Privacy policy
Bruichladdich is displaying this privacy statement to demonstrate our firm commitment to privacy.
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Categories of Personal Data collected
Information you give to Bruichladdich. You may provide information by contacting Bruichladdich via the Website or by email, telephone, social media, signing up for newsletters or by creating an account.
This information notably includes:
- your name;
- your age;
- your email;
- your billing address, delivery addresses and phone number;
- your credit/debit card details upon user’s request;
- your purchases;
- any events attended; and/or
- your client account data.
Technical usage information. When you visit the Website, Bruichladdich collects the information sent to it by your computer, mobile phone, or other device.
This information notably includes:
- your IP address;
- device information including identifier, name, and type of operating system;
- mobile network information; and
- standard web information, such as your browser type and the pages you access on the Website.
Legal basis
As described in the table above, the Processing activities carried out by Bruichladdich are based on (i) legal obligation, (ii) the performance of the sales contract, (iii) Bruichladdich’s legitimate interests, or (iv) your consent.
You cannot object to these Processing activities when they are implemented to meet a legal provision or when they are necessary for the performance of the sales contract.
When the Processing is based on by Bruichladdich’s legitimate interest, you can object to it. For doing so, please refer to Section 8 regarding your rights.
Where the Processing is based on your consent, you can withdraw it at any time by contacting the Bruichladdich Data Administrator at dataservices@bruichladdich.com
Recipients
Bruichladdich does not sell, rent or lease your Personal Data to others.
Further, Bruichladdich does not share your Personal Data to others except as described in the above table of this Privacy Policy. These Recipients are the following:
- Mail Marketing UK Ltd. located in the United Kingdom and which store your Personal Data in the United Kingdom, for the storage of data relating to customer relationship management and the fulfilment of website sales;
- Remy Cointreau Group local market Distribution and Brand Teams, and Group Distribution Chain Partners which may be based outside of the EEA (see below), for progression and fulfilment of local market user enquiries.
- MailChimp communication database located in the United States of America and which store your Personal Data in the United States of America, that require the data to select and serve relevant communications and newsletters to you and others; and
Bruichladdich may also share your Personal Data with third parties in the event that Bruichladdich sells any business and/or assets, and that your Personal Data are concerned by this sale.
Bruichladdich will share your Personal Data with law enforcement agencies, public authorities or other organisations if legally required to do so.
Transfer of your Personal Data outside the EEA
Most internal and external Recipients data are located in the United Kingdom, France or in an EEA Member State.
However, certain Personal Data are transferred to or made accessible to subsidiaries and third party companies located in a country outside the EEA which does not ensure a level of protection equivalent to that in force in the EEA.
Similarly, some external Recipients are located in a country outside the EEA or subcontract some of their activities themselves to a processor located in a country outside the EEA that does not provide an adequate level of protection.
In such cases, Bruichladdich guarantees the supervision of such transfers under the conditions provided for by the GDPR. These frames are shown in the following table:
| Categories of Personal Data | Internal or External Recipients | Transfer outside the EEA | Legal basis for the transfer |
|---|---|---|---|
| Marketing data | MailChimp (External) | From the United Kingdom to the United States | Privacy Shield |
| Customer enquiries and marketing data | “Remy Cointreau Group local market Distribution and Brand Teams (Internal) Remy Cointreau Group Distribution Chain Partners (External)” | From the EEA to the relevant local market country. | Standard contractual clauses between Bruichladdich, Remy Cointreau Group and the Distribution Chain Partners. |
If you wish to obtain a copy of these guarantees, you can send your request to the Data Administrator.
Retention
Bruichladdich retains your Personal Data as described in the table above.
After you have terminated your use of the Website, Bruichladdich stores your Personal Data in an aggregated and anonymised format.
Your rights
In certain circumstances, you have rights in relation to the Personal Data Bruichladdich holds about you. The table below sets out an outline of those rights and how to exercise them. Please note that Bruichladdich will require you to verify your identity before responding to any requests to exercise your rights. To exercise any of your rights, please email the Data Administrator at dataservices@bruichladdich.com . Please note that for each of the rights below, Bruichladdich may have valid legal reasons to refuse your request, in such instances Bruichladdich will let you know if that is the case.
| Right | Content |
|---|---|
| Access | You have the right to know whether Bruichladdich processes Personal Data about you, and if Bruichladdich does, to access Data Bruichladdich holds about you and certain information about how Bruichladdich uses it and who Bruichladdich shares it with. You can request a copy of these Data. |
| Portability | You have the right to receive a subset of the Personal Data you provide Bruichladdich in a structured, commonly used and machine-readable format and a right to request that Bruichladdich transfers such Personal Data to another party if Bruichladdich processes it on the bases of (i) Bruichladdich’s contract with you or (ii) with your consent and when the processing is carried out by automated means.”Remy Cointreau Group local market Distribution and Brand Teams (Internal) Remy Cointreau Group Distribution Chain Partners (External)” |
| Correction | If you believe that the Personal Data Bruichladdich holds about you are inaccurate or incomplete, you have the right to request its correction or modification. |
| Erasure | You may request that Bruichladdich erases the Personal Data Bruichladdich holds about you in the following circumstances: (i) where you believe it is no longer necessary for Bruichladdich to hold the Personal Data, (ii) Bruichladdich is Processing it on the basis of your consent and you wish to withdraw your consent, (iii) Bruichladdich is Processing your data on the basis of Bruichladdich’s legitimate interest and you object to such Processing, (iv) you no longer wish Bruichladdich to use your data to send you marketing or (v) you believe Bruichladdich is unlawfully Processing your data. |
| Restriction of Processing | You have a right to require Bruichladdich to restrict of Processing the Personal Data Bruichladdich holds about you in the following circumstances: (i) if you dispute the accuracy of your Personal Data, (ii) if the Processing is unlawful and you object to its deletion, (iii) if you believe that Bruichladdich no longer needs your Personal Data but that it is still necessary for you to establish, exercise or defend your legal rights or, (iv) if you have objected to Bruichladdich Processing Personal Data Bruichladdich holds about you. |
| Objection | You have the right to object to the Processing of the Personal Data Bruichladdich holds about you and Bruichladdich will consider your request. Please provide Bruichladdich with detail as to your reasoning so that Bruichladdich can assess whether there is a compelling overriding interest in Bruichladdich continuing to process such data or Bruichladdich needs to process it in relation to legal claims. |
| Right to give post-mortem instructions | If you are a French National or residing in France, you have the right under Article 40-1 of the Law No. 78-17 (the French Data Protection Act) to set guidelines regarding the retention, erasure and disclosure of your Personal Data after your death. |
Complaints
In the event that you wish to make a complaint about how Bruichladdich processes your Personal Data, please contact Bruichladdich’s Data Administrator in the first instance at the following email address: dataservices@bruichladdich.com . Bruichladdich will endeavour to deal with your request as soon as possible.
If you feel that the level of service or attention you receive by the Data Administrator above is insufficient, you may direct your query at any time to the Remy Cointreau Group Data Protection Officer at the following email address: privacy@remy-cointreau.com
This is without prejudice to your right to launch a claim with the data protection supervisory authority in the European Union country in which you live or work where you think Bruichladdich has infringed data protection laws.
Changes
Any changes Bruichladdich will make to this Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to this Privacy Policy.
