Legal
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 (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, and for the cookieless measurement signals described under “Advertising and analytics” below, which show us how the website and our advertising perform.
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.
Advertising, processors and international transfers
Cellar Advisor (UK Branch) Ltd, company number 16100703, of 21 Ellis Street, Knightsbridge, London SW1X 9AL, is the controller for the personal data processed through this website.
Advertising cookies and consent
We advertise on Google Search. With your consent we set Google Ads cookies, which record that a visit came from an advertisement and whether it led to an enquiry. We use Google Consent Mode v2. 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 receives only cookieless signals before you choose and if you refuse, and no advertising or analytics identifier is stored on your device. Without your consent, a reference to an advert click may be added to the web addresses of the pages you open, and an enquiry or price list request sent through one of our forms is reported to Google Ads as a cookieless signal, without your email address. You can change or withdraw your choice at any time through Cookie settings at the foot of any page.
Processors
Our website is hosted by Vercel Inc. Our content is managed in Sanity. Enquiry emails are delivered by Resend. Website analytics is provided by Google Analytics. Each acts as a processor on our instructions under a written agreement, and none of them uses your data for its own purposes. 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; policies.google.com/privacy explains how it uses the data.
International transfers
We are established in the United Kingdom, so personal data collected from visitors in the European Economic Area or Switzerland is transferred to the UK. The European Commission has adopted an adequacy decision for the United Kingdom, and Switzerland recognises the United Kingdom as providing adequate protection, so these transfers need no further safeguard. Where a processor stores data outside those countries we rely on the standard contractual clauses.
Your rights
You may ask us for a copy of the personal data we hold about you, ask us to correct or erase it, object to or restrict how we use it, and ask for it in a portable form. Where we rely on consent you may withdraw it at any time without affecting what we did before. Write to contact@cellar-advisor.com. You may also complain to a supervisory authority: the Information Commissioner in the United Kingdom, your national authority in the EEA, or the Federal Data Protection and Information Commissioner in Switzerland.
Switzerland and Liechtenstein
For visitors in Switzerland this notice is also given under the Swiss Federal Act on Data Protection. Article 45c of the Telecommunications Act requires that you are told about cookies and similar technologies and can refuse them. If your browser is set to a Swiss time zone, or you use the German-language pages of this site, we go further: nothing is loaded from Google and nothing is sent to Google until you accept, and advertising cookies and similar technologies are used only with your consent. If your browser uses a time zone outside the EEA and Switzerland, Google receives only cookieless signals before you choose and if you refuse, as described above, including a reference to an advert click in the web addresses of the pages you open and a signal when you send one of our forms. You can change your choice at any time through Cookie settings at the foot of any page. The supervisory authority is the Federal Data Protection and Information Commissioner, Feldeggweg 1, 3003 Bern. Liechtenstein follows the EEA regime and the paragraph on international transfers applies there in the same way.
