Customer Privacy & Cookies Policy

1. Overview

2. What do Gerry’s Wines & Spirits know about me?

3. Why do you need to know this about me?

4. Why are you allowed to use my data in this way?

5. Data collected from third parties.

6. Members of the public.

7. How does Gerry’s Wines & Spirits look after my data?

8. Do you keep my data forever?

9. Do you share my data?

10. Service providers

11. What about other companies in the Booker/Tesco group?

12. Cookies

13. What rights do I have (including subject access)?

14. How can I contact Gerry’s Wines & Spirits about my data?

This privacy notice covers the activities of Gerry’s Wines & Spirits. Gerry’s Wines & Spirits is a trade brand which is part of Venus Wine and Spirit Merchants PLC, a limited company registered in England under company number 05689256 whose registered offices are: Equity House, Irthlingborough Road, Wellingborough, Northamptonshire, England, NN8 1LT.

The data controller is the relevant company whose services are being used (collectively referred to in this Notice as "Venus" "Gerry’s Wines & Spirits" or "we" "our" or "us" We are registered as a data controller with the UK Information commissioner’s office, our registration number is Z1761904.

1. Overview

At Gerry’s Wines & Spirits., we’re working hard to serve our customers, communities and planet a little better every day. To do this, we need to be able to offer you products and services that meet these goals. Looking after the data you share with us is a hugely important part of this. We want you to be confident that your data is safe and secure with us, and that you understand how we use it to offer you a better and more relevant shopping experience.

When you shop or purchase goods with us online, or at our Soho shop, or when you communicate with us, we collect and create personal data about you.

Gerry’s Wines & Spirits. serve a variety of customers in different ways and this notice applies to you if you use our services. To use our services, you either visit our store in Soho, visit our website or place and order for delivery from our online store. From time to time, we may be contacted by individuals who are not the registered account holder In those circumstances we will gather specific information to address the query or issue (such as name, address and contact details). This policy does the following:

  • Sets out the different ways you interact with us and the types of personal data that we collect.
  • Explains the reasons why we use the data we collect.
  • Explains when and why we will share personal data with other organisations.
  • Explains the rights and choices you have when it comes to your personal data (including your marketing and cookie preferences).

2. What do Gerry’s Wines & Spirits know about me?

Gerry’s Wines & Spirits will collect and create different types of data. These include the following broad types of data.

Aggregated data
We try and remove personal data we don’t need. If we remove enough personal data, it becomes anonymous. This means that you can’t be identified.

We might also take data we hold and remove certain information and replace it with other non-identifying information, such as an ID number or reference number. This is an extra technique we use to protect data.

Identity and contact data (name, address, email address, & date of birth)
This is information that helps us identify who you are and how we can contact you. This includes your name, title, address, email, and telephone number. It also helps us mange the account(s) you hold with us, process your orders and refunds, provide additional services, deliver goods to your premises and communicate with you in emergencies or in relation to a product recall.

When you register or place and order as a customer of a Gerry’s Wines & Spirits we will collect (where applicable);

  • Your personal details, including your name, your address, the delivery address and recipient name if this is not you), your date of birth, email addresses, date of birth, phone number and title.
  • A username and password for logging into your account online.
  • If you choose to provide (when ordering as a gift), additional details such as a message to the recipient.

Financial, and transactional data (purchase information, banking, and payment details)
This is information about you, your bank account and payment card details, we use a 3rd party payment provider Sage Pay to process your card payments online.

We produce invoices and Receipts and make them available for you, including where we sent that product or as part of the transaction), this is to ensure we are compliant with HMRC VAT requirements.

User and interaction data (how you interact with products and services, delivered, online and in-branch)
User data is information collected about you as a user of our store, website and purchase of products. This may include where you provide feedback on your shopping experience; or are captured by CCTV or other camera technologies.

We’ll also collect information about you that allows us to create an analysis of you as a customer. This is to better judge what products and services to offer you.

Interaction data is information about how you interact with our products and services, namely what you click on and interact with on our websites, or with products in the Soho store.

Marketing data
This is information about your marketing preferences and your interaction with online marketing. For example, we can see when you open marketing emails and/or WhatApp marketing messages from Gerry’s Wines & Spirits (you can opt out of marketing at any time by telling us). This also includes if you interact with adverts from Gerry’s Wines & Spirits while browsing the internet or on social media such as Instagram. This enables us to judge its effectiveness when we compare your interactions with what you’ve purchased.

Location data
We collect and process location data about you to enable us to deliver goods to you.

Technical device data
This is information about the device you use to access our websites. This could be information that identifies your device, its operating system, internet address, your sign-in data, browser and plug-ins, location, where you came to our site from and where you go when you leave, as well as how often you visit. This is done via the use of cookies, which is covered further down in this notice.

Special category data
This is special information that the law says is more sensitive (sometimes it’s referred to as ‘sensitive personal data’) and it needs more protection.

For Gerry’s Wines & Spirits if we collect sensitive personal data in our interactions with you (for example, if you’re making a complaint to us, or reporting an accident), we’ll clearly explain what we’re doing, and we’ll only collect the data with your consent.

3. Why do you need to know this about me?

We’ve carefully considered the reasons for collecting and/or creating this data. Here’s a summary of when and why we believe it’s appropriate.

This means that processing your personal data allows us to:

I. manage the registered online accounts you hold with us.
II. process your orders and refunds.
III. produce invoices.

Why do we process your personal data in this way?
We need to process your personal data so that we can manage your customer accounts, provide you with the goods and services you want to buy, and help you with any orders and refunds you may ask for.

Why we’re using this data (legal basis)

  • Contractual necessity – at the time we collect it (purchase data, contact details, delivery/collection details).
  • Legitimate interests – following fulfilment of your order.
  • Legal obligation – to ensure compliance with HMRC VAT requirements.

We won’t be able to provide you with your products or services if you don’t provide us with this data.

To manage and improve our day-to-day operations.

I. Help to develop and improve our product range, services (digital and physical), our Soho Shop, information technology systems, know-how and the way we communicate with you.

Why do we process your personal data in this way?
We rely on the use of personal data to carry out market research and internal research and development. It also helps us to improve our information technology systems (including security), our product range, services, and shop. This allows us to serve you better as a customer.

II. Detect and prevent fraud or other crime.

Why do we process your personal data in this way?
It’s important for us to monitor how our services are used to detect and prevent fraud, other crimes, and the misuse of services. This helps us to make sure that you can safely use our services.

Why we’re using this data (legal basis)
Legitimate interests

To personalise your Gerry’s Wines & Spirits experience

I. Manage and improve our websites and mobile app.

Why do we process your personal data in this way?
We use cookies and similar technologies on our websites and mobile app to improve your experience. Some cookies are necessary so you shouldn’t disable these if you want to be able to use all the features of our websites and mobile app. You can disable other cookies, but this may affect your experience. For more information about cookies and how you can disable them, see the cookies and similar technologies section.

II. Use your online browsing behaviour, as well as your in-branch and online purchases (including invoices and transactions), to help us better understand you as a customer and provide you with personalised offers and services.
Why do we process your personal data in this way?
We use basic data about your general shopping habits (and those of similar customers) to group customers into different segments. This allows us to personalise our offers and services for you (including in our marketing communications).

III. Provide you with relevant marketing communications, relating to our products and services, and those of our suppliers, partners and the Gerry’s Wines & Spirits.
If we or our supplier partners run online advertising, this may be displayed on websites across the Gerry’s Wines & Spirits Group, non-Gerry’s Wines & Spirits websites and other media platforms (including such as Facebook, & Instagram)

We may also measure the effectiveness of this advertising. To do this, we may use certain basic data about your in-branch and online purchases (for example if you bought a particular product that was featured in an advert). However, we limit this to what is necessary, and it is always obscured or anonymised to protect your identity.

When we share your data in this way, it won’t be used by those platforms for their own purposes and will be deleted shortly after.

Why do we process your personal data in this way?
We want to make sure that we provide you with marketing communications, including online advertising, that are relevant to your interests. To achieve this, we measure your responses to marketing communications relating to products and services that we and our partners offer. This means that when you’re offered products and services, they best meet your needs as a customer.

Why we’re using this data (legal basis and consent)
We will send you relevant offers and news about our products and services in several ways including by email, text and WhatsApp where you have provided consent (if applicable) or alternatively where we have collected your contact details as part of a sale where you have not otherwise opted out to receive these marketing communications (Legitimate interests)

Changing your preferences
You can change your marketing preferences with us at any time by either notifying us by email or following the opt out/unsubscribe instructions found on all electronic communications that we send to you via Email or telephone or at a local branch. You can also manage your marketing preferences through your online account with us if you have one.

To contact and interact with you

I. Contact you about our services, for example by phone, email, or post, or by responding to social media posts that you’ve directed at us.
Why do we process your personal data in this way?
We want to serve you better as a customer, so we use personal data to provide you with clear information or help in response to your communications. or where you contact our team your call may be recorded for training and monitoring purposes.

II. Manage promotions you take part in.
Why do we process your personal data in this way?
We need to process your personal data, so that we can manage the promotions you choose to enter including those we run with our supplier and other third parties.

To resolve legal claims or disputes

Why do we process your personal data in this way?
This might be needed if you have an accident or there’s an incident at our Soho shop, for example. This could include medical reports.

Why we’re using this data (legal basis)
Bringing or defending legal claims.

To use CCTV to protect our colleagues, customers, members of the public and property to prevent and detect crime and anti-social behaviour.

Where there’s a security incident in our Soho Store, we may use CCTV to assist in our investigation into those incidents.

Why do we process your personal data in this way?
To protect our business, the local community, customers, and colleagues.

Why are we using this data (legal basis).

  • Legitimate interests
  • Exercising our legal rights

4. Why are you allowed to use my data in this way?

Whenever an organisation uses data, they must have a reason to use it. The law gives certain reasons for the use of data and Gerry’s Wines & Spirits will always use data according to one of those reasons. In the section ‘Why do you need to know this about me’ we’ve stated the different reasons that we might hold data.

In this section, we explain why we think those reasons are suitable and what this means for you.

There’s often a focus on consent to use personal data but, in many circumstances, consent wouldn’t be appropriate. For example, a shoplifter withdrawing consent to be filmed with CCTV would increase risk to you and our colleagues; or for example a customer withdrawing consent to process their payment information, would increase the risk to our business.

Therefore, in many situations, Gerry’s Wines & Spirits relies upon other legal reasons. For example, needing data to fulfil a ‘contract’ with you. At the point of you buying goods and services from Gerry’s Wines & Spirits, a contract is created and any data we collect to allow us to deliver or provide those services or goods can be used and kept making sure we fulfil our contract.

Another reason is called ‘legitimate interests. This is when there are legitimate and reasonable reasons when Gerry’s Wines & Spirits might collect and use data. For example, collecting information through our website is beneficial to both Gerry’s Wines & Spirits and you because we can understand what products you’re interested in and make sure the products we offer match that need.

Our use of your personal data when based on ‘legitimate interests’ are to:

  • Meet our customers’ needs, including delivering our products and services.
  • Promote and market our products and services, and those of our partners and service providers.
  • Service your account (such as your Gerry’s Wines & Spirits account), manage complaints, and resolve any disputes.
  • Understand our customers including their patterns and behaviours, as well as their likes and dislikes.
  • Protect and support our business, colleagues, customers and shareholders.
  • Prevent and detect anti-social behaviour, fraud and other crime.
  • Test and develop new products and services as well as improve existing ones.

We’ve assessed these fundamental reasons against the fundamental rights and freedoms provided to you under the law and balanced them up against the benefit both you and Gerry’s Wines & Spirits might receive from this data being used.

5. Members of the public

From time to time, we may be contacted by individuals who are not the account holder.

In those circumstances we will gather sufficient information to address the query or issue (such as name, address and contact details). In some case’s we may need to pass that information on to a third party, such as a supplier (in the event of a product related query) or a third party advisor to address the matter in question. Any information obtained will be processed purely for the purpose of the single issue or query raised and will be deleted in line with our retention policy once the matter has been closed.

We may also capture data of members of the public on our CCTV surveillance systems, this is to protect our business, the local community, customers, and colleagues. Please see section 3 for more information.

6. How does Gerry’s Wines & Spirits look after my data?

We know how important it is to protect and manage your personal data. This section sets out some of the measures we have in place.

  • We make sure staff are trained and rules are in place to make sure that data is used properly.
  • We have physical protections and digital/electronic systems in place to keep what we hold secure.
  • We use computer safeguards such as firewalls and data encryption to keep this data safe when it’s not being moved.
  • We only allow access to authorised colleagues and trusted partners.
  • We regularly watch our systems for possible weaknesses and attacks, and we carry out tests (penetration testing) to see what can be improved.
  • We’ll ask for proof of identity before we share your personal data with you.
  • We’ll reveal only the last four digits of your payment card number when confirming an order.

Your personal data may be transferred outside the UK. It may also be processed by companies outside the UK who work for us (or for one of our service providers). When we do this, your personal data will be subject to appropriate protections. If we do transfer personal data to outside of the UK, it’ll be protected in the same way as if it was being used in the UK. To do this, we use one of the following safeguards.

  • We transfer to a non-UK country whose privacy laws ensure an appropriate level of protection for personal data.
  • We put in place a contract with a third party that means they must protect personal data to the same standards as the UK.
  • We transfer personal data to organisations that are part of specific agreements on cross-border data transfers with the UK.
  • We complete a transfer risk assessment before agreeing to transfer data to any organisation who are in a country that does not have specific cross border arrangement and only if we decide the risk is low, we will progress and ensure we put in place an International Data sharing agreement with those organisations alongside a contract so that they protect the data to the same standards as the UK.

7. Do you keep my data forever?

We won’t keep your personal data longer than we need to. In most circumstances, this means we won’t keep your personal data for more than 7 years after the end of your relationship with us. For certain data sets, we have the following specific retention periods:

  • Information about purchases and the payment information relating to those purchases might be kept for up to 7 years after the transaction to allow us to meet statutory financial reporting requirements in areas such as VAT returns, investigate fraud and handle legal claims.
  • Customer complaints and feedback will be deleted 4 years after the date of the last communication.
  • CCTV data will be kept no longer than 1 month after its creation, unless footage has been retained as part of a legal claim, accident, or criminal investigation.
  • Health and safety records (for example, incident reports) will be deleted 7 years after their creation.
  • Where your personal data is needed because of a serious dispute (such as litigation) or investigation, your personal data will be deleted 7 years after the matter is closed.
  • When a customer has not shopped with Gerry’s Wines & Spirits for 2 years or more, the account will be closed and can no longer be used.

8. Do you share my data?

We may share personal data with other organisations (including other Gerry’s Wines & Spirits companies, Group companies and partners as listed below) in the following circumstances:

  • To deliver the products and services we have offered to you.
  • Offer products, services that may be of interest to you.
  • With our wholesale and service providers (as explained below in section 10)
  • To companies undertaking market research, surveys or gathering other industry related information relating to the services we provide your business.
  • We may share personal data with other organisations in the following circumstances;
    • If the law or a public authority says we must share the personal data.
    • To establish, exercise or defend our legal rights or we need to by law (this includes for the purposes of preventing fraud and reducing credit risk).
    • To investigate or manage any complaints that you may have about deliveries, products or services.
    • Where we restructure, sell, or transfer our business (or a part of it). For example, in connection with a takeover or merger.
    • To any company within our parent’s company group of companies (see section 11 “What about other companies in the Tesco/Booker Group below for more details”)

9. Service providers

These are organisations that help us to deliver and improve the services we offer to you. For example:

  • Technology and data services (such as storing, combining, and analysing data, and processing payments, and credit checking).
  • Fulfilment of orders.
  • Payment providers such as Sage Pay, Clover and PayPal.
  • Legal or other professional services.
  • Those who provide services on our behalf such as, sending communications on our behalf, managing website services or conducting market research.

We only share personal data that enable our service providers to provide their services and they only use it for purposes agreed with us. We may also combine service providers data with data held by Gerry’s Wines & Spirits to understand your purchases and interactions with us better.

10. What about other companies in the Booker/Tesco Group?

Gerry’s Wines & Spirits is a trade brand which is part of Venus Wine and Spirit Merchants PLC and Venus Wine and Spirit Merchants PLC along with Booker Limited, Makro Self Service Wholesalers Limited, Booker Retail Partners (GB) Limited, and Booker Direct Limited are all part of the Booker Group. We may share personal data we collect with other companies in Booker Group. For example, we may share your customer data amongst other Booker Group companies to enable us to deliver your goods and services from the most convenient location to you.

Booker Group is part of the Tesco Group, which includes companies such as Tesco Stores limited, Tesco Insurance, Tesco Mobile, dunnhumby, One Stop and Tesco Business Solutions. Data sharing is needed and essential for several reasons including corporate governance, provision of services, as well as achieving effective business management. For the avoidance of doubt, none of your product order data is shared with or used by the wider Tesco Group outside of the Booker Group.

An overview of why we share data with our Group companies is below;

Booker Limited
Venus Wines and Spirits are part of the Booker Group.

Sharing data with Booker helps our customers access a wider range of products. To find out more about what Booker do, click on the links.

Tesco
Tesco part of Tesco PLC, provides retail goods to customers as well as providing the following services to Gerry’s Wines & Spirits:

  • Central Management and Business Services
  • Technology and IT Services
  • Financial and Tax Services
  • Licensing, Legal and Compliance Services

These services involve the collection and processing of Gerry’s Wines & Spirits Group’s suppliers’, customers’ and colleagues’ personal data and systematic sharing between the different parties.

Sharing of personal data is undertaken to achieve sound corporate governance, effective business management and legal compliance. Find out more about what Tesco do, click on the link.

Tesco Bengaluru (Tesco Business Solutions)
Tesco Bengaluru part of the Tesco PLC, provides following services to Booker Group:

  • Central Management and Business Services
  • Legal and Compliance Services
  • Technology and IT Services
  • Financial and Tax Services

These services involve the collection and processing of Booker Group’s suppliers’, customers’ and colleagues’ personal data and systematic sharing between the different parties.

Sharing of personal data is undertaken to achieve sound corporate governance, effective business management and legal compliance. Find out more about what Tesco Bengaluru do, click on the link.

Tesco Insurance, Tesco Mobile, One stop & dunnhumby
We do not share any customer data with these group companies currently.

11. Cookies

We use cookies and similar technologies, such as tags and pixels (‘cookies’), to personalise and improve your customer experience as you use our websites and mobile app, and to provide you with relevant online advertising. This section provides more information about cookies, including how we use them and how you can make choices about our use of cookies.

How we use cookies
Cookies are small text files containing a unique identifier, which are stored on your computer or mobile device so that your device can be recognised when you’re using a particular website or mobile app. Some cookies may be used only for the duration of your visit, and others may be used to measure how you interact with services and content over time. Cookies help to provide important features and functionality on our websites and mobile app, and to improve your experience. Cookies can also be used to help us detect fraudulent activity or to prevent security breaches, so we may record information about your device within the cookie. The reasons we use cookies are;

Improve the way our websites and mobile apps work
Cookies allow us to improve the way our Websites and Mobile Apps work, so that we can personalise your experience and allow you to use many of their useful features. For example, we use Cookies so we can remember your preferences and the contents of your shopping basket when you return to our Websites and Mobile Apps.

Improve the performance of our websites and mobile apps
Cookies can help us to understand how our Websites and Mobile Apps are being used, for example, by telling us if you get an error messages as you browse.

These Cookies collect data that is mostly aggregated and anonymous.

Deliver relevant online advertising
We use Cookies to help us deliver online advertising that we believe is most relevant to you on our websites and other organisations' websites and using social media.

Cookies used for this purpose are often placed on our websites by other companies providing specialist services to us. These Cookies may collect information about your online behaviour, such as your IP address, the website you arrived from and information about your purchase history or the content of your shopping basket. This means that you may see our adverts on our websites and on other organisations' websites. You may also see adverts for other organisations on our websites.

Measuring the effectiveness of our marketing communications, including online advertising
Cookies can tell us if you have seen a specific advert or message, and how long it has been since you have seen it. This information allows us to measure the effectiveness of our online advertising campaigns and control the number of times you are shown an advert.

We also use Cookies to measure the effectiveness of our marketing communications, for example by telling us if you have opened a marketing email that we have sent you.

A list of the cookies we use can be found here;

Essential (4)
Essential cookies enable core functionality such as security, network management, and accessibility. You cannot turn these off here or the site won't work properly. You can change them by changing your browser settings or , but this will affect the way the website works.

We use these cookies for things like:

Security, Signing in, Site errors, Storing products in your trolley, Making payments

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Statistics (4)
We use Google Analytics cookies to help us improve our website by collecting and reporting information on how you use it. The cookies collect information but do not directly identify anyone.

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Your choices when it comes to Cookies

Web browser cookies
You can use your browser settings to accept or reject new cookies and to delete existing cookies. You can also set your browser to notify you each time new cookies are placed on your computer or other device. You can find more detailed information about how you can manage cookies through your browser’s help function.

If you choose to disable some or all cookies, you may not be able to make full use of our websites. For example, you may not be able to add items to your shopping basket, proceed to checkout, or use any of our products and services that require you to sign in.

12. What rights do I have (including subject access)?

Subject Access
You have the right to see the personal data we hold about you. This is called a Subject Access Request or SAR.

If you’d like a copy of the personal data we hold about you, please email DPO@booker.co.uk

Inaccurate data
If you believe we hold inaccurate or incomplete data, please let us know and we’ll correct it.

Withdrawal of consent
Where you gave us, information based upon your consent, if you withdraw that consent, we’ll stop using that data.

Objection to our use of your data
We’ll consider your objection to our use of your personal data. If, on balance, your rights outweigh our interests in using your personal data, then you can ask us to either restrict our use of it or delete it. In almost all cases relating to marketing, we’ll stop using that data at your request.

Restriction to use your data
There are several situations when you can restrict our use of your personal data. This includes (but is not limited to):

  • You’ve successfully made a general objection (as above).
  • You’re challenging the accuracy of the personal data we hold.
  • We’ve used your personal data unlawfully, but you don’t want us to delete it.

Deletion
There are several situations when you can have us delete your personal data. This includes (but is not limited to):

  • We no longer need to keep your personal data.
  • You’ve successfully made a general objection (as above).
  • You’ve withdrawn your consent to us using your personal data (and we don’t have any other grounds to use it).
  • We’ve unlawfully processed your personal data.

Complain to the data protection regulator (ICO)
We’d like the chance to resolve any complaints you have. However, you also have the right to complain to the UK data protection regulator (the ‘ICO’) about how we’ve used your personal data.

More information on your data protection rights
The ICO website also contains more detail on the data protection rights mentioned above, or if you’d like to speak to us about these rights in more detail, see the ‘how to contact us’ section below.

13. How can I contact Gerry’s Wines & Spirits about my data?

We want to ensure that the personal data we hold about you is accurate and up to date, if any of the details are incorrect, please let us know and we will amend them.

If you have any questions, wish to exercise any of your rights or have any complaints about how Gerry’s Wines & Spirits uses your personal data, please contact us.

Phone: 01933 371000

Mail: Gerry’s Wines & Spirits PLC, Head of Data Privacy & Risk (Registered Data Protection Officer), Legal Department, Booker, Equity House, Irthlingborough Road, Wellingborough, Northants. NN8 1LT

Email: DPO@Booker.co.uk

We reserve the right to make changes to this Privacy Notice from time to time, so please take time to review this periodically.

Reviewed and Updated: April 2025