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Privacy Policy

This Privacy Policy was updated on 20 May 2018 Loch Shiel Whisky Ltd, a alcohol and beverage company, incorporated under the laws of England and Wales under company registration number 09722069, whose registered office is at Mercury House, Shipstones Business Centre, North Gate, Nottingham NG7 7FN (“Loch Shiel Whisky Ltd” “We”).

Loch Shiel Whisky data protection and privacy measures are governed by the (i) the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and any national implementing laws, regulations and secondary legislation, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998 (“Data Protection Legislation”).

1. Introduction
2. Personal data and Basis for Collection
3. If you fail to provide personal data
4. How is your personal data collected
5. Purposes for which Loch Shiel Whisky Ltd
will use your personal data
6. Change of purpose
7. How your personal Data Retention
8. Your Rights
9. Children
10. Complaint
11. Question and Contact information

1. Introduction
This privacy policy sets out how Loch Shiel whisky Ltd uses and protects any information that you provide to Loch Shiel whisky Ltd (including information provided through the website www.lochshielwhisky.com or other websites through which loch Shiel Whisky Ltd provides its services to you (“Websites”)).

loch Shiel Whisky Ltd is a alcohol and spirits business producing own label brands through its organisation of blenders and bottling operations in Scotland and is a registered company based in the UK which supplies Whisky based products within a
supply chain processes; products and services (“Products and Services”). As such Loch Shiel Whisky Ltd may process personal data of its customers, contacts and visitors to its Websites.

2. Personal data and Basis for Collection
For the purpose of Data Protection Legislation, where personal data is provided directly to Loch Shiel Whisky Ltd through use of the Website(s), email, or other means Loch Shiel Whisky Ltd will be a data controller (as defined in the Data Protection Legislation) of such information. Where Loch Shiel Whisky Ltd is provided with information only for the purpose of performing a contract or where Loch Shiel Whisky Ltd cannot determine the use of such information, Loch Shiel Whisky Ltd will be data processor (as defined in the Data Protection Legislation) of such information.

Loch Shiel Whisky Ltd may collect, use, store and transfer different kinds of personal data about you which Loch Shiel Whisky Ltd have grouped together as follows:

Identity Data including names, username or similar identifier, title, job title, directorships.

Contact Data including billing address, delivery address, email address and telephone numbers.

Financial Data including bank account and payment card details.

Transaction Data including details about payments to and from you and other details of products and services you have purchased from Loch Shiel Whisky Ltd.

Usage Data including information about how you use Loch Shiel Whisky Ltd Services or submit an enquiry or query
through the Websites.

Marketing and Communications including your preferences in receiving marketing or surveys from us and our third
parties and your communication preferences.

Additional Information including additional information you chose to provide to us.

• Unless you provide such information to us to customise the service we may provide to you, Loch Shiel Whisky Ltd does not process 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 yourhealth and genetic and biometric data). Nor does Loch Shiel Whisky Ltd collect any information about criminal convictions and offences.

3. If you fail to provide personal data
Where you fail to provide personal data when requested, Loch Shiel Whisky Ltd may not be able to perform the contract it has or is trying to enter into. In this case, Loch Shiel Whisky Ltd may have to cancel the Services but we will notify you if this
is the case at the time.

4. How is your personal data
collected? Loch Shiel Whisky Ltd use different methods to collect personal data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, e-mail or otherwise. This includes personal data you provide when you:

ø apply for the Services or private label products;

ø give us some feedback or complete a survey so we may improve services;

ø request marketing to be sent to you; or o create an account on our Websites or apps or mobile device.

• Third parties. We may receive personal data about you from various third parties, including your employer who may need to verify to us the individual identity to use our services and platform to place financial orders for goods.

5. Purposes for which Loch Shiel Whisky Ltd will use your personal data
Set out below is 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 0207 164 6945 if you need details about the specific legal basis we are relying
on to process your personal data.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer and verify your identity when using log-ins (a) Identity
(b) Contact
Performance of a contract
To process and deliver the Services including: (a) Managing payments and charges (b) Collecting and recovering money owed to us (c) Contacting you and corresponding about the Services (d) to provide support to the services (a) Identity
(b) Contact
(c) Financial

(d)Transaction

Performance of a contract Necessary for our legitimate interests (to recover debts due to us)
To respond to queries and enquiries (a) Identity
(b) Contact
Legitimate interests (to offer similar services or offers)
To undertake any marketing to you (a) Identity
(b) Contact
Legitimate interests (to offer similar services or offers)
Business Performance – To manage our business performance and assess client satisfaction and improvement to our Services (a) Identity Data
(b) Individual Data
Legitimate interests (to improve the services we provide)
Events – To enable us to provide events to you which take into consideration your preferences (a) Identity Data
(b) Individual Data
(c) Event Data
Legitimate interests (to tailor events) Consent

6. Change of purpose
Loch Shiel Whisky Ltd will only use your personal data for the purposes for which it was collected for, 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 0207 164 6945 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 notethat 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.

7. How your personal data may be shared
Personal data that Loch Shiel Whisky Ltd collects in accordance with this Privacy Policy, may be shared as follows:

• with third party consultants selected by Loch Shiel Whisky Ltd, such as survey providers, product checkers and logistic
companies, import companies, resellers, other associated companies;

• With other UK and international Loch Shiel Whisky Ltd  member organisations;

 • where information is shared through public platforms in accordance with the provision of other services such as Coupon Issuer services we may implement;

• with marketplaces such as Amazon;

• where Loch Shiel Whisky Ltd is under a duty to disclose your personal data to comply with any legal obligation, or to
enforce or apply Loch Shiel Whisky Ltd terms and conditions and other agreements;

• with third party debt recovery agencies;

• to protect the rights, property, or safety of Loch Shiel Whisky Ltd and its customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and for compliance with laws; and

• with third parties to whom we may choose to sell, transfer, or merge parts of our business or our 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.

8. How Loch Shiel stores personal
data For secure storage, Loch Shiel Whisky Ltd ensures that it stores your personal data within the UK (Slough).

Loch Shiel Whisky Ltd may share your personal data with some third parties who are based outside the EEA. In this case, Loch Shiel Whisky Ltd will ensure that the appropriate security measures and processing provisions are in place to protect your
personal data either directly or through our data services centre. 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.

9. Personal Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Generally, we keep personal data in accordance
with our internal retention procedures, which are determined in accordance with our regulatory obligations and good practice. These retention periods depend on the nature of the information, and are subject to change. If you have any
questions in this regard, please contact us using the details below.

10. Your Rights
Under certain circumstances, you have rights under Data Protection Legislation in relation to your personal data. These include the right to:

• request access to your personal data;

• request correction of your personal data;

• request erasure of your personal data;

• object to processing of your personal data;

• request restriction of processing your personal data;

• request transfer of your personal data; and

• right to withdraw consent.

To exercise any of the above rights please email your request to: dataprotection@devine-distillatesgroup.com

Where you exercise your right to erasure or where information is deleted in accordance with Loch Shiel Whisky Ltd retention policy, please note that after the deletion of your personal data, it cannot be recovered, so if you require a copy of this personal data, please request this during the period Loch Shiel Whisky Ltd retains the data.

11. Children
The Website is not intended for children. Loch Shiel Whisky Ltd will not knowingly collect any personal data from persons under the age of 18 and will immediately delete any such datasubsequently so determined.

12. Complaints
If you would like to make a complaint in relation to how Loch Shiel Whisky Ltd may have stored, used or processed your personal data, 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). Loch Shiel Whisky Ltd would, however, appreciate the chance to deal with your  concerns before you approach the ICO so please contact us in the first instance.

Changes to this Privacy policy and your duty to inform us of changes

As and when necessary, changes to this privacy policy we will posted here. Where changes are significant, we may also email all our registered users with the new details, and where required by law, will we obtain your consent to these changes.

This Privacy Policy was last updated on 20 May 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.

Loch Shiel Whisky Ltd
A Devine Distillates Group Associated Company