Copyright © 2022 Greenalls Au
1 IMPORTANT NOTICE
1.1 This website is operated by G&J Distillers Ltd.
1.2 All references to ‘Quintessential Brands’, ‘our’, ‘us’ or ‘we’ within this policy are deemed to refer to G&J Distillers Ltd or its subsidiaries, affiliates and/or associates (as appropriate).
1.3 We value the privacy of those who provide personal data to us. This policy applies to our customers, website visitors, consumers, our suppliers and trade customers (and potential suppliers and trade customers), any third parties that we trade or may trade with and individuals outside our organisation with whom we interact. It describes:
1.3.1 the sources of personal data
1.3.2 the categories of data that we collect;
1.3.3 how we use this data;
1.3.4 the legal basis upon which we process it;
1.3.5 with whom it is shared; and
1.3.6 how it is stored.
1.6 If you are an employee, contractor or applying to work for us, a separate privacy notice applies to you instead.
1.9 You can contact our Data Privacy Manager at [email protected].
2 THE SOURCES FROM WHICH WE OBTAIN YOUR PERSONAL DATA
We obtain your personal data from the following sources:
2.1 directly from you, either in person (at our locations or otherwise), via other forms of media such as our website, e-mail, instant message, other social media channels, by telephone or via hand held devices. This could include personal data which you provide when you:
2.1.1 place an order for our products or services (for example placing an order or booking a distillery tour);
2.1.2 create an account on our website;
2.1.3 subscribe to our publications;
2.1.4 request information on our products or services or for other marketing to be sent to you;
2.1.5 enter into a competition or promotion; and
2.1.6 complete a survey from us or give us feedback;
2.3 from third parties such as retailers where you are a customer, analytics providers, advertising networks, search information providers, providers of technical, payment and delivery services, providers of social media platforms (such as Facebook, Twitter and Instagram), data brokers or aggregators, media agencies, market research companies, our suppliers, our trade customers, group companies, public websites, agencies (including booking agents) and public agencies (including customs officials), which we refer to as “Third Party Sources” throughout this policy.
3 CATEGORIES OF PERSONAL DATA
3.1 We, or third parties on our behalf, may collect, store, share, transfer and use any of the following personal data about you and we refer to this as “personal data” throughout this policy:
3.1.1 Individual Data. This includes personal data about you or which otherwise relates to your identity, such as your name, job title, company name, e-mail address, telephone number, account information, address, gender, date of birth and age, data provided when you correspond with us, any updates to data provided to us and if you attend our sites, CCTV footage and proof of identification and address. This also includes personal data which you or our Third Party Sources may give us about you when you or they are offering or providing services to us or when they are making a trade purchase from us;
3.1.2 Sales Data. This includes personal data about the goods or services we provide to you, such as details about payments to and from you, details of subscriptions to our services or publications and other details of products and services you have purchased from us, data needed to provide goods or services to you (including data on account opening forms, details of your order, order history, payment details, delivery address including details provided for us to contact you by SMS, delivery requirements and restrictions, trade references and tax information), the name you give us for personalised products, customer services data and customer relationship management and marketing data;
3.1.3 Services Data. This includes personal data (i) about services that we receive from you or (ii) that we receive from our trade customers, including bars, wholesalers, restaurants, media contacts, transport suppliers, warehouses, fulfilment centres, technical support equipment providers and engineers, brand ambassadors, and other contractors. This also includes supplier or trade customer due diligence data;
3.1.4 Advertising Data. This includes personal data which relates to your advertising preferences, such as information about your preferences in receiving marketing materials from us and our third parties and your communication preferences as well as your personal interests;
3.1.5 Account and Profile Data. This includes personal data which relates to your account or profile on our website, such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
3.1.6 Economic and Financial Data. This includes personal data which relates to your finances, such as your payment card details and information which we collect from you for the purposes of the prevention of fraud;
3.1.7 Social Media Data. This includes personal data you provide if you choose to use social media in order to contact us or find out about our competitions, products or services, your profile data (including your preferences and interactions with us on Facebook, Twitter and Instagram) and data which you post on message boards which are relevant to our business;
3.1.8 Audio and Visual Data. This includes personal data which is gathered using our CCTV or other recording systems in the form of images, video footage and sound recordings that is taken at any of our locations or otherwise by us for promotional purposes or if you attend our events (we will also give you notice of this at the event);
3.1.9 Information Technology Data. This includes personal data you provide when you visit our social media channels including our websites where we may automatically collect any of the following data technical data, including the Internet protocol (IP) address used to connect your computer to the internet, domain name and country which requests data, the files requested, browser type and version, browser plug-in types and versions, operating system and platform, data about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), time and length of visits to certain pages, page interaction data (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and data provided when requesting further service or downloads; and
3.1.10 Public Data. This includes personal data about you in the public domain, such as if you are a journalist or work for an institution/trade association in our industry. If you are a supplier or a trade customer (or a potential supplier or trade customer) we may obtain data about you from your company’s website or other public sources.
3.2 We do not collect any special categories of data.
3.3 Please note that we need certain types of personal data so that we can provide services to you or so you, or our Third Party Sources, can provide services to us. If you do not provide us with such personal data, or if you ask us to delete it, you may no longer be able to access our goods and services or provide goods and services to us.
3.4 We may also create personal data about you, for example, if you contact us by telephone to make a complaint, for example about our services or goods, then we may make a written record of key details of the conversation so that we can take steps to address the complaint.
4 PERSONAL DATA ABOUT OTHER PEOPLE WHICH YOU PROVIDE TO US
5 USE OF DATA
We, or our Third-Party Sources acting on our behalf, collect, use and store the personal data listed above for the following reasons:
5.1 Visiting our website or using one of our other social media channels (such as Facebook, Twitter and Instagram):
5.1.1 to allow you to access and use our website (including to ensure you are of legal drinking age);
5.1.2 to provide you with the information and services that you request from us;
5.1.3 to ensure the security of our services and our website;
5.1.4 to store information about your preferences, and to allow us to customise our website according to your individual interests;
5.1.5 to recognise you when you return to our website;
5.1.6 to enable you to participate in our competitions and promotions;
5.1.7 to process orders which you place for goods or services from us; and
5.1.8 for improvement and maintenance of our website and other social media channels (such as Facebook, Twitter and Instagram), technical support and preparing reports or compiling statistics in order to improve our goods and services. Such details will be anonymised as far as is reasonably possible and you will not be identifiable from the data collected.
5.2 Receiving goods and services from you to enable us to receive and manage services from you (including supplier due diligence, payment and expense reporting and financial audits).
5.3 Providing goods and services to you and performing our contractual obligations to you, including to provide relevant goods or services to you (including, to confirm and process orders, for administration of your account with us, billing, payment and debt collection purposes);
5.4 To manage our relationship with you, including:
5.4.1 to deal with any enquiries or issues you have about your order or our goods and services, including any questions you may have about how we collect, store and use your personal data, or any requests made by you for a copy of the data we hold about you;
5.5 To allow you to attend our events or participate in competitions and to send you photos that you have permitted us to take of you;
5.6 For quality assurance;
5.7 For internal purposes such as to carry out statistical analysis and market research, use data analytics, identify usage trends, determine and measure the effectiveness of promotional campaigns and advertising and improve our website, products/services, marketing, customer relationships and experiences;
5.8 For business development and marketing purposes, to contact you (including by email or post) with information about our products and services which either you request, or which we feel will be of interest to you (including newsletters), make suggestions and recommendations to you about goods or services that may be of interest to you, deliver relevant website content and advertisements to you and to measure or understand the effectiveness of our advertising;
5.9 For internal corporate reporting, business administration / activities, ensuring adequate insurance coverage for our business, to protect our business and website, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies;
5.10 To comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so;
5.11 To establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so;
5.12 If you visit one of our sites, for CCTV monitoring and ensuring the security of our staff and visitors, and our and their property;
5.13 If you contact us on social media, to monitor your interactions with us and our brand online, for market research and for planning future marketing campaigns;
5.14 If we use your photograph or video footage from an event, to amplify the event to a broader audience and for internal presentation purposes, for marketing and business development purposes or where we have your consent;
5.15 If you are a journalist, to contact you to invite you to write a news article about our products and services; to invite you to events, send you promotional material and for press releases;
5.16 To finance, restructure, sell, make ready for sale or dispose of our business in whole or in part including to any potential buyer or their advisers; and
5.17 To investigate and defend any third-party claims or allegations.
6 LEGAL BASIS FOR USE OF YOUR PERSONAL DATA
6.1.2 our use of your personal data is necessary for complying with our legal obligations (for example, providing information to HMRC); or
6.1.3 our use of your personal data for the establishment, exercise or defence of legal claims; or
6.1.4 our use of your personal data in order to protect the vital interests of an individual e.g. where there is a medical emergency at one of our premises; or
6.1.5 our use of your personal data as is necessary or for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). An example of our legitimate interests could be to:
(a) recovery of debt;
(b) prevention of fraud;
(c) the study in how to develop our products;
(d) protecting our business and property;
(e) the development of our business strategy;
(f) conduct and develop our business;
(g) operate our website or other IT networks (and keep them secure);
(h) select appropriately skilled and qualified suppliers;
(i) ensure a safe working environment for our staff and visitors;
(j) marketing, market research and business development;
(k) provide goods and services to our customers, make and receive payment, provide customer services and to know the customer that we are providing services to;
(l) place, track and ensure fulfilment of orders with our suppliers; and
(m) for internal group administrative purposes, as described in section 8.1 below
(n) health and safety reasons.
6.2 For certain purposes it may be appropriate for us to obtain your prior consent (which can be withdrawn at any time after giving it, as described below). The legal basis of consent is only used by us in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way.
6.3 If we rely on your consent for us to use your personal data in a particular way, but you later change your mind, you may withdraw your consent by contacting us at [email protected] and we will stop doing so. However, if you withdraw your consent for us to use your personal data for a particular purpose, this may impact the ability for us to provide goods and/or services to you and we may continue to rely on other lawful bases to process your personal data for other purposes.
8 DISCLOSURE OF PERSONAL DATA
8.1 We may share your personal data with any company that is a member of our group such as for internal administrative purposes (for example, ensuring consistent and coherent delivery of services to our customers, corporate strategy, compliance, auditing and monitoring, research and development and quality assurance). We may also share your personal data with our group where they provide products and services to us, such as information technology systems.
8.2 We may share your personal data with the following categories of third parties:
8.2.2 retailers, where you are a customer;
8.2.3 public agencies (including customs officials);
8.2.4 companies that assist us in our PR, marketing, advertising and promotional activities; and
8.2.5 analytics and search engine providers that assist us in the improvement and optimisation of our website.
8.3 We will also disclose your personal data to third parties:
8.3.1 to conduct and develop our business:
8.3.2 if we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets;
8.3.3 if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
8.3.4 in order to enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity;
8.3.5 such as external professional advisors like accountants, lawyers, bankers, insurers and auditors;
8.3.6 third parties operating plugins or content (such as Facebook, Twitter and Instagram) on our website which you choose to interact with; or
8.3.7 to protect the rights, property, or safety of the group, our staff, our customers or other persons. This may include exchanging personal data with other organisations for the purposes of fraud protection and credit risk reduction.
8.4 We may also disclose and use anonymised, aggregated reporting and statistics about users of our website or our goods and services and from interactions with us and our brands on social media for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.
9 RETENTION OF PERSONAL DATA
9.1 We keep your personal data for no longer than necessary for the purposes for which the personal data is processed. The length of time we retain personal data for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights, please contact us for more details on which are set out in our data retention policy at [email protected].
10 ACCURACY OF PERSONAL DATA
10.1 It is important that the personal data we hold about you is accurate and current and we take all reasonable precautions to ensure that this is the case but we do not undertake to check or verify the accuracy of personal data provided by you. Please keep us informed if your personal data changes during your relationship with us either by logging onto your account on the website or by contacting us. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
11 YOUR RIGHTS
11.1 You have certain rights in relation to your personal data. If you would like further information in relation to these or would like to exercise any of them, please contact us by email at [email protected] at any time.
11.2 You may have a number of rights in connection with the processing of your personal data, for example you may have the right to request that we:
11.2.1 provide access to any personal data we hold about you;
11.2.2 update any of your personal data which is out of date or incorrect;
11.2.3 delete any personal data which we are holding about you;
11.2.4 restrict the way that we process your personal data;
11.2.5 prevent the processing of your personal data for direct-marketing purposes;
11.2.6 provide, or not provide, your personal data to a third party provider of services;
11.2.7 provide you with a copy of any personal data which we hold about you; or
11.2.8 consider any valid objections which you have to our use of your personal data.
11.3 You may also have the right to lodge complaints regarding the processing of your personal data with the Information Commissioner’s Office or other relevant supervisory body. Please see https://ico.org.uk/concerns/ for how to do this.
11.4 We will consider all such requests and provide our response within a reasonable period (and in any event any time period required by applicable law). Please note, however, that certain personal data may be exempt from such requests in certain circumstances.
11.5 If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
12.1 We may collect and use your personal data for undertaking marketing by email, software app, telephone and post.
12.2 We may send you certain marketing communications (including electronic marketing communications to existing customers) for marketing and business development purposes.
12.3 If you wish to stop receiving marketing communications, you can contact us by email at [email protected] at any time.
13 TRANSFERS OF PERSONAL DATA
13.1 The personal data may be transferred, used, stored and/or accessed outside the UK or EEA.
13.2 This may be for the purposes listed in section 5 above, the provision of our services to you, the receipt of services from you or any of our Third Party Sources, the process of transactions and/or the provision of support services. Further details on to whom your personal data may be disclosed are set out in section 8 above.
13.3 In connection with such transfers, we will take appropriate measures to ensure that the recipient protects your personal data adequately in accordance with data protection law. These measures include, but are not limited to:
13.3.1 there are appropriate safeguards in place such as binding corporate rules or approved contractual clauses. A copy of the appropriate safeguard can be obtained by contacting us using the contact details set out above; or
13.3.2 the transfer is to a country that provides an adequate level of protection such as to a country approved by the relevant supervisory body or authority; or
13.3.3 a derogation for specific situations, applies to the transfer including by way of example explicit consent or necessary for the performance of a contract or exercise or defence of legal claims.
14.1 There may be sections of this website which can only be accessed by users who we have given a password.
14.2 If we do provide you with a user name and password, it is your responsibility to ensure that these details are kept confidential at all times and you must not disclose your password to any third party.
14.3 In the event that a third party gains access to your user name or password, you should notify us immediately by emailing [email protected]. We are not liable for any loss resulting from your failure to protect the confidentiality of your user name or password.
15.1 In the course of provision of submitting your order to us, your personal data may be transferred over the internet. Although we make every effort to protect the personal data which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal data transmitted to our website and that any such transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to prevent unauthorised access to it.
16 THIRD PARTY WEBSITES
18 FURTHER QUESTIONS OR MAKING A COMPLAINT
18.1 If you have any queries or complaints about our collection, use or storage of your personal data, or if you wish to exercise any of your rights in relation to your personal data, please contact [email protected]. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal data.
18.2 You may also make a complaint to the relevant data protection authority which in the UK is the Information Commissioner’s Office. If you are unsure which data protection authority to contact, please contact [email protected]. In addition, you may seek a remedy through local courts if you believe your rights have been breached.
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