PRIVACY POLICY

Last updated: May 2023

Silk Route Spirits Ltd respects your privacy and is committed to always protecting your personal information in everything we do. We are the data controllers in respect of the personal information which we hold about you. As data controllers, we are responsible for determining the purposes for which we use the information we hold about you. 

In accordance with the General Data Protection Regulation ((EU) 2016/679 / (UK) Data Protection Act 2018) (the “GDPR”), this privacy notice sets out how we use your information while operating our business and sets out your legal rights in relation to the information we hold about you. 

This privacy notice applies to our use of any personal information which we may collect from you through your use of this website, including any information you may provide when you purchase any product or service from us; sign up to our newsletters or take part in any competition or promotion sponsored by us. In addition, this privacy notice applies to our use of any information about you which we may collect from you via face-to-face communication, post, phone, email, social media or any other means of communication (including any form of electronic communication). This privacy notice also applies to any information about you which we may collect from any third party while running our business.

ABOUT US

References in this privacy policy to “we”, “us”, “our” are to Silk Route Spirits Limited company incorporated and registered in the United Kingdom.

CHANGES TO THIS POLICY

We may make changes to this privacy policy from time to time. Any changes will be posted on this page and the date at the top of this privacy policy will be updated accordingly. We recommend that you check this page periodically to review the latest version.

THE INFORMATION WE COLLECT ABOUT YOU

We only collect, use and store data that is necessary to support access to information you may need or to deliver an effective service or product to you. We never knowingly collect information from customers under the age of 18. If we learn that we have collected personal information from anyone under the age of 18 we will delete it immediately.

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

• Identity Data includes [name, title, date of birth and gender].
• Contact Data includes [billing address, delivery address, email address and phone numbers].
• Financial Data includes [bank account and payment card details]. We do not store or transfer financial information as it passed to and handled by the payment processor.
• Transaction Data includes [details about payments to and from you and other details of products and services you have purchased / ordered from us].
• Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes [details of your username as a registered user of our website (note – your password cannot be seen by us and is input by you only to gain access to our website); purchases or orders made by you in relation to any products or services; subscriptions by you to any newsletters or to any products or services we provide; details of any interests, preferences, survey responses, feedback or complaints which you have communicated to us; and details which you have provided in relation to taking part in any competition or promotion sponsored by us.
• Usage Data includes [information about how you use our website, products and services.
• Marketing and Communications Data includes [name, email address, your preferences in receiving marketing materials, promotions and/or newsletters from us and your communication preferences.

We may also be required to process additional information about you from time to time while operating our business where this is necessary for the purposes of administering our business correctly and/or promoting our products and services effectively.

Where we need to collect personal information 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 products or services). In this case, we may have to cancel a product or service you have ordered from us, but we will notify you if this is the case at the time.

HOW YOUR INFORMATION IS COLLECTED

We will mainly collect personal information about you through direct means with you. You may give us your personal information by filling in forms or by corresponding with us through our website or by post, phone, email, social media, or any other means of communication (including any form of electronic communication). This includes personal information you provide when you: 

• order / purchase our products or services.
• register / create an account on our website.
• subscribe to receive our products, services, publications, or newsletters.
• request marketing materials to be sent to you.
• enter a competition, promotion, or survey; or
• provide us with any feedback or other communications.

As you use our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies.

It is important that the personal information we hold about you is accurate and up to date. Please let us know if your personal information changes at any time during your relationship with us.

HOW WE USE YOUR INFORMATION

We will only use your personal information where we have a lawful basis for doing so. Most commonly, we will use your personal information in the following circumstances:

• Where we need to deliver our contract with you to fulfil your order or other services/information you have requested or consented to.
• To ensure that content on the Website is presented in the most effective manner for you and for your computer.
• To allow you to participate in interactive features of the Website.
• Where we need to comply with any legal obligation or regulatory requirement.

We may also use consent as a lawful basis for providing you with marketing communications in certain circumstances. For further details, please see the Marketing section below.

The table below sets out a description of the main ways we plan to use your personal information and which of the relevant lawful grounds for processing we rely on to do so. We have also identified what our legitimate interests where appropriate.

MARKETING

We may use your personal information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, promotions and/or offers may be relevant for you for the purposes of marketing.

You will receive marketing materials from us if you have requested this information from us. You may also receive marketing materials from us if you have purchased products or services from us or engaged in negotiations with us in connection with our products or services, or if you have provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving marketing materials. In these circumstances, we will provide you with marketing materials for the purposes of developing and promoting our products and services and growing our business.

If you have provided us with your details and none of the above circumstances apply, you will only receive marketing materials, email newsletters or email promotions from us in circumstances where you have provided an opt-in consent which confirms that you want to receive such marketing from us. In these circumstances, you have the right to withdraw your consent at any time to the use of your personal information for marketing purposes.

OPTING OUT OF MARKETING

You have the right, at any time, to change your mind to the processing of your personal information for direct marketing purposes. If you wish to opt out of such processing, we will cease to use your personal information for direct marketing purposes.

You can ask us to stop sending you marketing materials at any time by:

• following the opt-out links on any marketing communication, email message or email newsletter sent to you; or
• contacting us by email at cheers@silkroutespirits.co.uk, please mark e-mails with OPT OUT OF MARKETING in the subject

HOW LONG WE RETAIN YOUR INFORMATION

We will retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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

For example, where we no longer require information to be in a format where you can be identified personally, we will remove any personal details and store the data anonymously. Likewise, for purchases made on our website we will store your information for a period of 2 years from your last order or login to assist us with our unlimited returns policy. After this time, you will need to show us proof of purchase. If you wish to use your account after it has been deleted, you will need to create a new account. 

DISCLOSURES OF YOUR INFORMATION

We will never share or sell your data to third parties for marketing purposes and only use your information to provide you with the products or services you have requested from Silk Route Spirits Limited

However, we may need to provide access only to your information to a third party which provide services to us or act on our behalf in connection with the operation of our business. This could include:

• Professional advisers (including legal advisers and financial advisers), auditors, insurers, bankers, and financial organisations.
• Other third party service providers which provide services to us in connection with the operation of our business, including but not limited to: IT and system administration services and other technical services; website development services; data storage services; digital marketing and email deployment services; customer fulfilment services; logistics, distribution and delivery services; data analytics services; fraud prevention and credit reference services; and payment processing and receipt processing services.
• HM Revenue & Customs or any other public authority or regulatory authority in circumstances where we are required to disclose personal information by law.

We require all third-party service providers to respect the security of your personal information and to treat it in accordance with the law. We do not permit our third-party service providers to use your information for their own purposes and only permit them to process your information for specified purposes and in accordance with our instructions.

WHERE YOUR DATA IS STORED

We may store and process any of your personal data both inside and outside of the European Economic Area (“EEA”). 

If we use third party service providers from another country, we shall put in place suitable safeguards to ensure that your information is held securely. If you require further information about the safeguards, put in place you can request it from us by contacting us by email at cheers@silkroutespirits.co.uk, please mark e-mails with DATA STORAGE in the subject heading.

YOUR LEGAL RIGHTS IN RELATION TO YOUR INFORMATION

Under the GDPR, you have a legal right in relation to the personal information which we hold about you. We respect your legal rights in relation to your information and aim to uphold your rights in everything we do. Your legal rights under the GDPR include the following:

• Subject access right – You can ask us to provide you with a copy of the personal information which we hold about you and a description of how we use your information.
• Right to rectification – If you believe any information, we hold about you may be inaccurate or incomplete, you can require us to rectify these inaccuracies.
• Right to erasure / Right to be forgotten – You can require us to erase your information in certain circumstances. However, please note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Right to data portability – Where we process your information using automated means of processing on the basis of your consent or for the purposes of performing a contract with you, you can request that we supply such information to another party in a machine-readable format.
• Right to restriction of processing – You can require us to restrict or suspend our processing of your information in certain limited circumstances.
• Right to object to processing – Where we process your information on the lawful basis that such processing is necessary for the purposes of our legitimate interests, you have the right to object to us processing your information in certain circumstances.
• Right to object to processing for direct marketing purposes – You have the right to object at any time to the processing of your information for direct marketing purposes. If you object to us processing your information for direct marketing purposes, we will no longer process your information for such purposes.
• Right to withdraw consent – If we process your information on the basis of your consent, you have the right to withdraw your consent at any time to the processing of your information. However, please note that this will not affect the lawfulness of any processing of your information carried out before you withdraw your consent.

IF YOU HAVE ANY QUESTIONS OR CONCERNS

Please get in touch if you have any questions about how we use your information, or you wish to contact us about your legal rights or if you have any complaints or feedback about our use of your information. Please contact us at any time by sending an email to us at cheers@silkroutespirits.co.uk, please mark e-mails with GDPR QUESTION in the subject heading.

If you wish to submit a complaint or express any concerns about our use of your information, please contact us in the first instance. We will do our best to resolve your complaint or address your concerns to your satisfaction. You can make this request by email, post, or phone. We will reply within one month from the day after we receive your request, unless this day is a weekend or bank holiday, in which case it will be the next working day. Please note we may need to exclude certain information as part of your request if we are permitted to do so for legal or other reasons.

However, if you feel that we have not resolved your complaint or addressed your concerns, please note that you have right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues.

Please note that we may update this privacy notice at any time. Any changes to this privacy notice will be posted on our website, and where appropriate, notified to you by email.