Privacy Policy

PRIVACY POLICY

WHISKY HAMMER PRIVACY Notice

  1. Introduction
    1. This Privacy Notice (the ‘Notice) explains the personal information we collect from you, either directly or indirectly including on our website at www.whiskyhammer.com (the 'site'), and how we will use it. The Notice also explains the choices you can make about the data we collect, and how you can control these decisions.
    2. Whisky Hammer Limited is the controller and responsible for your personal data. "we", "our", " Whisky Hammer" and "us" refers to Whisky Hammer Limited.
    3. Questions about this Notice should be sent to us at [email protected].
    4. We reserve the right to amend this Notice from time to time without notice and at our sole discretion. You should review this Notice at regular intervals.
    5. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
  2. The types of personal information we collect and how we use it
    1. In this Notice we use the term personal information to mean any information that relates to an identifiable individual. It does not include data where the identity has been removed (anonymous data).
    2. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
      1. Where we need to perform the contract we are about to enter into or have entered into with you.
      2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
      3. Where we need to comply with a legal obligation.
    3. The table below shows what personal information we collect, where we get it from, how we use it and our legal basis for doing so.

Source

Data types

Purpose

Legal basis

Directly from you

Name

Phone number

Email address

Social media account identifier

Correspondence with us

Customer support

Performance of a contract

Legitimate interest in providing the best and most efficient customer support possible

Directly from you

Name

Phone number

Email address

Registering as a user on our site

Performance of a contract with you

Directly from you

Bank details

Billing address

Shipping address

Facilitating your participation as a buyer or a seller in an auction including sending you items you win at auction

Performance of a contract with you

Directly from you

ID

Age verification.

Legal obligation

Directly from you

Name

Email address

Marketing preferences

Purchase history

Auction activity history

To deliver and personalise our marketing communications to you such as information about our monthly auctions

Legitimate interest in understanding how our customers use our site and the purchases that are made and to help ensure that our marketing communications are of interest to recipients.

Consent (for electronic marketing)

Directly from you

Name

Email address

Marketing preferences

To manage our relationship with you including notifying you about changes to our terms and conditions or this Notice or asking you to leave a review

Performance of our contract with you

Legitimate interest – to keep our records updated and to study how customers use our products/services

Automatic collection – through cookies or other similar technologies when you use, access or interact with us via our site or app

Type of device you use to access our websites

The operating system and version

Your IP address

Your general geographic location, as indicated by your IP address

Your browser type

To develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, report on the performance of our business, and help us to understand geographic information about our website visitors better, so that we can improve our website for everyone

Protecting the security of our website and customers to detect and prevent fraud, to resolve disputes and enforce our agreements

Legal obligation

Legitimate interest - running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise

Consent (where placement of the cookie is subject to your consent given through the controls on the site)

Automatic collection – through cookies or other similar technologies when you use, access or interact with us via our site or app

The webpages you view on our websites and other usage information

Whether you interact with content available on our websites and how

To improve our site and service, including maintaining and improving the performance of our site and developing and adding new features or capabilities

Legitimate interest in providing, operating, supporting and improving the Whisky Hammer service to ensure our customers can buy and/or sell using our online auction platform as effortlessly as possible

Consent (where placement of the cookie is subject to your consent given through the controls on the site)

  1. 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 information but 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 information which will be used in accordance with this Notice.
  2. 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
  1. Marketing
    1. Whisky Hammer uses the data we collect to provide you with the services we offer, which includes using data to improve and personalise your experiences. We also use the data to communicate with you, for example, informing you about our monthly auctions.
    2. We provide you with choices regarding certain personal data uses, particularly around marketing and advertising. For information about managing email subscriptions and promotional communications, please visit your ‘My Whisky Hammer’ account.
  2. Change of purpose
    1. We will only use your personal information 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 wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
    2. If we need to use your personal information for an unrelated purpose, we will inform you and we will explain the legal basis which allows us to do so.
  3. How we may share personal information
    1. Whisky Hammer does not and will not sell personal information about our customers to other organisations for marketing purposes. We only disclose your data as described in this Notice.
    2. We may share information with the following types of third parties:
      1. Third party vendors: Whisky Hammer uses a variety of third-party vendors to carry out services like site management and hosting, shipping of items won on auction to buyers, debit/credit card processing and email communications. We only share your personal information as necessary. In this case, your personal information will be shared with these agents or contractors but only for the purpose of performing services on behalf of Whisky Hammer and in accordance with this Notice.
      2. Whisky Hammer affiliates: where you have provided your consent, we will share your contact details with our affiliated companies, including Still Spirit, for marketing purposes. We will also share your information with our affiliated companies for the purposes of aggregated analytics or where an affiliated company is engaged by us to provide you with services.
      3. Compelled disclosure: When legally required, strictly necessary for the performance of the services or to protect our rights, or the rights of our affiliates or users, we disclose your personal information to law enforcement authorities, HM Revenue and Customs (or similar bodies in other countries), debt collectors, investigative organisations, our affiliates or in legal proceedings.
      4. Sale or merger: We may share your personal information in the event of a merger, acquisition, or sale of all or a portion of our assets. We will inform you of any transfer via email and/or a prominent notice on our site and inform you of your rights.
      5. Sharing and disclosure of aggregate data: We share data in aggregate form and/or in a form which does not enable the recipient of such data to identify you, with third parties, for example, for industry analysis.
    3. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information in accordance with our instructions.
  4. International transfers
    1. When you make a payment to us, we will direct you through one of our third party payment providers. These third parties which facilitate payments to us may be based outside the UK or EEA and so please see the privacy notices linked below for each of the providers we use to find out more:
      1. Stripe
      2. PayPal
      3. Opayo
      4. Global Payments
  5. Security
    1. Whisky Hammer is committed to protecting the security of your personal information. However, while we take reasonable precautions to guard the personal information we collect, no security system is impenetrable.
    2. Whisky Hammer takes precautionary measures to help prevent information about you from loss, theft, misuse and unauthorised access, disclosure, alteration and destruction. For example, your data is protected with encryption during transition over the Internet. Please note, your password is stored using one-way hash, which means that it cannot be recovered (or disclosed) by anyone, including Whisky Hammer, it can only be reset.
    3. You can only access your Whisky Hammer account information and our service through the use of an individual user login and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please inform us immediately if you believe your password has been misused. You should always log out and close your browser when you finish your session. We will never ask you to disclose your password in an unsolicited phone call or email.
    4. If you have any questions about the security of your personal information, please contact us.
  6. Retention
    1. Whisky Hammer will retain your personal information for as long as it is necessary to enable you to use the site and your Whisky Hammer service, to provide services to you, to comply with applicable laws (including those regarding document retention), resolve disputes with any parties and otherwise as necessary to allow us to conduct our business. All personal information we retain will be subject to this Notice and our internal retention guidelines. If you have a question about a specific retention period for certain types of personal information we process about you, please contact us.
    2. We do not store any debit or credit card information. For sellers of whisky using our online auction service, we are required to store payment details (for a limited time) so that we can efficiently transfer the sales proceeds to your nominated account.
  7. Your Rights
    1. We want you to be in control of how your personal information is used by us. Under certain circumstances, you can do this in the following ways:
      1. you can ask us for a copy of the personal information we hold about you;
      2. you can inform us of any changes to your personal information, or if you want us to correct any of the personal information we hold about you;
      3. in certain situations, you can ask us to erase, block or restrict the personal information we hold about you, or object to particular ways in which we are using your personal information; and
      4. in certain situations, you can also ask us to send the personal information you have given us to a third party.
    2. Where we are using your personal information on the basis of your consent, you are entitled to withdraw that consent at any time. Moreover, where we process your personal information based on legitimate interest or the public interest, you have the right to object at any time to that use of your personal information.
    3. We rely on you to ensure that your personal information is complete, accurate and up to date. Please do inform us promptly of any changes to or inaccuracies in your personal information by contacting us.
    4. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
  8. Your Choices
    1. Whisky Hammer account and Whisky Hammer App: If you wish to access, edit or remove profile information, change your password, close your account or request deletion of your personal data, you can do so by logging in to your ‘My Whisky Hammer’ account or Whisky Hammer app or contacting us.
    2. Your communication, marketing and advertising preferences: You can opt out of receiving direct marketing communications from Whisky Hammer by following the instructions included in every email sent to you via the “Unsubscribe” tab. You can also opt out of email subscriptions by updating your Contact Options in your ‘My Whisky Hammer’ account. We respect your choice, and we will stop sending you promotional emails once you unsubscribe.
    3. Please note, regardless of your communication settings, we will continue to communicate with you regarding changes to terms and conditions, policy updates, routine customer service messages such as information about current or past purchases, delivery of products, service interruptions, data breaches or other significant information, such as safety issues.
    4. You can adjust the amount of interest-based advertising you may receive by changing your cookie settings. If you have opted out of receiving emails from us, we will not use your email for interest-based advertising activities.
  9. Complaints
    1. We are committed to working with you to obtain a fair resolution of any complaint or concern you may have about our use of your personal information. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to file a complaint with the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk).
    2. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
  10. If you are outside the UK
    1. If you live outside the UK and have any questions or complaints related to data protection please contact our representative in the European Union ('EU"), Datarep, so that you can contact them directly in your home country. DataRep has locations in each of the 27 EU countries and Norway & Iceland in the European Economic Area ('EEA'), so that Whisky Hammer Ltd’s customers can always raise the questions they want with them.
    2. If you want to raise a question to Whisky Hammer Ltd, or otherwise exercise your rights in respect of your personal data, you may do so by:
      1. sending an email to DataRep at [email protected] quoting <Whisky Hammer Ltd> in the subject line,
      2. contacting us on our online webform at www.datarep.com/data-request, or
      3. mailing your inquiry to DataRep at the most convenient of the addresses below – which should be addressed to Whisky Hammer Limited.

Country

Address

Austria

DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria

Belgium

DataRep, Place de L'Université 16, Louvain-La-Neuve, Waals Brabant, 1348, Belgium

Bulgaria

DataRep, 132 Mimi Balkanska Str., Sofia, 1540, Bulgaria

Croatia

DataRep, Ground & 9th Floor, Hoto Tower, Savska cesta 32, Zagreb, 10000, Croatia

Cyprus

DataRep, Victory House, 205 Archbishop Makarios Avenue, Limassol, 3030, Cyprus

Czech Republic

DataRep, IQ Ostrava Ground floor, 28. rijna 3346/91, Ostrava-mesto, Moravska, Ostrava, Czech Republic

Denmark

DataRep, Lautruphøj 1-3, Ballerup, 2750, Denmark

Estonia

DataRep, 2nd Floor, Tornimae 5, Tallinn, 10145, Estonia

Finland

DataRep, Luna House, 5.krs, Mannerheimintie 12 B, Helsinki, 00100, Finland

France

DataRep, 72 rue de Lessard, Rouen, 76100, France

Germany

DataRep, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany

Greece

DataRep, 24 Lagoumitzi str, Athens, 17671, Greece

Hungary

DataRep, President Centre, Kálmán Imre utca 1, Budapest, 1054, Hungary

Iceland

DataRep, Kalkofnsvegur 2, 101 Reykjavík, Iceland

Ireland

DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland

Italy

DataRep, Viale Giorgio Ribotta 11, Piano 1, Rome, Lazio, 00144, Italy

Latvia

DataRep, 4th & 5th floors, 14 Terbatas Street, Riga, LV-1011, Latvia

Liechtenstein

DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria

Lithuania

DataRep, 44A Gedimino Avenue, 01110 Vilnius, Lithuania

Luxembourg

DataRep, BPM 335368, Banzelt 4 A, 6921, Roodt-sur-Syre, Luxembourg

Malta

DataRep, Tower Business Centre, 2nd floor, Tower Street, Swatar, BKR4013, Malta

Netherlands

DataRep, Cuserstraat 93, Floor 2 and 3, Amsterdam, 1081 CN, Netherlands

Norway

DataRep, C.J. Hambros Plass 2c, Oslo, 0164, Norway

Poland

DataRep, Budynek Fronton ul Kamienna 21, Krakow, 31-403, Poland

Portugal

DataRep, Torre de Monsanto, Rua Afonso Praça 30, 7th floor, Algès, Lisbon, 1495-061, Portugal

Romania

DataRep, 15 Piaţa Charles de Gaulle, nr. 1-T, Bucureşti, Sectorul 1, 011857,

Romania

Slovakia

DataRep, Apollo Business Centre II, Block E / 9th floor, 4D Prievozska, Bratislava, 821 09, Slovakia

Slovenia

DataRep, Trg. Republike 3, Floor 3, Ljubljana, 1000, Slovenia

Spain

DataRep, Calle de Manzanares 4, Madrid, 28005, Spain

Sweden

DataRep, S:t Johannesgatan 2, 4th floor, Malmo, SE - 211 46, Sweden