Privacy
Last Updated: May 26th, 2023
We value the trust that our users and customers place in us when they give us access to their personal data. This Privacy Policy describes how we work to maintain that trust and protect that information.
In particular, this Privacy Policy details our collection, use and disclosure of personal and non-personal data, that you give to us when you access or use our online and/or mobile services and websites, and software provided by us on or in connection with such services or websites (collectively, the “Site”).
1.1 Personal Data and Non-Personal Data
Personal data (“Personal Data”) refers to any information that identifies you as a specific individual, and non-personal data (“Non-Personal Data”) refers to any information that does not identify you as a specific individual.
Please note that we will adhere to the applicable statutory definition in determining what is and is not Personal Data for the purposes of this Privacy Policy. Where this Privacy Policy refers to “information” or “your information” this may include both Personal and Non-Personal Data.
1.2 The Scope of our Privacy Policy
This Privacy Policy covers only data that we collect through the Site, and not any other data collection or processing, including, without limitation, the data collection practices of any affiliate or other third party, including any third-party operators of web pages to which the Site links, and any information that we collect offline or through any websites, products, or services that do not display a direct link to this Privacy Policy.
Occasionally, we may refer to this Privacy Policy in notices on the Site, including special purpose web pages, mobile applications, or other resources, for example, if we invite you to submit ideas to improve the Site.
This Privacy Policy applies to information collected by us through such special purpose resources, as modified in the particular notice (e.g., with respect to the types of data collected or our uses or disclosures of such information). We may amend this Privacy Policy at any time.
1.3 Changes to the Privacy Policy
Please review the "Last Updated legend at the top of this page to determine when the Privacy Policy was last amended. Any changes to this Privacy Policy will become effective on the "Last Updated" date indicated above. By using the Site or providing information to us following such changes, you will have accepted the amended Privacy Policy.
If we are going to use Personal Data collected through the Site in a manner materially different from that stated at the time of collection, then we will notify users via email and/or by posting a notice on our Site for 30 days prior to such use or by other means as required by law.
2. Information Collected
You provide different types of information in order for us to provide our services, products and features to you.
2.1 Information you provide to us
Through your activity on the Site and as part of the standard operation of the Site, we may collect and analyse information from your computer or mobile device and actions taken on the Site, including, but not limited to, your activity time on the Site and each page, page views, clicks, taps, session activity, browser type, operating system, type of device, MAC address, IP address and the domain name from which you accessed the Site.
2.2 Any other Personal Data we may receive from third parties
Any Personal Data that we may obtain from other third-party sources will be processed by us in accordance with this Privacy Policy and all applicable laws. We may collect or use information about you from publicly available websites. You will have the opportunity to claim or request removal of the information. However, we cannot guarantee that we will not later collect from publicly available websites other information that pertains to you.
2.3 Storage of your information
We shall retain users’ Personal Data to the extent such retention is adequate, relevant and limited to what is necessary for the purposes for which they are processed. In particular, we shall not retain Personal Data for any longer than necessary for the purposes of performing the processing outlined in this Privacy Policy.
We may also create and assign to your device, an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as username, email address, or post code.
The collection of this data is solely used in accordance with the purposes outlined in sections 4, 5 and 9 of this Privacy Policy, to the extent applicable. We may also store the information detailed in this section 2 of the Privacy Policy on the equipment or the equipment of third parties that we have a relationship with. Such storage services will be governed by appropriate protections, as required by applicable rules.
2.4 What Personal Data is required
We will indicate to you at the point of provision, as to whether or not particular Personal Data provided by you, is required in order to provide particular services or features to you. Where Personal Data that is required is not provided by you then, the particular feature or service may not be available to you.
2.5 The legal basis on which we collect your Personal Data
We collect and process your Personal Data, on the basis of different legal grounds, depending on the nature of the Personal Data being provided and the type of processing involved. More information is provided on this below:
– Performance of a Contract. Most of the Personal Data processed by us is performed on the basis that it is necessary for the performance of our agreement with you, or in order to take steps at the request of the user prior to entering such an agreement.
– Legitimate Interest. A second ground relied upon by us for other types of processing of your Personal Data, is that it is necessary for the purposes of legitimate interests pursued by us. Such legitimate interests will include where we send you marketing about our products and services, where we believe you have a reasonable expectation that we will perform a particular type of processing on your behalf, or where such processing is strictly necessary for fraud detection and prevention. We will only rely on such a ground where an assessment has been performed balancing the interests and rights involved and the necessity of the processing, in order to provide our services, products and features to you.
– Compliance with a Legal Obligation. A third ground relied upon for certain types of processing is that it is necessary in order to allow us to comply with a legal obligation. An example of this would be where we are required to retain business records for fixed periods of time in order to comply with local legal requirements.
– Consent. Finally, in certain limited situations, we rely on your consent in order to process your Personal Data. Where we require your consent in order to collect and process certain Personal Data, we seek your consent at the time of provision, and such processing will only be performed where consent is secured.
3. Limitation of use or disclosure of Personal Data
The Site is not for use by anyone under the age of 18. To use the Site, you agree that you must be the minimum age or older.
4. Purposes, uses and disclosures of Information
We may use any information collected pursuant to this Privacy Policy, including Personal Data, for the purposes set forth in sections 4, 5 and 9 of this Privacy Policy, to the extent applicable. In order to do this, we use your Personal Data to:
i) to measure and improve any services, products and features; and
ii) to protect our users and provide them with customer support.
More detail on these purposes, uses and disclosures of your information is set out below.
4.1 Send you messages and other promotional materials
If and to the extent permitted by applicable law, we may use your contact information to (a) send you messages; and (b) send you information about us, including promotional materials. We may use third-party partners to perform these activities on our behalf.
4.2 Your contact information
When you give us your contact information (such as your name and email address) and other forms of Personal and Non-Personal Data, you agree that we may utilize this information for the purposes outlined in sections 4, 5 and 9, to the extent applicable. In particular, you agree that we may, as part of communicating with you, or initiating communication with you on behalf of a third party, via such means as email, telephone (including mobile phone), or postal mail, including through the use of contact information that you may provide to us, or that we may otherwise obtain from third-party resources.
We reserve the right to charge third parties a fee for accessing your information, including Personal Data, as part of our services. At your direction, we may also share your Personal Data with selected agencies if you choose to contact them.
4.3 Preventing Fraud and Spam
We may also use information collected pursuant to this Privacy Policy to help diagnose problems with the Site and our services, to prevent potentially fraudulent or illegal activities, and to protect individuals from other activities that may be detrimental to you or others. We may investigate and disclose information from or about you or your use of the Site if we have a good faith belief that such investigation or disclosure:
(a) is reasonably necessary to comply with legal process (including subpoenas, search warrants, court orders) and law enforcement instructions and orders; or
(b) is helpful to prevent, investigate, or identify possible wrongdoing in connection with the use of the Site; or
(c) may protect our rights, reputation, property, safety, or that of the public; or
(d) as necessary to meet national security requirements.
We may use a variety of methods to detect and address anomalous activity and screen content to prevent abuse such as Spam or Fraud. However, such detection methods are not perfect and false positives may occur. These efforts may on occasion result in a temporary or permanent suspension or termination of some functions for some users.
4.4 Transfer of Information to Third Parties
– Transfers to Service Providers and Vendors. We may use third parties to perform services in connection with our operations, to improve the Site and our services, products and features, and to protect our users. These third parties may include (but are not limited to) service providers and vendors. We may also transfer your Personal Data in limited situations to certain third-party vendors that assist us with protecting our users and maintaining the quality of our services, products and features provided to those users.
– Transfers to Cloud Service Providers. Please also be aware that we may also use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable; these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Personal Data, by these companies.
– Transfers of Publicly Available Information. When users post content in a manner that is intended to make that content publicly available and searchable by individuals, we reserve the right to aggregate and share that information with third parties. We also reserve the right to share information aggregated from public sources in this capacity.
– Third-Party Sites you link to from our Site. You may also use certain third-party sites or services that you link to from our Site. In such cases, all information you provide to a third party is provided to that third party and not to us and is subject to the third-party’s privacy policy and terms of service. Please see section 8 of this Privacy Policy titled Links to Third-Party Sites for more information.
5. Additional uses and disclosures of Non-Personal Data
In addition to the other uses and disclosures of information set forth in this Privacy Policy, and notwithstanding anything in this Privacy Policy to the contrary, we may use and disclosure, for any purpose, any Non-Personal Data, except where we are required to do otherwise under applicable law.
If we combine any Non-Personal Data with Personal Data, then we will only use and disclose such combined information for the purposes described in sections 4 and 9 of this Privacy Policy while it is so combined.
6. Security
We seek to use reasonable security measures to help protect against the loss, misuse and alteration of the Personal Data under our control. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however, in addition, please note that emails, messages sent via your web browser, and other similar means of communication with other users, are not encrypted.
Therefore, while we strive to protect your information, we cannot guarantee its security. Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable; these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures.
However, we will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Personal Data, by these companies.
7. Cookies
“Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. We use these at various locations throughout the Site in order to make the navigation process as seamless as possible and to distinguish you from other users of our site. We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services;
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily; and
- Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
8. Links to Third-Party Sites
The Site may make available links to other websites. When you click on such links, you may leave our Site. The Site may also make available pages, which may contain information provided by third-party Employers.
WE ARE NOT RESPONSIBLE FOR THE INFORMATION COLLECTION, USE, DISCLOSURE OR OTHER PRIVACY PRACTICES OF ANY THIRD PARTY, INCLUDING OUR AFFILIATES, THIRD-PARTY SERVICE PROVIDERS, ANY AGENCIES (INCLUDING ANY AGENCY THAT PROVIDES AN AGENCY PAGE), ANY THIRD-PARTY SOCIAL MEDIA PLATFORM, ANY THIRD PARTY MAKING AVAILABLE THE DEVICES OR OPERATING SYSTEMS FOR WHICH THE SITE IS AVAILABLE, AND ANY THIRD PARTY OPERATING ANY WEBSITE TO WHICH THE SITE CONTAINS A LINK. YOU MAY HAVE RIGHTS DIRECTLY ENFORCEABLE AGAINST THESE THIRD PARTIES SO YOU SHOULD CONSIDER THEIR PRIVACY POLICIES TO LEARN MORE.
9. Acquisitions and Other Reorganizations
Information collected pursuant to this Privacy Policy, including Personal Data, may be disclosed to one or more third parties in connection with any change of ownership or control in our business (whether by merger, sale, or otherwise), or any other reorganization or joint venture, or assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding), and any such information may be used by such third party in accordance with this Privacy Policy.
Equally, information collected pursuant to this Privacy Policy, including Personal Data, may be disclosed to one or more third parties in connection with any acquisition or merger carried out by us of such third parties.
10. Exercising Your Rights with Respect to Your Personal Data
Our users that provide their Personal Data in the EU, and those that provide their Personal Data in any other jurisdictions that adopt laws affording equivalent protections to those in the EU, may avail of the rights detailed below.
10.1 The Right to Rectify Your Personal Data
You may make a formal request to have us rectify any inaccurate Personal Data on your behalf by sending an email to peter @ swanknightdistillery . com (removing the spaces) from the email address associated with your request.
10.2 The right to object/restrict the processing of Your Personal Data
If you have any queries or complaints about how we process your Personal Data, we encourage you to make a formal request to object to, or restrict, processing of your Personal Data by us. In order to do so please send an email to peter @ swanknightdistillery . com (removing the spaces) from the email address associated with your account.
10.3 The rights of access to and portability of Your Personal Data
You may make a formal request to access your Personal Data held by us. In order to do so, please send an email to peter @ swanknightdistillery . com (removing the spaces) from the email address associated with your account and paste the following sentence in your email: “I am requesting to access my personal data.” We will provide your Personal Data to you in a portable format to allow it to be transmitted to third parties.
10.4 The right to delete Your Personal Data
You may make a formal request to delete your Personal Data held by us. In order to do so, please email to peter @ swanknightdistillery . com (removing the spaces) from the email address associated with your account and paste the following sentence in your email: “I am requesting you to delete my personal data.” Once your request has been confirmed, we will initiate the necessary steps to execute this exercise, including the deletion of your account.
10.5 Some limitations
Such rights of rectification, objection, restriction, access, portability and deletion are subject to certain limitations, as provided for by applicable laws. Individual requests will be completed within the time allotted by relevant regulations, which start to run from the point of us confirming your request.
Where permitted, please note there may be a charge for subsequent requests from the same individual, which will be determined by us and only imposed to the extent permitted by applicable law.
11. Do Not Track requests
We do not respond to the browser “Do Not Track” (DNT) signal if enabled by the user in their web browser.
12. Opting Out
If you no longer want to receive marketing materials from us based upon your Personal Data, going forward, you may opt out of receiving such marketing related messages by sending an email to peter @ swanknightdistillery . com (removing the spaces). Please note that we may still send other messages to you, such as administrative messages. We will comply with your request as soon as reasonably practicable, and in accordance with applicable laws.