CULT WINES CANADA LIMITED

Privacy and Cookies Policy

We are Cult Wines Canada Limited, a company incorporated in Ontario, Canada with its head office at 110 Cumberland Street, Suite 333, Toronto, Ontario (we might refer to ourselves as "Cult Wines", "we", "our" or "us"). This is the Privacy and Cookies Policy ("Policy") our wine portfolio management services and the website hosted at www.wineinvestment.ca ("our Site") (together the "Services"). We are committed to protecting and respecting your privacy.

This Policy sets out:

  1. What information do we collect about you?
  2. How will we use your information?
  3. Sharing your information with others
  4. Cookies and other technologies
  5. How long do we keep your information?
  6. How do we protect your information?
  7. What are your rights?
  8. Where we store your information
  9. Payment processing
  10. Changes to this policy
  11. Contact us

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.By accepting our Services, you acknowledge you have read and understood this Policy.

 

1. What information do we collect about you?

Information you give us

  • To use our Services, you will need to register for an account ("Account") with us through the account opening request form available on our Site (we call this your "Account Opening Request") as part of the onboarding process. You will need to be at least 18 years of age to create an Account and to use our Services.
  • You will need to enter the following information into the Account Opening Request:
    full name
    address
    email address
    phone number
  • As part of the onboarding process, you will also provide us with the following:
    • information about your investment style, risk appetite and investment length so we can build your investor profile and furnish you with appropriate investment recommendations;
    • payment details to fund your Account, which is collected via the online form or bank transfer; and
    • Information about your financial background (i.e. your net worth, income, or job position) when you complete our investor declaration form.
  • In rare circumstances, we may also need you to provide certified copies of identification documents (i.e. passports) and utility bills for verification checks purposes. We do not retain copies after verification.
  • We may also collect records of any correspondence and communication if you contact us, including information you supply if you report a problem with our Site or Services to us. This covers information we learn about you from: letters, faxes, emails, texts & other digital messaging, calls, face-to-face conversations you have with us.
  • If you sign up for ongoing insights, newsletters, download reports or other promotional material from us, we will collect your contact information and marketing preferences.

Information from third parties

  • We may from time to time receive your Account Opening Request information (set out above) from third party introducers, where you have agreed for them to share your information with us. We use this information to onboard you and set up your Account (at your request).

 

2. How will we use your information?

You can see a full list of the types of data we process and the purpose for which we process it here.

We use personal data held about you in the following ways:

Information you give to us:

We will use this information to:

  • Set up your Account and fulfil any orders you make with us, including:
    • administering your account with us;
    • verifying and carrying out payments that you make through our Site; and
    • notifying you about changes to our Services.
  • Manage your Account moving forward;
  • In some circumstances, and depending on the type of account you hold with us, to set preferences and make decisions about you and your account on an automated basis i.e. through the use of artificial intelligence tools to manage your account based on your previous activity and stated preferences;
  • Provide you with information about our products and Services we feel may interest you, if you have given your consent to receiving marketing material from us at the point we collected your information or otherwise as permitted by law. See 'Our promotional updates and communications'.
  • Ensure in our legitimate interest that:
    • content from our Site is easy for you to read and understand on your devices; and
    • we answer any questions you have and give you any information that you request.

Information we collect about you from your use of our Services:

  • We will use some information, in our legitimate interest, to help us:
    • to run our Site and our Services and to help us spot problems;
    • to understand how people use our Site so we can improve them;
    • to keep our Site safe and secure;
    • to make sure any advertising we send or show to you is relevant to you; and
    • to allow you to participate in any interactive features of our service, when you choose to do so.

Our promotional updates and communications

  • With your prior consent or otherwise as permitted by law, we will use your personal information for marketing analysis and to provide you with promotional update communications about our products.
  • You can object to further marketing at any time by checking and updating your contact details within your account, or selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by sending us an email at [email protected]

 

3. Sharing your information with others

  • To provide our Services, we work with the following carefully selected third parties. To do this, we may share your information with these third parties:
    • the third parties responsible for arranging and fulfilling delivery of your wine order to our storage facility or to you (specifically your name and delivery address);
    • any service providers hired to provide administrative, communication, wine storage, delivery, payment processing or insurance services;
    • any group companies for business purposes;
    • any affiliated companies; and
    • any professional advisers.
  • We will also disclose your information to third parties:
    • in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this Policy;
    • if Cult Wines or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and
    • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to enforce or apply our terms of supply and other agreements with you; or to protect the rights, property, or safety of Cult Wines, our customers, or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction and to prevent cybercrime.
  • We also work with several third parties to provide the Site and the Services to you, as follows:

Table 01

 

4. Cookies and other technologies

  • Our Site uses cookies and/or other similar technologies such as device-IDs, in-App codes, pixel tags and web beacons to collect and store certain information. These typically involve pieces of information or code that a website transfers to or accesses from your computer hard drive or mobile device to store and sometimes track information about you. Cookies and similar technologies enable you to be remembered when using that computer or device to interact with websites and online services and can be used to manage a range of features and content as well as storing searches and presenting personalised content.
  • Our Site uses cookies and similar technologies either alone or in combination with each other to create a unique device ID, and to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site.
  • A number of cookies and similar technologies we use last only for the duration of your web or app session and expire when you close your browser or exit the Site. Others are used to remember you when you return to the Site and will last for longer.
  • We use strictly necessary cookies if they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights). We use all other cookies with your consent.
  • We use the following types of cookies:

    Strictly necessary cookies
    These are cookies that are required for the operation of our website and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our website or (on other sites) use a shopping cart.

    Functionality cookies
    These may be used to recognise you when you return to our website. This enables us, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, choice of language or region).

    Analytical/performance cookies
    These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

    Targeting/Advertising cookies
    These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

    Social networking cookies
    These cookies help us manage our social media, including enabling you to share content and enabling us to understand how you interact with us. We will use this information subject to your choices and preferences to improve our Site and services. We may also share this information with third parties for this purpose.

    We may also work with advertising networks that gather information about the content on our Site you visit and on information on other websites and services you visit. This may result in you seeing advertisements through our Site or our advertisements when you visit other websites and services of third parties. For more information about how to turn this feature off see below or visit http://www.youronlinechoices.co.uk.

    Table 02

    Disabling cookies
    The effect of disabling cookies depends on which cookies you disable but, in general, the website may not operate properly if all cookies are switched off.

    If you want to disable cookies on our website, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use.

    Microsoft Internet Explorer
    1. Select the Tools menu > Internet Options
    2. Click on the Privacy tab
    3. Click on Advanced within the Settings section and select the appropriate setting

    Google Chrome
    1. Select Settings > Advanced
    2. Under Privacy and Security > Content settings.
    3. Click Cookies and select the relevant options

    Safari
    1. Select Preferences > Privacy
    2. Click on Remove all Website Data

    Mozilla Firefox
    1. Choose the Tools menu > Options
    2. Click on the Privacy icon
    3. Select the Cookie menu and select the relevant options

    Opera 6.0 and further
    1. Choose Files menu > Preferences
    2. Select Privacy

    We may also separately prompt you regarding our use of cookies on the Site.

 

5. How long do we keep your information?

  • We retain the data you provide to us for as long as you have an Account with us in order to meet our contractual obligations to you and for seven years after that to identify any issues and resolve any legal proceedings. After you have deactivated your Account, we may store your information in an aggregated and anonymised format.

 

6. How do we protect your information?

  • All information you provide to us is stored on our secure servers.
  • Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
  • Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
  • Our Site may, from time to time, contain links to external Sites. We are not responsible for the privacy policies or the content of such Sites.

 

7. What are your rights?

  • You have the right under certain circumstances:
    • to be provided with a copy of any personal data we have about you (for example, your name and address); and
    • to request the correction of personal data held by us.
  • Your right to withdraw consent:
    • You may withdraw that consent at any time by contacting us [email protected], though this may impede our ability to provide service to you.
    • You can also change your marketing preferences at any time as described in 'Our promotional updates and communications' section;
  • You can ask us to do any of the aforementioned things at any time by contacting us at 1.855.808.2858.

 

8. Where we store your information

  • The data we collect from you is stored in the following countries outside of Canada, and is subject to access under foreign laws: United Kingdom, Ireland and Germany. For information about our use of service providers outside of Canada please contact us at 1.855.808.2858.

 

9. Payment processing

  • Payment details you provide will be kept securely. We use a third party to process your payments and information which you supply to Stripe is not within our control and subject to Stripe's privacy policy here: https://stripe.com/privacy

 

10. Changes to this policy

  • If we make any changes to this Policy, a new version will be posted on this page and you will be notified via email of the substantive changes. This policy was last updated on April 11, 2021.

 

11. Contact Us

  • We welcome your feedback and questions. If you would like to contact us or make a complaint about our privacy practices, please contact us:
    By email at [email protected]
    By phone on 1.855.808.2858 between the hours of 9am to 5pm from Monday to Friday
  • Our Data Protection Officer is:

    Carrie Tuck
    110 Cumberland Street
    Suite 333
    Toronto, Ontario
    M5R 3V5
    Canada

    Phone: 16478228067
    Email: [email protected]
    Website: www.wineinvestment.ca

  • Purpose for processing of personal data

    This table sets out:
    • What personal data we process
    • What we use that data for

It forms part of our Policy which you should also read.

Table 03.