This website is owned and run by Cru London Limited ("we", "our", "us”), which is part of the Cru Group. If we use the term “our Group”, this means us and our subsidiaries, our ultimate holding company and its subsidiaries (or any of them). The term “our online services” refers to www.cruworldwine.com, our mobile and tablet applications, our pages on third party social media platforms such as Instagram, Facebook, Twitter, Pinterest and Google+ and any other websites or apps we own or run from time to time. The term “our services” refers to our online services and any of our other products and services offered from time to time. If you use any of our services, we will refer to you using the terms “user”, “visitor”, “you”, “your”, “yours” in this policy.
We collect personal information about you when you register or subscribe for one of our services, place an order, buy a gift voucher, use our online services, interact with us in any other way, such as via social media, click on an advert that we put on our or someone else’s website, ask for information or assistance, give us a testimonial or other feedback, comment on any blogs or articles featured in our services, attend an event that we run or sponsor, enter competitions or special promotions, sign up for our special offers or other updates, participate in research panels or fill in surveys. By registering, subscribing or using our services, you consent to the use of your personal data in line with this policy. We may also receive information about you from our Group and from third parties, with whom we have a business relationship.
The information we collect and hold about you may include your name, email address, phone and mobile phone numbers, home address, shipping and payment card billing address, payment card details, IP address, search criteria, shopping history, shopping preferences, responses to research panels and surveys, the type of browser you use (a browser is the program you use to look at websites, such as Chrome, Firefox or Safari), the times when you access the site and for how long, your referring URL (the site you come from to reach our website), cell IDs (these are the unique identifiers of the telecommunications towers being used by your mobile phone when you use our locations-based services on your mobile phone or tablet) and other location information (for example, GPS measurements), photographs and other content you share with us when you use our services, date of birth, password details, answers to security questions and any other information you may give us.
We may record or monitor calls that you receive from us or make to us. We do this for security and training purposes, and to improve the services we provide to you.
Whenever you give us your personal information we will use it in accordance with applicable privacy laws and for the purposes set out in this policy, on the data entry forms you complete, in any relevant terms and conditions and on pages or emails which link to the data entry forms.
Use of your personal information
If you use any of our services, register for or attend one of our events, set up, look at or change your account details or contact your fine wine advisor or a member of our Customer Services team, we will record your personal details. Your information will be used in the first place to provide the products, services or information you have asked for and to provide you with a personalized fine wine/spirits buying experience. We keep the information you provide and may use it for several purposes, including: (i) accounting, billing, reporting and audit; (ii) credit checking or screening; (iii) authentication and identity checks; (iv) credit, debit or other payment card verification and screening; (v) debt collection; (vi) safety, security, health, training, administrative and legal purposes; (vii) data matching, statistical and market analysis, and marketing information; (viii) advertising and marketing for us, our Group and third parties; (ix) developing, testing and maintaining systems; (x) studies, research and development; (xi) customer surveys; (xii) customer care and to help us in any future dealings with you, for example by identifying your requirements and preferences; (xiii) where required by law or in connection with legal proceeding or disputes; and (iv) any other uses set out in the terms and conditions for use of our services.
Saved payment card details will only be shared with our payment partner and not with any other third parties and will only be used to process your order, using our payment partner's systems.
We may also use your personal information to send you marketing updates, as detailed in the next section.
Tracking use of our services
We collect, and use third parties to collect and share with us, information from lots of visitors to our online services and analyse it to build up a picture of how people use our websites. This helps us improve the services we offer. We may also give anonymous statistics about visitors to other, reputable organisations, but the information we provide will not include details that would allow these organisations to identify you.
We may use the information you give us about yourself and the information we collect via cookies when you use our online services to build up a picture of your interests. We may then use this information to try to make sure that when we send you marketing communications and when you visit our websites or use our online services, you don't miss offers and information that might interest you. This information may also be used by our third party advertising agencies and networks, to advertise our own or third party products and services to you when you visit third party websites and online services. This is called advert targeting or interest-based advertising.
When you request our mobile services, we may keep your mobile phone number, the make and model of your phone, the operating system used by your phone and details of your network operator, and we will link a unique identifier to your mobile phone number. We’ll store your device language, app language, country. We need this information in order to provide the features and services enabled through our mobile services and to administer our mobile service. We may also use it for SMS or voice marketing and market research.
Sharing personal information
From time to time, we may engage third party business partners to provide information about you or to collect personal information on our behalf. We may also share or match your data with third party business partners to provide you with the products, services or information you ask for or for interest-based advertising. We may pass your information onto one or more of the following organisations: (i) data processing companies, mailing houses and other third party suppliers working on our Group’s behalf; (ii) ad-serving agencies and other advertising intermediaries; (iii) credit reference or fraud prevention agencies, which may keep a record of that information; (iv) research students, universities and other research and development organisations; (v) regulatory bodies, government and enforcement agencies, such as the police.
Every now and again, we receive requests for information from government departments, the police and other enforcement agencies. If this happens, and there is a proper legal basis for providing your personal information, we will provide it to the organisation asking for it. We collate information about site traffic, sales, wish lists, and other commercial information which we may pass onto third parties, but this information does not include any details which can identify you personally.
When we use your information as described in this policy, this may involve sending your information outside the European Economic Area (EEA). When we do this, we make sure that appropriate steps are taken to protect your personal information and your rights in law. By providing us with your personal information, you agree that we may transfer, store and process your information outside the EEA. Governments in certain countries such as the USA have broad powers to access data for security, crime prevention and detection and law enforcement purposes.
Marketing opt-in and opt-out provisions
We offer you the chance to receive news and fine wine / spirits updates which, depending on your preferences, we will discuss with you by phone or live chat or send to you via email, SMS and/or direct mail. These include alerts for new products, features, enhancements, special offers, upgrade opportunities, contests, events of interest, and one-off marketing promotions. You can opt-out of receiving these updates, if you wish.
We, or our third party business partners, may also ask you if you want to receive marketing if you enter a promotion or attend an event thrown or sponsored by us. Other companies in our Group may also pass your personal information to us for marketing use. Marketing communications you subscribe to will only be sent by our Group.
You have the right to ask us not to use your personal information for marketing. At all times, we will offer you the opportunity to unsubscribe from any service or update to which you have subscribed, if you change your mind. Whenever you receive direct marketing from us, we will tell you how to unsubscribe. Alternatively you can change your marketing preferences by logging into My Account. To opt out of direct mail, please contact our Customer Care team:
If you tell us that you do not want to receive direct marketing, we will still contact you in order to provide you with products and services you request and for administration purposes.
Access to your personal information
You have the right to see information we hold about you, with some exceptions which are described in the privacy laws. If you would like a copy of your personal information, please contact our privacy officer at firstname.lastname@example.org. You will need to pay a processing fee.
You have the right to review and update your personal details. If for any reason you are concerned that the personal information we hold is not correct, please visit our online services and, after logging into the site using the menu on the home page, your personal information will be made available for review and change in the "Account" section. Only you or, upon your request, our Customer Care team, may access your personal data from our online services using your user ID and password. You can change or delete saved credit/debit card details each time you make a purchase. You will also be able to delete saved credit/debit card details by adding or editing a delivery/billing address. If you change your billing or delivery address while your order is still being processed, the order will be re-processed through security validation checks. If you prefer, you may contact us by email at email@example.com and we will amend your personal details.
Safeguarding your personal information
We will take reasonable care to maintain appropriate safeguards to ensure the security, integrity and privacy of the information you have provided to us. We have put in place technology and security policies which are designed to protect the personal information we hold about you. We also follow the security procedures that applicable privacy laws require. These cover storing, using and releasing any information you have provided and, as well as measures designed to prevent unauthorised access or use. When you place an order or access your account information, we use a Secure Socket Layer (SSL) encryption which encrypts your information before it is sent to us to protect it from unauthorised use.
We have appointed a Data Protection Officer and details of that person can be attained by contacting us via email at firstname.lastname@example.org.
All our staff have been trained on the importance of protecting our clients' personal information. We have conducted training sessions to make all staff aware of their responsibilities for safeguarding client personal information under the General Data Protection Regulation (GDPR) (EU) 2016/679 which came into force in the European Union on 25th May 2018.
Links to other websites
Our online services contain hyperlinks to websites that are owned and operated by other organisations. These websites have their own privacy and cookie policies, and we urge you to read them. They control how your personal information is used when you give it to these other organisations or they collect it with cookies. We do not approve any other websites and we are not responsible for any information, material, products or services that are on or accessible through those websites or for the privacy practices of websites run by other organisations. If you use these other websites you do so at your own risk.
Changes to this policy