Privacy
1. GENERAL INFORMATION
This privacy notice sets out the ways in which Inchcolm Distillery Limited, company number SC709603, (Inchcolm) collects, processes and shares your personal data.
2. WHAT INFORMATION IS COLLECTED THROUGH OUR WEBSITE
Inchcolm may collect, process and use the following information you provide when you are on our website, during the online order process and when you sign up for our newsletter online:
• name;
• address;
• email address;
• telephone number;
• IP address;
• your payment card information;
• browsing data, including pages you look at on our website, your URL and your IP address;
• your date of birth; and
• your purchase and website viewing history.
3. WHAT IS YOUR DATA USED FOR
Inchcolm processes your personal data in the following ways, and on the following legal bases:
• Your name and email address for the purposes of sending you our newsletter and marketing materials. Inchcolm will only do this if you have given your consent, or if you have purchased similar goods or services and have not chosen to opt-out. You may opt-out of the newsletter or marketing materials at any time by contacting chris@inchcolmdistillery.com or by changing your preferences.
• To carry out Inchcolm’s obligations arising from any contracts entered into between Inchcolm and you, for example to create and operate an Inchcolm account, to process and deliver any orders you place (including payment), and to confirm and keep you up to date with such orders. It does this on the basis that it is necessary in order to perform its contract with you.
• To keep a full record of owners of casks and to contact you about your cask. It does this on the basis that it is necessary in order to perform its contract with you.
• To enhance your experience of the Inchcolm website. It does this as it is in its legitimate interest to ensure that you receive the best experience possible when you shop with Inchcolm.
• To respond to your queries, including any queries about Inchcolm’s products.
• Any other purposes where Inchcolm has obtained your consent to do so.
Inchcolm may use your information in an anonymised and/or aggregated manner in order to analyse the data so that it can enhance its IT systems or website and carry out research. Inchcolm may share this anonymised and/or aggregated data with third parties, but you will not be identifiable from any such data.
4. DISCLOSING INFORMATION TO 3RD PARTIES
Inchcolm does not sell, trade, or otherwise transfer your personal identifiable information to outside parties other than as set out in this privacy notice.
Inchcolm provides your personal data:
• to selected third party providers in order to process and deliver your orders, for example delivery companies and payment providers;
• to selected marketing agencies, web-mailing companies and hosting companies who assist with the development and running of the website;
• to a third party bookkeeping company for the purpose of creating an invoice after you have ordered a cask or product;
• to other companies in the same group of companies as Inchcolm. These companies will only use your personal data in the same way as Inchcolm can under this privacy policy; and
• credit reference agencies or fraud prevention agencies.
Inchcolm occasionally may transfer your personal data outside of the European Economic Area (EEA) where is uses external third parties who are based outside the EEA. Whenever Inchcolm transfers your personal data out of the EEA, it ensures a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• it is only transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
• the third party enters into a specific contract which has been approved by the European Commission which gives personal data the same protection it has in Europe; or
• where the personal data is transferred to the US, the US third party is certified under the Privacy Shield, which requires the third party to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Inchcolm will disclose your personal data to third parties:
• if Inchcolm sells or buys any business or assets, in which case Inchcolm will disclose your personal data to the prospective seller or buyer of such business or asset;
• if Inchcolm or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or
• if Inchcolm is under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of Inchcolm, you or any third party, and to investigate illegal activities and breaches of any agreement Inchcolm has with you. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Inchcolm may pass your personal data to third parties in a statistical and/or aggregated manner in order to analyse the data, Inchcolm will always ensure that you are not identifiable in any such data.
5. PROTECTING YOUR PERSONAL DATA
Inchcolm has 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, it limits access to your personal data to those employees, agents, contractors and other third parties who have a business need to know and in accordance with this privacy notice. They will only process your personal data in accordance with Inchcolm’s instructions. Inchcolm has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where it is legally required to do so.
6. HOLDING YOUR PERSONAL DATA
Inchcolm will retain your data in accordance with its data retention policy. It may also retain your data for further periods where it needs to do so in order comply with any legal or regulatory requirements (including keeping certain records for seven years for VAT purposes), to carry out audits, to detect and prevent fraud, to enforce contracts or to resolve any disputes.
To determine the appropriate retention periods set out in its data retention policy, Inchcolm considers 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 Inchcolm processes your personal data and whether those purposes can be achieved through other means, and the applicable legal requirements.
7. YOUR RIGHTS
Where Inchcolm relies on consent as the condition for processing your personal data, for example for sending you electronic direct marketing, you have the right to withdraw that consent at any time.
You have various statutory rights in relation to your personal data. In particular, you have the right to:
• object to direct marketing communications at any time;
• request and obtain access to your personal data;
• rectification or erasure of your personal data, in certain circumstances;
• object to or restrict the processing of your personal data in certain circumstances;
• have your personal data stored in a manner in which it is portable from the environment in which it is stored by Inchcolm to another environment; and
• file a complaint with the Information Commissioner’s Office.
8. COOKIES
The Inchcolm website uses cookies. A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns.
Inchcolm uses cookies to help identify and track visitors, provide anonymised tracking data to third party applications like Google Analytics and store information for things like shopping baskets. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others.
9. CHANGES TO PRIVACY NOTICE
If Inchcolm decides to change this privacy notice, any changes will be posted on this page.
This privacy notice was last modified on 3 September 2018.
10. CONTACT
If you wish to contact Inchcolm in relation to this privacy notice, including in relation to any of the rights set out in section 8 above, please contact us at chris@inchcolmdistillery.com.