Privacy & Cookie Policy

Introduction

This privacy & cookie policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us when you use our website.

It is important that you read this privacy & cookie policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy & cookie policy supplements other notices and privacy policies and is not intended to override them.

We may revise this privacy & cookie policy at any time by amending this page. You are expected to visit this page from time to time to note any changes we make, as they affect you. This privacy & cookie policy was last updated on 17 January 2020.

About us

This is the privacy & cookie policy of Boe Gin Limited (“we”, “our”, “us”) with registered number SC626835. When we collect and use your personal data in the way set out in this privacy & cookie policy, we are the controller for the purpose of data protection law.

Contact us

If you have any questions about this privacy & cookie policy, or how we handle your personal information, please contact us at:

• Tel: +44 (0) 1786 817000
• Email: info@boegin.com

Personal data we may collect from you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data - this includes first and last names, your age, and details of the business you represent (if applicable).
• Contact Data - this includes billing address, delivery address, email address and telephone numbers (business and / or personal).
• Financial Data - this includes payment card details relating to products you receive from us.
• Transaction Data - this includes details about payments from you and other details of products you have purchased from us.
• Supplementary Information - this includes any information that you decide to provide us when you contact us with queries, complete surveys or questionnaires, enter competitions sponsored by us, or when you include instructions with your order.

How we collect data

We use different methods to collect personal data from and about you including through:

• Direct interactions. You may give us your personal data by filling in forms, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • order products;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website or social media platforms, we will automatically collect data using cookies and other similar technologies. This is usually anonymised data.
• Third parties. We may receive personal data about you from third parties who provide services on our behalf (discussed below).

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you (“Contractual Necessity”).
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (“Legitimate Interests”).
• Where we need to comply with a legal obligation (“Legal Obligation”).

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our Legitimate Interests are where appropriate.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To process your order, and delivery your ordered products to you.	Identity Data Contact Data Financial Data Transaction Data Supplementary Data	Contractual Necessity.
To ensure that you are of the appropriate age to order products from us.	Identity Data	Contractual Necessity. Legal Obligation
To answer your queries	Identity Data Contact Data Transaction Data Supplementary Data	Contractual Necessity. Legitimate Interest – of dealing with and responding to your query.
To receive feedback on our services and products.	Identity Data Contact Data Supplementary Data	Legitimate Interest – of improving our services and products.
To operate any competitions sponsored by us.	Identity Data Contact Data Supplementary Data	Legitimate Interest – of dealing with and operating a competition.
To send our newsletter to you.	Identity Data Contact Data Transaction Data Supplementary Data	Consent

We do not collect 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 your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods). In this case, we may have to cancel delivery of a product but we will notify you if this is the case at the time.

You must not provide us with your personal information if you are not of legal age to purchase alcohol in the jurisdiction in which you reside and (if different) in the jurisdiction in which you are accessing the website. 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.

Sharing of personal data

We contract with third party service providers and suppliers to deliver certain services. We may use the following types of providers:

1. our providers who host and maintain this website;
2. our digital marketing agency;
3. our IT and cloud providers;
4. our providers who handle orders and delivery on our behalf;
5. any providers who handle questionnaires, or competitions on our behalf;
6. our providers who process payments on our behalf.

Our service providers change from time to time and we will inform you if this is the case by updating this privacy policy. Currently we use Mailchimp to send our newsletter (please see Mailchimp’s privacy policy at: https://mailchimp.com/legal/privacy/) and Shopify to operate the online shop (please see Shopify’s privacy policy at: https://www.shopify.com/legal/privacy).

Boe Gin Limited is part of a group structure, and therefore your personal data may be shared with other companies within the group (all based in the UK).

We will also provide your personal information to third parties where there is a legal obligation to do so, for example to regulators, government departments, law enforcement authorities, tax authorities and any relevant dispute resolution body or the courts.

We may also provide your personal information to third parties in connection with any sale, merger, acquisition, disposal, reorganisation or similar change in our business.

We will provide information about you to any other person who is authorised by you to act on your behalf.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Storage of your data

The data that we collect from you will usually be stored inside the UK or the EU.

However, if you live or work outside of the UK or the EU, we may need to transfer your personal data outside of the UK or the EU to correspond with you. Where this applies, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

We also may transfer data outside the UK or the EU where our, service providers host, process, or store data outside the UK or the EU. Where we do this, we will ensure that the transfer is to a country covered by a decision of the Commission of the European Union or is otherwise made in circumstances where we have put appropriate safeguards are in place to protect your data in accordance with the data protection laws.

Our service providers change from time to time and we will inform you if this is the case by updating this privacy policy. Currently we use Mailchimp to send our newsletter (please see Mailchimp’s privacy policy at: https://mailchimp.com/legal/privacy/). Mailchimp is a US based company and is registered with the EU-US Privacy Shield. We also currently use Shopify to operate the online shop (please see Shopify’s privacy policy at: https://www.shopify.com/legal/privacy). Shopify is also a US based company and is registered with the EU-US Privacy Shield.

Retention periods

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you, or if we are required to hold on to it for longer for legal or regulatory purposes.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You can exercise you rights by contacting us.

You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We may not always be able to comply with your request to exercise your rights for specific legal reasons which will be notified to you.

Further details about your rights can be found on the ICO’s website at https://ico.org.uk/

Complaints

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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

We use the following cookies:

Name	Purpose	Duration	Third party access/use
Boeageverification - the Age Verified Cookie works in tandem with the Age Verification Trigger.	To confirm your age to ensure you are an appropriate age to visit the website. A user will not be able to access the website until they verify they are an appropriate age.	Expires once the user has left the website.
phpsessid	This is a default cookie used to identify the current session in PHP	Ongoing	PHP
Google Analytics   _utma	This cookie is used to determine unique visitors to the website.   Additionally, this cookie is provided with a unique ID that Google Analytics uses to ensure both the validity and accessibility of the cookie as an extra security measure.	Updated with each page view.	Google   Please see Google’s privacy policy and terms at: https://policies.google.com/privacy?hl=en   https://policies.google.com/terms?hl=en-US
Google Analytics   __utmb	This cookie is used to establish and continue a user session with the website. When a user views a page on the website, the Google Analytics code attempts to update this cookie. If it does not find the cookie, a new one is written and a new session is established.	Each time a user visits a different page on the website, this cookie is updated to expire in 30 minutes, thus continuing a single session for as long as user activity continues within 30-minute intervals.   This cookie expires when a user pauses on a page on the website for longer than 30 minutes.	Google   Please see Google’s privacy policy and terms at: https://policies.google.com/privacy?hl=en   https://policies.google.com/terms?hl=en-US
Google Analytics   __utmc	This cookie operated in conjunction with the __utmb cookie to determine whether or not to establish a new session for the user.	Each time a user visits a different page on the website, this cookie is updated to expire in 30 minutes, thus continuing a single session for as long as user activity continues within 30-minute intervals.   This cookie expires when a user pauses on a page on the website for longer than 30 minutes.	Google   Please see Google’s privacy policy and terms at: https://policies.google.com/privacy?hl=en   https://policies.google.com/terms?hl=en-US
Google Analytics   __utmz	This cookie stores the type of referral used by the visitor to reach the website, whether via a direct method, a referring link, a web site search, or a campaign such as an ad or an email link. It is used to calculate search engine traffic, ad campaigns and page navigation within the website.	The cookie is updated with each page view to the website by a user.	Google   Please see Google’s privacy policy and terms at: https://policies.google.com/privacy?hl=en   https://policies.google.com/terms?hl=en-US
Google Analytics   _ga	This cookie is used to distinguish unique users by assigning a randomly generated number as an identifier. It is included in each page request in website and used to calculate visitor, session and campaign data for the sites analytics reports.	The cookie is updated with each page view to the website by a user.	Google   Please see Google’s privacy policy and terms at: https://policies.google.com/privacy?hl=en   https://policies.google.com/terms?hl=en-US
Google Analytics   _gid	This cookie is responsible for tracking user behaviour.	It expires after 24 hours of inactivity.	Google   Please see Google’s privacy policy and terms at: https://policies.google.com/privacy?hl=en   https://policies.google.com/terms?hl=en-US
Facebook pixel	Advertising retargeting	Ongoing	Facebook   Please see Facebook’s privacy policy and terms at:   https://en-gb.facebook.com/policy.php   https://en-gb.facebook.com/legal/terms