Privacy policy

Clink* Privacy Statement

Who we are

This is the privacy statement of Clink*

William Grant & Sons (Company Number SC131772) is the data controller of all marketing data collected through www.clinkspirits.com. Our registered address is at the Glenfiddich Distillery, Dufftown, Banffshire AB55 4DH. All references to "our", "us", "we" or "Company" within this policy are deemed to refer to William Grant & Sons Limited, its subsidiaries, affiliates and associates.

The Hut.com Limited (trading as www.thehut.com) whose registered office is at Meridian House, Gadbrook Park, Gadbrook Way, Rudheath, Northwich, Cheshire, UK, CW9 7RA (“THG”) is the data controller for all data collected for the purpose of fulfilling your order, including payment and delivery details.

We are committed to protecting your personal data; your privacy matters to us. That is why we have developed this Privacy Notice to explain how we collect, use, share and store your personal information when you use this website, and to inform you about how we will look after that information. This includes any information you may provide us with when you sign up to keep in touch with us or take part in any competitions that we might run.

It is important that you take some time to read and familiarise yourself with this notice, together with our website terms and conditions and any other privacy or fair processing notices that we may provide on specific occasions when we are collecting or processing personal data about you. This will help you to be fully aware of how and why we are using your information.

If you do not agree with any term in this policy, please do not use the website or submit any personal information to or through it.

Types of personal information we collect

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

Types of personal information used by WG&S & THG	Description
Personal identifying	Your first name and last name and your date of birth.
Contact	Your billing and delivery addresses including postcode, your contact email and telephone numbers
Technical	Information sent to us as a result of connecting to our website, including internet protocol (IP) address, 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.
Transaction	Transaction and billing information, if you make any purchases from us or using our Site (e.g. credit/debit card details and delivery information)
Contractual	Details about the services we provide to you.
Usage	Information about how you use our website, products and services
Marketing and Communications	Information about your preferences in receiving marketing from us and your communication preferences.

How we use your personal information

In general terms, we collect and use personal information to:

deliver our services and meet our legal responsibilities
prepare and deliver our products to you
verify your identity where this is required

contact you by post, email or telephone
understand your needs and how they may be met
maintain our records
process financial transactions

More specifically, the table below explains how we use your personal information and the reasons that we rely on in doing so. Where these reasons include legitimate interests, we explain what these legitimate interests are.

What we use your information for	Our reasons	Our legitimate interests
To deliver our services and products (THG) To make and manage customer payments (THG) To manage fees, charges and interest due on customer accounts (THG) To collect and recover money that is owed to us (THG)	Contractual performance Legitimate interests Legal obligations	Being efficient about how we fulfil our legal and contractual duties Complying with regulations that apply to us
To manage our relationship with you which may include asking you to leave a review of take a survey or notifying you about changes to our terms or privacy statement.	Contractual performance Legal obligations Legitimate interests	Keeping our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	Contractual performance Legitimate interests.	Being able to study how customers use our products/services, to develop them and to grow our business.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising that we serve to you	Legitimate interests	To study how customers use our products/services to develop them, to grow our business and to improve our marketing strategy
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Legitimate interests	Defining types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy
To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, corporate governance and audit	Legitimate interests Legal obligations	Being efficient about how we fulfil our legal duties Complying with regulations that apply to us
To exercise our rights set out in contracts and agreements	Contractual performance
To make suggestions and recommendations to you about goods or services that may be of interest to you	Consent Legitimate interests	Developing our products/services and to be able to grow our business
Direct marketing about Clink* and the products sold on it Using your data to create look alike profiles for marketing purposes Profiling your data to help us decide what promotions you will be interested in Indirect targeted marketing by matching your profile with other third party providers that you use Some of this information will be collected through cookies and some will be collected from you through use of your account. We will use your browsing and purchase history along with other data you have provided to tailor our marketing for you. You can always opt out of marketing cookies, analytical cookies and marketing in your account preference centre	Consent
Suppression of marketing to you when we do not think you wish to hear about our promotions – for example, just after you have made a purchase	Legitimate Interests	Limiting the marketing that you are sent so that you do not receive excessive amounts to build a better relationship with you

Where we collect your personal information from

We may collect personal information about you (or your business) from the following sources:

Data you give to us e.g. by ordering products or services, entering into any competitions that we may run on this site or completing online questionnaires or if you contact us directly, for example, regarding enquiries or other feedback.

Technical Data e.g. your IP address, 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.

Data we collect when you use our services e.g. payment and transaction information, identity and contact information, etc.

Information you post on public areas of our site and social media

Information that you post on or through any public areas of the website (such as chatrooms, bulletin boards or discussion forums) and on any social media pages that we operate is publicly available information. This means that it is generally accessible to, and may be collected by, others and may be used by them to send you unsolicited messages. We do not have control over if or how other people may use that information therefore you should use caution and ensure not to disclose personal information when using public web areas or social media. We will not be responsible for any postings that you make with personal information in them.

Who we share your information with

We may share your personal information with the following third parties:

Payment service providers
Members of the WG&S & THG Company group
Our marketing agencies and third party database mangers
Third parties that provide services to you for the purpose of marketing
Trusted advisors

Service providers that we engage to support the operation of our services and delivery of our products
With third parties engaged in fraud prevention and detection.
With law enforcement or other governmental authorities, e.g. to report a fraud or in response to a lawful request.
In the event that we sell any business assets, the personal data of our customers may be disclosed to a potential buyer. In this event, we will make reasonable attempts to ensure the buyer will be bound by the terms of this Privacy Policy.
Otherwise where we have your consent or are otherwise legally permitted to do so.

Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

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

Marketing

We aim to provide you with choices relating to marketing and advertising.

We will get your express opt-in consent before directly sending you marketing communications or before sharing your personal information with any third party for marketing purposes.

If you no longer want to receive marketing communications from us (or would like to opt back in!), you can change your preferences at any time by contacting us (details below), clicking on the ‘unsubscribe’ link in any email, or updating your settings in your account. If you unsubscribe from marketing, please note we may still contact you with service messages from time to time (e.g. order and delivery confirmations, and information about your legal rights).

You may also see ads for Clink* and the products sold on Clink* on third party websites, including on social media. These ads may be tailored to you using cookies (which track your web activity, so enable us to serve ads to customers who have visited our Site). Where you see an ad on social media, this may because we have engaged the social network to show ads to our customers, or users who match the demographic profile of our customers. In some cases, this may involve sharing your email address with the social network. If you no longer want to see tailored ads you can change your cookie and privacy settings on your browser and these third party websites.

Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of our providing of services to you.

If you choose not to give your personal information

If you choose not to give your personal information it may prevent us from being able to provide our products or services to you.

How long we keep your personal information

We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting obligations that we may have. We will only keep personal data for longer where there is a legal requirement for us to do so.

To determine how long we should keep your information for, we will consider the amount, type, and sensitivity of the personal information involved as well as the potential risk of harm if it is lost, or used or disclosed without authorisation. We will also consider the purposes for which we process your personal data and whether we can achieve those purposes through other means without the need to keep your data.

In some circumstances you can ask us to delete your data (see section on "Your rights" below for more information).

In some circumstances, we may also anonymise your personal data so that it can no longer be associated with you, for example for statistical purposes. Where we do this, we may use this information indefinitely without further notice to you.

Where we hold your personal information internationally

We use service providers based around the world. Consequently, your personal data may be processed in countries outside of Europe, including in countries where you may have fewer legal rights in respect of your data than you do under local law. If we transfer personal data outside the European Economic Area we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate safeguards, in particular the EU’s standard contractual clauses. Please contact us if you would like more information about these safeguards.

Using our website

We collect and process the following information from our website:

details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access;
IP addresses – we will automatically receive your IP address when you visit the site; and
cookies – we will use cookies in accordance with our Cookies Policy [https://www.clinkspirit.com/cookie-information.list] you configure your browser not to accept them. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Where this website contains links to other sites, William Grant & Sons is not responsible for the privacy policies or practices of any third party. By clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Your rights

Access to your information – You have the right to request a copy of the personal information about you that we hold.

Correcting your information – We want to make sure that your personal information is accurate, complete and up to date and you may ask us to correct any personal information about you that you believe does not meet these standards.

Deletion of your information – You have the right to ask us to delete personal information about you where:

You consider that we no longer require the information for the purposes for which it was obtained
We are using that information with your consent and you have withdrawn your consent – see Withdrawing consent to using your information below

You have validly objected to our use of your personal information – see Objecting to how we may use your information below
Our use of your personal information is contrary to law or our other legal obligations.

Objecting to how we may use your information – You have the right at any time to require us to stop using your personal information for direct marketing purposes. In addition, where we use your personal information to perform tasks carried out in the public interest or pursuant to the legitimate interests of us or a third party then, if you ask us to, we will stop using that personal information unless there are overriding legitimate grounds to continue.

Restricting how we may use your information – in some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold or assessing the validity of any objection you have made to our use of your information. The right might also apply where this is no longer a basis for using your personal information but you don't want us to delete the data. Where this right to validly exercised, we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.

Portability – if we process personal information that you provide to us on the basis of consent or because it is necessary for the performance of a contract to which you are party, and in either case that processing is carried out by automated means, then you have the right to have that personal information transmitted to you in a machine readable format. Where technically feasible, you also have the right to have that personal information transmitted directly to another controller.

Automated processing – if we use your personal information on an automated basis to make decisions which significantly affect you, you have the right to ask that the decision be reviewed by an individual to whom you may make representations and contest the decision. This right only applies where we use your information with your consent or as part of a contractual relationship with you

Withdrawing consent using your information – Where we use your personal information with your consent you may withdraw that consent at any time and we will stop using your personal information for the purpose(s) for which consent was given.

Please contact us in any of the ways set out in the Contact information and further advicesection if you wish to exercise any of these rights.

Changes to our privacy statement

We keep this privacy statement under regular review and will place any updates on this website. We recommend that you check this page regularly to ensure that you have read the most recent version.

This privacy statement was last updated on 22nd June 2021.

Contact information and further advice

William Grant & Sons contact details are:

dataprotection@wgrant.com

William Grant & Sons Ltd
The Old Court House,
7 Parkshot,
Richmond
TW9 2RF

THG’s contact details are:

Email: customer.experience@thehutgroup.com

Address: Customer Services, Meridian House, Gadbrook Park, Cheshire, CW9 7RA

Telephone:  08001510758

Complaints

We seek to resolve directly all complaints about how we handle personal information but you also have the right to lodge a complaint with the Information Commissioner’s Office:

Online: https://ico.org.uk/global/contact-us/email/

By phone: 0303 123 1113

By post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF