www.chawlaprosecco.com, a alcohol and beverage brand, incorporated under RC Brands ltd in England and Wales. (“RC Brands Ltd” “We”).
RC Brands Ltd data protection and privacy measures are governed by the (i) the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and any national implementing laws, regulations and secondary legislation, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998 (“Data Protection Legislation").
Personal data and Basis for Collection
If you fail to provide personal data
How is your personal data collected
Purposes for which RC Brands Ltd
will use your personal data
Change of purpose
How your personal Data Retention
Question and Contact information
www.chawlaprosecco.com is an alcohol wine brand business based in the UK which supplies wine based products within a supply chain processes; products and services (“Products and Services”). As such www.chawlaprosecco.com may process personal data of its customers, contacts and visitors to its Websites.
2. Personal data and Basis for Collection
For the purpose of Data Protection Legislation, where personal data is provided directly to www.chawlaprosecco.com through use of the Website(s), email, or other means www.chawlaprosecco.com will be a data controller (as defined in the Data Protection Legislation) of such information. Where www.chawlaprosecco.com is provided with information only for the purpose of performing a contract or where www.chawlaprosecco.com cannot determine the use of such information, www.chawlaprosecco.com will be data processor (as defined in the Data Protection Legislation) of such information.
www.chawlaprosecco.com may collect, use, store and transfer different kinds of personal data about you which www.chawlaprosecco.com have grouped together as follows:
Identity Data including names, username or similar identifier, title, job title, directorships.
Contact Data including billing address, delivery address, email address and telephone numbers.
Financial Data including bank account and payment card details.
Transaction Data including details about payments to and from you and other details of products and services you have purchased from www.chawlaprosecco.com
Usage Data including information about how you use www.chawlaprosecco.com Services or submit an enquiry or query through the Websites.
Marketing and Communications including your preferences in receiving marketing or surveys from us and our third parties and your communication preferences.
Additional Information including additional information you chose to provide to us.
• Unless you provide such information to us to customise the service we may provide to you, www.chawlaprosecco.com does not process 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 does www.chawlaprosecco.com collect any information about criminal convictions and offences.
3. If you fail to provide personal data
Where you fail to provide personal data when requested, www.chawlaprosecco.com may not be able to perform the contract it has or is trying to enter into. In this case, www.chawlaprosecco.com may have to cancel the Services but we will notify you if this is the case at the time.
4. How is your personal data collected?
www.chawlaprosecco.com use different methods to collect personal data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with
us by post, phone, e-mail or otherwise. This includes personal data you provide when you:
o apply for the Services or private label products;
o give us some feedback or complete a survey so we may improve services;
o request marketing to be sent to you; or
o create an account on our Websites or apps or mobile device.
• Third parties. We may receive personal data about you from various third parties, including your employer who may need to verify to us the individual identity to use our services and platform to place financial orders for goods.
5. Purposes for which RC Brands Ltd will use your personal data
Set out below is a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us 0207 164 6945 Devine Distillates Group if you need details about the specific legal basis we are relying on to process your personal data.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new
Performance of a
customer and verify your identity when using log-ins
To process and deliver the Services including:
(b) Collecting and recovering money owed to us
(d) to provide support to the services
(a) Identity (b) Contact (c) Financial (d)Transaction
Performance of a contract Necessary for our legitimate interests (to recover debts due to us)
To respond to queries and enquiries
(a) Identity (b) Contact
Legitimate interests (to offer similar services or offers)
To undertake any marketing to you
(a) Identity (b) Contact
Legitimate interests (to offer similar services or offers)
Business Performance – To manage our business performance
(a) Identity Data (b) Individual Data
Legitimate interests (to improve the services we provide)
Events – To enable us to provide events to you which take
(a) Identity Data (b) Individual Data (c) Event Data
Legitimate interests (to tailor events)
6. Change of purpose
www.chawlaprosecco.com will only use your personal data for the purposes for which it was collected for, 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 0207 164 6945 Devine Distillates Group 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.
7. How your personal data maybe shared
with third party consultants selected by www.chawlaprosecco.com , such as survey providers, product checkers and logistic companies, import companies, resellers, other associated companies;
With other UK and international www.chawlaprosecco.com member organisations;
where information is shared through public platforms in accordance with the provision of other services such as Coupon Issuer services we may implement;
with marketplaces such as Amazon;
where www.chawlaprosecco.com is under a duty to disclose your personal data to comply with any legal obligation, or to enforce or apply www.chawlaprosecco.com terms and conditions and other agreements;
with third party debt recovery agencies;
to protect the rights, property, or safety of www.chawlaprosecco.com and its customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and for compliance with laws;and
with 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 notice.
8. How www.chawlaprosecco.com stores personal data
For secure storage, www.chawlaprosecco.com ensures that it stores your personal data within the UK (Slough).
www.chawlaprosecco.com may share your personal data with some third parties who are based outside the EEA. In this case, www.chawlaprosecco.com will ensure that the appropriate security measures and processing provisions are in place to protect your personal data either directly or through our data services centre. Data security
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, we limit access to your personal data to
those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
9. Personal Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Generally, we keep personal data in accordance with our internal retention procedures, which are determined in accordance with our regulatory obligations and good practice. These retention periods depend on the nature of the information, and are subject to change. If you have any questions in this regard, please contact us using the details below.
10. Your Rights
Under certain circumstances, you have rights under Data Protection Legislation in relation to your personal data. These include the right to:
request access to your personal data;
request correction of your personal data;
request erasure of your personal data;
object to processing of your personal data;
request restriction of processing your personal data;
request transfer of your personal data; and
right to withdraw consent.
To exercise any of the above rights please email
your request to: email@example.com
Where you exercise your right to erasure or where information is
deleted in accordance with www.chawlaprosecco.com retention policy,
please note that after the deletion of your personal data, it cannot
be recovered, so if you require a copy of this personal data, please
request this during the period www.chawlaprosecco.com retains the data.
The Website is not intended for children. www.chawlaprosecco.com will not knowingly collect any personal data from persons under the age of 18 and will immediately delete any such data subsequently so determined.
If you would like to make a complaint in relation to how www.chawlaprosecco.com may have stored, used or processed your personal data, you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). www.chawlaprosecco.com would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Where changes are significant, we may also email all our registered users with the new details, and where required by law, will we obtain your consent to these changes.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
RC Brands Ltd
A Devine Distillates Group Notice Update.
24 May 2018
Resources & Further Information