LAS OLAS LTD

CUSTOMER PRIVACY NOTICE

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.

The table below explains what we use your personal data for and why, as well as what our legitimate interests are where we are relying on our legitimate interests as the lawful basis to process your personal data:

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) 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)
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) Technical	(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 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 (f) Technical	(a) Consent* OR (b) Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy) * We will ask for your consent where we are legally required to do so (please see the ‘Marketing’ section below)
To use data analytics to improve our website, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about products that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our product line and grow our business)

 

4. Who we share your personal data with

We routinely share personal data with:

• our external third party payment service provider, Shopify (please see ‘Sharing your Personal Data with Shopify’ below);
• other external third parties we use to help us run our business, including our distribution centre Hutch Logistics, and our email marketing provider Klaviyo (see section 7 for more information about our marketing activities);
• our external professional advisors (such as our lawyers or accountants);

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.

Sharing your Personal Data with Shopify

Our online store is hosted through Shopify and we use Shopify’s payment gateway in order to process your payment when you purchase products from us. Shopify is a secure platform which stores your payment card details in accordance with the Payment Card Industry Security Standard (PCI-DSS). You payment and transaction data will be stored for as long as it necessary to complete the transaction, after which time, you payment details will be deleted. For more information about how Shopify process your personal data, please visit: https://www.shopify.com/legal/privacy.

5. Transferring your personal data out of the UK and EEA

To provide products to you and run our business, it is sometimes necessary for us to share your personal data outside the UK, for example, with our service providers either located outside the UK or transfer personal data outside of the UK.

Transfers of personal data outside of the UK are subject to special rules under UK data protection law. This is because non-UK countries do not have the same data protection laws as the United Kingdom. We will ensure the transfer complies with data protection law and all personal data will be secure.

As a result, when we transfer personal data outside of the UK we will ensure that the transfer complies with data protection law by following one of the below steps:

• Confirming that the recipient is located in a country which has been recognised as having an adequate level of protection for personal data, for example countries located within the EEA;
• Putting in place safeguards (such as approved standard contractual clauses) so that you have enforceable rights and effective legal remedies; or
• Confirming that a specific exception applies under data protection law.

For more information about our international transfers, please contact us using the information below.

6. Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies on our website. Cookies help us recognise you and your device and store some information about your preferences or past actions. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

For further information about cookies, our use of cookies, when we ask your consent before placing them, and how to disable them, please see our Cookies Policy.

7. Marketing

We may use your personal data to send you our newsletter and updates (by email or SMS) about our products, including exclusive offers, promotions or new products we are launching.

We often have a legitimate interest in using your personal data for marketing purposes (see the table above). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.

Regardless of whether you have given your consent to receive marketing communications, or it is in our legitimate interests to send them, you always have the right to opt out of receiving further promotional communications by:

• contacting us at hello@lasolasrumclub.com; or
• using the ‘unsubscribe’ link in emails.

We may ask you to confirm or update your marketing preferences if there are changes in the law, regulation, or the structure of our business.

Please note that we may also send you other communications in relation to your purchase of products or in order to respond to queries you have raised, such communications are service communications and are not considered a form of marketing communications.

8. Your rights

You have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal data (the right of access)
Rectification	The right to require us to correct any mistakes in your personal data
To be forgotten	The right to require us to delete your personal data—in certain situations
Restriction of processing	The right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

 

For further information about your rights please contact us or see the guidance provided by the UK Information Commissioner’s Office (ICO) on individuals’ rights.

If you would like to exercise any of your rights, please:

• email us at: hello@lasolasrumclub.com;
• let us have enough information to identify you g. your full name, address and customer or matter reference number);
• let us have proof of your identity if requested; and
• let us know which right you want to exercise and the data to which your request relates.

9. How long your personal data will be kept

We will not retain your personal data for longer than necessary for the purposes set out in this privacy notice. Different retention periods apply for different types of personal data.

When it is no longer necessary to retain your personal data, we will delete or anonymise it.

As an indication, if you purchase products from us, we will keep your personal data while we are processing and fulfilling your order. Thereafter, we will keep your personal data for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly; and
• to keep records required by law.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

You can request further details of retention periods for different aspects of your personal data by contacting us.

10. Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your data will do so only in an authorised manner and are subject to a duty of confidentiality.

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

11. How to complain

Please contact us if you have any query or concern about our use of your data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner in the UK. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113

12. How to contact us

You can contact us if you have any questions about this privacy notice or the data we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

hello@lasolasrumclub.com

13. Changes to this privacy notice

This privacy notice was last updated in February 2023. We keep our privacy notice under regular review to make sure it is up to date and accurate. If we change our privacy policy from time to time, we will post the details of any changes here. We may also take reasonable steps to notify you if such changes affect how your personal data is processed.

 

 

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