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NEW WINE INTERNATIONAL

PRIVACY POLICY

1. INTRODUCTION

This Privacy Policy will be effective as of 24th May 2018.

This privacy policy covers personal information, including any information we collect, use and share from you, as described further below. This privacy policy applies to all websites in the New Wine International family, our products and services, and any mobile applications (collectively, the “Services”).

When you obtain a service from us, your personal information will be collected, processed and transmitted in a way that adheres with the provisions of this privacy policy:

2. INFORMATION WE COLLECT FROM YOU

In the course of your use of the Services, we obtain the following information about you as described below. We collect this data for the purposes described below under “How We Use Your Information”.

a. USER INFORMATION, SIGNING UP FOR SERVICES
  • Information you provide prior to any registration process, such as your email when you provide it to us;
  • Information that you provide during any registration process (such as your name, email address, phone number, address or payment card information, geographic location and industry), when you call or email us or when you use our products or services; and
  • Payment information that you provide to us (by way of our Services or otherwise) when you purchase some of our products and services, including credit card data.
b. USE OF SERVICES, WEBSITE VISITS AND SUPPORT
  • Data relating to your online activity on our websites with respect to our Services, including the following:
    • IP address
    • browser type and version
    • geographic location
    • pages you view
    • how you got to our Services and any links you click on to leave our Services
    • when you update your information, communicate with us, or order new Services
    • metadata about your use of our Services and your emails you send (including clicks and opens)
    • your interactions with any videos we offer
    • issues you encounter requiring our support or assistance
    • any device or other method of communication you use to interact with the Services

We store this data we collect in a variety of places within our infrastructure, including system log files, back end databases and analytics systems.

c. SOCIAL MEDIA
  • Information from third party social networking sites, including information that social networking sites provide to us if you use your credentials at such social networking sites to log into some of our Services (such as your name and email address to pre-populate our sign-up form).
  • The information you allow us to access varies by social networking site, and depends on the level of privacy settings you have in place at the social networking site. You can control and find out more about these privacy settings at the applicable social networking site.
d. OTHER SOURCES
  • Information you provide to us at events;
  • Information you provide to us in surveys;
  • Information that is publicly available; and
  • Information you consent to us receiving from third parties.
3. HOW WE USE YOUR INFORMATION

We have a legitimate interest in running our organisational activities efficiently and in providing you with Services and useful content, and we use the information we collect, for the following purposes:

  • To communicate with you;
  • To provide the requested Services to you;
  • To provide you with useful content;
  • To ensure the proper functioning of our Services
  • To offer and improve our Services;
  • To provide you with requested information or technical support
  • To facilitate your movement through our websites or your use of our Services;
  • To do a better job of advertising and marketing our Services (our use of your information to do this is performed with your consent where required by applicable law);
  • To advertise and market third party products and services (such advertisement is only performed with your permission where your consent is required by applicable law);
  • To diagnose problems with our servers or our Services;
  • In connection with our security and compliance programs;
  • To administer our websites;
  • To target prospective customers with our products or services (such targeting is only performed with your permission where your consent is required by applicable law);
  • To assist us in offering you a personalized experience or otherwise tailor our Services to you; and
  • As otherwise described in this privacy policy.

We also use the information we receive in aggregated and anonymized formats to produce reports on trends and statistics, such as email open rates, or the number of users that have been exposed to, or clicked on our websites or evaluated or purchased our products and services.

Payment information that you provide to us, including credit card data, will only be used to facilitate payment for our products and services.

We may also use recorded telephone conversations for quality control purposes, to train our employees and for our own protection.

4. SHARING OF INFORMATION a. OUTSIDE NEW WINE INTERNATIONAL

We do not share your personal information with anyone outside the New Wine International Family except for the following reasons:

  • It is provided as part of a third party vendor or supplier service provision to New Wine to assist us in serving you. (E.g. our Information Technology and storage services; email service providers). T Service provider. Any such third party supplier may use your information only according to the terms of this privacy policy and are prohibited from using any of your personal information for any purpose beyond the purpose for which it was shared.
  • Where New Wine is required by law to do so. We may disclose your personal information to courts of law, law enforcement authorities to conduct an investigation, respond to a law enforcement subpoena or court order, bring legal action, prevent harm to others or pursue other relief when you or a third party are or may be:
  1. violating our terms and conditions of use;
  2. causing injury or other harm to, or otherwise violating the property or other legal rights, of us, other users, or third parties; or
  3. violating national, local, or other applicable law.

To the extent we are legally permitted to do so, it is our policy to notify you in the event that we are required to provide your personal information to third parties in connection with a court order.

b. WITHIN NEW WINE INTERNATIONAL

Within New Wine, your information is shared only with those that require it as a necessity to provide a service to you or for the necessary performance of their official duties.

5. SECURITY

The transmission of information via the internet, email or text message is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted through the Services or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organizational measures to safeguard your personal information against loss, theft and unauthorized use, access or modification.

When we collect financial account information, such as credit card numbers, we protect its transmission through the use of encryption such as the Transport Layer Security (TLS) protocol.

6. TRACKING TECHNOLOGIES AND ONLINE ADVERTISING

We use cookies, web beacons, pixels, tags, scripts and other similar technologies in the course of our business. Information about the technologies we use, why we use them (for example, in connection with online advertising), and how you can control them can be found in our Cookie Policy.

7. CHOICE/OPT-OUT
  • MARKETING COMMUNICATIONS FROM US
a. email

You always have the opportunity to opt out of our marketing communications with you or change your preferences by following a link in the footer of all non-transactional email messages from us or by emailing us at church@newwine.co.uk. Some communications from us are considered transactional or service communications (for example, important church notifications and financial communications), and some of our services are provided to you upon the condition that you are able to receive these communications from us. You would be required to formally notify us to cancel all transactional or service communications by writing to church@newwine.co.uk.

b. POST

Occasionally, we send you marketing information by post (e.g. about events, products or services). You retain the right to opt out of receiving such information by writing to church@newwine.co.uk or to our office address, New Wine International, Gateway House, John Wilson Street, Woolwich, London SE18 6QQ.

c. TELEPHONE / MOBILE

You have the opportunity to opt out of our communications to you via telephone or SMS text messaging. Notify us in writing to church@newwine.co.uk.

d. COOKIES

For information about how to manage and opt out from cookies, please visit our Cookie Policy.

e. INFORMATION FROM THIRD PARTIES

To manage the information we receive about you from a social networking site or other third parties (if applicable), you will need to follow the instructions from that party for updating your information and changing your privacy settings, where available. The information we collect is covered by this privacy policy and the information the third party collects is subject to such third party’s privacy practices. Privacy choices you have made on any third party site will not apply to our use of the information we have collected directly through our Services.

8. RETENTION OF PERSONAL INFORMATION

We retain your personal information to provide services to you and as otherwise necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain your personal information for no more than six years following the date on which you terminate your use of our Services unless there is a prevailing legitimate interest or we are otherwise required by law or regulation to retain your personal information for longer.

9. YOUR RIGHTS

Where the European Union’s General Data Protection Regulation 2016/679, or GDPR, applies, in certain circumstances and subject to data processing agreements, you have rights in relation to the personal information we hold about you. We set out below an outline of those rights and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by providing details only known to the account holder. To exercise any of your rights, please make your request in writing to church@newwine.co.uk. Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case.

a. ACCESS

You have the right to know whether we process personal information about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.

b. PORTABILITY

You have the right to receive a subset of the personal information you provide us if we process it on the legal bases of our contract with you or with your consent in a structured, commonly used and machine-readable format and a right to request that we transfer such personal information to another party. If you wish for us to transfer the personal information to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the personal information or its processing once received by the third party.

c. CORRECTION

You have the right to require us to correct any personal information held about you that is inaccurate and have incomplete data completed. Where you request correction, please explain in detail why you believe the personal information we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that while we assess whether the personal information we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.

d. ERASURE

You may request that we erase the personal information we hold about you in the following circumstances:

  • where you believe it is no longer necessary for us to hold the personal information;
  • we are processing it on the basis of your consent and you wish to withdraw your consent;
  • we are processing your data on the basis of our legitimate interest and you object to such processing;
  • you no longer wish us to use your data to send you marketing; or
  • you believe we are unlawfully processing your data.

Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure.

e. RESTRICTION OF PROCESSING TO STORAGE ONLY

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in the following circumstances:

  • You believe the personal information is not accurate for the period it takes for us to verify whether the data is accurate;
  • We wish to erase the personal information as the processing we are doing is unlawful but you want us to simply restrict the use of that data;
  • We no longer need the personal information for the purposes of the processing but you require us to retain the data for the establishment, exercise or defense of legal claims; or
  • You have objected to us processing personal information we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal information while we determine whether there is an overriding interest in us retaining such personal information.
f. OBJECTION

You have the right to object to our processing of data about you and we will consider your request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims.

You also have the right, at any time, to object to our processing of data about you in order to send you marketing, including where we build profiles for such purposes and we will stop processing the data for that purpose.

g. WITHDRAWAL OF CONSENT

Where you have provided your consent to us processing your personal data, you can withdraw your consent at any time by writing to us at church@newwine.co.uk.

10. THIRD PARTY LINKS AND INFORMATION COLLECTION AND USE BY OUR USERS

Some of our Services provide links to other websites. Because we do not control the information policies or practices of these third party sites, you should review their privacy policies to learn about how they collect and use personal information.

You may also log in to some of our Services using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you with the option to share certain personal information with us, such as your name and email address to pre-populate our sign up form. For example, if you take advantage of certain of our social media features, such as the Facebook Like button, and widgets, such as the “Share This” button or interactive mini-programs that run on our site, the applicable social networking sites may collect your IP address, which page you are visiting on our websites, and may set a cookie to enable it to function properly.

11. CHILDREN

We do not knowingly collect personal information from children under 13 without parental consent. If a parent or guardian becomes aware that his or her child has provided us with personal information without such parent or guardian’s consent, he or she should contact us by writing to church@newwine.co.uk. If we become aware that a child under 13 has provided us with personal information without parental consent, we will delete such information from our files.

12. DATA TRANSFER

In order for us to provide our Services to you, your personal information will be transferred to, and stored at/processed in the United Kingdom.

If your data is transferred outside the European Union, we will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this policy and in conformity with the provisions of the General Data Protection Regulations.

13. COMPLAINTS

In the event that you wish to make a complaint about how we process your personal information, please contact our Data Protection Officer at dpo@newwine.co.uk.

In the unlikely event that you are not satisfied with our response or believe we are not processing your personal data in accordance with the law you can contact the Information Commissioner’s Office (ICO) at:

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF