LAST UPDATED 1ST May 2018
Who we are
Brugal 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 (“Edrington”).
- What types of personal data we collect;
- How we collect personal data;
- When and why we share it with other organisations, including the types of organisations involved;
- How long we keep personal data for; and
- The rights and choices you have with regards to your personal data.
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
- Details of purchases and orders made by you;
- When you make a purchase or place an order with us, your payment card details;
- Your correspondence and communications with Brugal;
- Personal data which you have maybe shared via a public platform (such as on Brugal’s Facebook or Instagram feed);
- Your communication and marketing preferences;
- Your interests, preferences, feedback and survey responses;
- Online browsing activities on the Brugal website.
How do we collect your personal data?
We collect your personal data when:
- You subscribe to receive our newsletter;
- You make an online purchase or place an order online for a Brugal product or merchandise;
- You enter a ballot or competition related to Brugal or one of Brugal’s products;
- When you attend one of our events or visit one of our sites;
- When you contact us, for whatever reason.
How do we use your personal data?
Edrington (and trusted partners acting on our behalf) use your personal data:
- With your agreement, 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);
- We may send you personalised communications based on your preferences, and use of Brugal’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 (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 rely on your consent to send you marketing communications about Brugal. 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]
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;
- understanding our consumers’ behaviour, activities, preferences, and needs;
- 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.
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; and
- 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]
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 IT, delivery and marketing service providers.
- When you order products from us, we will share your details with our fulfilment partner, 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 subsidiary companies including Brugal & Co S.A., based in the Dominican Republic, who are involved in customer services and marketing activities related to Brugal.
Some of the third party service providers we use may be based outside of the European Economic Area (including our subsidiary company Brugal & Co S.A.), 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 means that they can only use your personal data to provide services to Edrington or to you, and no other purpose.
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.
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 wish to have your data deleted or removed please contact [email protected]
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.
If you have any questions or concerns about the way in which your Personal Data is processed, please contact [email protected].
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- verify you are old enough to view our site content;
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Unless otherwise stated all contents of this website are copyright of Edrington.
Any links to third party websites are provided solely for the purpose of your convenience. We have no control over the content of such websites and accordingly make no representation concerning the content of those sites to you nor make endorsement of any of them. We have not tested any content, software features or links found on their sites and do not give any representation regarding their quality, safety, suitability or reliability or any of the material contained in them.
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.
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.
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.
This policy may change from time to time. If we change anything important we will notify or contact you.