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Privacy Policy
1. Introduction
The Khoki United privacy policy (together with the Sales and Purchase of Goods Terms & Conditions and any other documents referred to in it) provide you with details of how we collect and process any personal data through your use of the website, https://www.wineswithattitude.co.uk/ (“the site”) or when you sign up to our newsletter or when you communicate with us by post, phone, email or otherwise. This includes information you provide when you register to use the site or place an order on the site (see Paragraph 3 for more examples). Khoki United Limited (“the Company” and “we”) is a UK wine retailer based online.
By providing us with your data, you warrant to us that you are over 18 years of age. It is very important that the personal data we hold about you is accurate and up to date. Please let us know if at any time your personal data changes by emailing us at info@khokiunited.com.
Changes to this privacy notice
This privacy notice was most recently updated on 6 January 2025 and is compliant with the General Data Protection Regulation (“GDPR”) that came into force on 25 May 2018. Any changes that we make in the future to this privacy notice will be posted on this page.
Contact Details
Khoki United Limited is the data controller. Our contact details are:
Email address: info@khokiunited.com
Telephone: 07349 886389
Postal address: Fiveways, 57-59 Hatfield Road, Potters Bar, Hertfordshire EN6 1HS
2. What data we collect about you
Under the GDPR personal data means any information about you from which you can be identified. It does not include data where your identity has been removed (“anonymised data”).
We may process certain types of personal data about you as follows:
Identity Data may include your first name, last name, username or similar identifier and title
Contact Data may include your billing address, delivery address (including delivery instructions), email address and telephone number(s)
Financial Data may include your bank account and payment card details
Transaction Data may include details about payments between us and other details of purchases made by you
Technical Data may include your login data, Internet Protocol address, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site
Profile Data may include your username and password, purchases or orders, your wine preferences and interests, feedback and survey responses
Usage Data may include information about how you use the site, products and services
Marketing and Communications Data may include your preferences for receiving marketing communications from us and your communication preferences
We may also process Aggregated Data from your personal data but this data does not reveal your identity and is not therefore personal data – for example we might review Usage Data to work out the percentage of website users using a specific feature of the site. If we were to link the Aggregated Data with your personal data so that you could be identified from it (which is extremely unlikely), then it would be treated as personal data which would be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes for example details about your race or ethnicity). Nor do we collect any information about criminal convictions and offences.
Where we are required to collect personal data by law, or under the terms of the contract between the Company and you, and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). In this case we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
3. How we collect your personal data
We use different methods to collect data from and about you including through:
Direct interactions: You may provide data by filling in forms on the site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
search for or order our products or services;
subscribe to our services or publications;
request resources or marketing be sent to you;
enter a competition, prize draw, promotion or survey;
give us feedback, reviews, testimonials; or
report a problem with the site.
Automated technologies or interactions: As you use the site, we may automatically collect Technical & Usage Data about your equipment, browsing actions and usage patterns; we do this to be able to understand better how visitors move around the site so that we can improve it. We collect this data by using cookies and similar technologies. Please see the cookie policy for more information.
Please note that you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. But if you disable or refuse cookies, please note that some parts of the site may become inaccessible or not function properly.
Third parties or publicly available sources: we may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
– analytics and search engine providers such as Google;
– advertising network such as Google and Facebook; and
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe; and
Identity and Contact data will be visible to us if you update your personal details in our newsletter subscriber list.
4. How we use your personal data
We will only use your personal data when the law allows us to do so. The most common legal bases for using personal data are:
Where we need to perform the contract between us
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
Where we need to comply with a legal or regulatory obligation.
For more information read the ICO’s description of the lawful bases. Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email, text or similar messages. You have the right to withdraw consent to marketing at any time by emailing us at info@khokiunited.com.
Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and which of the legal bases above we rely upon to do so. We have also identified what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:
Purpose/Activity
Type of data
Lawful basis for processing
To register you as a new account / customer
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order including:
(a) Managing payments, fees and charges
(b) Collecting and recovering money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests to recover debts owed to us
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services
To enable you to partake in a prize draw, competition or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow the business
To administer and protect the business and the site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests for running the business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise
(b) Necessary to comply with a legal obligation
To deliver relevant content and advertisements to you and measure and understand the effectiveness of any advertising
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow the business and to inform our marketing strategy
To use data analytics to improve our site, products/services, marketing, customer relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests to define types of customers for our products and services, to keep the site updated and relevant, to develop the business and to inform our marketing strategy
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests to develop our products/services and grow the business
Marketing communications
You will receive marketing communications from us if you have:
requested information from us or purchased goods or services from us; or
if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
in each case, you have not opted out of receiving that marketing.
We do not share your personal data with any third party for marketing purposes but if we ever were to do so we would obtain your express opt-in consent before we shared it.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at info@khokiunited.com at any time. Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please contact me.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
Delivery companies who pack and deliver or simply deliver your wine to you
Service providers who provide IT and system administration services
Mailchimp or other third party service provider through which we construct and deliver our email newsletters
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services
HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances
Third parties to whom we may choose to sell, transfer, or merge parts of the business or its assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We do not allow such third parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
Countries outside of the European Economic Area (“EEA”) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Some of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at info@khokiunited.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and the Information Commissioner’s Office (“ICO”) of a breach where we are legally required to do so. The ICO is the UK supervisory authority for data protection issues (www.ico.org.uk).
8. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data held by us. These include the right to:
Request access to your personal data
Request correction of your personal data
Request erasure of your personal data
Object to the processing of your personal data
Request the restriction of processing your personal data
Request the transfer of your personal data
Withdraw consent at any time where we are relying on consent to process your personal data
You can read more about these rights on the ICO’s website.
If you wish to exercise any of the rights set out above, please email us at info@khokiunited.com. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Third-party links
Thw site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy notice of each website that you visit.
contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@khokiunited.com.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the ICO but please contact us first if you do have a complaint so that we can try to resolve it for you.
Khoki United Cookie Policy
What are cookies?
A cookie is a small amount of information that’s downloaded to your computer or device when you visit certain websites. We use a number of different cookies on the Shopify website, including strictly necessary, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor. Read more about cookies (and other similar tracking technologies) and how we use the data collected through these technologies, in our Privacy Policy.
What cookies do we use and why?
Some cookies are necessary to allow you to browse our website, use its features, and access secure areas. The use of these cookies is essential for the website to work. For example, we use user-input cookies for the duration of a session to keep track of their input when filling in forms that span several pages.
We also use functional cookies to remember choices you’ve made or information you’ve provided, such as your username, language, or the region you are in. This allows us to tailor your website experience specifically to your preferences. For example, authentication cookies are functional cookies that are used for the duration of a session (or persistent, if you agree to the “remember me” function) to allow users to authenticate themselves on subsequent visits or to gain access to authorized content across pages. The functional cookies we use include:
User-centric security cookies to detect authentication abuses for a limited persistent duration, like repeated failed login attempts. These cookies are set for the specific task of increasing the security of the service.
Multimedia content player session cookies (flash cookies) are used for the duration of a session to store technical data needed to play back video or audio content (e.g. image quality, network link speed, and buffering parameters).
Load balancing session cookies are used for the duration of the session to identify the same server in the pool in order for the load balancer to redirect requests appropriately.
User interface customization persistent cookies are used to store a user’s preference regarding a service across web pages.
How long will cookies remain on my computer or mobile device?
The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device. See the section below on how to control cookies for more information on removing them before they expire.
How to control cookies?
You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.
Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as: www.allaboutcookies.org.
Many of the third party advertising and other tracking services listed above offer you the opportunity to opt out of their tracking systems. You can read more about the information they collect and how to opt out through the privacy policy links listed above.