Levercliff Associates Ltd has developed this policy to demonstrate our commitment to combine the finest quality services with the highest level of integrity in dealing with our clients. The policy explains how we collect store and use information about individuals. It will be continuously assessed against new technologies, business practices and the changing needs of everyone we deal with.

We ask that you read this policy carefully as it contains important information about what to expect when we collect information about you and how that may be used.

This policy applies to information we collect about:
- People who register for our Welsh Drinks newsletter.
- People who enquire about our Welsh Drinks Cluster members;
- Visitors to our Welsh Drinks Christmas website.

1. Who is collecting your data?
Data is collected by Levercliff Associates Limited (Co. No. [04599692]) of 1 The Sawmill, Brynkinalt Business Centre, Chirk, Wrexham, Wales, LL14 5NS.

2. The information we collect about you
2.1 Generally
When you register for our services we may collect the following personal information from you, where the information is relevant to the matter we are dealing with:
Name;
Postal address, email address and telephone numbers;
Date of birth;
2.2 Via our website
If you visit our Welsh Wine Week website, we may collect the following information: technical information, including the Internet protocol address used to connect your computer to the internet, browser type and version, time zone, browser plug-in types and versions, operating system and platform, information about your visit, including the full Uniform Resource Locators, clickstream to, through and from our site (including date and time), items you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, social networks used to browse to our pages and any phone number used to call us.
2.3 Special categories of data
We recognise the data we collect requires adequate protection:
Personally-Identifiable Information includes, for example, e-mail addresses, and ‘click stream’ data that tracks visitor activity on a Web site or online service.
We collect Personally-Identifiable Information and Sensitive Data only when there is a legitimate business need to do so.

3. Why is your data collected by us?
We mainly rely on three separate bases to lawfully process your information. Firstly, we may need to process your information in certain ways to provide services to you. This processing is necessary to perform the contract between us. Secondly, where you have given us consent to use your information in certain ways, we will rely on your consent. Thirdly, in certain cases we may process your information where necessary to further our legitimate interests, where those legitimate interests are not overridden by your rights or interests.
Occasionally we may rely on other legal bases to process your information such as to protect a user’s vital interests (such as where there is a risk of imminent harm) or to comply with a legal obligation. In certain cases you may indicate to us your preferences regarding the frequency, subject matter and/or format of communications. Please contact us for further information.

4. How long will your information be kept?
We will hold your data for as long as it is required to fulfil our contract with you. After that, it will be held for a period of six years. If you provide us with express consent to hold your data, we will retain it for as long as we consider you might be interested in our services, or until you withdraw consent. We will never sell personal data, including mailing lists, on to a third party.

5. How do we protect your information?
We put in place appropriate security procedures and technical and organisational measures to safeguard your personal information. This may include, in certain cases, encryption of data and use of passwords. We will use all reasonable efforts to safeguard your personal information. However, you should be aware that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the internet.

6. Access to your information and updating and correcting your information
6.1 You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please send an email to hello@levercliff.co.uk or send a letter to Fintan O’Leary of Levercliff Associates, 1 The Sawmill, Brynkinalt Business Centre, Chirk, Wrexham, Wales, LL14 5NS.
6.2 We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to us changes, for example if you change your email address, name or payment details, please let us know the correct details by sending an email to hello@levercliff.co.uk or by sending a letter to Fintan O’Leary of Levercliff Associates, 1 The Sawmill, Brynkinalt Business Centre, Chirk, Wrexham, Wales, LL14 5NS. You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate.
6.3 Fintan O’Leary oversees our compliance with this privacy policy and we have established procedures to ensure that every reasonable effort is made to address concerns about your data. If you have any questions about this policy or how we handle your personal information, please contact tom.evans@levercliff.co.uk
6.4 Levercliff Associates will continue to oversee implementation of and compliance with this policy and will adapt it to reflect changes in technology and the expectations of everyone we deal with.
6.5 You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. Details are available at www.ico.org.uk.

7. Sale of business
If our business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.

8. Links to other websites
Our website may contain links to other websites. This privacy policy only applies to our website so when you link to other websites you should read their own privacy policies.