PRIVACY POLICY

 

This is the privacy notice for Perthyn Spirits Limited and its trading style ‘Perthyn Spirits’.

Perthyn Spirits 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) or use any of our services that link to this privacy notice, and tell you about your privacy rights and how the law protects you.

This policy is set out as follows:

1.         Important Information and who we are
2.         The personal data we collect about you
3.         How is your personal data collected
4.         How we use your personal data
5.         Disclosures of your personal data
6.         International Transfers
7.         Data Security
8.         Data Retention
9.         Your Legal Rights
10.   Glossary

1: IMPORTANT INFORMATION AND WHO WE ARE

Who We Are
Perthyn Spirits Limited (Collectively referred to as “Perthyn”, “we”, “us” or “our” in the privacy notice) is a company which is incorporated in England & Wales with the number 13762921 and is registered under the Data Protection Act (ZB307600).

If you have any questions about this privacy notice, including any requests to exercise your rights under the Data Protection Act please contact us using the details set below.

Contact Details
Data Protection
Perthyn Spirits Limited
Unit B6 Penarth Road
Cardiff
CF11 8JQ 

Email address: Dataprotection@perthynspirits.com

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  
Our Privacy Policy is updated from time to time. We may email you if there are any major changes otherwise it is your responsibility to check here for changes.

This privacy notice was last updated on the 1 March 2022.

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  
Our 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 that does not identify you (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together in the categories shown below in bold, examples of data in each category are also shown, actual data collected may differ from the examples. This is information that you give to us by filling in forms on our website, using our app, or by corresponding with us by post, phone, email or otherwise:

  • Identity Data such as, title, first name, last name, date of birth, and gender.

  • Contact Data such as, address, email address and telephone numbers.

  • Transaction Data such as, details about payments to and from you and other details of products and services you have purchased from us.

  • Profile Data such as, your username and password, purchases or orders made by you, your interests, preferences, feedback, referral source and survey responses.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Data that we collect about you 

  • Technical Data from your interaction with our website such as, 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, application data and other technology on the devices you use to access this website or the app.

  • Usage Data includes information about how you use our website, products and services.

  • Call Recordings Records of your conversations with us (some calls are recorded).

Data we receive about you from 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 analytics & tracking providers some, such as Google are based outside the EEA (see our Cookies Policy for more information);

  • Identity Data, Contact Data, from third parties and other companies who contract with Perthyn in relation to its business.

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 policy.

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 support and appropriate information). In this case, we may have to cancel your contract, 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 and Contact Information and agreement to our Terms by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you

  • Access our website and/or online booking form

  • Request information to be sent to you;

  • 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.

  • 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 & tracking providers some such as Google based outside the EU;

- Google Tag Manager
-  Google Analytics
-  WordPress
-  YouTube
-  Hotjar

  • Third parties and other companies who contract with Perthyn from time to time.

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.

  • To process your data on behalf of a data controller your data may or may not be anonymised.

  • 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 setting cookies and sending third party direct marketing communications to you via email or text message. We may also rely on your explicit consent where we want to process special categories of data, where you choose to provide it to us in the context of our services. 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. Please 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: To manage orders you make with us.
Type of data: Identity.
Lawful basis for processing including basis of legitimate interest (depending on the circumstances in which we process your personal data): (a) Performance of a contract with you. (b) Necessary for our legitimate interests (to perform Covid tests on behalf our clients).

Purpose/Activity: To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy. (b) Asking you to leave a review or take a survey.
Type of data: Identity, Contact, Address, Profile, Marketing and Communication.
Lawful basis for processing including basis of legitimate interest (depending on the circumstances in which we process your personal data): (a) Performance of a contract with you. (b) Necessary to comply with a legal obligation. (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).

Purpose/Activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
Type of data: Identity, Contact, Technical.
Lawful basis for processing including basis of legitimate interest (depending on the circumstances in which we process your personal data): (a) 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). (b) Necessary to comply with a legal obligation.

Purpose/Activity: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
Type of data: Identity, Contact, Profile, Usage, Marketing and Communications, Technical.
Lawful basis for processing including basis of legitimate interest (depending on the circumstances in which we process your personal data): Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).

Purpose/Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
Type of data: Technical, usage.
Lawful basis for processing including basis of legitimate interest (depending on the circumstances in which we process your personal data): 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).

Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you.
Type of data: Identity, Contact, Technical, Usage, Profile.
Lawful basis for processing including basis of legitimate interest (depending on the circumstances in which we process your personal data): Necessary for our legitimate interests (to develop our products/services and grow our business).

Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you.
Type of data: Identity, Contact, Technical, Usage, Profile.
Lawful basis for processing including basis of legitimate interest (depending on the circumstances in which we process your personal data): Necessary for our legitimate interests (to develop our products/services and grow our business).

Purpose/Activity: To engage in research and development.
Type of data: Identity, Contact, Other Necessary data, Usage Data.
Lawful basis for processing including basis of legitimate interest (depending on the circumstances in which we process your personal data): Necessary for our legitimate interests.

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 in relation to our products and services (including our testing, wellness and therapeutic services) if you have requested information from us or purchased services from us 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 company outside the Perthyn group for marketing purposes.

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 product/service purchase or other transactions.

COOKIES  
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. View our full cookie policy for full details

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

Some of our external third parties who we use in our processes may process your information outside the UK and/or the EEA, to ensure your data is protected to an adequate level we will ensure that appropriate safeguards and security measures are in place for that transfer and storage as required by applicable law and we will have implemented at least one of the following:

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

We intend to maintain 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.

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.

By law we have to keep basic information about our customers including Contact, Identity, Financial and Transaction Data for six years after they cease being customers for tax purposes, unless a data audit dictates otherwise.

In some circumstances you can ask us to delete your data: see [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. Please click on the links below to find out more about these rights:

  • [Request access to your personal data].

  • [Request correction of your personal data].

  • [Request erasure of your personal data].

  • [Object to processing of your personal data].

  • [Request restriction of processing your personal data].

  • [Request transfer of your personal data].

  • [Right to withdraw consent].

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 (where relevant)

INTERNAL THIRD PARTIES  
Other companies in the Perthyn Group from time to time acting as joint controllers or processors and who are based in the UK and provide administration, back-office, marketing and communication services and undertake leadership reporting.

EXTERNAL THIRD PARTIES  

  • Service providers acting as processors who provide IT and system administration services including email distribution, Payment gateways, Feedback and service references, and management services to scheduling management, customer services and accreditations

  • Parties who passed your details to us or recommended us (use of service only)

  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom 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.

  • Partners who we work with to provide you with our products and services

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.