1. who we are

This privacy notice is issued by Las Olas Limited (“we”, “us”, “our”), a company registered in England and Wales with company number 11484619. We are a controller of your personal data and are responsible for ensuring that it is properly protected. We are registered with the Information Commissions Office in the UK with reference ZB513971.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK data protection laws. Please see the 'How to contact us' section at the end of this privacy notice if you have any questions about this privacy notice or the data we hold about you.

2. This privacy notice

Please read this privacy notice carefully as it contains important information about who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

3. Our collection and use of your personal data

Personal data means any information about an individual from which they can be identified, whether directly or indirectly.

How your personal data is collected

We collect personal data about you in difference ways, including:

• Direct interactions. You may give us your personal data when you purchase our products through our website, otherwise access our website, sign up to our newsletter, contact us, send us feedback, or complete customer surveys.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
• Third parties. Occasionally, we are involved with customer competitions run by third parties (for example where you have the chance to win our products in competitions run by other organisations). For such competitions, we will be given certain identity and contact information about you in order to provide you with the products, should you win.

Personal data we collect about you

The personal data we collect about you depends on how and why you engage with us. We may collect and use the following data about you:

• Identity Data - full name, title, date of birth, age, and we may ask you for your location in certain circumstances (e.g. when you take part in a survey or provide us with feedback).
• Contact Data - address, email address and telephone number(s).
• Financial Data - payment card details.
• Transaction Data - details about payments to and from you and details of the products you have purchased from us.
• Technical Data - internet protocol (IP) address, your login data, 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.
• Profile Data - your username and password, orders made by you, your interests and preferences.
• Usage Data - data about how you use our website, including survey responses.
• Marketing and Communications Data - your preferences in receiving marketing from us and your communication preferences.

We need this personal data to sell our products to you. If you do not provide personal data we ask for, it may delay or prevent us from providing our products to you.

Our website is not intended for use by children and we do not knowingly collect or use personal data relating to children under the age of 18.

We do not routinely collect any Special Categories of Personal Data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal conviction and offences.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a lawful basis for doing so, which includes:

• Consent: where you have given us clear consent for us to process your personal data for a specific purpose;
• Contract: where our use of your personal data is necessary to fulfil a contract we have with you, or because you have asked us to take specific steps before entering into a contract;
• Legal obligation: where our use of your personal data is necessary for us to comply with the law (not including contractual obligations); or
• Legitimate interests: where our use of your personal data is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal data which overrides our legitimate interests) and these can include business interests, individual interests or broader societal benefits.

Purpose / Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To sell and deliver our products to you, including: (a) to manage payments, fees and charges (b) to collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us and to provide our products to our customers) (c) Legal obligation to ensure that we only sell our alcoholic products to anyone over the age of 18
To manage our relationship with you which will include: (a) Notifying you about changes to our products, terms or privacy notice (b) Asking you to leave a review or take part in a survey (c) Responding to queries you may raise	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Necessary for our legitimate interests (for 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) (b) Necessary to comply with a legal obligation
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation
To deliver relevant website content and marketing materials to you and measure or understand the effectiveness of the marketing we send to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to manage our customer relationships, keep our records updated and to study the purchasing patterns of our customers so we can develop our products and business)

[ 4. Who we share your personal data with ]

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We may disclose your personal data to law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share personal data with other third parties, such as potential buyers of some or all of our business or during a company re-structuring. Alternatively, we may seek to acquire other business or merge with them. Personal data will be anonymised where possible, but this may not always be possible. The recipient of the personal data will be bound by confidentiality obligations.