About this notice
1.1 We appreciate your interest in our products and services and your visit to this website. Your privacy is important to us and we want you to feel comfortable with how we use and share your personal data.
1.2 This notice sets out how the Scotch Whisky Heritage Centre Ltd handles your personal data, including when and why it is collected, used and disclosed and how it is kept secure.
1.3 You will find our contact details at the end of this policy which you can use if you have any questions, including how to update or access your personal data or to make a complaint.
1.4 This policy may change, so please check this page from time to time to ensure that you’re happy with any changes.
1.5 This policy was last updated on 24 September 2018.
Who we are
2.1 The Scotch Whisky Heritage Centre Ltd, trading as The Scotch Whisky Experience, is the ‘controller’ of your personal data during your interactions with us. A ‘controller’ is a company that decides why and how your personal data is processed.
2.2 Where this policy refers to "we", "our" or "us" below, unless it mentions otherwise, it’s referring to the company that is the controller of your personal data. For the purposes of clarity and understanding, The Scotch Whisky Heritage Centre Ltd means The Scotch Whisky Experience and vice versa.
How and what personal data we collect
3.1 We may collect and process the following personal data about you:
Personal data you give to us: This is information about you that you give to us by entering information via our websites or our social media pages or by corresponding with us by phone, email or otherwise and is provided entirely voluntarily. The information you give to us includes your name, contact details (such as phone number, email address and address), enquiry details and your opinion of our products.
Personal data we collect about you: We may automatically collect the following personal data: our web servers store as standard details of your browser and operating system, the website from which you visit our website, the pages that you visit on our website, the date of your visit, and, for security reasons, e.g. to identify attacks on our website, the Internet Protocol (IP) address assigned to you by your internet service. We collect some of this information using cookies – please see Section 8.2 for further information. We may also receive personal data which you allow to be shared that is part of your public profile on a third-party social network.
You can ask us to delete Personal data at any time. Please see Withdrawing Your Consent in Section 7.4 for further details.
How we use your personal data
4.1 Where you have provided CONSENT we may use and process your personal data where you have consented for us to do so for the following purposes:
- to supply brochures and other material you have specifically requested from us; and
- to contact you via email, text message, post or telephone with marketing information about The Scotch Whisky Experience products and services (see Marketing section below for further details).
4.2 You may withdraw your consent for us to use your information in any of these ways at any time. Please see Withdrawing Your Consent in Section 7.4 for further details.
4.3 Where required to perform a CONTRACT with you we may use and process your personal data where it is necessary for the performance of a contract with you or to take steps at your request before entering into a contract with you.
4.4 Where required to comply with our LEGAL OBLIGATIONS we will use your personal data to comply with our legal obligations including:
- to assist HMRC, the Police or any other public authority or criminal investigation body;
- to identify you when you contact us; and
- to verify the accuracy of data that we hold about you.
4.5 Where there is a LEGITIMATE INTEREST we may use and process your personal data where it is necessary for us to pursue our legitimate interests as a business for the following purposes:
- for analysis, and profiling to inform our marketing strategy, and to enhance and personalise your customer or visitor experience;
- for market research to continually improve the products and services that we deliver to you;
- to administer our websites and for internal operations, including troubleshooting, testing, statistical purposes;
- for marketing activities (other than where we rely on your consent) e.g. to tailor marketing communications or send targeted marketing messages via social media and other third-party platforms;
- for the prevention of fraud and other criminal activities;
- to correspond and communicate with you;
- to create a better understanding of you as a customer or visitor;
- for network and information security, enabling us to take steps to protect your information against loss or damage, theft or unauthorised access;
- to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to comply with your request);
- for the purposes of corporate restructure or reorganisation or sale of our business or assets;
- for efficiency, accuracy or other improvements of our databases and systems e.g. by combining systems or consolidating records we hold about you;
- to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings; and
- for general administration including managing your queries, complaints, or claims.
Others who may receive or have access to your personal data
5.1 Our suppliers and service providers.
We may disclose your information to our third-party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud services providers (such as hosting and email management) or advertising agencies, administrative services or other third parties who provide services to us.
When we use third-party service providers, we only disclose to them any personal data that is necessary for them to provide their service.
5.2 Other ways we may share your personal data.
We may transfer your personal data if we’re under a duty to disclose or share it in order to comply with any legal obligation (e.g. by sharing your personal data with the Police), to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers. However, we will always take steps with the aim of ensuring that your privacy rights continue to be protected.
How long we keep your personal data
6.1 If we collect your personal data, the length of time we retain it is determined by several factors, including the purpose for which we use that information and our obligations under other laws. We do not retain personal data for longer than is necessary.
6.2 We may need your personal data to establish, bring or defend legal claims, in which case we will retain your personal data for 1 year after the last occasion on which we have used your personal data in one of the ways specified in How we use your personal data in Section 4.
6.3 The only exceptions to this are where:
- the law requires us to hold your personal data for a longer period, or delete it sooner;
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted in this section 6, or because we are required under the law (see further Erasing your personal data or restricting its processing in Section 7.6); and
- in limited cases, the law permits us to keep your personal data indefinitely provided we put certain protections in place.
7.1 Your rights as a ‘data subject’
You have several rights in relation to your personal data under data protection law. In relation to your exercise of those rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal data. Except in rare cases, we will respond to you within 30 days after we have confirmation of your identity or, where no such information is required, after we have received your request.
7.2 Accessing your personal data
You have the right to ask for a copy of the information that we hold about you and you can achieve this simply by communicating with us and confirming your identity. We may not provide you with a copy of your personal data if this concerns other individuals or we have another lawful reason to withhold that information.
7.3 Correcting and updating your personal data
The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us.
7.4 Withdrawing your consent
Where we rely on your consent as the lawful basis for processing your personal data, as set out in Section 4, you may withdraw your consent at any time by contacting us. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can also do so using our unsubscribe tool. If you withdraw your consent, our use of your personal data before you withdraw is still lawful.
7.5 Objecting to our use of your personal data
Where we rely on our legitimate business interests as the lawful basis for processing your personal data for any purpose(s), as out in Section 4, you may object to our use of your personal data for these purposes by contacting us. Except for the purposes for which we are sure we can continue to process your personal data, we will temporarily stop processing your personal data in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data. You may object to us using your personal data for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool or contact us directly.
7.6 Erasing your personal data or restricting its processing
In certain circumstances, you may ask for your personal data to be removed from our systems. Unless there is a reason that the law allows us to use your personal data for longer, we will make reasonable efforts to comply with your request. You may also ask us to restrict processing your personal data in the following situations:\
- where you believe it is unlawful for us to erase your data;
- you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings; and
- in these situations, we may only process your personal data whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
7.7 Transferring your personal data in a structured data file
Where we rely on your consent as the lawful basis for processing your personal data or need to process it in connection with your contract, as set out in Section 4, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine-readable form, such as a CSV, DOCX or PDF file.
You can ask us to send your personal data directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal data if this concerns other individuals or we have another lawful reason to withhold that information.
7.8 Lodging a complaint with the UK supervisory authority
You have the right to complain to the Information Commissioner’s Office (ICO) if you are concerned about the way we have processed your personal data. Please visit the ICO’s website at https://ico.org.uk for further details.
Security/ Cookies / Links / Social plugins
8.1 Security measures we put in place to protect your personal data
The Scotch Whisky Heritage Centre Ltd uses technical and organisational security measures to maintain the confidentiality, integrity and availability of your personal data. Our security measures are continually improved in line with technological developments.
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 information whilst in transit to our website and any transmission is at your own risk.
Where we have given (or where you have chosen) a password which enables you to access an account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
8.2 Use of 'cookies'
8.3 Links to other websites
In addition, if you linked to our website from a third-party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party website and recommend that you check the policy of that third-party website.
8.4 Social plugins
We use social plugins (buttons) of social networks such as Facebook, Instagram and Twitter.
After their activation, a direct link to the server of the respective social network is established. The contents of the button are then transmitted from the social network directly to your browser and incorporated in the website.
After activation of a button, the social network can retrieve data, independently of whether you interact with the button or not. If you are logged on to a social network, the network can assign your visit to the website to your user account. A social network cannot assign a visit to the website operated by our company unless and until you activate the respective button.
If you are a member of a social network and do not wish it to combine data retrieved from your visit to our website with your membership data, you must log out from the social network concerned before activating the buttons.
We have no influence on the scope of data that is collected by the social networks through their buttons. The data use policies of the social networks provide information on the purpose and extent of the data that they collect, how this data is processed and used, the rights available to you and the settings that you can use to protect your privacy.
9.1 We may collect your preferences to send you marketing information directly from us by email or text message (where applicable) including:
- if you register an account with us online; or
- if you become an Ambassador member.
We will only do so if you have consented to receiving such marketing information directly from us.
9.2 We may contact you with targeted advertising delivered online through social media and platforms (operated by other companies) by using your personal data or use your personal data to tailor marketing to improve its relevance to you, unless you object.
9.3 From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you consent to continue receiving marketing information from us.
9.4 You have the right to opt-out of our use of your personal data to provide marketing to you in any of the ways mentioned above. Please see Section 7.4 and Section 7.5 above for further details on how you can do this.
Changes to this policy
We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website, whichever is the earlier. We recommend you regularly check for changes and review this policy when you visit our website. If you do not agree with any aspect of the updated policy, you must promptly notify us and cease using our services.
If you have any questions, suggestions or complaints about the processing of your personal data or wish to contact us to amend/update your marketing preferences, please contact the Data Protection Officer.
Our Data Protection Officer is Jim Nation. You can contact him by post or by email:
The Scotch Whisky Heritage Centre Ltd