Privacy Policy for CL&L Fine Wines Ltd

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Effective Date: 21.04.2.26
Last Updated: 21.04.2.26

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1. Introduction

CL&L Fine Wines Ltd. (“we”, “us”, “our”) is committed to protecting and respecting your privacy.

This Privacy Policy explains how we collect, use, and protect your personal data when you visit our website.

We comply with:

• UK General Data Protection Regulation (UK GDPR)

• Data Protection Act 2018

• EU General Data Protection Regulation (EU GDPR), where applicable

• Applicable international privacy laws

2. Who We Are

• CL&L Fine Wines Ltd.

• Trading Address: 12 Whitethorn Avenue, Burnage, Manchester, M19 1EU

• Registered Address: 20 Wenlock Road, London, England, N1 7GU

• Company Number: 17068365

• Email: info@cllfinewines.co.uk

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3. Data We Collect

As our website is primarily informational (April 2026), we collect limited personal data. We may collect information when you interact with us through any communication forms on www.cllfinewines.co.uk, such as, but not limited to, via Contact Us page or any mailing list subscriptions.  The data we may collect:

a. Contact Data

• Name

• Email address

• Phone number (if provided)

b. Enquiry and Submission Data

• Information you provide when completing any via Contact Us forms, any mailing list subscriptions, or corresponding with us via email

c. Technical Data

• IP address

• Browser type and version

• Device information

• Time zone and approximate location

d. Usage Data

• Pages visited

• Time spent on the website

• Navigation paths

e. Anti-fraud Information

To comply with CL&L Fine Wines Ltd’s due diligence policies and HM Revenue and Customs’ Alcohol Wholesaler Registration Scheme (AWRS), we may collect information by reasonable means, including:

• Proof of identity (e.g. name, date of birth, identification documents where appropriate)

• Business identity details (e.g. company name, registration number, VAT number)

• Proof of trading status (e.g. licences, registrations, or authorisations to trade in alcohol)

• Verification of AWRS status where applicable

• Billing and trading addresses

• Transaction history and purchasing patterns (where relevant to due diligence)

• Correspondence and records of communications

• Information obtained from publicly available registers or regulatory databases

• Information required for anti-money laundering and fraud prevention checks

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4. How We Collect Your Data

We collect data through:

• Contact forms or direct email enquiries

• Website cookies and analytics tools

• Server logs and automated technologies

5. How We Use Your Data

We use your personal data to:

• Respond to enquiries and communications

• Provide information about our wines and services

• Improve website performance and user experience

• Monitor website usage and security

• Comply with legal obligations

• We do not currently process online payments or complete transactions via the website.

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6. Legal Basis for Processing

We rely on the following lawful bases:

• Legitimate interests – responding to enquiries and improving our services

• Consent – where you opt in to communications

• Legal obligation – compliance with applicable laws

7. International Users

Our website may be accessed globally.

If you are located outside the UK, your data may be processed in the UK or other countries where our service providers operate. We ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses

• Adequacy regulations where applicable

8. Sharing Your Data

We may share your data with:

• Website hosting providers

• IT and analytics service providers (e.g. Google Analytics or similar tools)

• Professional advisers (legal, regulatory)

• HM Revenue & Customs to comply with any laws and regulations, not limited to the Customs’ Alcohol Wholesaler Registration Scheme (AWRS)

• We do not sell your personal data.

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9. Cookies and Analytics

We use cookies and similar technologies to:

• Ensure website functionality

• Analyse visitor behaviour

• Improve performance

Where required, we will request your consent before placing non-essential cookies.

You can manage cookie preferences via your browser settings or our cookie banner.

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10. Data Security

We implement appropriate security measures, including:

Secure hosting environments
Access controls
Data minimisation practices

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11. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements.

• Enquiry and form submission data: typically retained for up to 12–24 months after last contact

• Technical and analytics data: retained in accordance with the policies of our analytics providers

• Contract-related data (including sales agreed following website enquiries): retained for up to 6–7 years to comply with UK legal, accounting, and VAT/tax retention requirements

Where data is no longer required, it will be securely deleted or anonymised.

12. Your Rights

Under UK GDPR and other applicable laws, you have rights including:

• Access your personal data

• Request correction or deletion

• Object to processing

• Restrict processing

• Request data portability

• Withdraw consent at any time

To exercise your rights, contact us at info@cllfinewines.co.uk

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13. Children’s Privacy

Our website is intended for individuals aged 18 or over, due to the nature of our products.

We do not knowingly collect data from individuals under 18.

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14. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for their privacy practices.

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15. Changes to This Policy

We may update this Privacy Policy periodically. Updates will be posted on this page with a revised date.

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16. Future E-Commerce Activities

If we introduce online purchasing functionality on our website, this Privacy Policy will extend to cover the collection and processing of additional personal data required to facilitate transactions.

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17. Additional Data Collected for E-Commerce

In addition to the data outlined above, we may collect:

• Identity and Contact Data: billing and delivery addresses

• Transaction Data: details of products purchased and order history

• Payment Data: limited payment information processed securely via third-party payment providers (we do not store full card details)

18. Payment Processing

Payments will be processed securely through trusted third-party providers (such as payment gateways and financial institutions). These providers process your data in accordance with their own privacy policies and applicable data protection laws.

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19. Order Fulfilment and Delivery

We may share necessary personal data with:

• Delivery and logistics providers

• Warehousing and fulfilment partners

This is solely for the purpose of completing and delivering your order.

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20. Fraud Prevention and Security

We may use your personal data to:

• Verify identity

• Prevent fraud and unauthorised transactions

• Ensure the security of our website and services

This processing is based on our legitimate interests in protecting our business and customers.

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21. Marketing and Customer Accounts

If e-commerce functionality is introduced, we may offer:

Customer accounts
Order tracking
Marketing communications relating to products and offers (subject to your preferences and applicable law)

You will always have the option to opt out of marketing communications.

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22. Data Retention for Transactions

Where e-commerce is implemented, we will retain transaction-related data in line with legal and regulatory requirements, including:

• Accounting and tax records (including VAT): typically retained for 6–7 years

• Information to comply with UK AWRS regulations: retained while the account remains active and for a reasonable period thereafter

• Customer account data: retained while the account remains active and for a reasonable period thereafter

23. Policy Updates

We will update this Privacy Policy prior to launching e-commerce functionality to reflect any additional data processing activities in detail.

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24. Complaints

If you are not satisfied with how we handle your data, you have the right to complain to:

Information Commissioner’s Office (ICO)

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25. Contact Us

If you have any questions about this Privacy Policy or your data, please contact:

CL&L Fine Wines Ltd.
Email: info@cllfinewines.co.uk
Trading Address: 12 Whitethorn Avenue, Burnage, Manchester, M19 1EU

Registered Address: 20 Wenlock Road, London, England, N1 7GU