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.

The Drinkaware Trust (“Drinkaware”, “we”, “us” or “our”) respects the privacy of every person who visits or registers with Drinkaware.co.uk (the “Site”), the users of our “My Drinkaware” mobile application (the “App”) and the products, tools and services that we make available from the Site and our App (our “Services”). We are committed to ensuring a safe online and mobile experience.

1) Purpose of this policy

This privacy notice (“Privacy Notice”) explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Notice also sets out your rights in respect of our processing of your personal information. For more information click below.

This Privacy Notice will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer it and/or provide you with access to it.

This Privacy Notice is intended to assist you in making informed decisions when using the Site, the App and our Services. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Terms of Use.

Please also note that this Privacy Notice only applies to the use of your personal information obtained by us, it does not apply to the use of your personal information collected during your communications with third parties.

2) Who are we and what do we do?

The Site, the App and the Services are provided by The Drinkaware Trust. For more information click below. The Drinkaware Trust is the data controller responsible for your personal information and is registered at the UK Information Commissioner’s Office with registration number: Z9912649.

The Drinkaware Trust is an English company limited by guarantee and registered in England and Wales with number 4547974 and with registered address Michael House, 35 Chiswell Street, EC1Y 4SE. Our Registered Charity Numbers are 1094586 and SC043163. 

3) How to contact us?

If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, please contact us by sending an e-mail to contact@drinkaware.co.uk or by post to:

FAO: The Data Protection Officer

The Drinkaware Trust

Michael House,

35 Chiswell Street,

London

England

EC1Y 4SE

4) What personal information do we collect and how do we use it?

Our primary goal in collecting personal information from you is to: (i) verify your identity; (ii) help us improve our Services and develop and market new products and services; (iii) carry out requests and orders made by you on the Site; (iv) carry out your requests when using our App; (v) investigate or settle inquiries or disputes; (vi) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vii) enforce our agreements with you; (viii) protect the rights, property or safety of us or third parties, including other users of the Site and App; (ix) provide support for the provision of our Services; and (x) use as otherwise required or permitted by law.

In particular, we collect and use your personal information for the following purposes:

Fulfillment of our Services - on the Site and when using our App.

We collect and maintain personal information that you voluntarily submit to us during your registration or when requesting our Services such as your name, email address, date of birth, sex, gender, postcode and if you are using our online shop, your address and payment card details.

We use the contact and payment details you have provided to us so that we can fulfil the services you have requested from our Site and/or our App. In particular, we use the contact and payment details you have provided to us where applicable so that we can fulfil the supply of products and services you have requested from our Site.

You can also volunteer to provide us with additional personal information when using some of the tools available on the Site, such as information about your drinking habits or your achievements or motivations.

Who do we share your personal information with for this purpose?

We will share your personal information with the following categories of third parties:

To provide our Site – third party web hosting companies;

To verify card payments and process refunds – credit card companies and other payment providers;

To order and deliver products – online shopping via Shopify, logistics and delivery companies;

What is our legal basis?

It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you. 

We only collect and use your location where we have your consent to do so.

Use of our Sites (including our Apps)

We collect and maintain personal information that you voluntarily submit to us during your registration or when requesting our Services such as your name, email address, date of birth, sex, gender, postcode and if you are using our online shop, your address and payment card details.

We use the contact and payment details you have provided to us so that we can fulfil the services you have requested from our Site and/or our App. In particular, we use the contact and payment details you have provided to us where applicable so that we can fulfil the supply of products and services you have requested from our Site. You can also volunteer to provide us with additional personal information when using some of the tools available on the Site, such as information about your drinking habits or your achievements or motivations.

Who do we share your personal information with for this purpose?

We will share your personal information with the following categories of third parties:

  • To provide our Site and App – third party web hosting companies;
  • To verify card payments and process refunds – credit card companies and other payment providers;
  • To deliver products – delivery and fulfilment companies;
  • To deliver the App – third party app stores
What is our legal basis?

It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you. We only collect and use your location where we have your consent to do so.

The Drinking Check and Digital Scratchcard tools (the “Tools”)

This section applies to our privacy practices when you use the Tools, which vary from the privacy practices described in the rest of our Privacy Notice. You should therefore take particular care to review this section of our Privacy Notice, so that you understand how we use personal information that you upload via either Tool. For more information see below.

The Tools allow you to input your age, sex, postcode and information about your drinking habits.

Where you have given your consent for us to do so, we may send you an email setting out facts and guidance based on the personal information you have provided about your drinking habits when using the Drinking Check Tool. Where you have given your consent for us to do so we may also send you regular emails that help you to monitor your drinking habits. We may track these emails as set out in the User insight, analysis and personalisation section.

Who do we share your personal information with for this purpose?

Your personal information will be shared with our email service partner.

What is our legal basis?

Your explicit consent.

Service enquiries

Our Site and App use various user interfaces to allow you to request information about our Services: these include printed and electronic enquiry forms and a telephone enquiry service. Contact information may be requested in each case, together with details of other personal information that is relevant to your enquiry. This information is used in order to enable us to respond to your requests.

Who do we share your personal information with for this purpose?

We do not share your personal information for this purpose.

What is our legal basis?

It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can to you.

Research and feedback

From time to we will invite you to participate in research and feedback about our products and Services to help us improve what we offer to our users.

Who do we share your personal information with for these purposes?

We use a third party service provider to assist us with research and feedback surveys.

What is our legal basis?

It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.

User insight, analysis and personalisation

We analyse your contact details with other personal information that we observe about you from your interactions with our Site and App or when downloading or using our App and Tools such as the IP address, operating system and browser type of your device. The personal information that we observe may be collected by us and our partners using Cookies, which collect information from the device and software you use. For further information, please see the Our use of Cookies section below for further information.

The personal information that we collect for this purpose may include the following:

  • an IP address and session ID to monitor Site and App traffic and volume, to track usage statistics, and to measure the effectiveness of our content and how visitors use our Sites, our App and our Services, so that we can understand which parts of our Sites are the most interesting and what kind of content our users like to see and to help us with the development of future product and service lines, the design of the shop and our Site and App.
  • information regarding your personal or professional interests, demographics, location, buying habits, experiences with our products and contact preferences, which we use to create profiles to personalise your Drinkaware experience, including the marketing that you may receive from us, ad to personalise online advertising that we deliver to you. See the Advertising and Marketing section below for further information.

In addition, we may collect personal information through our emails, to track receipt of an e-mail to you, to count users that have visited our Site from an email or opened an e-mail, and to collect other types of aggregate information for analytics purposes. When you open an e-mail from us, your contact information may subsequently be cross-referenced to the source e-mail. Some of our e-mails may also use a “click-through URL” linked to our Site. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

Who do we share your personal information with for this purpose?

We share your personal information with a variety of third party service providers to assist us with the above purposes.

What is our legal basis?

Where your personal information is collected through the use of non-essential Cookies, we rely on consent to collect your personal information and for the onward processing purpose. Please see the Our use of Cookies section below for further details. Where data is not collected through the use of non-essential Cookies, it is in our legitimate interest to use your personal information in this way, so that we can:

  • improve our Site, our App and our Services
  • measure the effectiveness of our advertising activities; and
  • personalise the experience that we provide to our visitors and customers, including for the advertising and marketing activities described below.

Advertising and Marketing

We carry out the following advertising and marketing activities using your personal information:

Email marketing

We use information that we observe about you from your interactions with our Site, our email communications to you and/or with our services (see the User insight, analysis and personalisation section above for more details of the information collected and how it is collected) and/or your email address, to send you marketing communications by email, where you have consented to receive such marketing communications, or where we have another lawful basis to do so.

Who do we share your personal information with for this purpose?

We share your personal information with a third party email marketing provider who assists us in delivering our email marketing campaigns to you.

What is our legal basis?

It is in our legitimate interest to use your personal information for marketing purposes, for example to decide what marketing content we think may appeal to you.

It is in our legitimate interest to use your personal information to send our marketing to you by post.

We will only send marketing communications to you by email and/or SMS where you have consented to receive such content by email and/or SMS, or where we have another lawful right to send marketing to you using email and/or SMS. For example, in certain circumstances we may rely on our legitimate interest to send marketing by email and/or SMS to consumers who have purchased our Services. We may also rely on our legitimate interest to send marketing by email and/or SMS to certain business users of our Sites and our Services.

In addition, please see the User insight, analysis and personalisation section above to learn about the lawful basis that we rely on to personalise the marketing that we send to you.

We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.

Online personalised advertising

We use information that we observe about you to provide you with personalised ads when you use other websites and online services. By “personalised ads”, we mean advertisements for products and services that you have shown an interest in when you have used our Site or our App or which we or our third party advertising partners think you otherwise might be interested in.

See the User insight, analysis and personalisation section for more information about the personal information that we use for this purpose.

Who do we share your personal information with for this purpose?

We share your personal information with a variety of third party advertising partners who assist us with our online personalised advertising campaigns. For more information about these advertising partners please do so via the Cookie Preference Centre link at the footer of our website.

What is our legal basis?

See the User insight, analysis and personalisation section to learn about the legal basis that we rely on to collect data via the use of Cookies.

Where we use your personal data to display online advertising to you, we rely on the consent that you have provided in respect of the collection of such data, or it is otherwise in our legitimate interests to promote our Site, our App and our Products and Services to you.

Our third-party advertising partners may rely on a different lawful basis in respect of their use of your personal data. Please read the privacy information provided by our advertising partners, which can be found in our cookie preference centre in the link at the footer of our website.

Advertising to you on social media

We share (usually in an encrypted or “hashed” form) certain contact data and identifiers (such as advertising identifiers associated with your device or browser). We do this so that Facebook can try to “match” your hashed data with the hashed data relating to its registered users.

Where there is a successful match of your hashed contact data (e.g. because you are our customer and/or a user of our Site and are also a registered Facebook user), our advertising will be displayed to you when you use Facebook. This is known as “custom audience” advertising, because we “customise” the audience that we want to reach on Facebook.

Some of the advertising that you see may be personalised to you using information that we observe about you through your use of the Site and App, which we share with Facebook. See the User insight, analysis and personalisation section for more information about the personal information that we use to do this.

This activity is also subject to the privacy choices you have elected to make on Facebook. In some cases we may be joint controllers with Facebook in respect of this activity – please see the Joint Controller activities section below for further information.

Who do we share your personal information with for this purpose?

We share your email address with third party service providers who assist us with social media remarketing campaigns. Your encrypted email address is also shared by us, or our third party service providers, with Facebook with this purpose.

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it under data protection laws as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our cookie preference centre for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to analyse your personal information for marketing purposes.

We will only engage in social media remarketing where you have consented to us sending you marketing communications.

Social media insight

In addition to advertising to you on social media (see above), we may ask Facebook to find other registered users of their services that share similar interests to you based on:

  • the information that we provide to Facebook to advertise to you (see above) and the information that we observe about you (see the User insight, analysis and personalisation section above for more information); and
  • the information Facebook hold about you.

This is known as “lookalike” audience advertising because we are trying to show our advertising to people who “look like” our customers and/or users. Please note that such activity is subject to the privacy choices you have elected to make on Facebook.

Who do we share your personal information with for these purposes?

We share your email address with third party service providers who assist us with social media remarketing campaigns. Your encrypted email address is also shared by us or our third party marketing consultancies with Facebook.

What is our legal basis?

Please see the Advertising to you on social media section above for details of the lawful basis that we rely on to share your personal information with Facebook.

It is in our legitimate interests to further use your personal information to advertise our Site, App and Services to other individuals who use Facebook and who share similar interests and characteristics with you.

If you are someone who has seen this advertising on Facebook, it is in our legitimate interests that Facebook uses the data that you have provided to it to advertise our Site, App and Services, although please note that we do not receive this data and you should exercise your rights in respect of such data in accordance with Facebook’s privacy notice.

Business administration and legal compliance

We use your personal information for the following business administration and legal compliance purposes:

  • to comply with our legal obligations;
  • to enforce our legal rights;
  • protect rights of third parties; and
  • in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
Who do we share your personal information with for these purposes?

We will share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.

What is our legal basis?

Where we use your personal information in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.

Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details.

5) How do we obtain consent?

Where our use of your personal information requires your consent, you can provide such consent:

  • at the time we collect your personal information following the instructions provided; or
  • by informing us by e-mail, post or phone using the contact details set out in this Privacy Notice.
6) Our use of cookies

Our Site uses cookies, pixels, web beacons, log files and other similar technologies (“Cookies”). If you would like to understand more about these technologies, please visit All About Cookies.

We use Cookies for the purposes described in the following sections of this Privacy Notice:

  • User insight, analysis and personalisation
  • Email marketing
  • Social media insight
  • Online personalised advertising

In some cases, the Cookies that we use may be provided by third party Vendors. Information about you may be shared with the relevant third party Vendor and used in accordance with their privacy notice.

To find out more, including why we use Cookies, which Cookies we use (including the third party Vendors that assist us and information about their privacy practices) and how you can manage your preferences via the Cookie Preference Centre link at the footer of our website.

We may also analyse use of our App through similar technologies known as SDKs, which are blocks of code which collect information. SDKs help us understand how you interact with our mobile applications and collect certain information about the device and network you use to access our applications, such as the advertising identifier associated with your device and information about how you interact with our applications. The table below sets out more information about the SDKs we may use in relation to our App and the purposes for which they are used:

Cookie name

1st Party or 3rd Party cookie

Cookie Type

Purpose

Platform

Google Firebase

3rd Party

Analytical

Analytics, databases, messaging and crash reporting

iOS and Android

Facebook

3rd Party

Social

Analytics, secure login, Facebook and Instagram ads

iOS and Android

 

Please note, you can also manage your Cookie preferences using functionality provided by your browser, but please be aware that in order to use some parts of our Site you will need to allow certain Cookies. If you block or subsequently delete certain Cookies, some aspects of our Site may not work properly and you may not be able to access all or part of our Site. For more information on cookie management and blocking or deleting cookies for a wide variety of browsers, visit All About Cookies.

In addition, if you do not want to be tracked by Google Analytics, you can install the Google Analytics opt-out browser add-on (but this will only work on certain browsers). Please also be aware that, when you access our Site via Google applications such as Google Chrome, Google may collect user information for the purpose of Google serving personalised advertising across your devices. These cookies are dropped for Google’s own purposes and as such we do not have any control over how or when they are dropped. You will need to opt out of receiving these cookies via your Google settings. For more information about how Google collects and uses your personal information see Google’s Privacy Notice.

 

 

7) Joint Controller activities

We are joint controllers with Meta Platforms, Inc. (“Meta”) in respect of the activities described in the Online personalised advertising section and the Advertising to you on social media section, where those activities involve advertising to you on platforms that are owned and operated by Meta.

Meta’s UK Controller Addendum (available here) determines our and Meta’s respective responsibilities for compliance with data protection obligations in respect of these activities. We and Meta are responsible for providing information about how your data might be processed in connection with these activities in our respective privacy notices.

Where we or Meta have a direct relationship with the data subject, we or Meta (as applicable) will be responsible for complying with any rights requests from the relevant data subject. However if you are not a user of our Site, our App or our Services, Meta will take primary responsibility for giving effect to your data subject rights in respect of these activities. For information about your rights, see the How to access your information and your other data rights? section.

For further information about how we and Meta use your personal data in connection with these activities, including the legal basis Meta relies on and the ways to exercise your data subject rights against Meta, please see Meta’s Data Policy at https://www.facebook.com/about/privacy.

8) Third party links and services

Our Site contains links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this Privacy Notice no longer applies. For more information below.

Your browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.

We do not monitor, control, or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.

This Privacy Notice applies solely to personal information collected by us through the Site, our App or when you use our Services and does not apply to these third party websites and third party service providers.

9) How long do we keep your personal information for?

We keep your personal information for a variety of periods depending on the purposes for which we process your personal information. See below for more details If your information is only useful for a short period e.g. for specific marketing campaigns we may delete it.

10) Confidentiality and security of your personal information

We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. For more information click below.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

  • unauthorised access;
  • improper use or disclosure;
  • unauthorised modification; and
  • unlawful destruction or accidental loss.

All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.

11. How to access your information and your other data rights?

You have the following rights in relation to the personal information we hold about you:

Your right of access

If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

Your right to rectification

If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to erasure

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to restrict processing

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to data portability

With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

Your right to object

You can ask us to stop processing your personal information, and we will do so, if we are:

  • relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
  • processing your personal information for direct marketing.

Your rights in relation to automated decision-making and profiling

You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

Your right to withdraw consent

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. If you wish to withdraw your consent, you can do by emailing contact@drinkaware.co.uk.

Your right to lodge a complaint with the supervisory authority

If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

12) Changes to this Privacy Notice

We may make changes to this Privacy Notice from time to time. For more information click below.

To ensure that you are always aware of how we use your personal information we will update this Privacy Notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal information.

Appendix: Data Retention Table

Data Type

Retention Policy

Users of the Drinkaware app or other apps that may be created in future

Drinkaware will retain the users’ data until they close their account or until the user has been inactive for 12 months.

Subscribers to Drinkaware consumer newsletters, such as the ‘Drink Free Days’ campaign newsletter

Newsletters are a regular communication and Drinkaware will retain user data until the user chooses to unsubscribe. Or fails to re-consent at 2.5 years recency.

Customers of Drinkaware’s online shop

Under HRMC and VAT regulations, Drinkaware is required to retain information about financial transactions for seven years.

 

Consumers receiving marketing

If a consumer has consented to marketing emails, Drinkaware will send them relevant and timely emails until they unsubscribe or don’t re-consent at 2.5 years. Drinkaware will keep a record that such users should not receive marketing.

People who have participated in Drinkaware research

Any individual agreeing to participate in Drinkaware research has a number of options:

·       To participate in a prize draw – personal information will be held until the draw takes place and then deleted

·       Agree to participate in future research - their email address will be retained for this purpose only until they unsubscribe.

(Any other active relationship they may have will continue until they indicate otherwise.) 

People who are a ‘business’ partner of Drinkaware

Information about Drinkaware’s ‘business partners’ will be retained indefinitely. When an individual (account manager or key contact) leaves the employment of the business partner, Drinkware will delete their contact details and any information relating to them but retain all pertinent business data.

If a business-to-business contact requests an unsubscribe or chooses to opt-out of Drinkaware communications, their personal contact data will be suppressed.

Individuals who have made, or have been, the subject of a complaint to Drinkaware under the Complaints Policy.

This information will be retained indefinitely as it is held on the organisational suppression file.

 

 

 

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