Privacy Policy

We are Cult Wines Limited, a company registered in England and Wales and with its registered office at The Clockwork Building, 45 Beavor Lane, London, W6 9AR (we might refer to ourselves as "Cult Wines", "we", "our" or "us"). This is the Privacy and Cookies Policy ("Policy") for our wine portfolio management services; the website hosted at www.wineinvestment.com; the Cult X Platform accessible at https://www.cultx.com/ and the Cult X App, ("our Sites"). The services available to you through our Sites are referred to in this Policy as the "Services".  

We are committed to protecting and respecting your privacy.

This Policy sets out:

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purposes of UK and EU data protection law ("Data Protection Law"), we are the data controller of your information.

Information you give us:

To use any of our Services on either wineinvestment.com or the Cult X platform (including the Cult X App), you will need to register for an account ("Account") with us through the account opening request forms available on our Sites (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:

As part of the onboarding process, you will also provide us with the following:

As a user of Cult X you will be able to build up a profile of your wine interests and preferences which will be stored as part of your user profile.

In some circumstances, we may also need you to provide certified copies of identification documents (i.e. passports) and utility bills for verification checks purposes.

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 Sites 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.

You can see a full list of the types of data we process, the purpose for which we process it and the lawful basis on which it is processed here.

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

Information you give to us:

We will use this information to:

If you have given your consent to receiving marketing material from us at the point we collected your information, where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications. See 'Our promotional updates and communications'.

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

We will use some information, in our legitimate interest, to help us:

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

Where permitted in our legitimate interest or with your prior consent, 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 info@cultwines.com.

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:

We will also disclose your information to third parties:

More information about our use of third-party cookies and tools can be found in the Cult Wines Cookie Policy and the Cult X Cookie Policy.

We also work with several third parties to provide the Sites and the Services to you, as follows

Reason for sharing your personal data

Third Party Processor

Privacy policy

Google
Google Analytics, Google Adwords, Google Remarketing, Google Tag Manager.
Woopra
Real-time analysis of website visitor flows.
Facebook
Facebook Pixel, Analytics

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 six 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.

All information you provide to us is stored on our secure servers which are hosted in the EEA.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Sites, 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 Sites; 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 Sites may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

You have the right under certain circumstances:

Your right to withdraw consent:

If we are processing your personal data because you have given us permission, you have the right to withdraw that consent without detriment at any time by contacting us at https://www.wineinvestment.com/contact or info@cultwines.com

You can also change your marketing preferences on the Cult Wines Site at any time as described in 'Our promotional updates and communications' section.

If your request or concern is not satisfactorily resolved by us, you can speak to your local data protection authority. If you are based in the EU see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html

The Information Commissioner is in charge of personal data protection in the UK and can give you more information about your rights and what you can expect from us: https://ico.org.uk/global/contact-us/

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") that may not be subject to equivalent Data Protection Law.

Where your information is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this Policy.

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  

We make a digital wallet service available to users of Cult X, use of the digital wallet and e-money service is subject to the privacy notice of our provider, Railsbank: https://www.railsbank.com/privacy-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 in May 2022.

We welcome your feedback and questions. If you would like to contact us, please contact us:

Our Data Protection Officer is:

Gemma Castle

Address: Clockwork Building, 45 Beavor Lane, London, W6 9AR, England, United Kingdom

Phone: +44 (0)207 1000 958

Email: gcastle@cultwinesltd.com

This table sets out:

Type of data

Lawful basis for processing including basis of legitimate interest

Purpose/Activity

To register you as a new customer
(a) Identity
(b) Contact
Performance of a contract with you
To enable you to use Cult X trading services including to: (a) list wines on Cult X as a Seller  (b) to view wines listed by Sellers, as a Buyer  (c) to make and receive offers as a Buyer or Seller (d) to purchase or transact a sale
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
Performance of a contract with you
To process your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) Arrange for your order to be delivered and stored
(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 due to us)
(c) Performance of a contract with you
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 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 our business)
To administer and protect our business and our Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(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 our business and to inform our marketing strategy)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(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 our business and to inform our marketing strategy)
To use data analytics to improve our Site, products/services, marketing, customer relationships and experiences
(a) Identity
(b) Contact
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site updated and relevant, to develop our 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 (including, in some circumstances, using automated decision making using artificial intelligence)
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Consent provided by you
To set preferences and make decisions about your Account in order to present goods or services that may be of interest to you when you visit the Site or use our Services (including, in some circumstances, using automated decision making using artificial intelligence)
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to develop our products/services and grow our business)