Privacy Notice

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.

Who do we share your personal information with for this purpose?

We will share your personal information with the following categories of third parties:

To provide our Site – third party web hosting companies;

To verify card payments and process refunds – credit card companies and other payment providers;

To order and deliver products – online shopping via Shopify, logistics and delivery companies;

What is our legal basis?

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.

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.

Who do we share your personal information with for this purpose?

We will share your personal information with the following categories of third parties:

• To provide our Site and App – third party web hosting companies;
• To verify card payments and process refunds – credit card companies and other payment providers;
• To deliver products – delivery and fulfilment companies;
• To deliver the App – third party app stores

What is our legal basis?

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 Notice. You should therefore take particular care to review this section of our Privacy Notice, 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.

Who do we share your personal information with for this purpose?

Your personal information will be shared with our email service partner.

What is our legal basis?

Your explicit consent.

Our Site and App use 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.

Who do we share your personal information with for this purpose?

We do not share your personal information for this purpose.

What is our legal basis?

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.

Who do we share your personal information with for these purposes?

We use a third party service provider to assist us with research and feedback surveys.

What is our legal basis?

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 and App or when downloading or using our App and Tools such as the IP address, operating system and browser type of your device. The personal information that we observe may be collected by us and our partners using Cookies, which collect information from the device and software you use. For further information, please see the Our use of Cookies section below for further information.

The personal information that we collect for this purpose may include the following:

• an IP address and session ID to monitor Site and App traffic and volume, to track usage statistics, and to measure the effectiveness of our content and how visitors use our Sites, our App and our Services, so that we can understand which parts of our Sites are the most interesting and what kind of content our users like to see and to help us with the development of future product and service lines, the design of the shop and our Site and App.
• information regarding your personal or professional interests, demographics, location, buying habits, experiences with our products and contact preferences, which we use to create profiles to personalise your Drinkaware experience, including the marketing that you may receive from us, ad to personalise online advertising that we deliver to you. See the Advertising and Marketing section below for further information.

In addition, we may collect personal information through our emails, to track receipt of an e-mail to you, to count users that have visited our Site from an email or opened an e-mail, and to collect other types of aggregate information for analytics purposes. When you open an e-mail from us, your contact information may subsequently be cross-referenced to the source e-mail. Some of our e-mails may also use a “click-through URL” linked to our Site. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

Who do we share your personal information with for this purpose?

We share your personal information with a variety of third party service providers to assist us with the above purposes.

What is our legal basis?

Where your personal information is collected through the use of non-essential Cookies, we rely on consent to collect your personal information and for the onward processing purpose. Please see the Our use of Cookies section below for further details. Where data is not collected through the use of non-essential Cookies, it is in our legitimate interest to use your personal information in this way, so that we can:

• improve our Site, our App and our Services
• measure the effectiveness of our advertising activities; and
• personalise the experience that we provide to our visitors and customers, including for the advertising and marketing activities described below.

We carry out the following advertising and marketing activities using your personal information:

Email marketing

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.

Who do we share your personal information with for this purpose?

We share your personal information with a third party email marketing provider who assists us in delivering our email marketing campaigns to you.

What is our legal basis?

It is in our legitimate interest to use your personal information for marketing purposes, for example to decide what marketing content we think may appeal to you.

It is in our legitimate interest to use your personal information to send our marketing to you by post.

We will only send marketing communications to you by email and/or SMS where you have consented to receive such content by email and/or SMS, or where we have another lawful right to send marketing to you using email and/or SMS. For example, in certain circumstances we may rely on our legitimate interest to send marketing by email and/or SMS to consumers who have purchased our Services. We may also rely on our legitimate interest to send marketing by email and/or SMS to certain business users of our Sites and our Services.

In addition, please see the User insight and, analysis and personalisation above to learn about the lawful basis that we rely on to personalise the marketing that we send to you.

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.

Online personalised advertising

We use information that we observe about you to provide you with personalised ads when you use other websites and online services. By “personalised ads”, we mean advertisements for products and services that you have shown an interest in when you have used our Site or our App or which we or our third party advertising partners think you otherwise might be interested in.

See the User insight, analysis and personalisation section for more information about the personal information that we use for this purpose.

Who do we share your personal information with for this purpose?

We share your personal information with a variety of third party advertising partners who assist us with our online personalised advertising campaigns. For more information about these advertising partners please do so via the Cookie Preference Centre link at the footer of our website.

What is our legal basis?

See the User insight, analysis and personalisation section to learn about the legal basis that we rely on to collect data via the use of Cookies.

Where we use your personal data to display online advertising to you, we rely on the consent that you have provided in respect of the collection of such data, or it is otherwise in our legitimate interests to promote our Site, our App and our Products and Services to you.

Our third-party advertising partners may rely on a different lawful basis in respect of their use of your personal data. Please read the privacy information provided by our advertising partners, which can be found in our cookie preference centre in the link at the footer of our website.

Advertising to you on social media

We share (usually in an encrypted or “hashed” form) certain contact data and identifiers (such as advertising identifiers associated with your device or browser). We do this so that Facebook can try to “match” your hashed data with the hashed data relating to its registered users.

Where there is a successful match of your hashed contact data (e.g. because you are our customer and/or a user of our Site and are also a registered Facebook user), our advertising will be displayed to you when you use Facebook. This is known as “custom audience” advertising, because we “customise” the audience that we want to reach on Facebook.

Some of the advertising that you see may be personalised to you using information that we observe about you through your use of the Site and App, which we share with Facebook. See the User insight, analysis and personalisation section for more information about the personal information that we use to do this.

This activity is also subject to the privacy choices you have elected to make on Facebook. In some cases we may be joint controllers with Facebook in respect of this activity – please see the Joint Controller activities section below for further information.

Who do we share your personal information with for this purpose?

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.

What is our legal basis?

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 preference centre 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.

Social media insight

In addition to advertising to you on social media (see above), we may ask Facebook to find other registered users of their services that share similar interests to you based on:

• the information that we provide to Facebook to advertise to you (see above) and the information that we observe about you (see the User insight, analysis and personalisation section above for more information); and
• the information Facebook hold about you.

This is known as “lookalike” audience advertising because we are trying to show our advertising to people who “look like” our customers and/or users. Please note that such activity is subject to the privacy choices you have elected to make on Facebook.

Who do we share your personal information with for these purposes?

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.

What is our legal basis?

Please see the Advertising to you on social media section above for details of the lawful basis that we rely on to share your personal information with Facebook.

It is in our legitimate interests to further use your personal information to advertise our Site, App and Services to other individuals who use Facebook and who share similar interests and characteristics with you.

If you are someone who has seen this advertising on Facebook, it is in our legitimate interests that Facebook uses the data that you have provided to it to advertise our Site, App and Services, although please note that we do not receive this data and you should exercise your rights in respect of such data in accordance with Facebook’s privacy notice.

Business administration and legal compliance

We use your personal information for the following business administration and legal compliance purposes:

• to comply with our legal obligations;
• to enforce our legal rights;
• protect rights of third parties; and
• in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

Who do we share your personal information with for these purposes?

We will share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.

What is our legal basis?

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.

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:

• relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
• processing your personal information for direct marketing.

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.