This policy applies where we act as a data controller for your personal data, i.e., where we determine the purposes and means of the processing of such personal data, including personal data entered onto our website or via our Liquid Opulence Portfolio Management team.
The nature of the unregulated services advertised on our website means that we might obtain certain data about you. This statement sets out the principles governing our use of your Data. By registering and using our website, you agree to this use.
Legal Basis for Collecting and Processing Your Data
The law on data protection sets out a number of lawful bases for which a company may collect and process your personal data. Only 4 of these are relevant to us.
- Personal data is processed on the basis of our legitimate interests
- Personal data is processed on the basis of a contractual obligation
- Personal data is processed on the basis of legal compliance
- Personal data is processed on the basis of a person’s consent
Legitimate interests mean the interests of our company in conducting and managing our business to enable us to give you the best products and services and the best and most secure experience. For example, we have an interest in marketing our products and services to you and making sure our marketing is relevant to you. Therefore, we may process your information to send you marketing tailored to your interests.
It can also apply to processing that is in your interests. For example, we may process your information to protect you against fraud when transacting on our website and ensure our websites and systems are secure.
When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative) and your rights under data protection laws. Our legitimate business interests do not automatically override your interests. We will not use your personal data for activities where our interests are overridden by the impact on you unless we have your consent or are otherwise required or permitted to by law.
We use legitimate interests to process your personal data so that we can:
- Allow your Liquid Opulence Portfolio Manager to manage your account and optimise your portfolio performance
- To provide you with newsletters, specialist reports and additional useful investor information
- To provide Certificates of Ownership
- 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 provide you with special offers and promotions
Information we collect from you
Information that you give us by filling in forms on our website or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our website, subscribe to our online service and any other activities commonly carried out on our website. The information you give us may include your name, address, e-mail address, phone number or financial information concerning any proposed investment you may wish to make and that we are requested to obtain on behalf of clients.
Information we collect about you
With regard to each of your visits to our website or call with our Portfolio Management Team, we may collect the following information:
- Your name, date of birth and contact details
- Purchases and orders made by you
- Your payment card details (which we encrypt) when you purchase our products or services
- Your wine preferences, favourites, ratings and reviews
- Your online browsing history on our website
- Your correspondence with us, including emails, letters and telephone calls
How and why we use your personal data and on what lawful basis
- We use your personal data
- to provide you with information about the investment products you enquired about
- to notify you about changes to our service.
- On the basis of our contractual obligation to send you the wines, other products and services you have purchased and to manage any accounts you have registered with us so that
- we can provide you with products and services
- you can place orders
- we can fulfil those orders and communicate with you about them
- On the basis of our legitimate interest to improve the range of wines, offers and the associated products we offer you. To help identify new products and services to present you with personalised offers on our website or through our Portfolio Management Team.
- On the basis of our legal compliance to comply with the law. For example
- To ensure that we only sell products containing alcohol to those aged 18 or over
- To detect and prevent fraud and other illegal activities
- To assist regulators, trade bodies and law enforcement agencies
- To verify your identity and age.
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
- Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.
- To ensure that content from our website is presented most effectively for you and your computer.
We will ensure we obtain your full consent before obtaining any information from you.
Disclosure of your Data
For the avoidance of doubt, we will not disclose your Data to any third parties other than in accordance with this Policy and the circumstances detailed below:
- Selected third parties such as prospective investors or business partners
- If we sell any or all of our business to the buyer
- Where we are legally required by law to disclose your personal information
- To further fraud protection and reduce the risk of fraud
Where we store your data
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. All information you provide to us is stored on our secure servers.
Where we have given you, or where you have chosen, a password that enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
If we share your personal data with service providers outside the UK and the EEA, we will ensure reasonable safeguards are put in place to protect your personal data. Our standard practice is to use ‘standard data protection clauses provided by the European Commission and recognised by the ICO as appropriate for such transfers.
How Long We Store Your Data For
Whilst you are an active customer (which, for the avoidance of doubt, means you have purchased from us), we will retain your data for as long as needed to give you the best possible customer service. We will anonymise your data five years after your last transaction (sale, refund or payment), provided you have not interacted with us for one year.
For the purposes of this policy, an interaction is defined as an identifiable website purchase or contacting our Wine Portfolio Team.
In certain circumstances, we may retain your data where such retention is necessary for compliance with a legal obligation to which we are subject, to resolve disputes and enforce our agreements.
You have several rights under data protection laws summarised below.
Right of access: You have the right to contact us verbally or in writing to request details of the information we hold.
Right of rectification: You have the right to have any incomplete or inaccurate information that we hold about you corrected.
Right to erasure: This enables you to delete or remove personal information when there is no suitable reason for us to continue processing it.
Right to restrict processing: In certain circumstances, you have the right to request we suspend the processing of your data.
Right to data portability: You have the right to request the transfer of your data to a third party.
Right to object: You have the right to object to the processing of your data for marketing purposes.
Subject access requests
You have the right to see what personal data we hold about you under GDPR.
To obtain a copy of the personal information we hold about you, write to us at, Liquid Opulence Limited, 320 City Road, London, EC1V 2NZ or email email@example.com requesting a Subject Access Request.
We do not charge for the first request, but we may charge a fee if the request is repetitive or unreasonable. We aim to respond to requests within 28 days.
You can exercise your rights at any time by emailing us at firstname.lastname@example.org or calling us on +44 20 07278 0397.
If you feel we mishandled your data or you are unhappy with our response, you have the right to lodge a complaint with the Information Commissioner’s Office.
Liquid Opulence Ltd runs this website, and we are committed to protecting and respecting your privacy.
This Privacy and Cookies Policy (this Policy) sets out the basis on which any personal data we collect from you or that you provide to us will be processed by us. Please read the following carefully to understand our views and practices regarding your data and how we will treat it.
The nature of the unregulated services as advertised to be provided by us on our website means that we might obtain certain data about you. This statement sets out the principles governing our use of your data. By registering and using our website generally, you agree to this Use.
By visiting our website www.liquidopulence.co.uk you are accepting and consenting to the practices described in this Policy.
Our website may, from time to time, contain links to and from other websites. The fact that we have provided these third-party links at our website does not constitute an endorsement, authorization, sponsorship or affiliation by us with respect to the third party’s website, its owners or its providers. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check their policies before you submit any personal data to these websites.
Marketing tools used by Liquid Opulence Limited may share your information with processors. However, we abide to obtain your consent prior to sending any information, in line with protocols established by the General Data Protection Regulation (GDPR) in April 2016. Some of the processors include The Rocket Science Group LLC (MailChimp) and Hubspot (Base CRM). We welcome you to read their privacy policies.
Access to Data
In accordance with the General Data Protection Regulation (GDPR) Act, you have the right to access any Data that we hold relating to you. If you have any questions about how we use your data, or if you want to exercise any of your rights described above, please contact our Data Protection Team by emailing email@example.com or writing to Liquid Opulence Limited, 320 City Road, London, EC1V 2NZ.
Please note that we will use our best endeavours to reply as soon as possible to your request. However, standard timeframes allow up to one month to comply with any requests.
We may update this policy from time to time to take account of any new business activity or to reflect any changes in law or best practice concerning data protection. We will notify you if we do so.
This policy was last updated on 21st February 2021.