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 and, for the visitors it applies to, through the cookieless measurement signals described under “Advertising and analytics” below.

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 and occasional event invitations (where you have opted in, or where you enquired through our Contact page and did not opt out, as described under “Lawful basis for processing” below), and comply with legal and regulatory obligations. You can unsubscribe from the market report at any time.

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 where you have opted in.
• Legitimate interests, for handling enquiries submitted through our website and responding to them, for the cookieless measurement signals described under “Advertising and analytics” below, which show us how the website and our advertising perform, and for sending our monthly market report and occasional event invitations to people who enquired about our services through our Contact page and were told there that they would receive them, unless they opted out there or have since unsubscribed. The Contact page gives that notice only if your browser is set to a time zone outside the European Economic Area, Switzerland and Canada and you are not using the German-language pages of this site. Everyone else using that page is asked to opt in, and enquiries sent through our other forms do not add you to the list.

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

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. We do not use either to identify you, and neither sets cookies unless you accept the relevant category on our cookie banner. If your browser is set to a time zone in the European Economic Area or Switzerland, or you are using the German-language pages of this site, nothing is sent to Google until you accept, and then only for the categories you accepted. For all other visitors, including in the UK, Google Analytics and Google Ads receive cookieless measurement signals before you choose and if you refuse, and after a click on one of our adverts a reference to that click may be added to the web addresses of the pages you open. Our Cookie Policy explains this in full. You can withdraw your consent at any time using the “Cookie settings” link in the footer of every page.

For those other visitors, if you send an enquiry or ask for our price list without having accepted marketing cookies, Google Ads receives only a cookieless signal that the form was sent, and neither your email address nor a hashed version of it is sent. When you send an enquiry or ask for our price list and you have accepted marketing cookies, we may share a secured version of your email address with Google so that it can confirm whether the enquiry came from one of our adverts. Before it is sent, the address is converted into a fixed string of characters using SHA-256 hashing, a one-way process. Google compares that string with the hashed email addresses of its own account holders to match the enquiry to a click on one of our adverts. 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) on our behalf. For advertising (Google Ads), including showing our adverts to people who have visited this site, Google acts as an independent controller under its own terms, as described under “Advertising and analytics” above.

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.