1. WHO WE ARE
This Privacy Policy explains how [KJM Process Limited], trading as [Cainbrook Distillery](“we”, “us” or “our”), collects, uses and protects your personal information.
For data protection purposes, we are the data controller responsible for your personal information.
Our details are:
Business name: [KJM Process Limited] Trading name: [Cainbrook Distillery] Address:[Court Cottage, 42 Coughton Hill, Alcester, B49 5HX] Company number: [12941097 Email: [info@cainbrook.com] Website: [cainbrook.com]
We are committed to respecting your privacy and protecting your personal information.
2. INFORMATION WE COLLECT
We may collect the following information when you visit our website, place an order or contact us.
Identity and contact information
This may include:
· your name;
· billing address;
· delivery address;
· email address;
· telephone number; and
· the name and address of a gift recipient where applicable.
Order information
This may include:
· products ordered;
· order value;
· delivery details;
· transaction dates;
· order history;
· refunds and returns; and
· communications relating to an order.
Payment information
Payments are normally processed through third-party payment providers.
We generally do not receive or store your complete debit or credit card details. We may receive limited information from the payment provider, such as:
· payment confirmation;
· payment status;
· transaction reference;
· card type; and
· limited card information such as the final digits of the card number.
Age-verification information
Because we sell alcohol, we may collect or process information necessary to confirm that customers meet the legal minimum age for purchasing alcohol.
This may include:
· confirmation that you are aged 18 or over;
· date of birth where required;
· the outcome of an electronic age-verification check; or
· confirmation from our delivery provider that appropriate age verification was completed.
Where possible, we aim to retain confirmation that an age check was successfully completed rather than copies of identity documents.
Website information
When you use our website, certain technical information may be collected automatically, including:
· IP address;
· browser type;
· device type;
· operating system;
· pages visited;
· date and time of visits;
· referring website; and
· website usage information.
Some of this information may be collected using cookies or similar technologies.
Marketing information
If you subscribe to our mailing list or agree to receive marketing, we may record:
· your name;
· email address;
· marketing preferences;
· when and how you subscribed; and
· whether you have opened or interacted with our marketing communications.
Communications
If you contact us by email, telephone, social media or another method, we may retain information contained in those communications.
3. HOW WE COLLECT YOUR INFORMATION
We obtain most personal information directly from you when you:
· place an order;
· create an account;
· contact us;
· subscribe to our mailing list;
· enter a promotion or competition;
· communicate with us through social media; or
· use our website.
We may also receive limited information from third parties involved in providing our services, such as:
· payment processors;
· age-verification providers;
· delivery companies;
· website and e-commerce providers; and
· fraud-prevention or security providers.
Where someone purchases one of our products as a gift for you, we may receive your name and delivery address from the purchaser.
4. HOW WE USE YOUR INFORMATION
We may use personal information to:
· process and fulfil your orders;
· take and confirm payment;
· arrange delivery;
· communicate with you about an order;
· verify that alcohol is being sold and delivered only to people legally entitled to receive it;
· process returns, refunds and complaints;
· provide customer service;
· maintain appropriate accounting and tax records;
· prevent fraud and misuse of our website;
· protect the security of our website and business;
· manage our relationship with customers;
· improve our products, website and customer service;
· send marketing communications where we are permitted to do so; and
· comply with our legal and regulatory obligations.
We will not use your personal information for purposes that are incompatible with the purposes for which it was collected unless permitted or required by law.
5. OUR LAWFUL BASES FOR USING YOUR INFORMATION
UK data protection law requires us to have a lawful reason for processing personal information.
We generally rely upon the following lawful bases.
Contract
We process information where it is necessary to enter into or perform our contract with you.
For example, we need your name, delivery address and contact information to process and deliver your order.
Legal obligation
We process information where this is necessary to comply with legal obligations applying to our business.
This can include:
· alcohol licensing and age-verification requirements;
· accounting requirements;
· tax requirements; and
· responding to lawful requests from regulators or other authorities.
Legitimate interests
We may process information where it is necessary for our legitimate business interests and those interests do not override your rights.
These interests may include:
· operating and improving our business;
· protecting our business against fraud;
· maintaining website and information security;
· handling customer enquiries and complaints;
· keeping appropriate business records; and
· understanding how customers use our website.
Consent
Where required, we may rely upon your consent, particularly in relation to certain marketing activities or non-essential website technologies.
You can withdraw your consent at any time.
6. MARKETING
We may occasionally send information about our gin, new products, events, offers or other news.
We will only send electronic marketing communications where we are legally permitted to do so.
This will normally be because:
· you have specifically asked to receive marketing from us; or
· you have previously bought, or discussed buying, similar products from us and the applicable rules allow us to contact you.
Where we rely on the existing-customer marketing rules, we will provide an opportunity to opt out when we obtain your contact details and in every subsequent marketing communication.
You can stop receiving marketing emails at any time by:
· clicking the unsubscribelink in an email; or
· contacting us at info@cainbrook.com
Stopping marketing communications will not affect service messages concerning an order you have placed.
We do not sell your contact details to other businesses for their own marketing purposes.
7. WHO WE SHARE YOUR INFORMATION WITH
We only share personal information where reasonably necessary to operate our business, fulfil an order or comply with the law.
This may include:
Payment providers
To process payments and refunds.
Delivery companies
To deliver your order and carry out appropriate age verification at delivery.
Delivery companies will normally receive information such as your:
· name;
· delivery address;
· telephone number;
· email address; and
· information necessary to identify the delivery as containing age-restricted goods.
Age-verification providers
Where we use an electronic age-verification service, relevant information may be shared with that provider for the purpose of confirming that you satisfy the applicable age requirement.
Website and technology providers
We may use third parties to provide:
· website hosting;
· e-commerce systems;
· email services;
· data storage;
· website security;
· analytics; and
· technical support.
Professional advisers
Information may be disclosed where necessary to accountants, insurers, lawyers and other professional advisers.
Government and regulatory bodies
We may disclose information where required by law or where reasonably necessary to comply with requests from bodies such as:
· HM Revenue & Customs;
· licensing authorities;
· the police;
· courts; or
· other regulatory authorities.
We require organisations processing personal information on our behalf to handle it appropriately and securely.
8. INTERNATIONAL TRANSFERS
Some of the service providers used to operate our website, process payments, provide email services or store information may process personal information outside the United Kingdom.
Where personal information is transferred outside the UK, we take reasonable steps to ensure that appropriate protections required by UK data protection law are in place.
These may include transfers to countries recognised as providing adequate protection or the use of approved contractual safeguards.
9. HOW LONG WE KEEP YOUR INFORMATION
We do not keep personal information for longer than reasonably necessary.
The period will depend upon why the information was collected.
As a general guide:
· Order and transaction records: normally retained for up to six years or for such longer period as required for accounting, taxation or legal purposes.
· Payment records: retained as necessary to maintain appropriate transaction records, although complete payment-card details are normally held by our payment provider rather than by us.
· Customer correspondence and complaints: normally retained for a reasonable period after the matter has been resolved.
· Marketing information: retained while you remain subscribed or until it is no longer reasonably required.
· Marketing opt-out information: we may retain limited information confirming that you have opted out so that we can respect your preference in future.
· Website and security records: retained for an appropriate period according to their purpose and the systems we use.
· Age-verification records: retained only for as long as reasonably necessary for legal, licensing, fraud-prevention or evidential purposes.
We may retain information for longer where necessary in connection with a legal claim, regulatory investigation or other legal requirement.
10. COOKIES
Our website may use cookies and similar technologies.
Some cookies are necessary for the website to operate correctly, for example to:
· remember the contents of your shopping basket;
· process orders;
· maintain website security; and
· remember certain website settings.
We may also use other cookies or similar technologies for analytics or marketing.
Where the law requires your consent before these technologies are used, we will ask for that consent.
More information is available in our Cookie Policy and through the cookie settings available on our website.
11. KEEPING YOUR INFORMATION SECURE
We take reasonable technical and organisational measures to protect personal information against:
· unauthorised access;
· accidental loss;
· misuse;
· alteration;
· disclosure; or
· destruction.
Access to personal information is restricted to people and service providers who reasonably need it for the purposes described in this Privacy Policy.
No internet or electronic storage system can be guaranteed to be completely secure, but we take reasonable steps appropriate to the size and nature of our business and the information we process.
12. YOUR DATA PROTECTION RIGHTS
Depending upon the circumstances, you may have the right to:
Access your information
You can ask us for a copy of personal information we hold about you.
Correct your information
You can ask us to correct information which is inaccurate or incomplete.
Delete your information
You can ask us to delete personal information in certain circumstances.
This right does not necessarily apply where we need to retain information to comply with a legal obligation or establish, exercise or defend legal claims.
Restrict our use of your information
You may have the right to ask us to restrict how we process your information in certain circumstances.
Object to processing
You may have the right to object where we process information on the basis of legitimate interests.
You have an absolute right to object to your personal information being used for direct marketing.
Data portability
In certain circumstances you may have the right to receive information you have provided to us in a structured, commonly used and machine-readable format or ask us to transfer it to another organisation.
Withdraw consent
Where we rely upon your consent, you can withdraw that consent at any time.
Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.
To exercise any of these rights, please contact:
We may need to confirm your identity before dealing with a request.
You will not normally have to pay a fee for exercising your data protection rights.
13. CHILDREN AND ALCOHOL SALES
Our alcoholic products are not available for purchase by anyone under 18.
Our website and online shop are directed at adults.
We do not knowingly seek to collect personal information from children for the purpose of selling or marketing alcohol to them.
If we reasonably believe that a person attempting to purchase alcohol is under 18, we may refuse or cancel the transaction.
14. AUTOMATED DECISION-MAKING
We do not normally use your personal information to make decisions based solely on automated processing which have legal or similarly significant effects upon you.
Some third-party systems, such as payment, fraud-prevention or age-verification systems, may use automated processes when assessing a transaction.
Where applicable, further information may be available from the relevant provider.
15. LINKS TO OTHER WEBSITES
Our website may contain links to websites operated by other organisations.
We are not responsible for the privacy practices of third-party websites.
You should review the privacy policy of the relevant website when leaving our site.
16. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in:
· our business;
· our website;
· the services we use; or
· applicable data protection law.
The latest version will be published on our website with the date on which it was last updated.
17. CONTACTING US
If you have any questions about this Privacy Policy or how we use your personal information, please contact us.
18. COMPLAINTS TO THE INFORMATION COMMISSIONER
If you have concerns about how we use your personal information, please contact us first so that we can try to resolve the matter.