Privacy Notice

Drinkaware are committed to protecting the privacy of our users. This Privacy Notice is intended to inform you how we gather, define, and utilise your information.

1. Who we are and what we do

Who we are

We are The Drinkaware Trust (“Drinkaware”, “us”, “we”, “our”). We are a limited company registered in England and Wales under registration number 04547974 and we have our registered office at 1^st Floor Michael House, 35, Chiswell Street, London, England, EC1Y 4SE. We are registered with the UK supervisory authority, the Information Commissioner’s Office (“ICO”), in relation to our processing of Personal Data under registration number Z9912649.

What we do

We are an alcohol charity working with individuals, public authorities and organisations with the aim of reducing alcohol harm in the UK. We provide a toolkit of services with the aim of supporting people who want to change the way they drink which includes the MyDrinkaware App and our online Drinking Check. We are committed to protecting the privacy and security of the Personal Data we process about you.

Controller

Unless we notify you otherwise, we are the controller of the Personal Data we process about you. This means that we decide what Personal Data to collect and how to process it.

2. Purpose of this privacy notice

The purpose of this privacy notice is to explain what Personal Data we collect about you and how we process it. This privacy notice also explains your rights, so please read it carefully. If you have any questions, you can contact us using the information provided below under the ‘How to contact us’ section.

3. Who this privacy notice applies to

This privacy notice applies to you if:

You visit our website
You use our app or other online services
You subscribe to our newsletter
You contact us to enquire about our goods or services
You purchase goods or services from us
We purchase goods or services from you
You participate in our research or feedback surveys
You partner with us or become a Drinkaware funder
You attend one of our in-person events

Please note, if you access the DrinkChat on our website, this is an externally provided service and Drinkaware do not collect, store, process or access personal data submitted through this channel.

4. What Personal Data is

‘Personal Data’ means any information from which someone can be identified either directly or indirectly. For example, you can be identified by your name or an online identifier.

‘Special Category Personal Data’ is more sensitive Personal Data and includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purposes of uniquely identifying someone, data concerning physical or mental health or data concerning someone’s sex life or sexual orientation.

5. Personal Data we collect

The type of Personal Data we collect about you will depend on our relationship with you. For the type of Personal Data we collect see the table below in the section entitled ‘Purposes, lawful bases and retention periods’.

6. How we collect your Personal Data

We collect most of the Personal Data directly from you in person, by telephone, text or email, our Drinkaware App and/or via our website.

However, we may also collect your Personal Data from third parties such as:

reputable companies who provide lead generation contact lists
others to whom you have provided consent
publicly available sources such as social media platforms

7. Purposes and Lawful Bases

We will only use your Personal Data when the law allows. Most commonly, we will use your Personal Data in the following circumstances:

Categories of individuals	Categories of Personal Data	Purpose of Processing	Lawful Basis
Individuals who use our Drinking Check (required information)	Age, sex	To provide the most appropriate advice to you. For example, biological sex plays a role in how alcohol affects your health which is why we ask for this to conduct the Drinking Check	Contract
Individuals who use our Drinking Check (voluntary information)	Full name, email address, drinking habits, gender identity	It is in our legitimate interests to ensure that people have an option to request a copy of the result and advice from the Drinking Check It is also in our legitimate interests to ensure people who are taking the Drinking Check are given the opportunity to provide their gender identity for the purposes of inclusivity and to support people who are gender minorities through analysis of this data	Legitimate interests and substantial public interest- equality of opportunity or treatment
Individuals who use our app (required information)	Full name, email address, age, password, sex, and information such as drinking habits	It is in our legitimate interests to collect your personal information to authenticate you and to protect the information you log on your account Where we ask for information such as sex and age, this is to enable us to provide you with our service and to tailor the advice we provide to you, as mentioned above with our Drinking Check	Legitimate interests and contract
Individuals who use our app (voluntary information)	Gender identity, postcode	It is in our legitimate interests to collect information (such as postcode) for the purposes of reporting and research, at which point the personal data will be anonymised/ aggregated. As mentioned above with the Drinking Check, it is also in our legitimate interests to provide the opportunity for people to provide information regarding their gender identity for the purposes of inclusivity	Legitimate interests and substantial public interest -equality of opportunity or treatment
Organisations who purchase our logo licence (funders)	Full name and contact details of employees and members of the organisation, job title, work email address, work telephone number, office/site address, notes from phone calls, interaction records via email	It is in our legitimate interests to keep a record of personal information of our funders in order to maintain a relationship and to contact funders when their licence is due for renewal	Legitimate interests
Organisations who purchase our logo licence (funders)	Payment information including bank account number, bank name, sort code, details of transaction	To fulfil your order with us and to keep a record of financial transactions for tax purposes	Contract and legal obligation
Organisations we partner with	Full name and contact details of employees and members of the organisation, job title, work email address, work telephone number, office/site address, notes from meetings	It is in our legitimate interests to keep a record of our partnerships for the purposes of insight and internal reporting and to record personal information of key contacts to facilitate the partnership	Legitimate interests
Individuals who purchase through our online shop	Name, email address, payment card details	To fulfil your order with us and to keep a record of financial transactions for tax purposes	Contract and legal obligation
Individuals who have been invited to participate in research and provide feedback	Name, demographic information, location information, drinking habits/ behaviour, age, phone number, email address, details of feedback	It is in our legitimate interests to collect information that will help us to improve our service	Legitimate interests
Individuals who contact us via our website, chatbot, or our social media pages	Name, job title, company name, email address, phone number, details of enquiry or complaint	It is in our legitimate interests to respond appropriately to queries or complaints	Legitimate interests
Suppliers and contractors	Name, job title, company name, sort code, account number, phone number, email address	To pay you for the service we have contracted form you and to keep a record of financial transactions for tax purposes	Contract and legal obligation
Individuals who have subscribed to our email newsletter	Full name, email address	It is in our legitimate interests to promote our aims and services to people, however, we will only contact you for this purpose when we have obtained your consent to do so	Consent

Where Personal Data is processed because it is necessary for the performance of a contract to which you are a party, we will be unable to provide our services without the required information.

8. How long we keep your data

We will retain your personal data for as long as is necessary to provide you with our services and for a reasonable period thereafter to enable us to meet our contractual and legal obligations and to deal with complaints and claims.

At the end of the retention period, your personal data will be securely deleted or anonymised.

9. Sharing your Personal Data

We may share your Personal Data with our carefully selected third parties, including public authorities such as the HMRC for tax purposes. Other third parties may include:

Web hosting companies and digital service providers for the provision and maintenance of our website and app.
Payment providers such as Shopify to facilitate payment through our online shop.
Couriers and delivery companies to deliver any goods purchased from us.
Email service providers to assist in our interactions with you.
Companies who assist with our research and feedback efforts.
Companies who support with our marketing activities.
Lawyers, accountants and government functions who assist us with business administration and to meet various legal and regulatory obligations.

10. International Transfers

Your Personal Data may be processed outside of the UK. This is because the organisations we use to provide our service to you are based outside the UK.

We have taken appropriate steps to ensure that the Personal Data processed outside the UK has an essentially equivalent level of protection to that guaranteed in the UK. We do this by ensuring that:

Your Personal Data is only processed in a country which the Secretary of State has confirmed has an adequate level of protection (an adequacy regulation), or
We enter into an International Data Transfer Agreement (“IDTA”) with the receiving organisation and adopt supplementary measures, where necessary. (A copy of the IDTA can be found here international-data-transfer-agreement.pdf (ico.org.uk)).

11. Marketing Communications

From time to time, and with your consent we may use your information to contact you with details about our services which we feel may be of interest to you. You have the right at any time to stop us from contacting you for marketing purposes. If you wish to exercise these rights you can do so by following the ‘unsubscribe’ link on any emails received or contacting us at contact@drinkaware.co.uk.

12. Your rights and how to complain

You have certain rights in relation to the processing of your Personal Data, including to:

Right to be informed

You have the right to know what personal data we collect about you, how we use it, for what purpose and in accordance with which lawful basis, who we share it with and how long we keep it. We use our privacy notice to explain this.

Right of access (commonly known as a “Subject Access Request”)

You have the right to receive a copy of the Personal Data we hold about you.

Right to rectification

You have the right to have any incomplete or inaccurate information we hold about you corrected.

Right to erasure (commonly known as the right to be forgotten)

You have the right to ask us to delete your Personal Data.

Right to object to processing

You have the right to object to us processing your Personal Data. If you object to us using your Personal Data for marketing purposes, we will stop sending you marketing material.

Right to restrict processing

You have the right to restrict our use of your Personal Data.

Right to portability

You have the right to ask us to transfer your Personal Data to another party.

Automated decision-making

You have the right not to be subject to a decision based solely on automated processing which will significantly affect you. We do not use automated decision-making.

Right to withdraw consent

If you have provided your consent for us to process your Personal Data for a specific purpose, you have the right to withdraw your consent at any time. If you do withdraw your consent, we will no longer process your information for the purpose(s) you originally agreed to, unless we are permitted by law to do so.

Right to lodge a complaint

You have the right to lodge a complaint with the relevant supervisory authority, if you are concerned about the way in which we are handling your Personal Data. The supervisory authority in the UK is the Information Commissioner’s Office who can be contacted online at:

Or by telephone on 0303 123 1113.

How to exercise your rights

You will not usually need to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

If you wish to exercise your rights, you may contact us using the details set out below within the section called ‘How to contact us and our Data Protection Officer’. We may need to request specific information from you to confirm your identity before we can process your request. Once in receipt of this, we will process your request without undue delay and within one month. In some cases, such as with complex requests, it may take us longer than this and, if so, we will keep you updated.

13. Children’s Privacy

We do not offer our products and services to children and we do not knowingly collect Personal Data of children without parental consent, unless permitted by law. If you are a child, you must have your parent’s permission to use our services. If you learn that a child has provided us with their Personal Data without parental consent, you may contact us, as described below, and if appropriate, we will securely and permanently delete it, in accordance with applicable law.

14. How to contact us and our Data Protection Officer

If you wish to contact us in relation to this privacy notice or if you wish to exercise any of your rights outlined above, please contact us as follows:

The Drinkaware Trust,

Michael House, 35,

Chiswell Street,

London,

England,

EC1Y 4SE.

contact@drinkaware.co.uk

020 7766 9900

We have also appointed a Data protection Officer (“DPO”). Our DPO is Evalian Limited and can be contacted as follows:

Evalian Limited,

West Lodge,

Leylands Farm,

1 Nobs Crook,

Colden Common,

Winchester,

Hampshire,

SO21 1TH.

dpo@evalian.co.uk

03330500111

Please mark your communications FAO the ‘Data Protection Officer’.

15. Changes to this privacy notice

We may update this notice (and any supplemental privacy notice), from time to time as shown below. We will notify of the changes where required by applicable law to do so.

Last modified 23/08/2024.

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