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Spirit of Bannockburn
Last Updated: 12/5/21
Comply with legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
This policy aims to give you information on how the business collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or rent a product or service or purchase a product or service or take part in a competition.
Please read this policy carefully. If you do not agree with the terms of this policy, please do not access the Site.
CHANGES TO THIS POLICY
We reserve the right to make changes to this policy at any time and for any reason. Any changes or modifications will be effective immediately upon posting the updated policy on the Site.
You are encouraged to periodically review this policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised policy by your continued use of the Site after the date such revised policy is posted.
WHAT INFORMATION WE COLLECT
We may collect information about you in a variety of ways. The information we may collect on the Site includes:
Personally identifiable information, such as your name, shipping address, email address, and telephone number, and demographic information, such as your age, gender, address, and interests, that you voluntarily give to us when you make an account with the Site, or when you choose to participate in various activities related to the Site, such as online chat, forms, surveys and placing an order. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Site.
Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site.
Mobile device data
Device information, such as your mobile device ID, model, and manufacturer, and information about the location of your device, if you access the Site from a mobile device.
Data from competitions, giveaways, and surveys
Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.
Special categories of personal data
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA IS COLLECTED
We use different methods to collect data from and about you including through:
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Automated technologies or interactions
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources as set out below:
USE OF YOUR INFORMATION
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you
To process and deliver our service to you including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURE OF YOUR INFORMATION
We may share information we have collected about you in certain situations. Your information may be disclosed as follows:
By Law or to Protect Rights
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.
Third-Party Service Providers
We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.
With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by the General Data Protection Regulations (GDPR) and applicable electronic marketing regulations.
When you post comments, contributions, reviews or other content to the Site, your posts may be viewed by all users and may be publicly distributed outside the Site in perpetuity.
We may use third-party advertising companies to serve ads when you visit the Site. These companies may use information about your visits to the Site and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.
We may share your information with our affiliates, in which case we will require those affiliates to honor this policy. Affiliates include any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
We may share your information with our business partners to offer you certain products, services or promotions.
Other Third Parties
We may share your information with advertisers and investors for the purpose of conducting general business analysis.
Cookies and Web Beacons
Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your personal computer, mobile or tablet device when you go offline, whilst session cookies are deleted as soon as you close your web browser. We use both session and persistent Cookies for the purposes set out below:
You should be aware that getting a new computer, mobile device or tablet device, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.
THIRD PARTY WEBSITES
The Site may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Site, any information you provide to these third parties is not covered by this policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Site.
SECURITY OF YOUR INFORMATION
We have 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, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
By law we have to keep basic information about our customers including Contact, Identity, Financial and Transaction Data for 7 years after they cease being customers.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
You may request details of personal information which we hold about you under the Data Protection Act 2018. If you would like a copy of the information held on you please write to firstname.lastname@example.org.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
POLICY FOR CHILDREN’S INFORMATION
We do not knowingly collect or solicit information from children under the age of 18. By using the Site, you represent that you are at least 18 years of age. If you become aware of any data we have collected from someone under the age of 18, please contact us by emailing email@example.com.
OPTIONS REGARDING YOUR INFORMATION
You may at any time review or change the information in your account or terminate your account by:
Emails and Communications
If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:
If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.
HOW TO COMPLAIN
If you have any concerns about our use of your personal information, you can make a complaint to us at firstname.lastname@example.org
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk