Titanic Brewery Co Limited (“We”) respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
This privacy notice applies to information we collect about:
- Visitors to our website;
- Visitors to our premises;
- Customers (current and past);
- Suppliers (current and past); and
- Titanic Brewery loyalty card holders.
This version was last updated in November 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
We are the controller and responsible for your personal data.
Our full details are:
Full name of legal entity: Titanic Brewery Co Limited
Name or title of data privacy manager: David Robinson-Smith
Email address: [email protected]
Postal address: Unit 4 Callender Place, Lingard Street, Burlsem, Stoke on Trent, ST6 1JL
Telephone number: 01782 823447
3.1 What is personal data?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature, or the number of customers purchasing certain products. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
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.
3.2 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.
We use different methods to collect data from and about you including through:
You may reject cookies from our website by altering the settings on your browser. If you choose to reject cookies from our website, you may be unable to access some areas of the Website.
Any third party advertisement may also incorporate cookies for which we have no control.
We use a third party service to collect standard internet log information and details of visitor behaviour patterns. We collect this information to establish how many of our visitors use particular areas of our website. The information collected will only be used in a way that shall not identify you. We do not allow our third party service to identify you if you have visited our website.
(b) Online accounts and purchases
When you set up an online account or place an order, we will request personal data from you. This personal data will be used to verify your identity for setting up your account or processing you order. This information will be used when you interact with us through our website.
Your personal data will be kept for a period of 24 months from the date that you last logged into the website if you have an account, unless you are a member of our loyalty club or have subscribed to our communications/updates. For purchases, please see point 6.2 of this Privacy Notice.
4.2 Direct interactions
We may collect personal data from direct interactions with you. This may include:
- details of your visits to our establishments; or
- any information supplied by you through membership of our loyalty scheme or for subscription to our updates; or
- any information supplied by you when you directly interact with us. This may include through correspondence, telephone calls and any other direct interactions.
- how is your personal data used?
The personal data which we collect and store enables us to provide our service to you. This data may be used for the following purposes stated below.
We may use your personal data for marketing purposes. This may include:
- supplying information to you from us relating to the products and services which we offer, which may be of interest to you; and
- contacting you to notify you of any changes to our website which may affect the service we offer you; and
- using or permitting third parties to use your personal data, so that they may supply you with information of products and services that may be of interest to you.
We may only use your personal data for marketing purposes with your consent. You may withhold your consent when providing your details to us. If you have given consent but you wish to revoke your consent, you may revoke your consent at any time by giving 3 months notice.
5.2 Disclosure to third parties
We may share your personal data with third parties. This may include:
- Logistics providers organising the delivery of your products.
- Service providers who provide IT and service administration support.
- Professional advisers including legal advisors, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
Some of our third party processors may be based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data to a third party outside the EEA, we ensure that a similar degree of protection is afforded by ensuring that at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection as it is afforded in the EEA; or
- Where we used providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
5.4 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: [email protected]
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.
- How is your personal data stored?
6.1 Data security
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.
6.2 How long will we store your data?
By law, we have to keep basic information about you as our customers (including Contact, Identity, Financial and Transaction Data) for six years after you cease being our customers for tax purposes.
We will also keep your purchase history for the duration of any warranty period applicable to the goods or services purchased, which may be in excess of the period stated above.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are summarised below:
7.1 Request access to your personal data (commonly known as a “data subject access request”).
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
7.2 Request correction of the personal data that we hold about you.
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
7.3 Request erasure of your personal data.
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
7.4 Object to processing of your personal data
Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms you may object to our processing of your personal data. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
7.5 Request restriction of processing of your personal data.
This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
7.6 Request the transfer of your personal data to you or to a third party.
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7.7 Withdraw consent at any time
Where we are relying on consent to process your personal data you may withdraw this consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
7.8 How to exercise your rights
If you wish to exercise any of the rights set out above, please contact us: [email protected] [If you are submitting a data subject access request it would be helpful if you could complete a copy of our subject access request form which can be found here. This will enable us to identify and deal with your request much more quickly.]
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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 may 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.
7.9 Your right to complain to the Information Commissioner’s Office.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us: [email protected] in the first instance.