- IMPORTANT INFORMATION AND WHO WE ARE
Who We Are
Our Digital Services are operated by a member of the Distell Group of companies, namely Distell International Limited, registered in Scotland with company number SC109881 and having its registered office at 8 Milton Road, College Milton North, East Kilbride G74 5BU.
- 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 as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- 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, purchases or orders made by you, 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 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.
- HOW YOUR PERSONAL DATA IS COLLECTED & USED
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- join a loyalty programme;
- book a tour;
- use a QR code displayed on products;
- visit a brand website;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- give us feedback or contact us; or
- undertake any other request that requires the submission of Personal Data.
- Third parties or publicly available sources. We also receive Personal Data about you from various third parties and public sources. We will only obtain such information where we have your consent and/or another legal ground to do so. This information may come from:
- Publicly accessible sources, e.g. the Electoral Roll or Companies House;
- Credit reference agencies;
- Customer due diligence providers;
- A bank or building society (with your consent);
- Other third party websites we have partnered with.
We, or a third party on our behalf, may collect and use your mobile/computer/tablet device ID to provide a more tailored browsing experience, to alert you to nearby events or promotions and for reporting and analysis. We, or a third party on our behalf, may collect information in the form of log files that record activity and gather statistics about browsing habits. These entries are generated anonymous, and help us gather, among other things, (i) your web browser type and operating system, (ii) information about your session (such as the URL you came from, the date and time you visited our Digital Services, and which pages you have viewed and for how long), and, (iii) other similar navigational or click-stream data. We also use log file information for our internal marketing and demographic studies, so we can constantly improve and customise the online services we offer you. Log files are only used internally, and are not associated with any personally identifiable individual.
- PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
Under data protection law, we can only use your Personal Data if we have a proper reason for doing so, e.g. (i) to comply with our legal and regulatory obligations; (ii) for the performance of a contract with you or to take steps at your request before entering into a contract; (iii) for our legitimate interests or those of a third party; or (iv) where you have given consent.
- When you register or sign-up via our Digital Services: the Personal Data you give is used to provide you with the benefits that typically come along with registration. This includes information on the products and brands that you have signed up to (and, if you have opted-in, to receive information about other Distell products), the ability to send, receive and personalise communications you select at the time of registration or that automatically come with your registration, e.g. subscription to a newsletter, creation of an account, participation in a sweepstake or contest, invitation to or attendance at an event organised by us or on our behalf;
- When you are selected or invited to attend an event we will use your Personal Data to provide you with details, tickets and entry information and to provide the organisers with information to allow them to verify your attendance;
- When you enter a sweepstake or contest we use your Personal Data to identify unique entrants and to inform winners and others of the outcome;
- When you use the ‘Send to a friend’ feature, Personal Data for one-time use (typically, names and email addresses) is used only once e.g., to send a message, and is not retained by us;
- When using e-commerce on some of our websites, we, or a third party on our behalf will use your Personal Data to create your account, facilitate the purchase process, manage your order and deliver your products under the contract you have with us, or the third party, and to understand your purchase history. We may use automated or technical solutions to detect fraudulent activity or payment and this may include profiling based on automated decision making;
- When you use a QR Code or equivalent feature displayed on our products: we use your Personal Data to send you more information on the products where the QR code or equivalent feature was displayed or other Distell products (if you opt-in to receive that information);
- When you submit Personal Data on the iPads or other mobile devices available in the Distillery Visitor Centres, this is used to send you more information on the relevant products;
- Feedback, questions, or comments through our ‘Contact Us’ form, if you contact us via an online contact form, your information is used to respond to your inquiry or comment;
- When you submit your Personal Data, you may also be given the option (through a tick box or other consent mechanism) to have your information used for an activity or service different from the one you are requesting. For example, if you enter a contest to win a prize, you may also be invited to sign up for a newsletter about other products. If you choose to have your information used for another activity or service in this way we will use your information to provide them to you.
In addition, when you submit your Personal Data, you may be given the option (through a tick box or other consent mechanism) for your information to be used for other Distell products. If you choose this option we (and other Distell Group affiliates) will use your information to provide you with information and promotions regarding other Distell products.
We retain your Personal Data in our global consumer database which allows us to ensure that your Personal Data remains accurate and up to date and to share your Personal Data with appropriate Distell group affiliates. To avoid duplication in our database, we may use information about each of your interactions with one of our Distell Group affiliates to check whether your Personal Data is still accurate. We will use that information to complete, enhance or update your Personal Data with the additional information you might have provided.
Subject to applicable laws, this may include occasionally combining, updating, or otherwise enhancing the Personal Data collected through our Digital Services with anonymised data we get from outside records or third parties. For instance, we may combine purely demographic or survey information, e.g. age, gender, household information, and other interests, not linked to any personal information about you with Personal Data collected in other cases such as during account registration.
We may also use your Personal Data, the combined information referred to above and/or demographic information for our internal marketing, segmentation, analysis and demographic studies. This helps us to constantly improve, personalise, and customise the products and services we provide.
Legitimate Interests – Managing our Business
In relation to a number of uses of Personal Data we refer to above we are doing this on the basis that it is in our legitimate interests – or those of a third party – for us to do so. A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. These interests cover a number of aspects of our business operations, namely:
- Ensuring that we are as efficient as we can be so we can deliver the best Digital Service and products for you that we can and understanding our customers and the users of our Website;
- To allow us to provide bespoke Digital Services and products where requested by you, to personalise your experience and to tailor the content, offers and promotions we send to you promoting our products and services;
- Protecting our commercially valuable information and also our intellectual property;
- Preventing and detecting fraud and/or criminal activity that could be damaging for us and for you;
- For credit control purposes and to make sure our customers can pay for the products we provide;
- Understanding how our business is performing and considering how to improve our performance; and
- Ensuring we are able to keep up to date with our customers and contacts and developments in their organisations.
We may use your Personal Data to send you updates, by email, text message, telephone or post, about our products and Digital Services, including exclusive offers, promotions or new products and Digital Services.
We have a legitimate interest in processing your Personal Data for promotional purposes. This means we do not always need your consent to carry out promotional activities. However, where consent is needed, we will ask for this consent separately and clearly.
You have the right to opt out of receiving promotional communications at any time using the ‘unsubscribe’ link in emails; or using the ‘STOP’ number in texts.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or Digital Services in the future, or if there are changes in the law, regulation, or the structure of our business.
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product purchase, product service experience or other similar transactions.
- DISCLOSURES OF YOUR PERSONAL DATA
We will never share your Personal Data with any third party that intends to use it for direct marketing purposes, unless we have specifically told you and you have given us explicit permission to do this.
We may also share your Personal Data with other third parties, but only in the following circumstances:
- We may use third parties to help deliver our products or Digital Services to you, e.g. payment service providers, warehouses and delivery companies;
- We may share your Personal Data with social media providers such as Facebook, Twitter and Instagram, in which case email addresses will be uploaded then hashed, e.g. where you are a registered user of Facebook, we will use your email address in an encrypted format to enable Facebook to find other registered users of their services that share similar interests to you based on: (i) information that we observe about you from your different interactions with us; and (ii) the information Facebook holds about you;
- We may share your Personal Data with third parties who provide programmatic advertising services to serve you with relevant advertising;
- We may use service providers, agents or contractors e.g. marketing and digital agencies to support the internal operation of our Digital Services, and to assist us with administering them or the various functions, programs and promotions available on them. Any such third party must provide appropriate levels of security for your Personal Data and, where required, are bound by a legal agreement to keep your Personal Data private, secure and to process it only on our specific instructions;
- When we run a joint or co-sponsored program or promotion on our Digital Services with another company, organisation, or other reputable third party, we may collect and process Personal Data and share it with that partner or sponsor as part of the event. If your Personal Data is being collected by, or is shared with, a company other than one that is part of the Distell Group as part of any such promotion, we will let you know at the time it is collected;
We may also disclose your Personal Data if we are required to do so by law or by law enforcement agencies or regulatory bodies, or if such action is necessary to comply with legal or regulatory processes, or to protect or defend us and/or other third parties against error, negligence, breach of contract, theft, fraud, or other illegal or harmful activity to comply with our audit and security requirements or to audit compliance with our corporate policies, procedures, legal or contractual obligations.
In the event of a merger or acquisition of all or part of us by another company, or in the event that we were to sell or dispose of all or a part of our business. In this case the acquirer would have access to the information maintained by us, which could include Personal Data, subject to applicable law. Similarly, Personal Data may be transferred as part of a corporate reorganisation, insolvency proceeding, or other similar event, if permitted by and done in accordance with applicable law.
- INTERNATIONAL TRANSFERS
The Distell group operates globally and your Personal Data may be transferred across international borders. It may be transferred to and stored at a destination outside the country in which you reside, including countries that have less strict or no data protection laws, when compared to those in your country. Your Personal Data may also be transferred between different companies of the Distell Group located in different countries.
Whenever we transfer your information as described above, we will ensure the transfer complies with data protection law both during transit and at the storage location and all Personal Data will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. If you are located in the EEA, you may contact us using the contact details below for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.
- 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 as promptly as possible.
Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, e.g. if you feel that the security of any account you might have with us has been compromised, please immediately notify us of the problem by contacting us at the contact details below.
- DATA RETENTION
How Long will we Retain your Personal Data?
We may store the Personal Data that you send to us via our Digital Services in our databases. We will not retain your Personal Data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of Personal Data.
We retain your Personal Data as long as your account is active, for the duration of a contract with you or however long it takes to provide you with the products or services requested, to answer queries or resolve problems, to show that we treated you fairly, to keep records required by law and to improve or offer new services.
We may also need to retain your Personal Data to comply with our legal and regulatory obligations, resolve disputes, enforce our agreements, and similar records management purposes.
We may also retain your Personal Data for a reasonable period after you stop using our services or our Digital Services. After this period, your Personal Data will be deleted from all systems in the Distell Group.
If you ask us to delete your information in accordance with your rights set out in paragraph 9 below, we will retain basic information on a suppression list to record your request and to avoid sending you unwanted materials in the future.
Interfaces with Third Party Websites and Services
Our Websites may contain links, references and content from other websites and services outside of our control. Please be aware that we have no control over these websites and our Privacy and Cookie Policies does not apply to them. We will not be liable to you for any issues arising in connection with their use of your information and we encourage you to read the Privacy and Cookie Policies and Conditions of Use of any linked, referenced or interfacing websites and services you visit or use.
- YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data.
You have the following rights, which you can exercise free of charge, by asking us to:
- provide a copy of your Personal Data (the right of access);
- correct any mistakes in your Personal Data;
- delete your Personal Data – in certain situations;
- restrict processing of your Personal Data – in certain circumstances, e.g. if you contest the accuracy of the data;
- provide you with a copy of the Personal Data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations.
You can also object:
- at any time to your Personal Data being processed for direct marketing including profiling;
- in certain other situations to our continued processing of your Personal Data, e.g. processing carried out for the purpose of our legitimate interests.
If your Personal Data has been processed on the basis of your consent, you can withdraw your consent at any time. We hope that we can resolve any query or concern you may raise about our use of your information. You also have the right to complain to the supervisory authority in the European Union where you work, normally live or where any alleged infringement of data protection laws occurred.
If you would like to exercise your right to object to direct marketing please use the link to unsubscribe on emails or contact us at the below email address.
If you would like to exercise any of your other rights, please email us on email@example.com.
Your objection, or withdrawal of consent, may mean we cannot provide the products or services you have requested of us or you may not be able to use the services we offer. We will advise you where this is the case. In certain circumstances even if you withdraw your consent we may still be able to process your Personal Data if required or permitted by law or for the purpose of exercising or defending our legal rights or meeting our legal and regulatory obligations.
- HOW TO CONTACT US
|Full Name of Legal Entity
|Distell International Limited
|Name of Data Privacy Manager
|Avalon House, 72 Lower Mortlake Road, Richmond, Surrey, TW9 2JY
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.