Privacy & Cookies notice

INTRODUCTION

1. All references to “our”, ”us”, ”we” or ”Company” within this policy are deemed to refer to William Grant & Sons Limited, its subsidiaries, affiliates and associates.

This Privacy & Cookies notice (together with our Website(s) Terms & Conditions and any other documents referred to on them) set out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following information carefully to understand our practices regarding your personal data and how we will treat it. By using our Virtual Reality experience, you are accepting and consenting to the practices described in this policy.

For the purpose of the Data Protection Act 1998 (Act), the data controller is William Grant & Sons Limited, registered in Scotland with company number SC131772 and registered address at The Glenfiddich Distillery, Dufftown, Banffshire, AB55 4DH.

INFORMATION WE MAY COLLECT FROM YOU

2. You must not provide us with your personal information if you are not of legal age to purchase alcohol in the country in which you reside and (if different) in the country in which you are accessing the Website(s). We do not intend to collect personal information from any individuals under the legal purchase age, or to market alcoholic beverages to anyone under the legal purchase age. If we receive notice or believe that someone under the legal purchase age has provided us with personal information we will make every reasonable effort to remove such personal information from our files, or to flag such personal information and (to the extent permitted by law) retain it for the sole purpose of ensuring that it is no longer used.

It is your choice to provide us with personal information. We will only collect personal information that you choose to provide.  This includes personal information you provide us with:

1. when registering with our Website(s), contacting us, completing surveys or questionnaires, entering competitions, promotions or events sponsored or promoted by us, and posting information on public areas of our Website(s) or on our social media sites;
2. through your use of our Website(s) or on our social media sites such as your name, contact details, personal preferences, technical use and details of your website use (e.g. products you viewed or searched for, length of visits to certain pages and page interaction information); 
3. when you purchase products from us through our online shops and through the fulfillment of your orders; and
4. when you correspond with us by phone, email or otherwise.

By doing so, you are agreeing to our use of that information as set out in this Privacy & Cookie notice and Website(s) Terms & Conditions.

3. Sometimes, we will give you the option to choose whether you would like to receive information from us or not (e.g. by choosing to opt in or opt out of receiving emails from us with news about our brands or promotional offers).  However, you will sometimes not have the option to opt out, such as when we are satisfying the obligations of a contract with you, or administering a transaction requested by you.

COOKIES

4. Our Website(s) uses cookie files to distinguish you from other users of our Website(s). We may also obtain information about your general internet usage by using a cookie file. Cookies are small text files that are placed on your computer by websites that you visit (Cookies). This helps us to provide you with a good experience when you browse our Website(s) and also allows us to improve our Website(s). We may also obtain information about your general internet usage by using Cookies. Cookies can't harm your computer and we don't store personally identifiable information, but we do use encrypted information gathered from them to help improve your experience of the Website(s) and to deliver a better and more personalised service.

Cookies enable us to:

• estimate our audience size and usage pattern; and
• recognise you when you return to the Website(s).

So that you can make full use of the personalised features on our Website(s), your computer, mobile phone or other device (Device) will need to accept Cookies.

We collect anonymised information about visitors' age, gender and interests to enable us to better meet our visitors' needs for future marketing activity. For information on how to opt-out, please view section 8 of our policy.

5. Here's a list of the main Cookies that may be sent to your Device and what we use each Cookie for. You can set your browser to reject Cookies (see section 7 below for more information on how to do this), but if you do this, certain personalised features of our Website(s) cannot be provided to you.

6. To support our Website(s) we may occasionally embed photos and video content from other third party websites such as Flickr and YouTube. Pages with this embedded content may present you with Cookies from these websites. We do not control the distribution of these Cookies and you should check the relevant third party website for more information about these.

7. You may refuse to accept Cookies from us by: (a) not opting in to the use of Cookies by us on the landing page of the Website(s); or (b) activating the setting on your browser which allows you to refuse the setting of Cookies (visit http://www.allaboutcookies.org/ for assistance with adjusting your browser settings).

8. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

WHERE WE STORE YOUR PERSONAL DATA

9. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy & Cookies notice. All information you provide to us is stored in secure managed servers. Any payment transactions are encrypted using SSL technology, and payment details are not kept following completion of the transaction. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website(s), you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

10. If you are giving us your personal information in the course of purchasing, registering, or subscribing to a service or product, then we will only use your information in order to provide you with that service or for closely related purposes.  We use some carefully selected third parties to help us deliver these services and products to you but they are only allowed to use your personal information to deliver the service or product you have purchased, registered or subscribed to.  Some of our trusted third parties in supporting these services will transfer your information overseas, but we make sure that your information remains protected and secure.

Unfortunately, the transmission of information via the internet is not completely secure.
Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website(s); any transmission is at your own risk. Once we have received your information, we will use strict procedures and data encryption to try to prevent unauthorised access.

USES MADE OF THE INFORMATION

11. We use information held about you in the following ways:

1. to ensure that content from the Website(s) is presented in the most effective manner for you and for your computer and/or Device;
2. to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
3. to allow you to participate in interactive features of the Website(s), when you choose to do so;
4. to notify you about changes to our products and services; and
5. the fulfillment of online purchases.

DISCLOSURE OF YOUR INFORMATION

12. We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

13. We may disclose your personal information to our suppliers, distributors (wholly or partly owned) and other contractors who are engaged by us to assist in the provision of products and services to you, including delivery of products ordered by you and the conduct of market research which you have agreed to participate in.

14. We may disclose your personal information to third parties:

1. In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
2. If the Company, or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
3. If the company is under a duty to disclose or share your personal data in order to comply with any legal obligation; or to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

YOUR RIGHTS

15. You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data, unsubscribing from communication. You can also exercise the right at any time by contacting us at:

William Grant & Sons Ltd

Independence House

84 Lower Mortlake Road

Richmond

Surrey

TW9 2HS

16. The Website(s) may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

ACCESS TO INFORMATION

17. The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 (UK Sterling) to meet our costs in providing you with details of the information we hold about you.

You can find out if we hold any personal information by making a ‘subject access request’ under the Data Protection Act 1998.  If we do hold information about you we will:

1. give you a description of it;
2. tell you why we were holding it;
3. tell you who it could be disclosed to; and
4. let you have a copy of the information in an intelligible form.

To make a request for any personal information we may hold you need to put a request in writing using the contact details at the end of this notice.

CHANGES TO OUR PRIVACY & COOKIES NOTICE

18. Any changes we may make to our Privacy & Cookies notice in the future will be posted on this page and, where appropriate, notified to you by email.

CONTACT

19. Questions, comments and requests regarding this Privacy &Cookies notice are welcomed and should be addressed to:

William Grant & Sons Brands Ltd

Independence House

84 Lower Mortlake Road

Richmond

Surrey

TW9 2HS

GOVERNING LAW AND JURISDICTION

20. This Privacy & Cookies notice shall be governed by and construed in accordance with the laws of Scotland. Disputes arising in connection with this Privacy & Cookies notice shall be subject to the exclusive jurisdiction of the Scottish Courts although the Company retains the right to bring proceedings against you for breach of this Privacy & Cookies notice in your country of residence or any other relevant country.

Issue Date: October 2016