PRIVACY AND COOKIES POLICY
WHO WE ARE
Naked Grouse is owned by Highland Distillers Limited, a private limited company (registered in Scotland No. 158731), and our registered office is at 100 Queen Street, Glasgow G1 3DN.
HOW WE PROTECT YOUR PERSONAL DATA
Naked Grouse is committed to keeping your personal data safe and secure and to protecting and respecting the privacy of your personal information. To prevent unauthorised access, maintain data accuracy and ensure the correct usage of your personal data, we monitor and adjust our procedures to safeguard and secure the personal data we collect online.
- what type of personal data we collect
- when we collect your personal data
- how we use your personal data
- our legal reasons for holding personal data
- who we share your personal data with
- how long we keep personal data for
- what rights and choices you have with regard to your personal data
WHAT TYPES OF PERSONAL DATA DO WE COLLECT ABOUT YOU?
We collect the following types of personal data:
- your name, age/date of birth (for age verification purposes only) and location
- your contact details (postal addresses including billing and delivery addresses) and contact telephone numbers
- details of orders you place through our online shop
- your payment card details, when you make a purchase or place an order with us
- your correspondence and communications with Naked Grouse
- personal data which you may have shared via a public platform (such as on our Facebook pages or Instagram feeds)
- your communication and marketing preferences
- your interests, preferences, feedback and survey responses
- your online browsing activities on our website
WHEN AND WHERE DO WE COLLECT YOUR PERSONAL DATA?
We collect your personal data when you:
- sign up to receive news or updates from Naked Grouse
- [place an order for our products or merchandise from our online shop]
- enter a ballot for the opportunity to purchase a Naked Grouse product
- enter a competition related to Naked Grouse or one of our products (including merchandise)
- attend one of our events or visit one of our sites
- contact us with any customer service enquiries
HOW DO WE USE YOUR PERSONAL DATA?
Naked Grouse (and trusted partners acting on our behalf) use your personal data:
- to provide you with information, products or services that you request from us, or which we feel may interest you (but only when you’ve given your consent to be contacted by us)
- to allow us to send you personalised communications based on your preferences and use of our products
- to verify your identity and your age
- for crime and fraud prevention, detection and related purposes
- to enable us to manage any customer service interactions with you
- to ensure that our web content is presented in the most efficient way for you and your computer
- to allow you to participate in interactive features on our website, when you choose to do so
- where we have a legal right or duty to use or disclose your information (for example, in relation to an investigation by a public authority or in a legal dispute)
WHAT IS OUR LEGAL REASON FOR HOLDING PERSONAL DATA?
Data protection laws require us to state our legal reason for processing your personal data. We need your consent to send you marketing communications about Naked Grouse and you can
withdraw your consent to receive these communications at any time by using the unsubscribe button included in the communications we send you, or by contacting us at [email protected]
We also collect and use your personal data because it is necessary for:
- the pursuit of ‘our legitimate interests’ (as set out below)
- the purposes of complying with our duties and exercising our rights under a contract for the sale of goods to a consumer
- compliance with our legal obligations
Our legitimate interests
The normal legal basis for processing consumer data, is that it is necessary for Naked Grouse’s legitimate interests, including:
- selling and supplying goods to our consumers
- protecting our consumers, employees and other individuals and maintaining their safety, health and welfare
- promoting, marketing and advertising our products
- understanding our consumers’ behaviours, activities, preferences, and needs
- improving existing products and developing new products
- complying with our legal and regulatory obligations
- handling consumer contacts, queries, complaints or disputes
- preventing, investigating and detecting crime, fraud or anti-social behaviour, and prosecuting offenders
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
To effectively fulfill our obligations to you, and to provide you with certain benefits, we use a number of trusted and reliable third parties to carry out functions that involve the processing of your personal data. These include IT, delivery and marketing service providers.
We use marketing service providers to administer services on our behalf, such as sending communications to you and administering any competitions, promotions or ballots that we run.
Some of the third party service providers we use may be based outside the European Economic Area, but we will only transfer personal data to these service providers where we are satisfied that adequate levels of protection and security controls are in place to protect your personal data. We impose contractual obligations on service providers relating to data protection and security, which mean that they can only use your personal data to provide services to Naked Grouse or to you, and for no other purpose.
We may provide information to others (such as governmental or law enforcement agencies) in the good faith that such action is necessary to:
(i) enforce or apply our Terms and Conditions
(ii) comply with any legal claims raised against Naked Grouse
(iii) protect the rights, property or safety of Naked Grouse
(iv) protect the rights, property or safety of the public
If Naked Grouse become involved in a merger, acquisition, bankruptcy or other transaction involving the sale of some or all of our assets, user information (including personal information collected from you through your use of our website) could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you, either through email and/or a prominent notice on our website.
WHAT ARE YOUR RIGHTS?
You have a number of rights under the Data protection laws in relation to the way we process your personal data, namely:
- to access your data
- to have your data rectified if it is inaccurate or incomplete
- in certain circumstances, to have your data deleted or removed
- in certain circumstances, to restrict the processing of your data
- a right of data portability, namely to obtain and reuse your data for your own purposes across different services
- to object to direct marketing
- not to be subject to automated decision making (including profiling), where it produces a legal effect or a similarly significant effect on you
- to claim compensation for damages caused by a breach of the Data Protection Laws
If you wish to exercise any of these rights, please contact [email protected]
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will not retain your personal data for longer than necessary for the purposes set out in this Policy. Different retention periods will apply to different types of data.
If you have any questions or concerns about the way in which your personal data is processed, please contact [email protected]
You have the right to complain about data protection matters to the Information Commissioner’s Office (ICO). The ICO is the UK’s independent body set up to uphold information rights. You can find out more about the ICO on its website (https://ico.org.uk/) or contact them by calling 0303 123 1113.
COOKIES AND HOW WE USE THEM
Cookies are small files that are downloaded to your computer or mobile device when you browse certain websites. Cookies contain information that is transferred to your computer’s hard drive. If you’d like to find out more about cookies and how they work, please visit allaboutcookies.org.
By using our website, you agreed that we can place the following cookies on your device:
|TYPE OF COOKIE
||CATEGORY & DESCRIPTION
|Age Gate Cookie
||Strictly Necessary Cookies
This type of cookie is essential to enable you to move around our website and use its features.
|We use the Age Gate Cookie to verify both your country and age to confirm that you are old enough to view our site content.
These cookies collect information about how our visitors use our website.
|This analytical tool allows us to track which parts of our site you visit and also tells us which websites you came from to get to our website, to help us improve the functionality and experience of our website. All information collected by this cookie is aggregated and is therefore anonymous. However, if you’d like to opt out of being tracked by Google Analytics across all the websites you visit, go to tools.google.com/dlpage/gaoptout
This type of cookie is used to remember customer selections that change the way our site behaves or looks.
|At your request we may place a cookie to remember your preferences so that you do not need to re-enter your details (country/age and language).
|Links to other social networking sites
||Third Party Cookies
These cookies enable users to access third party sites.
|To provide you with a quick link to social networking sites such as Twitter and Facebook, we embed external cookies from third parties within our website. You can view the cookie usage policy of these third parties on their own websites.
|Google AdSense / DoubleClicks
||Remarketing /Customised Advertising
These cookies are used to advertise on third party websites (including Google) to previous visitors to our site, as well as to develop remarketing lists for customised campaigns.
|To serve advertising based on a user’s previous visit to our website.
You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to opt out of interest-based advertising entirely by changing your cookie settings or permanently using a browser plugin.
||Remarketing /Customised Advertising
These cookies are used to deliver advertising relevant to you or audiences with similar preferences.
Naked Escape Competition - Terms and Conditions
The Naked Escape promotion is run by Naked Grouse. It offers entrants the opportunity to discover their ‘Naked persona’ by answering 5 multiple choice questions hosted on http://NakedGrouse.com, providing a valid email address, their date of birth, country of residence and a public Instagram handle. In doing so they will be entered into a prize draw to win a Naked Escape in Scotland [for four people] for a two-night stay, with activities tailored to their persona. Please see below for full terms and conditions.
- The promoter is Naked Grouse, Highland Distillers Limited (company no. SC15873) whose registered office is at 100 Queen Street, Glasgow, G1 3DN. (“Naked Grouse”).
- The competition is open to residents aged 18 or over and over the legal drinking age in the entrant’s country of residence except employees of Edrington Distillers Limited, Highland Distillers Limited, or any employees of any third parties currently engaged by The Edrington Group of companies, and their immediate relations, and anyone else otherwise connected with the organisation or judging of this competition.
- Winning entrants can select three other people from their own country of residence to accompany them on the trip. This person must be 18 or over and of legal drinking age in the country of their residence. (the “Accompanying Entrants”)
- Naked Grouse will require proof of age and photographic identification of the Winner and the Accompanying Entrants. Failure to provide age verification may result in entrants being disqualified from the Competition.
- There is no entry fee and no purchase necessary to enter this competition.
- By entering this competition, an entrant is deemed to have read and understood and accepted to be bound by these terms and conditions.
- By participating in the Naked Grouse Escape, each of the Accompanying Participants are deemed to have read and understood and accepted to be bound by these terms and conditions.
- Route to entry for the competition and details of how to enter are via [http://NakedGrouse.com]
- Only one entry will be accepted per person. Multiple entries from the same person will be disqualified.
- Naked Grouse will accept no responsibility for any incomplete entries or entries that do not comply with these terms and conditions in any way.
- The competition will open on 22 May 2019 and will close for entry on 10 July 2019, at 11:59PM GMT. After this date, no further entries to the competition will be permitted or accepted.
- No responsibility can be accepted for entries not received for whatever reason.
- Bot activity or suspected bot activity will result in entries being disqualified.
- Naked Grouse will share your personal details with Naked Grouse’s third party suppliers (including Made Brave and Stripe Communications) to allow the trip to be delivered in Scotland.
- Naked Grouse reserves the right to cancel or amend the competition and these terms and conditions without notice at any time and particularly in the event of a catastrophe, war, civil or military disturbance, act of God or any actual or anticipated breach of any applicable law or regulation or any other event outside of Naked Grouse’s control.
- Naked Grouse shall have the right, at its sole discretion and at any time, to change or modify these terms and conditions, such change shall be effective immediately upon posting to this webpage. (https://nakedgrouse.com/). Any changes to the competition will be notified to existing entrants as soon as possible by Naked Grouse.
- This promotion is in no way sponsored, endorsed or administered by, or associated with, Facebook, Instagram or any other Social Network.
- The prize is as follows: Travel to and from Scotland in August 2019, a two-night stay in the Naked Grouse Naked Escape pod with meals, drinks and tailored experiences provided throughout. Transport to and from Naked Escape experience to closest Airport provided throughout including return travel home.
- At the time of your entry, you must be able to qualify that you and the Accompanying Entrants are physically able to travel to Scotland; otherwise you must forfeit the prize. If your health circumstances change in the run up to the competition date, you must notify Naked Grouse immediately.
- Entrants and Accompanying Entrants are responsible for any costs associated with extending their stay after the Naked Escape. Entrants and Accompanying Entrants are responsible for ensuring they have taken out the appropriate travel and health insurance for this trip.
- The prize is as stated and no cash or other alternatives will be offered. The prizes are not transferable. Prizes are subject to availability and we reserve the right to substitute any prize with another of equivalent value without giving notice.
- Winners will be chosen at random and will be notified on the email provided on entry within 5 days of the closing date. If the winner cannot be contacted or does not claim the prize within 7 days of notification, we reserve the right to withdraw the prize from the winner and pick a replacement winner.
- Naked Grouse will then notify the winner of prize details and make arrangement for fulfilment directly.
- The competition and these terms and conditions will be governed by Scots law and any disputes will be subject to the exclusive jurisdiction of the courts of Scotland.
- By submitting an entry, and by agreeing to participate in the Naked Grouse Escape the Entrant and Accompanying Entrants agrees to Naked Grouse’s use, of their names and images in any publicity material, as well as use, reposting or repurposing their entry. Any personal data relating to the winner or the Accompanying Entrants will be used solely in accordance with current data protection legislation in the UK and will not be disclosed to a third party without the entrant’s, or Accompanying Entrants, as applicable, prior consent.
- The winner of this Trip and the Accompanying Entrants agrees to Naked Grouse taking photographs of the Winner and Accompanying Entrants and to use these in future marketing and promotional materials.
- The promoter is not responsible for inaccurate prize details supplied to any entrant by any third party connected with this competition.
- If Naked Grouse believe there has been any breach of these terms and conditions or incorrect, illegible, fraudulent or other invalid or improper information has been provided, or the Winner or any of the Accompanying Entrants have breached Naked Grouse’s brand values, including but not limited to responsible drinking, Naked Grouse may at its sole discretion refuse to process an entry or to award the Prize.
- Naked Grouse will not be held liable to any Accompanying Entrant or winner for any fraud committed by any third party not in an event beyond its control.