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Privacy Policy

Liquorette Website Privacy Policy

August 2018

We take your privacy very seriously and we respect your right to privacy when you use our website and our pages on social networks, and whenever else you communicate electronically with us (our “Digital Services”). That’s why we’ve developed this Privacy Policy to explain how we collect, store, use and process the Personal Data you share with us through our Digital Services.

Please read this Privacy Policy carefully as it contains important information on who we are and how and why we collect, store, use and share your Personal Data. It also explains your rights in relation to your Personal Data and how to contact us or supervisory authorities in the event you have a complaint.

“We”, “us” and “our” refer to TYL UK Ltd.

We collect, use and are responsible for certain Personal Data about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that Personal Data for the purposes of those laws.

Before using our Digital Services, please read this Privacy Policy. If you do not agree to this Privacy Policy or our Cookies Policy, please do not use our Digital Services.

We are the controller when processing your Personal Data in the conditions described in this Privacy Policy, which includes any Personal Data you submit to this website (“Website”).

1. What type of information do we collect from you?

Personal Data means any information that can be used to personally identify you or contact you online or elsewhere.

In order for you to take advantage of particular opportunities provided through the Website (for example, to use for the services offered on the Website), we may require that you provide us with Personal Data. We collect and use the following Personal Data from you:

  • your name and contact information, including postal address, telephone number, e-mail address.
  • information to enable us to check and verify your identity, e.g. your date of birth.
  • your name and email address from accounts you link to us, e.g. Facebook.
  • information about how you use our website, IT, communication and other systems.
  • your responses to surveys, competitions and promotions.
  • information provided to us for your attendance at events, including which events you attend as well as information about access or dietary requirements.

2. How your personal data is collected?

We collect most of this Personal Data from you in person, by telephone or email and/or via our Website, for example:

  • when registering your account;
  • when ordering products;
  • when registering or signing up online to a newsletter;
  • when registering to attend events;
  • loyalty schemes and product promotions;
  • entering competitions or prize draws;
  • providing feedback, questions, enquiries, surveys or comments through ‘Contact us’ section;

3. How do we use information collected from you?

Under data protection law, we can only use your Personal Data if we have a proper reason for doing so, e.g.:

  • to comply with our legal and regulatory obligations;
  • for the performance of a contract with you or to take steps at your request before entering into a contract;
  • for our legitimate interests or those of a third party; or
  • where you have given consent.

Generally, the information we collect is only used for any purpose for which you submitted it to us, for any purpose made clear to you at the point it was collected or here in this Privacy Policy. These purposes may include:

  • to fulfill your product order, e.g., to allow you to order products and have it delivered to you or to provide you with information that you request.
  • to send you important information regarding the Website, changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important, you may not opt-out of receiving such communications.
  • to inform you of products, programs, services and promotions that we believe may be of interest to you.r
  • to fulfill your order(s) (e.g., to process credit card payments in connection with your order).
  • to permit you to send messages regarding Website-related content to a friend through the Website. If you wish to use this feature, you may be required to provide us, and we may use, with your friend’s email address.
  • to facilitate your sending of such message to your friend. By using this functionality, you affirm that you are entitled to use and provide us with the recipient's name and email address for this purpose. We will not to use your friend’s Personal Data for any other purpose other than to allow the message to be sent and/or to troubleshoot any issues with respect to the sending of such message, unless we disclose such other purpose.
  • to you at the time you provide such Personal Data to us.
  • to permit you to participate in sweepstakes, contests and similar promotions (collectively, “Promotions”). You should carefully review the rules, if any, of each Promotion in which you participate, as they may contain additional important information about our use of your Personal Data. To the extent that the terms and conditions of such rules concerning the treatment of your Personal Data conflict with this Privacy Policy, the terms and conditions of such rules shall control.
  • to customize content on our Website (e.g., the restaurants that will deliver to your location).
  • for our internal business purposes, such as data analysis, audits, developing new products, enhancing our website, improving our services, identifying usage trends and determining the effectiveness of our promotional campaigns.
  • IP Addresses. We use IP addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site. We may also use and disclose IP Addresses for all the purposes for which we use and disclose Personal Data. Please note that we treat IP Addresses, server log files and related information as Non-Personal Data, except where we are required to do otherwise under applicable law.

When you submit your Personal Data, you may also be given the option (through a tick box or other consent mechanism) to have your information used for an activity or service different from the one you are requesting. For example, if you enter a contest to win a prize, you may also be invited to sign up for a newsletter about other products. If you choose to have your information used for another activity or service in this way we will use your information to provide them to you.

In addition, when you submit your Personal Data, you may be given the option (through a tick box or other consent mechanism) for your information to be used for other products. If you choose this option we will use your information to provide you with information and promotions regarding other products.

We may also use your email address to send you transactional or administrative communications such as confirmation emails when you sign up for, or unsubscribe from, a specific registration or activity or make an order for products. We may also use it for certain service-related announcements, such as updates to our Privacy Notice, discontinued features or programs on our Digital Services, changes to our online services or technical support policies.

Legitimate interests - managing our business

In relation to a number of uses of Personal Data we refer to above we are doing this on the basis that it is in our legitimate interests – or those of a third party – for us to do so. A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. These interests cover a number of aspects of our business operations, namely:

  • Ensuring that we are as efficient as we can be so we can deliver the best Digital Service and products for you that we can and understanding our customers and the users of our Website;
  • To allow us to provide bespoke Digital Services and products where requested by you, to personalise your experience and to tailor the content, offers and promotions we send to you promoting our products and services;
  • Protecting our commercially valuable information and also our intellectual property;
  • Preventing and detecting fraud and/or criminal activity that could be damaging for us and for you;
  • Understanding how our business is performing and considering how to improve our performance; and
  • Ensuring we are able to keep up to date with our customers and contacts and developments in their organisations.

4. How is personally identifiable information disclosed

We may disclose Personal Data:

  • to our affiliates so that they may use such Personal Data for the purposes described in this Privacy Policy. TYL UK Ltd. is the party responsible for the management of the jointly-used Personal Data.
  • to our third-party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, delivery services, infrastructure provision, IT services, customer service, e-mail delivery services, credit card processing and other similar services to enable them to provide services.
  • as required to fulfill your purchase.
  • to identify you to any person to whom you send messages regarding Website-related content through the Website.
  • to third parties sponsors of promotions (irrespective of whether such promotions are hosted by us), or otherwise in accordance with the rules applicable to such promotion. You should carefully review the rules, if any, of each promotion in which you participate, as they may contain additional important information about a sponsor's or other third parties' use of your Personal Data. To the extent that the terms and conditions of such rules concerning the treatment of your Personal Data conflict with this Privacy Policy, the terms and conditions of such rules shall control.
  • to an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
  • as we believe to be appropriate: (a) under applicable law including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain.

5. What happens if you do not wish to share your personal data with us?

If you choose not to submit any Personal Data when requested, you may not be able to participate in certain activities or use some of the personalised features of our Digital Services. This may also limit the services and special offers we can provide you. For example, if you refuse to share your email address, you will not be able to order any products, receive any of our newsletters or otherwise register for our Digital Services. However, you do not need to give us any Personal Data to simply browse our websites and learn more about us and our products.

6. Who do we disclose your personal data to and why?

We will never share your Personal Data with any third party that intends to use it for direct marketing purposes, unless we have specifically told you and you have given us explicit permission to do this.

If you wish to withdraw your consent to such sharing and use of your information, please address your request as indicated in Section 10 of this Privacy Policy.

We may also share your Personal Data with other third parties, but only in the following circumstances:

  • We may use third parties to help deliver our products or Digital Services to you, e.g. payment service providers, warehouses and delivery companies;
  • We may share your Personal Data with third parties who provide programmatic advertising services to serve you with relevant advertising;
  • We may use service providers, agents or contractors e.g. marketing and digital agencies to support the internal operation of our Digital Services, and to assist us with administering them or the various functions, programs and promotions available on them. Any such third party must provide appropriate levels of security for your Personal Data and, where required, are bound by a legal agreement to keep your Personal Data private, secure and to process it only on our specific instructions;
  • When we run a joint or co-sponsored program or promotion on our Digital Services with another company, organisation, or other reputable third party, we may collect and process Personal Data and share it with that partner or sponsor as part of the event. If your Personal Data is being collected by (or is shared with) a company other than us as part of any such promotion, we will let you know at the time it is collected;
  • When we run a promotion in partnership with a third party, we may provide a separate link to their privacy policy which you should read before you share any Personal Data. The operators of other sites may collect information from you which will be used by them in accordance with their own data protection policy or privacy policy. If you do not want your information to be collected by or shared, you can choose not to opt in or participate in these events at the time the Personal Data is collected or requested;
  • We may also disclose your Personal Data if we are required to do so by law or by law enforcement agencies or regulatory bodies, or if such action is necessary to comply with legal or regulatory processes, to respond to or pursue any claims, or to protect the safety or rights of us, our employees, customers, or the public;
  • In the event of a merger or acquisition of all or part of us by another company, or in the event that we were to sell or dispose of all or a part of our business. In this case the acquirer would have access to the information maintained by us, which could include Personal Data, subject to applicable law. Similarly, Personal Data may be transferred as part of a corporate reorganisation, insolvency proceeding, or other similar event, if permitted by and done in accordance with applicable law;
  • We may share aggregated demographic or survey information with third parties, but this information is in anonymous form and does not contain any Personal Data. The aggregate information that we share may include anonymous information that is captured through the use of cookies and other similar tracking technology, as explained in Section 2.

7. Is your personal data sent to recipients located in other countries and why?

We are a global group and your Personal Data may be transferred across international borders. It may be transferred to countries that have different data protection laws to the country from where you submitted your Personal Data.

We will, however, ensure the transfer complies with data protection law both during transit and at the storage location and all Personal Data will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.

Some of our service providers for the operation of our Digital Media are based in the United States. The transfers of personal data to these services providers are implemented in accordance with applicable laws and rely on standard contractual clauses as set out by the European Commission or on the EU-US Privacy Shield. Such service providers are also bound by a contract that ensures a high standard of privacy protection and requires (amongst other provisions) that they act only on our instructions and implement technical measures necessary on an ongoing basis to keep your Personal Data secure.

8. How long do we keep your personal data?

We may store the Personal Data that you send to us via our Digital Services in our databases. We will not retain your Personal Data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of Personal Data.

We retain your Personal Data as long as your account is active, for the duration of a contract with you or however long it takes to provide you with the products or services requested, to answer queries or resolve problems, to show that we treated you fairly, to keep records required by law and to improve or offer new services.

We may also need to retain your Personal Data to comply with our legal and regulatory obligations, resolve disputes, enforce our agreements, and similar records management purposes.

We may also retain your Personal Data for a reasonable period after you stop using our services or our Digital Services. After this period, your Personal Data will be deleted from all.

If you ask us to delete your information in accordance with your rights set out in Section 10 below, we will retain basic information on a suppression list to record your request and to avoid sending you unwanted materials in the future.

9. How do we keep your personal data secure?

We have appropriate security measures to prevent your Personal Data from being accidentally lost, or used or accessed unlawfully. These include: (i) storing your Personal Data in secure operating environments that are not available to the public and that are only accessible to authorised employees, our agents and contractors; and, (ii) verifying the identities of registered users before they can access Personal Data we store about them.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

10. Your rights

You have the following rights, which you can exercise free of charge:

You can ask us to:

  • provide a copy of your personal data (the right of access) including the categories of data that are used in profiling or decision making processes.
  • correct any mistakes in your personal data including in the profile.
  • delete your personal data - in certain situations.
  • restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data.
  • provide you with a copy of the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.

You can object:

  • at any time to your personal data being processed for direct marketing including profiling;
  • in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.

You can also contest the result of an automated decision.

If your Personal Data has been processed on the basis of your consent, you can withdraw your consent at any time.

We hope that we can resolve any query or concern you may raise about our use of your information. You also have the right to complain to the supervisory authority in the European Union where you work, normally live or where any alleged infringement of data protection laws occurred.

If you would like to exercise any of your rights please email us on [email protected]

Your objection (or withdrawal of consent) may mean we cannot provide the products or services you have requested of us or you may not be able to use the services we offer. We will advise you where this is the case. In certain circumstances even if you withdraw your consent we may still be able to process your Personal Data if required or permitted by law or for the purpose of exercising or defending our legal rights or meeting our legal and regulatory obligations.

If you participated in a program that involved a third party and you agreed to receive communications from that third party, you will need to contact them directly to opt-out. This process should be outlined in the third party’s privacy policy.

11. Changes to this privacy policy

We may change this Privacy Policy from time to time, so please check back regularly to keep informed of updates to this Privacy Policy and our Cookies Policy.