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Privacy

1. Who We Are

Winedrops is operated by Banquist Limited (“Winedrops,” “we,” “us,” or “our”), a company registered in England and Wales under number 12090778, with its registered office at Bk 311 Cremer Street, Brickfields, London, England, E2 8HD.

For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, Banquist Limited is the data controller responsible for your personal data.

This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit our website and mobile application at winedrops.co.uk (the “Site”), create an account, purchase products, or otherwise interact with us. It applies to all visitors, members, customers, and competition entrants.

If you have any questions about this Privacy Policy or how we handle your personal information, please contact us at help@winedrops.co.uk.

2. Our Commitment to Your Privacy

  • We will only use your data for the purposes described in this Privacy Policy and in accordance with the lawful bases set out in Section 5.
  • We will protect your data with appropriate technical and organisational safeguards.
  • We will use clear, plain English to explain how your data is used.
  • We will always give you the ability to manage your communication preferences.
  • If we no longer need your information, we will delete it in accordance with our retention practices.
  • We will never sell your personal data.

3. Information We Collect

3.1 Information You Provide to Us

We collect personal information that you voluntarily provide when you create an account, place an order, subscribe to our membership, enter a competition, respond to a survey, or contact our customer service team. This may include:

  • Identity information: your name, date of birth, and proof of age (you must be at least eighteen (18) years old to purchase alcohol through Winedrops).
  • Contact information: your email address, phone number, and delivery address.
  • Payment information: your payment card number, expiry date, and billing address. Payment card details are processed through our third-party payment gateway provider (Stripe) and are not stored on our servers.
  • Account information: your username, password, membership tier, and communication preferences.
  • Communication content: any information you provide when you contact us, leave a review, respond to a survey, or post content on our Site.

3.2 Information We Collect Automatically

When you visit our Site, we automatically collect certain information through cookies and similar tracking technologies, subject to your consent where required under the Privacy and Electronic Communications Regulations 2003 (PECR). This may include:

  • Device information: device type, make, model, operating system, and web browser.
  • Usage information: pages viewed, links clicked, browsing duration, and frequency of visits.
  • Network information: IP address and approximate geographic location.
  • Advertising identifiers: information collected by advertising platforms (such as Meta/Facebook pixels, Google Ads tags, and similar technologies) that were part of your journey to our Site.

3.3 Information from Third Parties

We may receive your personal information from third parties, for example when you enter a competition run jointly with one of our partners. Where a third party shares your data with us, we will always give you the option to opt out of marketing communications.

4. How We Use Your Information

4.1 To Fulfil Orders and Provide Our Service

  • Processing and delivering your wine orders.
  • Managing your membership account, including subscription billing and renewals.
  • Sending you service communications such as order confirmations, dispatch notifications, store credit updates, and membership renewal reminders.
  • Providing customer service and support, including maintaining records of our communications with you (emails, instant messages, social media postings, reviews, telephone recordings, SMS messages, and letters). We also use these records to train our staff and improve our products and services.

4.2 To Verify Your Age and Identity

As a reseller of alcohol-based products, we are required to verify that you are at least eighteen (18) years old. We use your date of birth and, where necessary, identification documents to comply with this legal requirement. We may also use your date of birth for promotional activities such as birthday rewards or discounts, and to understand our customer demographic.

4.3 To Communicate with You

  • Sending you daily deal notifications, weekly shop updates, and information about upcoming sales and promotions via email and app push notifications. You can manage these in the app under Menu > Notifications.
  • Keeping you informed about winemakers, wine education, and Winedrops news via post, phone, or email. You can opt out at any time by emailing help@winedrops.co.uk or clicking “unsubscribe” in any email.
  • Occasionally contacting you to request feedback, invite you to complete a questionnaire, or submit a product review. These submissions may be used on our website, social media, and marketing channels, and shared with our winemaker and supplier partners. We will not share any personal data included in your submissions without your permission.

4.4 To Improve Our Service

  • Analysing how you interact with our Site so we can improve its design, functionality, and search features.
  • Understanding purchase patterns and preferences to develop better products and offers.
  • Conducting internal analytics, including analysis of preferred subscription choices and product trends.
  • Research, anonymous profiling of website visitors, site improvements, testing our systems, and developing new products. Where we use your data for these purposes, we will always anonymise it so you cannot be identified.

4.5 For Advertising and Marketing

  • Showing you Winedrops advertisements when you browse the internet, including on social media platforms and search engines.
  • Tailoring the content you see on our Site based on your browsing behaviour and purchase history.
  • Using advertising technologies such as pixels, ad tags, beacons, and cookies, as well as services provided by advertising platforms including Meta/Facebook Custom Audiences and Google Ads.

Note: When we use services such as Meta/Facebook Custom Audiences, we share certain data (such as hashed email addresses) with those platforms. Meta and Google act as independent controllers for some of this data. See Section 6 for your choices regarding these activities.

4.6 To Prevent Fraud and Protect Our Business

We use your information to detect, prevent, and investigate fraud, unauthorised access, and other illegal activities, and to protect the rights and safety of Winedrops, our members, and the public.

We process your information where necessary to comply with applicable laws, regulations, and legal processes, including those related to the sale and distribution of alcoholic beverages, tax reporting, and data protection law.

5. Lawful Bases for Processing

Under the UK GDPR, we must have a lawful basis for processing your personal data. The bases we rely on are as follows:

  • Performance of a contract: We process your identity, contact, and payment information to fulfil your membership, process orders, deliver wine, issue refunds, and provide customer service (Sections 4.1 and 4.2).
  • Legal obligation: We process your date of birth and identification data to verify you are at least 18 years old, as required by law. We also retain transaction records for tax and accounting purposes (Sections 4.2 and 4.7).
  • Legitimate interests: We process your data for fraud prevention, service improvement, internal analytics, and direct marketing where you are an existing customer and we are promoting similar products or services (Sections 4.3, 4.4, 4.5, and 4.6). Our legitimate interest is to operate and grow our business. You have the right to object to processing based on legitimate interests — see Section 10.
  • Consent: We rely on your consent to set non-essential cookies and tracking technologies on your device (Section 7), and to send you marketing communications where you are not an existing customer or where we use channels requiring consent (such as SMS). You can withdraw consent at any time.

6. How We Share Your Information

We never sell your personal data. However, we do share your information with third parties in the following circumstances:

6.1 Service Providers

We share your information with trusted third-party service providers who assist us in operating our business, including payment processors (Stripe), delivery and shipping companies, email and communication platforms, cloud hosting providers, customer service tools, and marketing agencies. These providers process your data on our behalf and are contractually required to use it only for the purposes we specify and to protect it appropriately. They act as data processors under the UK GDPR.

6.2 Advertising Partners

We share certain information (such as hashed email addresses, browsing data, and purchase activity) with advertising platforms including Meta/Facebook and Google to serve you targeted advertisements. These platforms may act as independent controllers for some of this data. You can opt out of this at any time by adjusting your cookie preferences on our Site, or by contacting us at help@winedrops.co.uk.

6.3 Competition and Promotion Partners

If you enter a competition or promotion run jointly with a third party, we may share your name and contact details with that partner. We will always make clear at the point of entry who the partner is, what data will be shared, and how you can manage your data held by them.

We may disclose your information if required to do so by law, regulation, legal process, or governmental request, or where we believe disclosure is necessary to protect our rights, your safety, or the safety of others, investigate fraud, or respond to a law enforcement request.

6.5 Business Transfers

In the event of a merger, acquisition, reorganisation, or sale of all or a portion of our assets, your personal information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have regarding your information.

7. Cookies and Tracking Technologies

We use cookies and similar technologies on our Site to provide functionality, analyse usage, and deliver targeted advertising. We comply with the Privacy and Electronic Communications Regulations 2003 (PECR) and the UK GDPR in relation to cookies.

7.1 Types of Cookies We Use

  • Strictly necessary cookies: required for the Site to function properly, including session management, authentication, and shopping basket functionality. These do not require your consent and cannot be disabled.
  • Analytics cookies: help us understand how visitors interact with our Site by collecting and reporting information (e.g., Google Analytics). These require your consent.
  • Advertising cookies: used to deliver relevant advertisements and track the effectiveness of our marketing campaigns (e.g., Meta/Facebook Pixel, Google Ads tags). These require your consent.
  • Preference cookies: remember your settings and preferences to enhance your browsing experience. These require your consent.

When you first visit our Site, you will be presented with a cookie consent banner that allows you to accept or decline non-essential cookies. You can change your cookie preferences at any time through the cookie settings link on our Site, or by adjusting your browser settings.

We also collect non-personally identifiable information such as aggregated page views, browser types, and visit frequency, which does not identify any individual.

8. How Long We Keep Your Information

We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Our specific retention periods are:

  • Account and membership data: retained for as long as your account is active, and for up to two (2) years after account closure to handle any post-cancellation queries, disputes, or legal obligations.
  • Transaction and order data: retained for six (6) years from the date of the transaction to comply with HMRC tax and accounting requirements.
  • Marketing data: retained until you opt out of marketing communications, at which point we will suppress your contact details to prevent future marketing.
  • Customer service records: retained for three (3) years from the date of the last interaction for quality assurance and training purposes.
  • Age verification data: retained for as long as your account is active and for a reasonable period afterward as required by applicable licensing regulations.

When your data is no longer required, we will securely delete or anonymise it.

9. International Data Transfers

Winedrops is based in the United Kingdom. Some of the third-party service providers we use to operate our business (such as cloud hosting providers, payment processors, and advertising platforms) may process your data outside the United Kingdom and the European Economic Area (EEA).

Where we transfer your personal data outside the UK, we ensure that appropriate safeguards are in place in accordance with the UK GDPR and guidance from the Information Commissioner’s Office (ICO). These safeguards may include:

  • Transfers to countries that the UK government has determined provide an adequate level of data protection.
  • The use of International Data Transfer Agreements (IDTAs) or the UK Addendum to the EU Standard Contractual Clauses.
  • Other transfer mechanisms recognised under UK data protection law.

If you would like further information about the safeguards we use for international transfers, please contact us at help@winedrops.co.uk.

10. Your Rights Under UK Data Protection Law

Under the UK GDPR and the Data Protection Act 2018, you have the following rights in relation to your personal data:

  • Right to be informed: You have the right to know how we collect and use your personal data. This Privacy Policy fulfils that obligation.
  • Right of access: You have the right to request a copy of the personal information we hold about you (a “subject access request”).
  • Right to rectification: You have the right to request that we correct any inaccurate or incomplete personal information.
  • Right to erasure: You have the right to request that we delete your personal data in certain circumstances (for example, where it is no longer necessary for the purposes for which it was collected).
  • Right to restrict processing: You have the right to request that we restrict the processing of your personal data in certain circumstances (for example, where you contest its accuracy).
  • Right to data portability: You have the right to request that we provide your personal data in a structured, commonly used, machine-readable format, and to transmit it to another controller.
  • Right to object: You have the right to object to our processing of your personal data where we rely on legitimate interests as our lawful basis. You also have an absolute right to object to direct marketing at any time.
  • Right to withdraw consent: Where we rely on your consent to process your data (such as for non-essential cookies or certain marketing communications), you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
  • Rights related to automated decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects. We do not currently make decisions about you based solely on automated processing.

10.1 How to Exercise Your Rights

To exercise any of the rights described above, please contact us at help@winedrops.co.uk. We will verify your identity before processing your request and will respond within one (1) month, as required by the UK GDPR. In complex cases, we may extend this by a further two months, but we will inform you if this is necessary.

You will not normally be charged a fee to exercise your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. We may also refuse to comply with your request in these circumstances.

10.2 Right to Complain

If you are not satisfied with our response to your privacy request, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

Website: ico.org.uk

Telephone: 0303 123 1113

We would appreciate the opportunity to address your concerns before you contact the ICO, so please do reach out to us first.

11. Marketing Communications

For existing members and customers, we may send marketing communications by email and post about products and services similar to those you have previously purchased or enquired about. This is permitted under the “soft opt-in” rule in the Privacy and Electronic Communications Regulations 2003 (PECR), provided we gave you the opportunity to opt out when your data was first collected, and in every subsequent communication.

Where you are not an existing customer, or where we wish to use channels that require consent (such as SMS), we will only send marketing communications with your prior consent.

You can unsubscribe from marketing communications at any time by clicking “unsubscribe” in any email, adjusting your notification preferences in the app (Menu > Notifications), or contacting help@winedrops.co.uk. Opting out of marketing will not affect service communications such as order confirmations and dispatch notifications.

12. Data Security

We have implemented appropriate technical and organisational security measures to protect your personal information from unauthorised access, alteration, disclosure, or destruction. These include encryption of data in transit and at rest, access controls, regular security assessments, and staff training on data protection obligations.

Payment card information is processed by our third-party payment provider (Stripe) and is not stored on our servers. All payment processing is compliant with the Payment Card Industry Data Security Standard (PCI DSS).

However, no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security. Any transmission of personal information is at your own risk.

We have procedures in place to deal with any suspected personal data breach and will notify you and the ICO where we are legally required to do so.

13. Children’s Privacy

Our Site and services are not directed at individuals under the age of eighteen (18). We do not knowingly collect personal information from anyone under 18. If we become aware that we have collected personal information from a person under 18, we will take steps to delete that information promptly. If you believe we have inadvertently collected information from a person under 18, please contact us at help@winedrops.co.uk.

14. Third-Party Websites and Links

Our Site may contain links to third-party websites, products, or services. These third-party sites are not controlled by us, and we are not responsible for their privacy practices or content. We encourage you to review the privacy policy of every website you visit. Clicking on third-party links or visiting third-party websites is at your own risk.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you by posting the updated policy on our Site with a revised “Last Updated” date. Where required by law, we will provide additional notice (such as by email). Your continued use of the Site after any changes constitutes your acceptance of the updated Privacy Policy.

16. How to Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Email: help@winedrops.co.uk

Address: Banquist Limited (trading as Winedrops), Bk 311 Cremer Street, Brickfields, London, England, E2 8HD

We have appointed a Data Protection Officer to oversee compliance with this Privacy Policy. For data protection enquiries, please contact our DPO at help@winedrops.co.uk.

We always welcome feedback from our members and site visitors. Our Memberships team is happy to answer any questions you may have.