Privacy Policy

Who we are

The Famous Grouse is ultimately owned by The Edrington Group Limited, a private limited company (registered in Scotland No. 36374), and our registered office is at Edrington, 100 Queen Street, Glasgow G1 3DN. Processing of personal data relating to the Famous Grouse is also undertaken by other group companies of Edrington – follow the link for additional details of these companies. 

In this Privacy Policy, the Edrington Group Limited and the relevant group companies are referred to as Edrington, we, us or our.

Edrington is the controller in relation to the processing of your personal data described in this Privacy Policy. We have a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your rights in relation to your personal data, please contact us at the details set out below.

Overview

Edrington is committed to protecting and respecting the privacy of its consumers’ personal data.   Looking after the personal data that we collect on our consumers is a priority for us and we want you to be confident that your information is in safe hands.  We’ve developed this Privacy Policy to let you know:

• What types of personal data we collect;
• How we collect personal data;
• The purposes we collect personal data for, including how we use it to make our products better and to offer better services and experiences to our consumers;
• The circumstances in which we may share it with other organisations that support our operations, including the types of organisations involved;
• Where we store your personal data;
• How long we keep personal data for; and
• The rights and choices you have with regards to your personal data. 

It is important that you read this Privacy Policy together with any other privacy policy or fair processing 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 Policy supplements other notices and privacy policies and is not intended to override them.

What types of Personal Data do we collect about our Consumers?

• Your name, age/date of birth (for age verification purposes) and location;
• Your contact details: postal addresses including billing and delivery addresses, contact telephone numbers and email address;
• Details about payments to and from you and other details of purchases, orders made by you, including your purchase history and ballots you have submitted for the purchase of The Famous Grouse’s products;
• When you make a purchase or place an order with us, your payment card details;
• Details of any event or experience bookings you have made, including details you have provided or we may have collected from you in connection with your attendance at any events or experiences we have arranged with you (such as any accessibility or dietary requirements or other interests related to the event or experience);
• Your 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 the website (Technical Data);
• Information about how you use our website, products and services (Usage Data);
• Your correspondence and communications with The Famous Grouse;
• Personal data which you have maybe shared via a public platform (such as on The Famous Grouse’s Facebook or Instagram feed);
• Your preferences in receiving marketing from us and our third parties and your communication preferences;
• Information which may be collected or generated by our customer engagement personnel and/or representatives, or when you participate in an online experience, such as:
  • preferences regarding our products and offerings including any "wish list" items regarding preferred The Famous Grouse products and experiences and how you share your experiences and passion for The Famous Grouse with others;
  • lifestyle preferences and interests such as preferred travel destinations, preferred restaurants / cuisines and whisky and drink preferences / collection;
  • social indicators such as your profession and connections;
  • engagement data such as when you open or click on our emails, how long you have been a consumer of The Famous Grouse, and how you interact with our personnel /representatives;
  • communication channel preferences (e.g. social media handles and app-based messaging) such as LinkedIn, Facebook, Twitter, WeChat and WhatsApp;
• Information about any experiences, gifts, special invitations or benefits made available to you;
• Your interests, preferences, feedback and survey responses; and
• Online browsing activities on The Famous Grouse’s website.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

Other than the data listed above, 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, biometric data).

Where we need to collect personal data by law, 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 (e.g. to provide you with goods or services). In this

How do we collect your personal data?

We collect your personal data by different methods, including:

• Direct interactions: This includes personal data you provide when:
  • You subscribe to receive our newsletter;
  • You create an account on our website or participate in one of our online experiences;
  • You make an online purchase or place an order online for a Famous Grouse product or merchandise;
  • You enter a ballot or competition related to The Famous Grouse or one of The Famous Grouse’s products;
  • You attend one of our events, visit one of our sites (e.g. our distillery) or you avail of one of our experiences (e.g. whisky tastings, dinning and food, and other bespoke or exclusive experiences);
  • You interact with one of our representatives;
  • You communicate with us through telephone, text messaging, or other app-based or social media direct messaging; and
  • You contact us, for whatever reason.
• Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We may also gather statistical information on emails sent to you (e.g. opens, clicks, delivery rates, unsubscribes and forwards). This helps us to assess and improve email performance and our engagement with you. We collect this personal data by using cookies, pixels and other similar technologies. Please see the section below on ‘Cookies’ for further details.
• Third party sources of information: We may obtain information about you from the following third party sources:
  • Where you interact with a third party acting on our behalf (e.g. a representative of one of our distributors or joint venture partners);
  • Our professional advisors (e.g. lawyers, accountants and bankers); and
  • Publicly available sources (e.g. how you share your experiences and passion for The Famous Grouse with other on social media and retailers of The Famous Grouse).
• Technical Data: We also collect Technical Data from the following third parties:
  • Analytics providers (such as Google based outside the UK and/or EU);
  • Advertising networks; and
  • Search information providers.

Online analytics

We use various types of online analytics, including Google Analytics, a web analytics service provided by Google, Inc. (Google), on our website. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the website, compile reports on the related activities, and provide other services related to website and app activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website or app. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google click here.

Surveys

From time to time, and subject to your consent where required by applicable local law, we may provide you with the opportunity to participate in surveys, some of which might be sponsored or conducted by a third party. Participation in these surveys is completely voluntary. If you choose to participate, we will request certain personal data from you. If there is a third party sponsor involved in the survey, we may provide certain personal data to the third party sponsor. Please make sure to review the sponsor’s privacy policy and be aware that any surveys offered by us may be governed by specific rules and terms and conditions that are separate from and in addition to this Privacy Policy. By participating in any such surveys you will become subject to those rules, including but not limited to receiving emails containing survey communications.

How do we use your personal data?

Edrington (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. This is only done when you’ve given your consent to be contacted by us, or where we are permitted to contact you in accordance with data protection law (such as where you have not opted-out of receiving such information from us at the time of making a purchase from us);
• We may send you personalised communications based on your preferences, and use of The Famous Grouse’s products;
• To verify your identity and your age;
• For crime and fraud prevention, detection and related purposes;
• To enable Edrington 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; and  
• Where we have a legal right or duty to use or disclose your information (e.g. in relation to an investigation by a public authority or in a legal dispute).  

We may also combine your personal data collected through various sources, including information collected through our website and services, and develop a profile that will be used for the purposes above.

What is our legal reason for holding personal data? 

Data protection laws require us to state our legal reason for processing your personal data.  

Where we have requested your consent, we will rely on this consent to send you marketing communications about The Famous Grouse.  We may also send you marketing communications about The Famous Grouse where you have requested information from us or made a purchase and you have not opted out of receiving such communications.

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]. Where you opt out of receiving marketing communications, this will not remove any personal data provided to us as a result of a purchase that you have made.

Edrington also collects and uses 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; or
• complying with our legal and regulatory obligations.

Our legitimate interests

The normal legal basis for processing consumer data, is that it is necessary for the legitimate interests of Edrington, including:

• selling and supplying goods to our consumers;
• protecting consumers, employees and other individuals and maintaining their safety, health and welfare;
• promoting, marketing and advertising our products, services, events, experiences and brand partnerships;
• understanding our consumers’ behaviour, activities, preferences, and needs, including through the use of profiling;
• improving existing products and developing new products;
• handling consumer contacts, queries, complaints, or disputes; and
• preventing, investigating and detecting crime, fraud, or anti-social behaviour and prosecuting offenders.  

Where we process your personal data in pursuit of our legitimate interests, you have the right to object to us using your personal data for the above purposes. If you wish to object to any of the above processing, please contact us at [email protected]. If we agree and comply with your objection, this may affect our ability to undertake the tasks above for your benefit.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you require any further information on how the processing for the new purpose is compatible with the original purpose, please contact us using the details below.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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 (commonly referred to as a “data subject access request”) – this enables you to access the personal data we hold about you and to receive confirmation of how we are processing it;
• to have your data rectified if it is inaccurate or incomplete – 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;
• in certain circumstances, to have your data deleted or removed – this enables you to ask 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. Please note however, 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;
• in certain circumstances, to restrict the processing of your data – this enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • if you want us to establish the data's accuracy;
  • where our use of the data is unlawful but you don’t want us to erase it;
  • 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
  • you have objected to our use of your data (see below) but we need to verify whether we have overriding legitimate grounds to use it,
• a right of data portability, namely to obtain and reuse your data for your own purposes across different services. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to information which you initially provided consent for us to use or where we used the information to perform a contract with you;
• to object to the processing of your 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;
• not to be subject to automated decision-making (including profiling), where it produces a legal effect or a similarly significant effect on you;
• the right to withdraw your 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 you with certain products of services. We will advise you if this is the case at the time you withdraw your consent; and
• to claim compensation for damages caused by a breach of the data protection laws.

Who do we share your Personal Data with?

To effectively fulfil 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 which involve the processing of your Personal Data.  These include:

• vendors who will process your personal data on our behalf and under our written instructions to carry out their services during the course of our business, such as IT, delivery and marketing service providers, financial institutions, customer and relationship management vendors and other cloud-based solutions providers that are used by Edrington in the conduct of our business. We contract with such vendors to ensure that they only process your personal data by implementing the appropriate technical and organisational measures for such processing;
• vendors that process your personal data in order to assist us to better understand our consumers and how we can improve our customer engagement;
• when you order products from us, we will share your details with our fulfilment partner (currently Intervino in the UK and Speakeasy in the US), who will process your orders as set out in our Terms and Conditions;
• we use marketing service providers to administer services on our behalf, such as sending communications to our consumers, administering any promotions or ballots which we run;
• other agencies and fulfilment partners to administer events, competitions and brand programmes that you have opted into;
• our professional advisors (e.g. lawyers, accountants and bankers);
• our subsidiary companies who are involved in customer services and marketing activities related to The Famous Grouse and other entities in the Edrington group of companies; and
• The Famous Grouse’s third party distributors and joint venture partners.

We may provide information to others (such as governmental or law enforcement agencies) in the good faith belief that such action is necessary to: (i) enforce or apply our Terms and Conditions; (ii) comply with any legal claims raised against Edrington; (iii) protect the rights, property or safety of Edrington; or (iv) protect the rights, property or safety of the public.

If Edrington becomes 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 the Website.

Where we store your personal data

We may transfer your personal data outside the United Kingdom and/or EEA. This is primarily to allow us to:

• receive consultancy, marketing and IT services (e.g. cloud storage services, database development and management services, email/webmail services and customer relationship management services) from vendors located in non-UK/EEA jurisdictions, such as the US, South Africa and Australia; and
• provide special invitations, products, services, experiences and other benefits to you, from other Edrington group companies, or selected third party distributors or joint venture partners.

Where your personal data is transferred outside of the UK and/or EEA, we will ensure your personal data is afforded an adequate level of data protections (as required by data protection laws), including:

• by transferring the data to a country that the UK authorities or European Commission have deemed as providing an adequate level of data protection (an "adequacy decision");
• by implementing an appropriate international transfer mechanism under data protection law, such as standard contractual clauses or a data transfer agreement / addendum approved for this purpose by the UK authorities or European Commission;
• by relying on a "transfer derogation" under data protection law (e.g. where the transfer is based on your explicit consent, or is necessary to perform a contract with you); or
• where we are otherwise permitted to make the transfer under data protection law.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the UK and/or EEA.

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 Privacy Policy, including for the purposes of maintaining our relationship with you as well as satisfying any legal, regulatory, tax, accounting or reporting requirements. 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 of our relationship with you.

Different retention periods will apply to different types of data.  To determine the appropriate retention period for personal data, we consider any ongoing relationship we have with you, the likelihood you may want to make a further purchase from us in the future, 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.

When we no longer need to use your personal data, we will remove it from our systems and records, and or take steps to anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations we are subject to).

In certain circumstances, you can ask us to delete or remove your data (see the section entitled "What rights do you have?" above for further information on your rights).

We may also use your personal data collected by recording phone calls and retaining a transcript of our live chats with you through our website (including where these are handled by Edrington’s third party technical services partner) for the following purposes:

1. Account management;
2. Prevention, detection, investigation and prosecution of fraud;
3.  Complaint handling and resolution;
4. Measuring the quality of the call;
5.  Internal training on call handling.

We have a legitimate interest in retaining calls and live chats in order to offer our consumers a good service and to protect our business. If you object to the call recording, you may choose to end the call when you are informed that calls may be recorded.  If you use our live chat function to get in touch with us, you will be informed that we will keep a record of the discussion at the start of the chat and you will be able to end the chat at any time.  You will have the option to contact us through alternative means. All calls and live chat records will be retained for a period of one year.

How do we protect your personal data?

Edrington is committed to keeping your personal data safe and secure.  To prevent unauthorised access, maintain data accuracy and ensure the correct usage of personal data, we monitor and adjust our physical, electronic and managerial procedures to safeguard and secure the personal data we collect online.

Third party websites and apps

Our website and services may contain links to other websites or apps operated by third parties. Please be advised that the practices described in this Privacy Policy do not apply to information gathered through these third party websites and apps. We have no control over, and are not responsible for, the actions and privacy policies of third parties and other websites and apps.

Questions

If you have any questions or concerns about the way in which your Personal Data is processed, please contact [email protected].  

Complaints

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/). The ICO can be contacted by calling 0303 123 1113.

You can also lodge a complaint with a data protection regulator in the EEA member state in which you are based.

We would however appreciate the chance to discuss and work with you to address your concerns before you approach the ICO or another regulator, so please contact us in the first instance.

Changes

Edrington may update this Privacy Policy from time to time as our privacy practices change, or as required by applicable legal or regulatory requirements. Where it is practicable, we will notify you of any significant changes. However, the last update date is given below and Edrington encourages you to review this Privacy Policy periodically so you remain informed of how we uses your personal data.

Cookies

Cookies are small files downloaded to your computer or mobile device when you browse certain websites. Cookies contain information that is transferred to your computer's hard drive.

Please visit www.allaboutcookies.org for more information about cookies and the way they work.

We use cookies on your device when you use our website to:

1. verify you are old enough to view our site content;

2. track which parts of a site you visit and which websites you came from to get to our website. All information collected by this cookie is aggregated and is therefore anonymous

3. with your consent we may place a cookie to remember your preferences so that you do not need to re-enter your details (country/age and language).

4. 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.

You can choose to accept or decline cookies.  Most web browsers automatically accept cookies, but you can alter your browser settings to decline cookies if you prefer.  This may prevent you from taking full advantage of the website. 

If you would like to opt out of being tracked by Google Analytics across all websites which you view, please visit http://tools.google.com/dlpage/gaoptout.

Some areas of our site use AddThis, a widely used social bookmarking service that makes it easy to share articles to social media websites like Twitter or Facebook. If you would like to opt out please visit http://www.addthis.com/privacy.

What is a cookie?

A cookie is a small file of letters and numbers that we store on your browser of the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. A cookie will usually contain the name of the domain it originated from, the “lifespan” of the cookie and a unique identifier (usually a randomly generated number).

What type of cookies do we use?

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services such as web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies:

• Wistia
• Google Analytics
• Acquia Lift
• Shopify

To deactivate the use of third party advertising cookies, you can visit the “Manage Cookies” page to manage the use of these types of cookies.

You may block cookies by activating the setting on your browser that allows you to turn off or disable cookies. However, if you block all cookies you may not be able to view content or access all or parts of our website.

With the exception of essential cookies, all other cookies will expire after 90 days.

Copyright

This website is protected by copyright. Permission is given for the downloading and temporary storage of one or more of these pages for the purpose of viewing on a personal computer or monitor. The reproduction, permanent storage, or re-transmission of the contents of this website is prohibited without the prior written consent of Edrington. For permission to reproduce any of the contents of this website please contact [email protected].

Unless otherwise stated all contents of this website are copyright of Edrington.

Disclaimer

Please note that telephone and other connection charges may apply to your use of this website. For details of such charges you should contact your telephone company and internet service provider.

The information contained in this website may include opinions or views which, unless expressly stated otherwise, are not those of Edrington.

This website is not guaranteed to be free from any so-called computer viruses and it is strongly recommended that you check for such viruses before down-loading it to your computer equipment.

The information and other contents of this website are designed to comply with Scots law. This website shall be governed by and construed in accordance with Scots law and all parties irrevocably submit to the jurisdiction of the Scottish courts. If anything on this website is construed as being contrary to the laws applicable in any other country, then this website is not intended to be accessed by persons from that country and any persons who are subject to such laws shall not be entitled to purchase our products unless they can satisfy us that such purchase would be lawful.

Liability

Whilst every effort has been taken to ensure that the information provided on this website is correct at the time of writing it is not possible to provide any guarantee of accuracy.  Edrington does not accept responsibility or liability to any person for loss or damage suffered as a consequence of their placing reliance upon the information. You should make appropriate queries and satisfy yourself before placing any reliance upon or taking any action on such information. By so placing reliance or taking action you accept that you do so at your own risk.