The Drinkaware Trust (“Drinkaware”, “we”, “us” or “our”) respects the privacy of every person who visits or registers with Drinkaware.co.uk (the “Site”), the users of our “My Drinkaware” mobile application (the “App”) and their use of the products, tools and services that we make available from the Site (our “Services”) and we are committed to ensuring a safe online and mobile experience.
This Privacy Policy (“Privacy Policy”) explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Policy also sets out your rights in respect of our processing of your personal information. For more information click below.
This Privacy Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer it and/or provide you with access to it.
This Privacy Policy is intended to assist you in making informed decisions when using the Site, the App and our Services. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Terms of Use.
Please also note that this Privacy Policy only applies to the use of your personal information obtained by us, it does not apply to the use of your personal information collected during your communications with third parties.
The Site, the App and the Services are provided by The Drinkaware Trust. For more information click below.
The Drinkaware Trust is the data controller responsible for your personal information and is registered at the UK Information Commissioner’s Office with registration number: Z9912649
The Drinkaware Trust is an English company limited by guarantee and registered in England and Wales with number 4547974 and with registered address Salisbury House Upper Ground Floor (Room 264), London Wall, London, England EC2M 5QQ. Our Registered Charity Numbers are 1094586 and SC043163.
If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact us by sending an e-mail to contact@drinkaware.co.uk or by post to:
FAO: The Data Protection Officer
The Drinkaware Trust
Salisbury House, Upper Ground Floor (Room 264)
London Wall, London England EC2M 5QQ
Our primary goal in collecting personal information from you is to: (i) verify your identity; (ii) help us improve our products and services and develop and market new products and services; (iii) carry out requests and orders made by you on the Site; (iv) carry out your requests when using our App; (v) investigate or settle inquiries or disputes; (vi) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vii) enforce our agreements with you; (viii) protect the rights, property or safety of us or third parties, including other users of the Site and App; (ix) provide support for the provision of our Services; and (x) use as otherwise required or permitted by law.
In particular, we collect and use your personal information for the following purposes:
We collect and maintain personal information that you voluntarily submit to us during your registration or when requesting our Services such as your name, email address, date of birth, sex, gender, postcode and if you are using our online shop, your address and payment card details.
We use the contact and payment details you have provided to us so that we can fulfil the services you have requested from our Site and/or our App. In particular, we use the contact and payment details you have provided to us where applicable so that we can fulfil the supply of products and services you have requested from our Site.
You can also volunteer to provide us with additional personal information when using some of the tools available on the Site, such as information about your drinking habits or your achievements or motivations.
We will share your personal information with the following categories of third parties:
It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you.
We only collect and use your location where we have your consent to do so.
This section applies to our privacy practices when you use the Tools, which vary from the privacy practices described in the rest of our Privacy Policy. You should therefore take particular care to review this section of our Privacy Policy, so that you understand how we use personal information that you upload via either Tool. For more information below.
The Tools allow you to input your age, sex, postcode and information about your drinking habits. The Drink Compare Calculator provides you with a comparative result against other drinkers of the same gender and similar age.
Where you have given your consent for us to do so when signing up to use the Tools, we will send you an email setting out facts and guidance based on the personal information you have provided about your drinking habits. We will then use beacons and other tracking technologies that monitor your interaction with the email sent to you. If you use the DrinkCompare Tool and where you have given your consent for us to do so we will send you regular emails that help you to monitor your drinking habits.
Your personal information will be shared with our email service partner.
Your explicit consent.
Our Site uses various user interfaces to allow you to request information about our Services: these include printed and electronic enquiry forms and a telephone enquiry service. Contact information may be requested in each case, together with details of other personal information that is relevant to your enquiry. This information is used in order to enable us to respond to your requests.
We do not share your personal information for this purpose.
It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can to you.
From time to we will invite you to participate in research and feedback about our products and Services to help us improve what we offer to our users.
We use a third party service provider to assist us with research and feedback surveys.
It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.
We analyse your contact details with other personal information that we observe about you from your interactions with our Site or when downloading or using our App and Tools such as the IP address, operating system and browser type of your device.
Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile. This includes the following:
Our web pages and e-mails contain “cookies” "web beacons" or “pixel tags.” (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag.
In some of our e-mail messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.
Please see our Cookie Notice further information.
This information is used to create profiles and insights about your interaction with the website and the interactions of our other customers. Where we have your consent to do so, we will also use your location data for customer insight purposes.
By using this information, we are able to measure the effectiveness of our content and how visitors use our Sites and our Services. This allows us to learn what pages of our Sites are most useful to our visitors, which parts of our Sites are the most interesting and what kind of content our users like to see.
We also use this information to help us with the development of future product and service lines, the design of the shop and the website.
We also use this information for marketing purposes (see the marketing section below for further details).
We share your personal information with a variety of third party service providers to assist us with user insight analytics.
Where your personal information is completely anonymised, we do not require a legal basis to use it under data protection laws as the information will no longer constitute personal information that is regulated under such laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best services to you and our other customers and users.
We carry out the following marketing activities using your personal information:
We use information that we observe about you from your interactions with our Site, our email communications to you and/or with our services (see the User Insight and Analysis section above for more details of the information collected and how it is collected) and/or your email address, to send you marketing communications by email, where you have consented to receive such marketing communications, or where we have another lawful basis to do so.
We share your personal information with a third party email marketing provider who assists us in delivering our email marketing campaigns to you.
Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Notice for further details.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.
We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.
We use information that we observe about you from your interactions with our Site, our email communications to you (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) to provide you with personalised online advertising.
We share your personal information with a variety of third party service providers who assist us with our online personalised advertising campaigns. These providers are described in our Cookie Notice.
Where your personal information is completely anonymised, we do not require a legal basis to use it under data protection laws as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Notice for further details.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.
We use information that we observe about you from your interactions with our Site, our email communications to you and/or with our products and services (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) to provide you with personalised advertising on Facebook where you are a registered user of such service.
We do this using Facebook Custom Audiences. Please note that such activity is also subject to the privacy choices you have elected to make on Facebook.
We share your email address with third party service providers who assist us with social media remarketing campaigns.
Your encrypted email address is also shared by us, or our third party service providers, with Facebook with this purpose.
Where your personal information is completely anonymised, we do not require a legal basis to use it under data protection laws as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Notice for further details.
Where your personal information is not in an anonymous form, it is in our legitimate interest to analyse your personal information for marketing purposes.
We will only engage in social media remarketing where you have consented to us sending you marketing communications.
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:
We do this using Facebook Lookalike Audiences. Please note that such activity is subject to the privacy choices you have elected to make on Facebook.
We share your email address with third party service providers who assist us with social media remarketing campaigns.
Your encrypted email address is also shared by us or our third party marketing consultancies with Facebook.
Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Notice for further details.
Where your personal information is not in an anonymous form, it is in our legitimate interest to analyse your personal information for marketing purposes.
We use your personal information for the following business administration and legal compliance purposes:
We will share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.
Where we use your personal information in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.
Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details.
Where our use of your personal information requires your consent, you can provide such consent:
Our Sites use certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Notice to find out more about the cookies we use and how to manage and delete cookies.
Our Site contains links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this Privacy and Cookie Notice no longer applies. For more information below.
Your browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.
We do not monitor, control, or endorse the privacy practices of any third parties.
We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.
This Privacy Notice applies solely to personal information collected by us through the Site, our App or when you use our Services and does not apply to these third party websites and third party service providers.
We keep your personal information for a variety of periods depending on the purposes for which we process your personal information. See below for more details
If your information is only useful for a short period e.g. for specific marketing campaigns we may delete it.
We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. For more information click below.
We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.
You have the following rights in relation to the personal information we hold about you:
If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
You can ask us to stop processing your personal information, and we will do so, if we are:
You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
We may make changes to this Privacy Notice from time to time. For more information click below.
To ensure that you are always aware of how we use your personal information we will update this Privacy Notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal information.
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Data Type |
Retention Policy |
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Users of the Drinkaware app or other apps that may be created in future |
Drinkaware will retain the users’ data until they close their account or until the user has been inactive for 12 months. |
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Subscribers to Drinkaware consumer newsletters, such as the ‘Drink Free Days’ campaign newsletter |
Newsletters are a regular communication and Drinkaware will retain user data until the user chooses to unsubscribe. Or fails to re-consent at 2.5 years recency. |
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Customers of Drinkaware’s online shop |
Under HRMC and VAT regulations, Drinkaware is required to retain information about financial transactions for seven years.
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Consumers receiving marketing |
If a consumer has consented to marketing emails, Drinkaware will send them relevant and timely emails until they unsubscribe or don’t re-consent at 2.5 years. Drinkaware will keep a record that such users should not receive marketing. |
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People who have participated in Drinkaware research |
Any individual agreeing to participate in Drinkaware research has a number of options: · To participate in a prize draw – personal data will be held until the draw takes place and then deleted · Agree to participate in future research - their email address will be retained for this purpose only until they unsubscribe. (Any other active relationship they may have will continue until they indicate otherwise.) |
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People who are a ‘business’ partner of Drinkaware |
Information about Drinkaware’s ‘business partners’ will be retained indefinitely. When an individual (account manager or key contact) leaves the employment of the business partner, Drinkware will delete their contact details and any information relating to them but retain all pertinent business data. If a business-to-business contact requests an unsubscribe or chooses to opt-out of Drinkaware communications, their personal contact data will be suppressed. |
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Individuals who have made, or have been, the subject of a complaint to Drinkaware under the Complaints Policy. |
This information will be retained indefinitely as it is held on the organisational suppression file. |