PRIVACY POLICY

Who we are

Our website address is https://de-toren.com.
All references to “De Toren“, “we“, “us” and “our” in these terms and conditions are deemed to refer to the proprietor of www.de-toren.com, De Toren Private Wine Cellar.
All references to “you” and “your” are deemed to refer to any user and/or visitor of www.de-toren.com (“Website“). This privacy policy finds application to all users of the Website and related software applications, collectively referred to as “our Platforms”. These Platforms are used to access and facilitate purchasing of De Toren products.

By using this website, you consent to submission, collation, processing and disclosure of your information as outlined in the policy below. If you are below the age of 18 years, which is the legal age for consumption of alcohol, you are not permitted to purchase products from De Toren’s Website.

Personal Information We Collect

We will only collect your personal information with your consent and in the course of your interaction with this website when you:

  • complete a contact form
  • subscribe to our mailing list
  • register an account
  • place an order

The personal information we process includes your name and surname, e-mail address, billing and delivery address, contact numbers, personal identification numbers and tax registration number (such as a VAT number) in the case of a legal entity. You retain the full right to “opt out” of receiving any email communications. We also process the personal information of our suppliers such as a name, registration number, contact details, tax registration number and bank account details in order to comply with accounting standards and SARS requirements.

As part of the employment process, we also process the personal information of candidates and staff members in order to comply with certain legal obligations in terms of labour relations legislation. This information can include a name and surname, identification number, tax registration number, contact details and bank account details.

We do not intend to transfer any of the personal information processed outside of South Africa.

Your Rights

In terms of POPIA you have certain rights in respect of the personal information we process:

You can complain to us about the way we process your personal information. If we cannot resolve your complaint, you can submit a compliant to the Information Regulator of South Africa.

  • You have the right to access the personal information we hold about you.
  • You can request us to correct or update your personal information.
  • You can object to the way we process your personal information.
  • You have the right to ask us to delete your personal information.

This is, however, subject to our obligation in terms of certain legislation to keep record of the information collected for a longer period.

Disclosure

Under no circumstance will your information be sold or rented to any third parties for their own use. We may however disclose your information to third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.

Data Protection

We value your trust in providing any personal information for any of the above reasons and promise to make every reasonable effort to protect your information. This will entail privacy and security precautions at least equal to any precautions taken to protect our own confidential information.

If we, on reasonable grounds believe that an unauthorized person has gained access to your personal information, we will notify you and the Information Regulator, unless the Information Regulator or the responsible investigating authority instructs us otherwise.

User Tracking and Cookies

When you access our website we may use various technological tools to improve your experience on our website through the use of cookies and/or user tracking.

Cookies are small files that a site or its service provider transfers to your computer through your web browser if you have allowed them to do so. They enable a site or service provider system to recognize your browser and remember information. We use cookies to:

  • create a user-friendly experience
  • tailor our services and personalise your experience based on your needs and interests
  • ensure that the website works on your device
  • send opt-in marketing communication if you are not a client or registered user of De Toren

Cookies can be disabled in your web browser’s settings, but this could result in limited website functionality and a diminished browsing experience with many sites on the internet.

When you access our website, whether or not you are a registered user of De Toren, we process information to improve your user experience every time you visit our website. Depending on how you access our website, we may receive the following:

  • log information through online identifiers, including information on how, when and for how long you use our website, the content you view and search queries you submit.
  • Information about your sign-up, shopping and general user behaviour such as product interest or preferences, cart abandonment, frequency of visits and subscription action.
  • Information about the equipment you use to access our use our website, including the type of device you are using, how you access our website and your operating system.
  • The geographic location from where you access our website, including your device’s global positioning system signal and information about nearby wifi networks and cell towers. We get this information when you use location-enabled services.

To better understand our users, we collect the above data through contact forms, account registrations, email subscriptions and purchases on our Estate. We also collect data by making use of technology platforms such as Google Analytics, Google Ads, Google Tag Manager, Orrto, Hotjar and Facebook as well as other social media platforms.

Hotjar, mentioned above, uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

We’ve enabled Google Analytics Advertising features which may include the following features:

  • Remarketing with Google Analytics
  • Google Display Network Impression Reporting
  • Google Analytics Demographics and Interest Reporting
  • Integrated services that include the collection of data via advertising cookies and identifiers

Our Google Ads and Google Analytics accounts are linked to allow data flow between these products, in compliance with Google’s Terms of Service and applicable privacy laws. However, affirmative consent for data processing is not shared across platforms; users’ consent for each platform remains separate.

Our Facebook Page and Meta Account are subject to Facebook’s community standards. Any information collected from you via Call-To-Action buttons through ads, event bookings, etc. will only be processed with your prior consent. This data is not collected by Facebook or Meta. Our Facebook page processes insights which does not include your personal information, it is an anonymous overview which may reflect group data such as age groups. In the event that we run ads, we pass data such as email addresses and phone numbers to Meta.

Orrto is our marketing automation platform which offers the following:

  • Analytics reports: to understand and visualize our customer data
  • Journeys: to engage audiences across the customer lifecycle
  • Customer data platform: to integrate, unify and segment customer data

How Data is Used

The data we collect is used for the following purposes:

  • To improve your user experience
  • To reach you through marketing and advertising campaigns via email, Google or social platforms
  • To process purchases and refunds through our third-party payment processors.

We may link to external websites or social media platforms which each have their own terms and conditions. We take no responsibility or liability for the content and activities of these other websites and platforms. As we have no control over the changes in content these sites make, any opinions reflected on the website do not necessarily represent those of De Toren or its clients.

Contact Information

Please contact us if you have any questions regarding this statement and the exercise if your rights in terms of POPIA:
The Deputy Information Officer
De Toren Private Cellar
Polkadraai Road
Stellenbosch
E-mail: nicolette@de-toren.com

Changes to our Privacy Policy

This policy may be reviewed and updated from time to time and any changes will be posted on this page and replaces all previous versions.

This policy was last updated on 2024/8/12