Privacy Policy

Privacy Policy

This page sets out how Cellar Advisor (UK Branch) Ltd (company number 16100703, registered in England and Wales) collects, uses and protects personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Cellar Advisor (UK Branch) Ltd is the data controller for the personal data described in this policy. Our registered office is 21 Ellis Street, Knightsbridge, London SW1X 9AL.

Data we collect

We collect personal data you provide directly (name, email address, phone number, investment objectives) when you contact us, book a consultation, or open an account. We also collect data about your use of our website through analytics cookies where you have consented.

How we use your data

We use your data to provide our advisory services, communicate with you about your portfolio, send you our monthly market report (where you have opted in), and comply with legal and regulatory obligations.

Lawful basis for processing

We rely on the following lawful bases under UK GDPR:

• Consent, for analytics and advertising cookies, and for marketing communications such as our monthly market report.
• Legitimate interests, for handling enquiries submitted through our website and responding to them.

Data retention

We retain personal data for the following periods:

• Enquiries that do not become clients: 24 months from your last contact with us.
• Newsletter subscribers: until you unsubscribe. We keep a permanent record of your unsubscribe request so that we can continue to honour it.
• Clients: for the period set out in your client agreement, and for at least 6 years from the end of the relationship where a statutory retention requirement applies.
• Website analytics: 14 months.

Advertising and analytics

Where you have given consent, we use Google Analytics 4 to understand how the website is used, and Google Ads to measure which campaigns bring people to the site and to show relevant advertising elsewhere. Neither is used to identify you personally, and neither is set unless you accept the relevant category on our cookie banner. You can withdraw your consent at any time using the “Cookie settings” link in the footer of every page.

When you submit an enquiry after clicking one of our adverts, and you have accepted marketing cookies, we may share a secured version of your email address with Google so that it can confirm the enquiry came from that advert. Before it is sent, the address is converted using SHA-256 hashing, a one-way process that turns it into a fixed string of characters. That string cannot be converted back into your email address, by Google or by anyone else. We never send your email address to Google in a readable form.

Google may process this data outside the UK. Where that happens, the transfer is covered by the UK extension to the EU-US Data Privacy Framework or by Standard Contractual Clauses.

Who processes your data

We work with a small number of service providers who process personal data on our behalf, each under a written data processing agreement:

• ThinkTech Systems Ltd, website management, analytics and advertising campaign management. ThinkTech Systems Ltd is registered with the Information Commissioner's Office and processes personal data only on our documented instructions.
• Vercel Inc. and Sanity Inc., website hosting and content management, engaged as sub-processors by ThinkTech Systems Ltd under the same instructions.
• Resend: for sending email communications.
• Google Ireland Limited, website analytics (Google Analytics 4) and advertising measurement (Google Ads), used only where you have consented.

Your rights

You have the right to access, correct, or request deletion of your personal data. To exercise these rights, contact us at hello@cellar-advisor.com.

Contact

For data protection queries, contact Cellar Advisor (UK Branch) Ltd (company number 16100703), 21 Ellis Street, Knightsbridge, London SW1X 9AL. Email: hello@cellar-advisor.com.