Privacy Policy

LOCH LOMOND GROUP CUSTOMER PRIVACY NOTICE

01. INTRODUCTION

Loch Lomond Distillers Limited (“Loch Lomond Group”, “we”, “us” and “our”) is committed to protecting and respecting your privacy. This Notice explains how we collect, use and share your personal data, including in connection with your use of the following websites (our “Websites”):

www.lochlomondgroup.com
www.benlomondgin.com
www.glenscotia.com
www.lochlomondwhiskies.com
www.littlemilldistillery.com
glensvodka.com
www.highcomm.co.uk

Loch Lomond Group trades and operates under a number of different brands including Ben Lomond, Clansman, Glengarry, Glens Scotia, Glens Vodka, High Commissioner, Inchmoan, Inchmurrin, Littlemill, Loch Lomond, Loch Lomond Group and Loch Lomond Whiskies.

This Notice may change from time to time. We will advise you of material changes, but you are advised to review this Notice periodically.

If you have any questions, feel free to get in touch via the method set out in the“Contact us”section of this notice below.

02. WHAT PERSONAL DATA DO WE COLLECT
ABOUT YOU AND HOW DO WE COLLECT IT?

We may collect and generate personal data about you in accordance with this Notice. This personal data includes:

When you visit our Websites or fill in forms on our Website or elsewhere, including at our shops and distilleries and at events and festivals:

details of your visits to our Websites and the resources that you access, including Internet Protocol (IP) address, traffic data, location data, weblog statistics and other communication data; and
personal details that you provide by filling in forms on our Websites or elsewhere, such as when you register to receive information such as a newsletter or contact us via the contact us page, including your name, e-mail, telephone number, postal and billing address, date of birth and location data (including country and nearest city).

When you contact us or we contact you or you take part in competitions, surveys or reviews about our products:

information that you provide about yourself anytime you contact us about our products (for example, your name, date of birth, contact details and transaction information relating to any purchase of our products), including by phone, email, post, through social media or via a third party seller or distributor of our products;
details of emails and other communications we send to you that you open, including any links that you click on in those communications;
your feedback and contributions to surveys or reviews; and
information that you provide by filling in forms on our Websites or elsewhere, such as when you register to receive information such as a newsletter or contact us via the contact us page including your name, e-mail, telephone number, postal and billing address, date of birth; and location data (including country and nearest city).

When you visit our shops, offices or distilleries or interact with us at events or festivals

information collected through the use of CCTV at our shops, offices or distilleries, including images;
personal details that you provide to book a tour of our distilleries or to purchase or reserve a product(s), including your name, e-mail, telephone number, postal and billing address and date of birth; and
certain payment information, including the location of payments made by credit/debit card.

Other sources of personal data

We may also receive information about you from:

our customers (including wholesalers, distributors and supermarkets) who promote and sell our products to individuals;
third party marketing agencies employed by us; or
our competition partners.

We may combine information we have about you from various sources, including the data that you have provided to us.

03. HOW DO WE USE YOUR PERSONAL DATA?

We use your personal data for the following purposes:

to service your needs including fulfilling ordersof any products or samples, including delivery of those products or samples;
to process and keep records of paymentsyou make in relation to our products or tours;
to promote and market our products and services,if you have indicated that you would like to receive marketing from us, to send you newsletters and other marketing materials including details of special offers, promotions, events, distillery tours, festivals and product launches;
to run competitionsin accordance with the relevant terms and conditions; to notify winning participants and arrange delivery of prizes; to notify competition participants who request details of winning entries of the name and geographical location of the prize winners;

to provide customer servicesincluding the assessment and resolution of any complaints or enquiries made to us;
to organise toursof our shops and distilleries;
to protect and supportour business, personnel and customers;
to prevent and detect fraud, anti-social behaviour and other crimesincluding maintaining the security of our shop, offices and distilleries; and
for compliance,to comply with legal, regulatory and other requirements, such as verifying that you are of the correct age to use our products and access our Websites.

04. ON WHAT BASIS DO WE USE YOUR PERSONAL DATA?

We use your personal data on the following basis:

with your consent, where you have indicated that you would like to receive marketing from us;
in order to fulfill a contract we have with you for the sale of our products;
for the legitimate interests of the Loch Lomond Group, being the purposes set out in the“How do we use your personal data?”section above; and
to comply with certain legal and regulatory obligations of the Loch Lomond Group.

Where you have given your consent to receive marketing from us, you have the right to withdraw that consent at any time by contacting us atunsubscribe@lochlomondgroup.com.

05. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

We may share certain of your personal data with:

members of the Loch Lomond Group of companies;
marketing agencies that provide services to the Loch Lomond Group;
our customers (including wholesalers, distributors and supermarkets), who promote and sell our products; and
delivery companies who provide delivery fulfillment services.

We may also need to make your personal data available to other parties, such as:

legal and regulatory authorities;
accountants, auditors, lawyers and other outside professional advisors; and
companies that provide products and services to Loch Lomond Group (such as IT systems, service and software suppliers and other third parties engaged to assist Loch Lomond Group in carrying out business activities).

06. TRANSFERS OF YOUR PERSONAL DATA OUTSIDE OF YOUR HOME COUNTRY

Your personal data may be processed by Loch Lomond Group, its affiliated companies and those other parties described above, outside the European Economic Area. Where the European Commission has not issued an adequacy decision in relation to the jurisdiction where your personal data is processed, we will ensure that there are adequate mechanisms in place to protect your personal data in accordance with applicable data protection and privacy law.

We will do this through use of data transfer agreements implementing standard data protection clauses. You can find more information about data transfer agreementshereand can receive further information about the data transfer agreements that concern your personal data by contacting us via the method set out in the“Contact us”section of this notice below.

07. PROTECTING YOUR PERSONAL DATA

We adopt a variety of internal information security measures to keep your personal data safe, including to protect it from unauthorised access, use, disclosure, alteration or distribution. In addition, our IT providers have adopted high information security standards. Where Loch Lomond Group retains a third-party service provider, that provider will be carefully selected in accordance with Loch Lomond Group’s policies and procedures.

08. HOW LONG WILL WE KEEP YOUR PERSONAL DATA?

We will always keep your personal data for the period required by law. We will also keep your personal data where we need to do so in connection with legal action or an investigation involving Loch Lomond Group. Otherwise, we will only keep your personal data for the period necessary to fulfill the purposes outlined above and in any event for no more than seven years thereafter.

09. COOKIES

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is also used to track visitor use of our Websites and to compile statistical reports on website activity.

We use cookies to collect personal information to enable us to reflect our users' interests and by noting who has seen which pages (including click through from emails), how frequently particular pages are visited and to enable us to determine the most popular areas of our Website.

We may use cookies to enrich your experience of using our Website by allowing us to tailor what you see to what we have learned about your preferences during your visits to our Website. Sometimes we may use services of third parties and they may use cookies on our behalf in order to provide their services.

The table below explains the cookies on our Websites.

Cookie Name	Purpose and further information
Google Analytics _utma, _utmb, _utmc, _utmt, _utmz	These cookies are used to build up information for the Analytics service run by Google. They allow us to run reports on how the website is accessed, what pages are visited and traffic sources. The information stored in these cookies is non-personally identifiable. To opt out of being tracked by Google Analytics across all websites, visit this page
Age restriction age_gate	This cookie is used to remember date-of-birth details for the website user. This cookie has a short time expiry to ensure that users returning to the site will be prompted to confirm their age.
Content management system exp_tracker, exp_last_activity, exp_last_visit, exp_csrf_token	These cookies are used to improve the user experience of the Websites by building up anonymous data profiles that enable us to understand user journeys and behaviour across the Websites.
Facebook fbm_, fbsr_	These cookies determine whether a user is logged into Facebook. This is only applicable to users who opt to authenticate their age via Facebook.

For further information visitwww.aboutcookies.orgorwww.allaboutcookies.org. You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, some features of our Website may not function as a result.

10. YOUR RIGHTS

You may be entitled to:

request the correction of your personal data;
request the deletion of your personal data in certain circumstances, for example where your personal data is no longer required for the purposes set out in the“How do we use your personal data?”section above;
request the restriction of the processing of your personal data in certain circumstances;
object to the processing of your personal data. In this case, we will no longer process your personal data unless there are compelling legitimate grounds for doing so or where it is necessary in relation to a legal claim;
ask Loch Lomond Group about the processing of your personal data and to be provided with a copy of your personal data; and
request receipt or transmission to another organisation, in a machine-readable form, of the personal data that you have provided to Loch Lomond Group.

If you would like more information about your rights, to exercise these rights, or if you have any concerns about Loch Lomond Group’s processing of your personal data, please contact us via the method set out in the“Contact us”section of this notice below. If you choose to exercise your rights, we will respond in accordance with, and to the extent required by, our legal obligations.

If you believe that we have illegally processed your personal data, or if you have suffered as a result of unlawful processing of your personal data, you can present a claim to your local supervisory authority.

Where you are given the option to share your personal data with us, you can always choose not to do so. If you object to the processing of your personal data, Loch Lomond Group will respect that choice in accordance with its legal obligations. This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described above.

11. CONTACT US

If you have questions about the processing of your personal data, or need additional information, please contactdataprotection@lochlomondgroup.com

12. DATA CONTROLLER

Loch Lomond Distillers Limited is the controller of your personal data.

July 2019