The Glenturret Privacy Policy

1 Who we are

This is the privacy statement of The Glenturret Limited, a company incorporated in Scotland with registered number SC616414 (hereafter “Glenturret” or “We”).

2 Types of personal information We collect

2.1 Your personal data (being your email address and name) will be used by Glenturret for the purposes of providing information regarding The Glenturret Scotch Whisky and the Glenturret distillery.

2.2 We may collect, use and store different types of personal information about you, which We have grouped together as follows:

Types of personal information

Description

Financial

Details of purchases and orders made by you

When you make a purchase or place an order with us, your payment card details

Transactional

Your name, age/date of birth (for age verification purposes) and location

Your contact details: postal addresses including billing and delivery addresses, contact telephone numbers

Marketing

Your correspondence and communications with Glenturret

Personal data which you have maybe shared via a public platform (such as on Glenturret Facebook or Instagram feed)

Your communication and marketing preferences

Your interests, preferences, feedback and survey responses

Online browsing activities on the Glenturret website

3 How We use your personal information

3.1 In general terms, We collect and use personal information to:

3.1.1 deliver our services and meet our legal responsibilities;

3.1.2 verify your identity and date of birth where this is required;

3.1.3 contact you by post, email or telephone;

3.1.4 understand your needs and how they may be met;

3.1.5 maintain our records; and

3.1.6 for crime and fraud prevention, detection and related purposes.

3.2 We use your personal data to manage our business capability, planning and communications in an efficient and proper way and to deliver our services. More specifically, the table below explains how We use your personal information and the reasons that We rely on in doing so. Where these reasons include legitimate interests, We explain what these legitimate interests are.

What We use your information for

Our reasons

To provide you with information, products or services that you request from us, or which We feel may interest you

Consent

Sending you personalised communications based on your preferences, and use of the Glenturret’ products

Consent

To enable the Glenturret to manage any customer service interactions with you

- Legitimate interests; and

- The purposes of complying with our duties and exercising our rights under a contract for the sale of goods to a customer

To ensure that our web content is presented in the most efficient way for you and your computer

Legitimate interests

To allow you to participate in interactive features on our website, when you choose to do so

Legitimate interests

To verify your identity and your age

Complying with our legal and regulatory obligations

For crime and fraud prevention, detection and related purposes.

Legitimate interests

Where We have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute)

Complying with our legal and regulatory obligations

4 Our Legitimate interests

4.1 The normal legal basis for processing customer data, is that it is necessary for the legitimate interests of Glenturret, including:

4.1.1 selling and supplying goods to our customers;

4.1.2 protecting customers, employees and other individuals and maintaining their safety, health and welfare;

4.1.3 promoting, marketing and advertising our products;

4.1.4 understanding our customers’ behaviour, activities, preferences, and needs;

4.1.5 improving existing products and developing new products;

4.1.6 handling customer contacts, queries, complaints, or disputes; and

4.1.7 preventing, investigating and detecting crime, fraud, or anti-social behaviour and prosecuting offenders.

5 Where We collect your personal information from

5.1 We collect your personal data when:

5.1.1 you subscribe to receive details of our: product information, products launches, events, newsletters or other marketing preferences;

5.1.2 you make an online purchase or place an order online for a Glenturret product or merchandise;

5.1.3 you enter a ballot or competition related to the Glenturret or one of the Glenturret products;

5.1.4 when you attend one of our events or visit one of our sites; or

5.1.5 when you contact Glenturret, for whatever reason.

6 Who We share your information with

6.1 To effectively fulfil our obligations to you, and to provide you with certain benefits, We use a number of trusted and reliable third parties to carry out functions which involve the processing of your personal data. These include IT, delivery and marketing service providers.

6.2 We use marketing service providers to administer services on our behalf, such as sending communications to our customers, administering any promotions or ballots which We run.

6.3 We use other agencies and fulfilment partners to administer events, competitions and brand programmes that you have opted into.

6.4 Some of the third party service providers We use may be based outside of the European Economic Area, but We will only transfer personal data to these service providers where We are satisfied that adequate levels of protection and security controls are in place to protect your personal data. We impose contractual obligations on service providers relating to data protection and security which means that they can only use your personal data to provide services to the Glenturret or to you, and no other purpose.

6.5 We may provide information to others (such as governmental or law enforcement agencies) in the good faith belief that such action is necessary to: (i) enforce or apply our Terms and Conditions; (ii) comply with any legal claims raised against the Glenturret; (iii) protect the rights, property or safety of the Glenturret; or (iv) protect the rights, property or safety of the public.

6.6 If the Glenturret becomes involved in a merger, acquisition, bankruptcy, or other transaction involving the sale of some or all of our assets, user information, including personal information collected from you through your use of our Website, could be included in the transferred assets. Should such an event occur, We will use reasonable means to notify you, either through email and/or a prominent notice on the Website.

7 How long We keep your personal information

7.1 We will not retain your personal data for longer than necessary for the purposes set out in this privacy notice.

7.2 If you wish to have your data deleted or removed please submit a request to the contact address set out in paragraph 10 of this privacy notice.

8 Your rights

8.1 Access to your information

You have the right to request a copy of the personal information about you that We hold.

8.2 Correcting your information

We want to make sure that your personal information is accurate, complete and up to date and you may ask us to correct any personal information about you that you believe does not meet these standards.

8.3 Deletion of your information

8.3.1 You have the right to ask us to delete personal information about you where:

8.3.1.1 You consider that We no longer require the information for the purposes for which it was obtained

8.3.1.2 We are using that information with your consent and you have withdrawn your consent – see Withdrawing consent to using your information below

8.3.1.3 You have validly objected to our use of your personal information – see Objecting to how We may use your information below

8.3.1.4 Our use of your personal information is contrary to law or our other legal obligations.

8.4 Objecting to how We may use your information

You have the right at any time to require us to stop using your personal information for direct marketing purposes. In addition, where We use your personal information to perform tasks carried out in the public interest or pursuant to the legitimate interests of us or a third party then, if you ask us to, We will stop using that personal information unless there are overriding legitimate grounds to continue.

8.5 Restricting how We may use your information

8.5.1 In some cases, you may ask us to restrict how We use your personal information. This right might apply, for example, where We are checking the accuracy of personal information about you that We hold or assessing the validity of any objection you have made to our use of your information.

8.5.2 The right might also apply where this is no longer a basis for using your personal information but you don't want us to delete the data. Where this right to validly exercised, We may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.

8.6 Portability

If We process personal information that you provide to us on the basis of consent or because it is necessary for the performance of a contract to which you are party, and in either case that processing is carried out by automated means, then you have the right to have that personal information transmitted to you in a machine readable format. Where technically feasible, you also have the right to have that personal information transmitted directly to another controller.

8.7 Automated decisions

We do not currently undertake any automated decision making.

8.8 Withdrawing consent using your information

8.8.1 Where We use your personal information with your consent you may withdraw that consent at any time and We will stop using your personal information for the purpose(s) for which consent was given.

8.8.2 Please contact us in any of the ways set out in the Contact information and further advice section if you wish to exercise any of these rights.

9 Cookies

9.1 Cookies are small files downloaded to your computer or mobile device when you browse certain websites. Cookies contain information that is transferred to your computer’s hard drive.

9.2 Please visit www.allaboutcookies.org for more information about cookies and the way they work.

9.3 We use cookies on your device when you use our website to (a) verify you are old enough to view our site content (b) track which parts of a site you visit and which websites you came from to get to our website. All information collected by this cookie is aggregated and is therefore anonymous (c) with your consent we may place a cookie to remember your preferences so that you do not need to re-enter your details (d) provide you with a quick link to social networking sites such as Twitter and Facebook which we embed external cookies from third parties within our website, You can choose to accept or decline cookies. Most website browsers automatically accept cookies, but you can alter your browser settings to decline cookies if you prefer. This may prevent you from taking full advantage of this website.

9.4 If you would like to opt out of being tracked by Google Analytics across all websites which you view, please visit http://tools.google.com/dlpage/gaoptout

9.5 Some areas of our site use AddThis, a widely used social bookmarking service that makes it easy to share articles to social media websites like Twitter or Facebook. If you would like to opt out please visit http://www.addthis.com/privacy.

10 Changes to our privacy statement

10.1 We keep this privacy statement under regular review and will place any updates on this website.

10.2 This privacy statement was last updated on 1 March 2019.

11 Contact information and further advice

If you have any questions or concerns about the way in which your Personal Data is processed, please contact: enquiries@theglenturret.com

12 Complaints

We seek to resolve directly all complaints about how We handle personal information but you also have the right to lodge a complaint with the Information Commissioner’s Office:

Online: https://ico.org.uk/global/contact-us/email/

By phone: 0303 123 1113

By post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF