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- Log data
- Device data
- Personal information
- Legitimate reasons for processing your personal information
- Collection and use of personal information
- Disclosure of personal information to third parties
- International Transfers of Personal Information
- How we treat personal information
- Your rights and controlling your personal information
- Storage and security
- Cookies and web beacons
- Links to other websites
- Children’s privacy
- Business transfers
- Additional disclosures for General Data Protection Regulation (GDPR)
- Amendments
PRIVACY POLICY
Welcome to Good Pair Days (United Kingdom)! Each month, enjoy a selection of wines delivered to your door and handpicked by our sommelier just for you. And there’s more – you’ll receive recipes, goodies and access to quizzes, your wine history, reviews, badges and loyalty points that you can share with your friends and family. To provide the best service, we may collect some information about you.
We understand that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including through our UK website and UK mobile application (Site). In this Privacy Policy we, us or our means Good Pair Days Ltd, company number 13585473.
Information we collect falls into one of two categories: voluntarily provided information and automatically collected information. Voluntarily provided information refers to any information you knowingly and actively provide us when using or participating in any of our services and promotions. Automatically collected information refers to any information automatically sent by your devices in the course of accessing our products and services.
Log data
When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.
Additionally, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.
Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.
Device data
When you visit our website or interact with our services, we may automatically collect data about your device, such as:
- Device Type;
- Operating System;
- Unique device identifiers;
- Device settings;
- Geo-location data;
Data we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.
Personal information
The types of personal information we may collect about you include:
- your name;
- images of you;
- your contact details, including email address, mailing address, street address and/or telephone number;
- your date of birth;
- your preferences and/or opinions;
- information you provide to us through customer surveys;
- your sensitive information as set out below;
- details of products and services we have provided to you and/or that you have enquired about, and our response to you;
- your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
- information about your access and use of our Site, including through the use of Internet cookies, your communications with our Site, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
- additional personal information that you provide to us, directly or indirectly, through your use of our Site, associated applications, associated social media platforms and/or accounts from which you permit us to collect information, including Facebook;
- any other personal information requested by us and/or provided by you or a third party.
We may collect these types of personal information directly from you or from third parties including from a third party who orders our products as a gift for you.
Legitimate reasons for processing your personal information
We only collect and use your personal information when we have a legitimate reason for doing so. In which instance we only collect personal information that is reasonably necessary to provide our services to you.
Collection and use of personal information
We may collect, hold, use and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:
- to enable you to access and use our Site, associated applications and associated social media platforms;
- to enable you to customize or personalise your experience of our website;
- to deliver products and/or services to you;
- to contact and communicate with you;
- for internal record keeping, administrative purposes, invoicing and billing purposes;
- for security and fraud prevention, and to ensure that our sites and apps are safe, secure, and used in line with our terms of use;
- for analytics, market research and business development, including to operate and improve our Site, associated applications and associated social media platforms;
- for technical assessment, including to operate and improve our app, associated applications, and associated social media platforms;
- to run competitions and/or offer additional benefits to you;
- for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you;
- to comply with our legal obligations and resolve any disputes that we may have;
- to consider your employment application.
We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, Our marketing and market research activities may uncover data and insights, which we may combine with information about how visitors use our site to improve our site and your experience on it.
Disclosure of personal information to third parties
We may disclose personal information to:
- a parent, subsidiary or affiliate of our company;
- third party service providers for the purpose of enabling them to provide their services, including (without limitation) delivery service providers, IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, analytics providers, professional advisors and payment systems operators;
- our employees, contractors and/or related entities;
- our existing or potential agents or business partners;
- sponsors or promoters of any competition we run;
- anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
- credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
- courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
- third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located, or that store data, outside of the United Kingdom;
- third parties to collect and process data;
- an entity that buys, or to which we transfer all or substantially all of our assets and business.
Third parties we currently use include:
- Amazon Web Services (https://aws.amazon.com/)
- Stripe (https://stripe.com/)
- PeopleVox (https://peoplevox.com/)
- Scurri (https://www.scurri.com/)
- Shippit (https://shippit.com/)
- Mixpanel (https://mixpanel.com/)
- SendGrid (https://sendgrid.com/)
- PostHog (https://app.posthog.com/)
- Google (https://www.google.com)
- Facebook (https://www.facebook.com/)
- Pinterest (https://www.pinterest.com)
- Twilio (https://twilio.com/)
- Slack (https://slack.com/)
- 1Password (https://1password.com/)
- Typeform (https://www.typeform.com/)
- Zendesk (https://www.zendesk.com/)
- Xero (https://www.xero.com/au/)
- Deputy (https://www.deputy.com/au)
- Sentry (https://sentry.io/)
International transfers of personal information
The personal information we collect is stored and/or processed in Australia, United States, and United Kingdom, or where we or our partners, affiliates, and third-party providers maintain facilities.
The countries to which we store, process, or transfer your personal information may not have the same data protection laws as the country in which you initially provided the information. If we transfer your personal information to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this privacy policy.
How we treat personal information that is also sensitive information
Sensitive information is a sub-set of personal information that is given a higher level of protection under the UK GDPR Privacy Principles. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information.
We do not currently collect sensitive information, however if in the future we do collect sensitive information, provided you consent, your sensitive information may only be used and disclosed for purposes relating to the primary purpose for which the sensitive information was collected.
Sensitive information may also be used or disclosed if required or authorised by law.
Your rights and controlling your personal information
Choice and consent: Please read this Privacy Policy carefully. By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of this Site or the products and/or services offered on or through it.
Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Restrict: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.
Access: You may request details of the personal information that we hold about you. An administrative fee may be payable for the provision of such information.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
Complaints: If you wish to make a complaint about how we have handled your personal information, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint.
Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example providing user support), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.
Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
Downloading of Personal Information: We provide a means for you to download the personal information you have shared through our site. Please contact us for more information.
Storage and security
We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification.
Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure and no one can guarantee absolute data security.
We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.
You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.
We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this privacy policy. For example, if you have provided us with personal information as part of creating an account with us, we may retain this information for the duration your account exists on our system. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you.
However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.
If you don't make an order for 4 years then your account information is deleted for data privacy reasons.
Cookies and web beacons
We may use cookies on our Site from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our Site with personal information, this information may be linked to the data stored in the cookie.
We may use web beacons on our Site from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.
We may use Google Analytics to collect and process data. To find out how Google uses data when you use third party websites or applications, please see https://policies.google.com/privacy or any other URL Google may use from time to time.
By using the YouTube widget on the dashboard users are agreeing to be bound by YouTube’s terms of service. The client uses YouTube API Services. To find out how Youtube uses data please see www.youtube.com/t/terms or any other URL YouTube may use from time to time.
Links to other websites
Our Site may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.
Business transfers
If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.
Children’s privacy
We do not aim any of our products or services directly at children under the age of 18 and we do not knowingly collect personal information about children under 18.
Additional disclosures for General Data Protection Regulation (GDPR)
Data Controller / Data Processor: The GDPR distinguishes between organisations that process personal information for their own purposes (known as data controllers) and organizations that process personal information on behalf of other organizations (known as data processors ). We, Good Pair Days, located at the address provided in our Contact Us section, are a Data Controller with respect to the personal information you provide to us.
Legal Bases for Processing Your Personal Information: We will only collect and use your personal information when we have a legal right to do so. In which case, we will collect and use your personal information lawfully, fairly and in a transparent manner. If we seek your consent to process your personal information, and you are under 16 years of age, we will seek your parent or legal guardian’s consent to process your personal information for that specific purpose. Our lawful bases depend on the services you use and how you use them. This means we only collect and use your information on the following grounds:
Consent From You
Where you give us consent to collect and use your personal information for a specific purpose. You may withdraw your consent at any time using the facilities we provide; however this will not affect any use of your information that has already taken place. You may consent to providing your email address for the purpose of receiving marketing emails from us. While you may unsubscribe at any time, we cannot recall any email we have already sent. If you have any further enquiries about how to withdraw your consent, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.
Performance of a Contract or Transaction
Where you have entered into a contract or transaction with us, or in order to take preparatory steps prior to our entering into a contract or transaction with you. For example, if you contact us with an enquiry, we may require personal information such as your name and contact details in order to respond.
Our Legitimate Interests
Where we assess it is necessary for our legitimate interests, such as for us to provide, operate, improve and communicate our services. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests.
Compliance with Law
In some cases, we may have a legal obligation to use or keep your personal information. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If you have any further enquiries about how we retain personal information in order to comply with the law, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.
International Transfers Outside of the European Economic Area (EEA): We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.
Your Rights and Controlling Your Personal Information: Restrict: You have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.
Objecting to processing: You have the right to object to processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your personal information.
Data portability: You may have the right to request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may also have the right to request that we transfer this personal information to a third party.
Deletion: You may have a right to request that we delete the personal information we hold about you at any time, and we will take reasonable steps to delete your personal information from our current records. If you ask us to delete your personal information, we will let you know how the deletion affects your use of our website or products and services. There may be exceptions to this right for specific legal reasons which, if applicable, we will set out for you in response to your request. If you terminate or delete your account, we will delete your personal information within 14 days of the deletion of your account. Please be aware that search engines and similar third parties may still retain copies of your personal information that has been made public at least once, like certain profile information and public comments, even after you have deleted t he information from our services or deactivated your account.
Amendments
We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our Site. We recommend you check our Site regularly to ensure you are aware of our current Privacy Policy.
If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy.
For any questions or notices, please contact our Privacy Officer at:
Good Pair Days Ltd, company number 13585473.
Email: uk@goodpairdays.com
Last update: 8 Nov 2021