Halewood Artisanal Spirits (UK) Limited respects your privacy and is committed to
protecting your personal data. This privacy notice will inform you as to how we look
after your personal data when you visit our website (regardless of where you visit it
from) and when we collect your data, and tell you about your privacy rights and how
the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used
in this privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This privacy notice aims to give you information on how Halewood Artisanal Spirits
(UK) Limited collects and processes your personal data through your use of this
website, including any data you may provide through this website when you sign up
to our newsletter, agree to receive marketing from us, or take part in a competition.
This website is not intended for children and we do not knowingly collect data
relating to children.
It is important that you read this privacy notice together with any other privacy notice
or fair processing notice we may provide on specific occasions when we are
collecting or processing personal data about you so that you are fully aware of how
and why we are using your data. This privacy notice supplements the other notices
and is not intended to override them.
Controller
Halewood Artisanal Spirits (UK) Limited is the controller and responsible for your
personal data (collectively referred to as “Halewood”, “we”, “us” or “our” in this
privacy notice).
We have appointed a data privacy manager who is responsible for overseeing
questions in relation to this privacy notice. If you have any questions about this
privacy notice, including any requests to exercise your legal rights, please contact
the data privacy manager using the details set out below.
Contact details
Our full details are:
Full name of legal entity: Halewood Artisanal Spirits (UK) Limited
Email address: dataprotection@halewood-int.com
Postal address: 1
st Floor, Tennyson House, 159-165 Great Portland Street, London,
England, W1W 5PA
Telephone number: 0151 4808800
You have the right to make a complaint at any time to the Information
Commissioner’s Office (ICO), the UK supervisory authority for data protection issues
(www.ico.org.uk). We would, however, appreciate the chance to deal with your
concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 10 May 2018.
The data protection law changed on 25 May 2018.
It is important that the personal data we hold about you is accurate and current.
Please keep us informed if your personal data changes during your relationship with
us.
Third-party links
This website may include links to third-party websites, plug-ins and applications.
Clicking on those links or enabling those connections may allow third parties to
collect or share data about you. We do not control these third-party websites and are
not responsible for their privacy statements. When you leave our website, we
encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual
from which that person can be identified. It does not include data where the identity
has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you
which we have grouped together follows:
• Identity Data includes first name, last name, gender, date of birth.
• Contact Data includes postal address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone
setting and location, browser plug-in types and versions, operating system and platform and other technology on
the devices you use to access this website.
• Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third
parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic
data for any purpose. Aggregated Data may be derived from your personal data but
is not considered personal data in law as this data does not directly or indirectly
reveal your identity. For example, we may aggregate your Usage Data to calculate
the percentage of users accessing a specific website feature. However, if we
combine or connect Aggregated Data with your personal data so that it can directly
or indirectly identify you, we treat the combined data as personal data which will be
used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this
includes details about your race or ethnicity, religious or philosophical beliefs, sex
life, sexual orientation, political opinions, trade union membership, information about
your health and genetic and biometric data). Nor do we collect any information about
criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we
have with you and you fail to provide that data when requested, we may not be able
to perform the contract we have or are trying to enter into with you (for example, to
provide you with goods or services). In this case, we may have to cancel a product
or service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Profile and Marketing Data by filling in forms or by
corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• subscribe to our newsletter, services or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect
Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using
cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit
other websites employing our cookies. Please see the Cookies section below for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties
and public sources as set out below:
• Technical Data from the following parties:
• analytics providers such as Google;
• advertising networks; and
• search information providers.
• Contact Data from providers of technical services.
• Identity and Contact Data from data brokers or aggregators.
• Marketing agencies – we may employ the services of agencies to run competitions or promotions on our behalf
and they may collect personal data as part of the campaign.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we
will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental
rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal
data other than in relation to sending direct marketing communications to you via
email or text message. You have the right to withdraw consent to marketing at any
time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use
your personal data, and which of the legal bases we rely on to do so. We have also
identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground
depending on the specific purpose for which we are using your data. Contact us if
you need details about the specific legal ground, we are relying on to process your
personal data where more than one ground has been set out in the table below:
Purpose/Activity Type Of Data Lawful Basis For Processing Including Basis
Of Legitimate Interest
To Manage Our Relationship With You Which
Will Include:
(A) Notifying You About Changes To Our Terms
Or Privacy Policy
(A) Identity
(B) Profile
(I) Necessary To Comply With A Legal Obligation
(Ii) Necessary For Our Legitimate Interests (To Keep
Our Records Updated And To Study How Customers
Use Our Products/Services)
(B) Asking You To Leave A Review Or Take A
Survey
(C) Marketing And
Communications
To Enable You To Partake In A Prize Draw,
Competition Or Complete A Survey
(A) Identity
(B) Contact
(C) Profile
(D) Usage
(E) Marketing And
Communications
(I) Performance Of A Contract With You
(Ii) Necessary For Our Legitimate Interests (To Study
How Customers Use Our Products/Services, To
Develop Them And Grow Our Business, To Run
Competitions, Prize Draws And Promotions)
To Administer And Protect Our Business
And This Website (Including
Troubleshooting, Data Analysis, Testing,
System Maintenance, Support, Reporting
And Hosting Of Data)
(A) Identity
(B) Contact
(C) Technical
(I) Necessary For Our Legitimate Interests (For Running
Our Business, Provision Of Administration And IT
Services, Network Security, To Prevent Fraud And In
The Context Of A Business Reorganisation Or Group
Restructuring Exercise)
(Ii) Necessary To Comply With A Legal Obligation
To Deliver Relevant Website Content And
Advertisements To You And Measure Or
Understand The Effectiveness Of The
Advertising We Serve To You
(A) Identity
(B) Contact
(C) Profile
(D) Usage
(E)Marketing And
Communications
(F) Technical
Necessary For Our Legitimate Interests (To Study How
Customers Use Our Products/Services And Website,
To Develop Them, To Grow Our Business And To
Inform Our Marketing Strategy)
To Use Data Analytics To Improve Our
Website, Products/Services, Marketing,
Customer Relationships And Experiences
(A) Technical
(B) Usage
Necessary For Our Legitimate Interests (To Define
Types Of Customers For Our Products And Services,
To Keep Our Website Updated And Relevant, To
Develop Our Business And To Inform Our Marketing
Strategy)
To Make Suggestions And
Recommendations To You About Goods Or
Services That May Be Of Interest To You
(A) Identity
(B) Contact
(C) Technical
(D) Usage
(E) Profile
Necessary For Our Legitimate Interests (To Develop
Our Products/Services And Grow Our Business)
Marketing
We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising. We have established the following
personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view
on what we think you may want or need, or what may be of interest to you. This is
how we decide which products, services and offers may be relevant for you (we call
this marketing).
You will receive marketing communications from us if:
• you have requested information from us or consented to receiving information from us;
• or you have purchased goods or services from us or if you provided us with your details when you entered a
competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any
external company.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time
by following the opt-out links on any marketing message sent to you, or by
contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to
personal data provided to us as a result of a purchase made by you, product/service
experience or other commercial transactions.
Cookies
(i) Cookies are small files that are written or downloaded to your computer’s hard
drive when you access a website. In compliance with the Privacy and Electronic
Communications (EC Directive) Regulations 2003, and other relevant legislation in
force from time to time, we may issue cookies to your computer when you log onto
the Website. The cookies from our Website allow us to store and quickly retrieve
login information on your computer and provide data that we can use to improve the
quality of our service. They also allow us to monitor Website traffic and to
personalise the content of the Website for you. You may set up your computer to
reject cookies although, in that case, you may not be able to use certain features on
our Website.
(ii) Some of our business partners (including the advertisers or offer providers on our
Website) may use cookies on our Website. We have no access to or control over
these types of cookies.
(iii) Use of cookies by this website
Cookies are small text files that are placed on your computer by websites that you
visit. They are widely used in order to make websites work, or work more efficiently,
as well as to provide information to the owners of the site.
The table below explains the cookies we use and why.
Cookie Name Purpose
Google
Analytics
_utma
_utmb
_utmc
These Cookies Are Used To Collect Information About How Visitors Use Our
Site. We Use The Information To Compile Reports And To Help Us Improve
The Site. The Cookies Collect Information In An Anonymous Form, Including
The Number Of Visitors To The Site, Where Visitors Have Come To The Site
From And The Pages They Visited.
_utmz
Site Cookie
Acceptance
Acknowledged_cookie_policy This Cookie Is Used To Record If A User Has Accepted The Use Of Cookies
On The Website.
Most web browsers allow some control of most cookies through the browser settings.
To find out more about cookies, including how to see what cookies have been set
and how to manage and delete them, visit www.allaboutcookies.org.
You can set your browser to refuse all or some browser cookies, or to alert you when
websites set or access cookies. If you disable or refuse cookies, please note that
some parts of this website may become inaccessible or not function properly.
To opt out of being tracked by Google Analytics across all websites visit
http://tools.google.com/dlpage/gaoptout.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless
we reasonably consider that we need to use it for another reason and that reason is
compatible with the original purpose. If you wish to get an explanation as to how the
processing for the new purpose is compatible with the original purpose, please
contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and
we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or
consent, in compliance with the above rules, where this is required or permitted by
law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the
purposes set out in the table in paragraph 4 above.
• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively,
we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new
owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it
in accordance with the law. We do not allow our third-party service providers to use
your personal data for their own purposes and only permit them to process your
personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA).
However, if you click on a third party link we will have no control over where your
data is transferred and you should check the privacy policy of that website.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data
from being accidentally lost, used or accessed in an unauthorised way, altered or
disclosed. In addition, we limit access to your personal data to those employees,
agents, contractors and other third parties who have a business need to know. They
will only process your personal data on our instructions and they are subject to a
duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach
and will notify you and any applicable regulator of a breach where we are legally
required to do so.
8. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes
we collected it for, including for the purposes of satisfying any legal, accounting, or
reporting requirements.
To determine the appropriate retention period for personal data, we consider the
amount, nature, and sensitivity of the personal data, the potential risk of harm from
unauthorised use or disclosure of your personal data, the purposes for which we
process your personal data and whether we can achieve those purposes through
other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see the section entitled
“Request erasure” below for further information.
In some circumstances we may anonymise your personal data (so that it can no
longer be associated with you) for research or statistical purposes in which case we
may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation
to your personal data.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the
other rights). However, we may charge a reasonable fee if your request is clearly
unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your
request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your
identity and ensure your right to access your personal data (or to exercise any of
your other rights). This is a security measure to ensure that personal data is not
disclosed to any person who has no right to receive it. We may also contact you to
ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may
take us longer than a month if your request is particularly complex or you have made
a number of requests. In this case, we will notify you and keep you updated.
10. GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing
our business to enable us to give you the best service/product and the best and most
secure experience. We make sure we consider and balance any potential impact on
you (both positive and negative) and your rights before we process your personal
data for our legitimate interests. We do not use your personal data for activities
where our interests are overridden by the impact on you (unless we have your
consent or are otherwise required or permitted to by law). You can obtain further
information about how we assess our legitimate interests against any potential
impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your request
before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal
data where it is necessary for compliance with a legal or regulatory obligation that we
are subject to.
THIRD PARTIES
Internal Third Parties
Other companies in the Halewood Group acting as joint controllers or processors
and who are based in the UK and provide IT and system administration services and
undertake leadership reporting.
External Third Parties
• Service providers acting as data processors based in the UK who provide IT and system administration services /
PR and marketing services / website hosting and administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers
who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the
United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access
request”). This enables you to receive a copy of the personal data we hold about you
and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you
to have any incomplete or inaccurate data we hold about you corrected, though we
may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or
remove personal data where there is no good reason for us continuing to process it.
You also have the right to ask us to delete or remove your personal data where you
have successfully exercised your right to object to processing (see below), where we
may have processed your information unlawfully or where we are required to erase
your personal data to comply with local law. Note, however, that we may not always
be able to comply with your request of erasure for specific legal reasons which will
be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate
interest (or those of a third party) and there is something about your particular
situation which makes you want to object to processing on this ground as you feel it
impacts on your fundamental rights and freedoms. You also have the right to object
where we are processing your personal data for direct marketing purposes. In some
cases, we may demonstrate that we have compelling legitimate grounds to process
your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask
us to suspend the processing of your personal data in the following scenarios: (a) if
you want us to establish the data’s accuracy; (b) where our use of the data is
unlawful but you do not want us to erase it; (c) where you need us to hold the data
even if we no longer require it as you need it to establish, exercise or defend legal
claims; or (d) you have objected to our use of your data but we need to verify
whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide
to you, or a third party you have chosen, your personal data in a structured,
commonly used, machine-readable format. Note that this right only applies to
automated information which you initially provided consent for us to use or where we
used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your
personal data. However, this will not affect the lawfulness of any processing carried
out before you withdraw your consent. If you withdraw your consent, we may not be
able to provide certain products or services to you. We will advise you if this is the
case at the time you withdraw your consent.