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Privacy For Our Clients

Bordeaux Index recognises the importance of respecting and protecting your personal data (information) and yet in order to be able to continue to provide you with the level of service you have come to expect from us we need to collect, process and share a certain amount of information about you. In this document, we explain what information we're likely to hold, how we collect it and how we will use or share it. It also explains your rights and how to contact us or the ICO in the event you have a complaint. Our commitment to you is that we will continue to treat your personal data fairly and legally and with the same discretion and respect as we have always applied.

Bordeaux Index Limited is the data controller of your information. This means that we exercise some judgment in determining how and why to process the information you share with us. We may share your information with the other members of our group of companies (including our Hong Kong, Singapore and US companies). If you have questions about how we process your information that aren’t answered in this policy, we invite you to get in touch with us here. This policy applies to all your information however captured, including through our website or via our office.

We incorporate marketing preferences in your online account, which affect how we will process your information. By using the marketing preferences functionality, you can specify whether you would like to receive direct marketing communications and limit the use of your information. You can access your marketing preferences through your online account.

What information we collect and how we use it

Here we summarise the information we collect, why and how we use it and who we share it with. We will keep your data secure and won't sell your personal data to third parties – ever. We only use your personal data to help us provide you with a great service, and tailor the information we share with you to help make it relevant, useful and timely. We will only share your personal data with organisations involved in fulfilling our role as your wine merchant, such as delivery or storage companies.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

All your information falls into one or more of the following categories:

We may process any of your information identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data with law enforcement and fraud prevention agencies, so we can help tackle fraud or where such disclosure is necessary for compliance with a legal obligation to which we are subject, in order to protect your vital interests or the vital interests of another natural person, or in connection with the establishment, exercise or defence of legal claims, whether in court or not.

We may also process any of your information where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

Please do not supply us with any other person's personal information (including personal information of children), unless we prompt you to do so. If you do share your friends’ details with us, please ensure you have their prior authorisation.

Transferring your personal information outside of the European Economic Area ("EEA")

For the most part, we have ensured that the information you share with us is stored and hosted in the European Economic Area (EEA). Sometimes, we may need to share your personal data outside the EEA for example, where your data could be processed by our staff working in the United States of America, Singapore or Hong Kong. These transfers are subject to special rules under European and UK data protection law because non-EEA countries don’t have the same data protection laws. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it 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;
  • we will use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. If you’d like a copy of these contractual provisions, or would like further information on the specific mechanism used by us when transferring your personal data out of the UK, please contact us here.
How long we hold on to your information

We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law. After this period, it will be deleted or in some cases anonymised.

For example, where you have made a purchase with us, we will keep a record of your purchase for the period necessary for invoicing, tax and warranty purposes. Whilst you are an active customer (which means you have purchased from us) we will hold on to your information for as long as needed to give you the best possible customer service; financial information we will hold for 7 years. We may also keep a record of correspondence with you (for example, if you have made a complaint) for as long as is necessary to protect us from a legal claim.

Where we have collected the personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent then we will delete your personal information. However, please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.

For any wine that you have requested us to keep in our bonded warehouse, whilst it remains under bond we, by law, need to retain the purchase history, including all personal details associated with that purchase in order to prove the bonded value to HMRC.

In certain circumstances we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, to resolve disputes and enforce our agreements.

Your rights

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. At any time you can amend your marketing preferences to reduce, remove or increase the amount we contact you with special offers. You can do this by accessing your online account.

Right to complain

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance here if you're in the UK or here if you're within the EEA and we will endeavour to resolve your query as soon as possible. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to complain to a supervisory authority which in the UK is the Information Commissioner's Office. You can contact them on https://ico.org.uk/

Securing your information

At Bordeaux Index, most of the information we hold is stored on our own secure servers located in the UK or in the cloud. The key solutions we use are well- known, global businesses that are compliant with personal data laws and secure. We may use other smaller, local service providers from time to time and in these cases, will ensure that they are bound by personal data laws and obligations of confidentiality.

Despite this, nothing can be 100% secure and we will notify you and the ICO of a suspected data security breach where we are legally required to do so.

About Changes

This privacy notice was published on 01 January 2019 and last reviewed in July 2023.

We may change this privacy notice from time to time. Where these changes are substantial or have an impact to your rights, we will let you know. You should check this page occasionally to ensure that you are happy with any changes to this policy.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

EU Representative

We have appointed Data Protection Representative Limited (trading as DataRep) to act as our representative in the European Economic Area to comply with Article 27 of the GDPR. If you are based outside the UK and would prefer to contact our representative in connection with your data privacy rights, please contact DataRep using the details shown here.

Card Subscription

Bordeaux Index does not hold your card details in our systems. Card details are held securely at a 3rd party provider in compliance with PCI standards for processing card details. The process for saving cards for subscription use e.g. storage payments provides a unique token that we do store in Bordeaux Index and is then used in later payment transactions in the 3rd party payment providers system.

LiveTrade Mobile App

LiveTrade Mobile Application

This section applies specifically to users of the LiveTrade mobile application ("LiveTrade App").

Information We Collect

In addition to the information described elsewhere in this Privacy Policy, the LiveTrade App may collect and process information relating to:

    • Account registration and profile information
    • Portfolio holdings and valuation data
    • Trading activity and transaction history
    • Storage and ownership records
    • Customer support enquiries
    • Device and application usage information
    • Notification preferences

This information is used to provide and improve the services available through the LiveTrade App, including portfolio management, trading functionality, customer support, security and platform performance.

Analytics & Performance Monitoring

To help us understand how users interact with the LiveTrade App and to improve the user experience, we use analytics and performance monitoring tools, including Google Firebase Analytics.

These tools may collect information such as:

    • Device type and operating system
    • Application version
    • User interactions within the app
    • Session activity
    • Performance and stability data
    • Crash reports and diagnostic information

This information is generally aggregated and used to help us improve the functionality, reliability and performance of the LiveTrade App.

Push Notifications

The LiveTrade App may send push notifications relating to:

    • Account activity
    • Transaction updates
    • Portfolio and valuation updates
    • Trading opportunities
    • Service announcements
    • Security and account-related notifications

Where required by law, users may choose whether to receive certain categories of notifications and can manage notification preferences through their device settings or within the app.

Data Processing

Personal information collected through the LiveTrade App is used to:

    • Provide trading and portfolio management services
    • Maintain account and ownership records
    • Process transactions and settlement activity
    • Deliver customer support
    • Improve platform functionality and performance
    • Monitor platform security and prevent misuse

Security

We take appropriate technical and organisational measures to protect personal information processed through the LiveTrade App, including measures designed to protect against unauthorised access, loss, misuse or disclosure.

Your Choices

Users may control certain data collection and communication preferences through:

    • Device privacy settings
    • Notification settings
    • Marketing communication preferences

You may also exercise your data protection rights as described elsewhere in this Privacy Policy.

 

Tracking & Analytics

What Information Is Collected?

To help us understand how the LiveTrade App is used and to improve the user experience, we may collect information including:

    • Device type and operating system
    • App version
    • General usage and navigation activity
    • Session duration and feature usage
    • Performance and stability information
    • Crash and diagnostic reports
    • Notification preferences and interactions

We do not collect information from your device beyond what is necessary to provide, maintain and improve the LiveTrade service.

Why Is This Information Collected?

This information helps us to:

    • Improve app performance and reliability
    • Identify and fix technical issues
    • Understand how features are being used
    • Enhance the user experience
    • Monitor platform security
    • Develop new functionality and services

Analytics information is used to help us improve the LiveTrade platform and better serve our users.

Third-Party Analytics

LiveTrade uses Google Firebase Analytics to help measure app performance, understand user engagement and identify opportunities for improvement.

Firebase Analytics may collect information relating to device characteristics, app usage and technical performance. This information is used to support the operation, maintenance and enhancement of the LiveTrade App.

For further information about how your personal data is processed, please refer to our Privacy Policy.

 

Data & Permissions Page

Your Privacy

LiveTrade uses certain information to provide trading, portfolio management and customer support services. We are committed to handling your information responsibly and transparently.

For full details, please refer to our Privacy Policy.

Account Management

To create and manage your account, we may use information such as:

    • Name
    • Email address
    • Telephone number
    • Account preferences
    • Delivery and storage information

This information allows us to verify your identity, maintain your account and provide access to LiveTrade services.

Transaction Processing

To facilitate the buying and selling of fine wine, we may use information relating to:

    • Transaction history
    • Portfolio holdings
    • Ownership records
    • Settlement information
    • Payment-related information

This information is required to process trades, maintain ownership records and complete settlement activities.

 

Portfolio Tracking

To provide portfolio and valuation services via My Portfolio, we may process information relating to:

    • Wines held within your portfolio
    • Storage locations
    • Historical transactions
    • Portfolio valuations
    • Performance data

This information enables us to provide portfolio insights, valuation updates and account reporting.

 

Customer Support

If you contact us for assistance, we may use information such as:

    • Account details
    • Previous transactions
    • Support requests
    • Communications with our team

This helps us respond to enquiries and provide support more efficiently.

 

Analytics & Performance

To improve the LiveTrade experience, we use Google Firebase Analytics.

Analytics information may include:

    • Device type
    • Operating system
    • App version
    • Feature usage
    • Performance data
    • Crash reports

This information helps us improve app reliability, functionality and user experience.

 

Notifications

LiveTrade may send notifications relating to:

    • Transaction updates
    • Account activity
    • Portfolio updates
    • Trading opportunities
    • Service announcements

Notification preferences can be managed through your device settings and, where available, within the app.

 

Permissions

Depending on your device and settings, LiveTrade may request permission to:

Notifications

Used to provide account alerts, transaction updates and service communications.

You can manage notification permissions at any time through your device settings.

Your Choices

You can:

    • Update your account information
    • Manage notification preferences
    • Adjust privacy settings available on your device
    • Contact us regarding your personal data

For more information, please refer to our Privacy Policy.

Notifications

Sliders to opt in/out of the following:

    • Trade updates
    • Order confirmations
    • Portfolio alerts
    • Market opportunities

 

Tracking & Analytics

What Information Is Collected?

To help us operate, maintain and improve the LiveTrade App, we may collect information including:

    • Device type and operating system
    • App version
    • General app usage and navigation activity
    • Feature usage and engagement data
    • Session activity
    • Performance and stability information
    • Crash and diagnostic reports
    • Notification interactions and preferences

We do not collect information that is not necessary to provide, secure and improve the LiveTrade service.

 

Why Is This Information Collected?

The information collected helps us to:

    • Improve app performance and reliability
    • Identify and resolve technical issues
    • Understand how users interact with the platform
    • Enhance the user experience
    • Develop new features and functionality
    • Monitor platform security and prevent misuse
    • Deliver relevant account and service notifications

Analytics data helps us continually improve the quality, stability and effectiveness of the LiveTrade App.

 

Third-Party Analytics

LiveTrade uses Google Firebase Analytics to help us understand how the app is used and to monitor app performance.

Firebase Analytics may collect information relating to device characteristics, app usage, feature engagement and technical performance. This information is used to support the operation, maintenance and ongoing improvement of the LiveTrade App.

Information collected through analytics tools is used to improve our services and user experience and is processed in accordance with our Privacy Policy.

For more information about how personal data is collected, used and protected, please refer to our Privacy Policy.

 

 

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