1. WHO ARE WE

This website (“Site”) is operated by Cabinet Ventures Limited, a company registered in England and Wales under company registration number (12034007) CVL,” “we,” “us” and/or “our”). Our registered address is 72-74 Dean Street, London W1D 35G. You can contact us as indicated under the “Contact” section below.

The data controller responsible for your personal data is Cabinet Ventures Limited (“CVL, “we,” “us” and/or “our”).

2. WHAT IS THIS PRIVACY POLICY FOR

This privacy policy (“Privacy Policy”) applies to personal data that we collect from you as a user of this Site, (“you” or “your” being interpreted accordingly). It provides information on what personal data we collect, why we collect the personal data, how it is used and the lawful basis on which your personal data is processed, and what your rights are under the applicable data protection and privacy laws, including the General Data Protection Regulation (“GDPR”) which became applicable to us and you as of 25 May 2018.

‘Personal data’ as used in this Privacy Policy means any information that relates to you from which you can be identified.

By using our Site or submitting your personal data you are taken to accept the terms of this Privacy Policy, so please read it carefully.

3.PERSONAL DATA WE COLLECT

This website is hosted by Squarespace. Squarespace collects personal data when you visit this website, including:

•    Information about your browser, network and device

•    Web pages you visited prior to coming to this website

•    Your IP address

 Squarespace needs the data to run this website, and to protect and improve its platform and services. Squarespace analyzes the data in a de-personalized form.

This information may also include details about your use of this website, including:

•    Clicks

•    Internal links

•    Pages visited

•    Scrolling

•    Searches

•    Timestamps

We share this information with Squarespace, our website analytics provider, to learn about site traffic and activity.

4.OTHER INFORMATION

Personal details you choose to give when corresponding with us by phone or e-mail, social media channels, participating in user/customer/member surveys or otherwise visiting and interacting with this Site. We can also combine personal data that you provide to us with other information we collect about you when you make a purchase through third-party services such as websites supplying House Cabinet goods and beverages.

5.AUTOMATICALLY COLLECTED PERSONAL DATA

Log Data: When you visit our Site, our servers record information (“log data”), including information that your browser automatically sends whenever you visit the Site. This log data includes your Internet Protocol (“IP”) address (from which we understand the country you are connecting from at the time you visit the Site), browser type and settings, the date and time of your request.

Our Site uses cookies (small text files placed on your device) and similar technologies to distinguish you from other users. This is to provide you with a good user experience when you browse our Site and allows us to improve its features. For detailed information on the cookies and similar technologies we use, please see our Cookie Policy.

6.HOW WE USE YOUR PERSONAL DATA

We use your personal data in the following ways:

To contact you in connection with your submitted inquiry and use any information you choose to submit in response, provided that you gave us your consent to being contacted in this way at the time you provided us with the personal data.

House Cabinet and our affiliated businesses may provide you, or permit selected third party service providers to provide you, with information about goods or services, events and other promotions we feel may interest you. We (or such third party providers) will contact you by email only with your consent, which was given at the time you provided us with the personal data.

As necessary for certain legitimate business interests, which include the following:

  • where we are asked to deal with any enquiries or complaints you make.

  • to administer our Site, to better understand how visitors interact with our websites and ensure that our Site is presented in the most effective manner for you and for your computer/device.

  • to conduct analytics to inform our marketing strategy and enable us to enhance and personalise the experience we offer to our members and our communications, including by creating customer or member profiles to enable personalised direct marketing communications.

  • to provide postal communications which we think will be of interest to you.

  • if you ask us to delete your data or to be removed from our marketing lists and we are required to fulfill your request, to keep basic data to identify you and prevent further unwanted processing.

  • to share personal data among our affiliated businesses for administrative purposes, for providing membership services and in relation to our sales and marketing activities.

  • we may anonymise, aggregate and de-identify the data that we collect and use such anonymised, aggregated and de-identified data for our own internal business purposes, including sharing it with our current and prospective members, business partners, our affiliated businesses, agents and other third parties for commercial, statistical and market research purposes, for example to allow those parties to analyse patterns among groups of people, and conducting research on demographics, interests and behavior.

  • for internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our Site, network and information systems secure.

  • to (a) comply with legal obligations, (b) respond to requests from competent authorities; (c) enforce our terms and conditions; (d) protect our operations or those of any of our affiliated businesses; (e) protect our rights, safety or property, and/or that of our affiliated businesses, you or others; and (f) enforcing or defending legal rights, or preventing damage.

We may use your personal data for other purposes which you have consented to at the time of providing your data.

As used in this Privacy Policy, “legitimate interests” means the interests of House Cabinet  in conducting and managing our organisation. When we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object at any time to processing of your personal data that is based on our legitimate interests, on grounds relating to your particular situation (for more information on your rights, please see “Your Data Protection Rights” section below).

7. DISCLOSURE OF YOUR INFORMATION

We share your personal data with third parties in the following situations:

Other Service Providers: CVL, like many businesses, sometimes hires selected third parties who act on our behalf to support our operations, such as (i) card processing or payment services (see the section below headed “Payment Information”), (ii) credit reference agencies to protect against possible fraud, (iii) IT suppliers and contractors (e.g. data hosting providers or delivery partners) as necessary to provide IT support and enable us to provide membership services and other goods/services available on this Site or to members, (iv) web analytics providers, (v) providers of digital advertising services (vi) providers of CRM, marketing and sales software solution. Pursuant to our instructions, these parties may access, process or store your personal data in the course of performing their duties to us and solely in order to perform the services we have hired them to provide.

Business Transfers: if we sell our business or our company assets are acquired by a third party personal data held by us about our members, membership applicants or customers may be one of the transferred assets.

Administrative and Legal Reasons: if we need to disclose your personal data (i) to comply with a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process. (ii) to enforce our Terms & Conditions or other applicable contract terms that you are subject to or (iii) to protect us, our members, membership applicants, or contractors against loss or damage. This may include (without limit) exchanging information with the police, courts or law enforcement organisations.

8.PERSONAL DATA TRANSFERS

Your personal data will be transferred to and stored in countries other than the country in which the information was originally collected, including the United States and other destinations outside the European Economic Area (“EEA”), to our service providers and affiliated businesses for the purposes described above.

Please note that the countries concerned may not provide the same legal standards for protection of your personal data that you have in the United Kingdom or EEA. Where we transfer your personal data to countries outside of the EEA we will take all steps to ensure that your personal data will continue to be protected. We will implement appropriate safeguards for the transfer of personal data to our service providers in accordance with the applicable law, such as relying on our service providers’ Privacy Shield certification or implementing standard contractual clauses for data transfers. We have implemented data transfer agreements pursuant to applicable data protection law in order to implement appropriate safeguards for the transfer of personal data to House Cabinet affiliate companies in countries outside the EEA. If you would like to receive more information on the safeguards that we implement, including copies of relevant data transfer contracts, please contact us as indicated below.

9.SECURITY

Where we have given you (or where you have chosen) a password or log-in which enables you to access certain restricted parts of our Site, you are responsible for doing everything you reasonably can to keep these details secret. You must not share your password or log-in details with anyone else.

Unfortunately, the transmission of information over the internet or public communications networks can never be completely secure. We will take appropriate technical and organisational security measures to protect the personal data that you submit to us against unauthorised/unlawful access or loss, destruction or damage, although we cannot 100% guarantee the security of personal data that you provide to us online.

10.PERSONAL DATA RETENTION

We will keep your personal data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy, or for the duration required by any legal, regulatory, accounting or reporting requirements, whichever is the longer. We retain information submitted through the Site and the other websites we operate for two years following account closure or contact with you, as applicable. When you consent to receive marketing communications, we will keep your data until you unsubscribe.

To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the purposes for which we process your personal data, applicable legal requirements or operational retention needs, and whether we can achieve those purposes through other means.

Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data.

11.YOUR PERSONAL DATA PROTECTION RIGHTS

Certain applicable data protection laws give you specific rights in relation to your personal data. In particular, if the processing of your personal data is subject to the GDPR, you have the following rights in relation to your personal data:

Right of access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data along with certain other details such as the purpose of the data processing. If you require additional copies, we may need to charge a reasonable fee.

Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your personal data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.

Right to erasure: You may ask us to delete or remove your personal data, such as where our legal basis for the processing is your consent and you withdraw consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data with so you can contact them directly. We may continue processing personal data where this is necessary for a legitimate interest in doing so, as described in this Privacy Policy.

Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your personal data in certain circumstances, such as where you contest the accuracy of the personal data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your personal data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.

Right to data portability: You have the right to obtain your personal data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will provide you with your personal data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.

Right to object: You may ask us at any time to stop processing your personal data, and we will do so:

If we are relying on a legitimate interest to process your personal data -- unless we demonstrate compelling legitimate grounds for the processing or

If we are processing your personal data for direct marketing.

Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.

Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your personal data, you can report it to the UK data protection authority (the Information Commissioner’s Office or ICO), or, as the case may be, any other competent data protection authority of an EU member state that is authorised to hear those concerns (you may find EU Data Protection Authorities’ contact information here).

If you wish to exercise any of these rights please contact us as described in the “Contact” section below. We may also need to ask you for further information to verify your identity before we can respond to any request.

12.CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or modifications. If required by the applicable law, we will notify you of any material or substantive changes to this Privacy Policy.

13.CONTACT

Questions, comments or requests regarding this Privacy Policy should be addressed to cheers@drinkladya.com

 

COOKIE POLICY

This cookie policy (“Cookie Policy”) describes the cookies that Cabinet Ventures Limited (“CVL”) use on our respective websites (“Site”) and the choices that you have. This Cookie Policy forms part of the privacy policy of CVL. Please refer to the privacy policy for the relevant business for information about (i) the purposes for which we use your personal data and our lawful basis for processing it, (ii) how we protect your data, and (iii) your rights and our obligations in relation to such use.

 If you are based in the European Economic Area, when you first visit the Site, you will be asked to consent to the use of cookies on the Site in accordance with this Cookie Policy, and if you accept we will store them on your computer.

1. COOKIES AND OTHER TECHNOLOGIES

A cookie is a piece of information sent to your browser from a website and stored on your computer’s hard drive. Cookies can help a website like ours recognize repeat users and allow a website to track web usage behavior. Cookies work by assigning a number to the user that has no meaning outside of the assigning website. For more details on cookies and similar technologies please visit All About Cookies.

Cookies can be stored on your computer for different periods of time. “Session cookies” only last for as long as the browser session and are deleted automatically once you close your browser. “Persistent cookies” cookies survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again.

 The Site uses first party cookies (cookies set directly by our host provider and are essential for using and navigating our services).

2.TYPES OF COOKIES

Analytics / Performance

Squarespace Analytics. Squarespace Performance cookies help us analyze how the site is being accessed and used, and enable us to track performance while improving our site. For example, we use cookies to determine if you viewed a page. This helps us provide you with information that you find interesting.

You can set your browser to not accept cookies, but this may limit your ability to use the Services. We currently don’t respond to DNT:1 signals from browsers visiting our Services.

Functionality/Persistent

Squarespace Analytics. Squarespace uses some Functionality cookies because they allow visitors to navigate and use key features on our site such as the URL redirect function.

You can set your browser to not accept cookies, but this may limit your ability to use the Services. We currently don’t respond to DNT:1 signals from browsers visiting our Services.

 Advertising/Persistent

 Instagram. Instagram helps you stay in touch with your network through your website/mobile application. Because we include a link for you to view our Instagram profiles via our Site, Instagram includes an advertising cookie on the Site. Learn more here: https://help.instagram.com/1896641480634370?ref=ig

The providers listed below also offer direct opt-out functionalities:

Instagram. To opt out, please visit https://help.instagram.com/1896641480634370?ref=ig

 Your Choices. Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site. 

Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.

3.CHANGES

We may change the type of third party service providers that place cookies on the Site and amend this Cookie Policy at any time by posting the amended version on the Site. Unless additional notice or consent is required by applicable laws, this will serve as your notification of these changes.

4.CONTACT

If you have any questions or concerns, please contact Cabinet Ventures at cheers@drinkladya.com