Privacy Policy

Drinkaware are committed to protecting the privacy of our users. This privacy policy is intended to inform you how we gather, define, and utilise your Information.

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 “Track and Calculate Units” mobile application (the “App”) and their use of the services, products and tools that we make available from the Site and our App (our “Services”) and we are committed to ensuring a safe online and mobile experience.

1) Purpose of this policy

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. 

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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 and Conditions.

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.

2) Who are we and what do we do?

The Site, the App and the Services are provided by The Drinkaware Trust.

 

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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 3rd Floor (Room 519), London Wall, London, England EC2M 5QQ. Our Registered Charity Numbers are 1094586 and SC043163. 

3) How to contact us?

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 3rd Floor (Room 519)

London Wall, London England EC2M 5QQ

4) What personal information do we collect and how do we use it?

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, including collecting information about your location if you select certain functionality within the 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:

Fulfillment of our Services - on the Site and when using our App.

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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, age, gender, phone number, 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 about you when using some of the tools available on the Site, such as information about your drinking habits or your achievements or motivations.

“Weak Spot” Function in our App - Where you have chosen to use the ‘Weak Spot’ functionality in the App, we may collect data relating to the location of your device. The ‘Weak Spot’ functionality allows you to share with us specific locations where you drink. We will then send drinking related reminders to your device if we identify that you are near such locations.

If you do not want to share with us the location of your device for this purpose, do not enter a ‘Weak Spot’.

You may turn off the location settings on your device at any time by accessing the “Privacy” or “Permissions” section of the “Settings” of your Apple or Android device and by deactivating “Location Services” or “Location”. 

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 deliver products – delivery 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.

The DrinkCompare Calculator and MyDrinkaware Tools (the “Tools”)

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.

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The Tools allow you to input your age, gender and information on your drinking habits. The tool then 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.

Service enquiries

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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.

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.

Research and Feedback

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From time to time 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.

User insight and analysis

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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:

  • an IP address to monitor Site traffic and volume;
  • a session ID to track usage statistics on our Site;
  • information regarding your personal or professional interests, demographics, buying habits, experiences with our products and contact preferences.

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 policy for further information.

This information is used to create profiles and insights about your use of our Site and Services. Where we have your consent to do so, we will also use your location data for 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 attractive to our visitors, which parts of our Sites are the most interesting and what kind of content our registered users like to see.

We also use this information to help us with the selection of future product and service lines, store and websites design.

We also use this information for marketing purposes (see the marketing section below for further details).

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 User insight analytics.

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 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.

Marketing communications

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

Email marketing

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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?

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 Policy 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.

Online personalised advertising

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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.

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

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 Policy.

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 Policy 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.

 

 

Social media remarketing

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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.

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 Policy 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

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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:

  • 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); and
  • the information Facebook hold about you.

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.

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?

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 Policy 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.

Business administration and legal compliance

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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.

5) How do we obtain consent?

Where our use of your personal information requires your consent, you can provide such consent:

  • at the time we collect your personal information following the instructions provided; or
  • by informing us by e-mail, post or phone using the contact details set out in this Privacy Policy.

 

6) Our use of cookies and similar technologies

Our Sites use certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.

7) Third party links and services

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 Policy no longer applies.

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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 Policy 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.

8) Confidentiality and security of your personal information

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.

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We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

  • unauthorised access;
  • improper use or disclosure;
  • unauthorised modification; and
  • unlawful destruction or accidental loss.

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.

9) How to access your information and your other data rights?

You have the following rights in relation to the personal information we hold about you:

Your right of access

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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.

Your right to rectification

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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.

Your right to erasure

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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.

Your right to restrict processing

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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.

Your right to data portability

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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.

Your right to object

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.

Your rights in relation to automated decision-making and profiling

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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.

Your right to withdraw consent

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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.

Your right to lodge a complaint with the supervisory authority

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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.

10) Changes to this Privacy

We may make changes to this Privacy and Cookie Policy from time to time.

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To ensure that you are always aware of how we use your personal information we will update this Privacy Policy 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 Policy periodically to be informed of how we use your personal information.

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