose your personal information to third parties and their advisers if we are approached by a potential buyer in connection with the potential sale of our business or of any part of it (including any of our brands). Should we proceed to sell or reconstitute any part of our business that holds your personal information, it will be necessary in some circumstances to share or transfer that information to the buyer or new entity.
You will always be notified of such a change of control or ownership and will be given the opportunity to object or opt out of any further communications from us or the buyer or new entity, except where such use of your personal information is necessary for a lawful purpose.
Payments for services to Digby Fine English are processed through Stripe and shall comply with the standard procedures and requirements as laid down by law to ensure that personal data is kept secure.
When you sign up to membership of the Kenelm Club and agree to pay by direct debit, we will securely share the bank or building society details you pass to us with our third party direct debit service provider, via user portal and secure file upload/download. This information is retained by us securely in order to claim monthly or annual payments from your account as per your instructions. All transactions are covered by the Direct Debit Guarantee.
We keep your personal information in accordance with our Data Retention Policy which reflects our needs to provide services to you as contracted and also as required to meet legal, statutory and regulatory obligations. The need to hold information is regularly reviewed and data will be disposed of when no longer required.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such system and are required to keep the information confidential.
We take appropriate steps to ensure a safe processing of personal data, however, we cannot guarantee the security of data transmitted through our website or by email. Any transmission is at your own risk.
Data that we process for taster sessions and in relation to our exclusive club shall be stored by Adobe Spark. You can refer to their policies for handling data at https://www.adobe.com/uk/privacy/policy.html
Digby Fine English recognises a data subjects rights and will uphold these in accordance with data protection laws. You are entitled to see the information held about you and you may ask us about any of the following:
Subject access requests
Data subjects (i.e. individuals) have the right to access personal data that is held by submitting a subject access request (SAR) by email to cheers@digbyfineenglish.com. We will endeavour to respond quickly to any such requests, which legally require us to respond within one month of receiving the request and necessary information.
Right to rectification
Data subjects have the right to request that we amend or change personal data that is inaccurate or incorrect.
Right to erasure
Data subjects have the right to ask us to delete personal information from our systems without giving any reason and at any time. We will act on any such request without delay.
Right to restrict processing
Data subjects have the right to rectification or erasure of personal data in the following circumstances:
Right to data portability
Data subjects have the right to obtain and request the transfer of their data to different service providers.
Right to object
Data subjects have the right to object to the processing of data at any time based on their particular situation. This includes objecting to profiling unless it is in the ‘public interest’ or exercised lawfully by an official authority. We will only process data under lawful grounds.
Right not to be subject to decisions based on automated processing
We do not use any automated processing that results in any automated decision based on a data subject’s personal information.
If you wish to invoke any of these rights, you should contact the person responsible for data protection by email to cheers@digbyfineenglish.com
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 may refuse to comply with your request in these circumstances.
We will report any unlawful breach of data as required by the GDPR within 72 hours of the breach occurring, if it is considered that there is an actual, or possibility, that data within our control including the control of our data processors, has been compromised. If the breach is classified as ‘high risk’ we will notify all data subjects concerned using an appropriate means of communication. We will report any relevant breaches to the ICO, see below.
Questions and queries
If you have any concerns about how we handle your data, please get in touch by email to cheers@digbyfineenglish.com
Changes to our Privacy Policy
We reserve the right to change this Privacy Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. You will be deemed to have accepted any changes to the terms of the Privacy Policy on your next visit of the website following the amendment.
Complaints
If you want to raise a concern about the use of your data, you can contact us by email to cheers@digbyfineenglish.com. Alternatively, you can formally raise a concern or complaint to the Information Commissioner’s Office (ICO) directly on 0303 123 1113, or see the options for reporting issues on https://ico.org.uk/concerns/
