Privacy Policy

LAST UPDATED April 6th, 2023

 

WHO WE ARE

Noble Oak is owned by Edrington Distillers Limited, a private limited company (registered in Scotland No.014472), and our registered office is at 100 Queen Street, Glasgow, G1 3DN. Processing of personal data relating to Noble Oak as described in this Privacy Policy is also undertaken by other group companies of The Edrington Group Limited (Noble Oak’s ultimate parent company) – details of these companies can be found [here] . 

In this Privacy Policy, Noble Oak Spirits Company and the relevant Edrington group companies are referred to as Noble Oak, we, us or our.

Noble Oak is the controller in relation to the processing of your personal data described in this Privacy Policy. We have a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your rights in relation to your personal data, please contact us at the details set out below.

OVERVIEW

Noble Oak is committed to protecting and respecting the privacy of its consumers’ personal data.  Looking after the personal data that we collect on our consumers is a priority for us and we want you to be confident that your information is in safe hands.  We’ve developed this Privacy Policy to let you know:

• What types of personal data we collect;
• How we collect personal data;
• The purposes we collect personal data for, including how we use it to make our products better and to offer better services and experiences to our consumers;
• The circumstances in which we may share it with other organizations that support our operations, including the types of organizations involved;
• Where we store your personal data;
• How long we keep personal data for; and
• The rights and choices you have with regards to your personal data.  

It is important that you read this Privacy Policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

WHAT TYPES OF PERSONAL DATA DO WE COLLECT ABOUT OUR CUSTOMERS?

• Your name, age/date of birth (for age verification purposes) email address, postal address (if you are happy to provide this), zip code and location;
• Your 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 the website (Technical Data);
• Your correspondence and communications with Noble Oak;
• Information about how you use our website, products and services (Usage Data);
• Details of any event or experience bookings you have made, including details you have provided or we may have collected from you in connection with your attendance at any events or experiences we have arranged with you (such as any accessibility or dietary requirements or other interests related to the event or experience);
• Personal data, which you have maybe shared via a public platform (such as on Noble Oak’s Facebook or Instagram feed);
• Your preferences in receiving marketing from us and our third parties and your communication preferences;
• Information about any experiences, gifts, special invitations or benefits made available to you;
• Your interests, preferences, feedback and survey responses; and
• Online browsing activities on Noble Oak website.

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 data but is not considered personal data in law as this data 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 data which will be used in accordance with this privacy policy.

Other than the data listed above, we do not collect any Special Categories of Personal Data about you (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, biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, 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 (e.g. to provide you with services). In this case, we may have to cancel an experience you have with us but we will notify you if this is the case at the time.

To see the categories of personal data we collect, please see appendix below.

HOW DO WE COLLECT YOUR PERSONAL DATA?

We collect your personal data by different methods, including:

• Direct interactions: This includes personal data you provide when:
  • You subscribe to receive our newsletter;
  • You attend one of our events or visit one of our sites;  
  • You enter a ballot or competition related to Noble Oak or one of Noble Oak’s products;
  • You interact with one of our representatives;
  • You communicate with us through telephone, text messaging, or other app-based or social media direct messaging; and
  • You contact us, for whatever reason.
• 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. Please see our Cookies Policy for further details.
• Third party sources of information: We may obtain information about you from the following third party sources:
  • Where you interact with a third party acting on our behalf (e.g. a representative of one of our distributors or joint venture partners);
  • Our professional advisors (e.g. lawyers, accountants and bankers); and
  • Publicly available sources (e.g. how you share your experiences and passion for Noble Oak with others on social media and retailers of Noble Oak).
• Technical Data: We also collect Technical Data from the following parties:
  • Analytics providers (such as Google)
  • Advertising networks; and
  • Search information providers.

ONLINE ANALYTICS

We use various types of online analytics, including Google Analytics, a web analytics service provided by Google, Inc. (Google), on our website. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the website, compile reports on the related activities, and provide other services related to website and app activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website or app. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google click here.

SURVEYS

From time to time, and subject to your consent where required by applicable local law, we may provide you with the opportunity to participate in surveys, some of which might be sponsored or conducted by a third party. Participation in these surveys is completely voluntary. If you choose to participate, we will request certain personal data from you. If there is a third party sponsor involved in the survey, we may provide certain personal data to the third party sponsor. Please make sure to review the sponsor’s privacy policy and be aware that any surveys offered by us may be governed by specific rules and terms and conditions that are separate from and in addition to this Privacy Policy. By participating in any such surveys you will become subject to those rules, including but not limited to receiving emails containing survey communications.

HOW DO WE USE YOUR PERSONAL DATA?

Noble Oak (and trusted partners acting on our behalf) use your personal data:

• To provide you with information, products or services that you request from us, or which we feel may interest you. This is only done when you’ve given your consent to be contacted by us, or where we are permitted to contact you in accordance with data protection law;  
• We may send you personalized communications based on your preferences, and use of Noble Oak’s products;
• To verify your identity and your age;
• For crime and fraud prevention, detection and related purposes;
• To enable Noble Oak to manage any customer service interactions with you;
• To ensure that our web content is presented in the most efficient way for you and your computer;
• To allow you to participate in interactive features on our website, when you choose to do so; and  
• Where we have a legal right or duty to use or disclose your information (e.g. in relation to an investigation by a public authority or in a legal dispute).  

We may also combine your personal data collected through various sources, including information collected through our website and services, and develop a profile that will be used for the purposes above.

WHAT IS OUR LEGAL REASON FOR HOLDING YOUR PERSONAL DATA?

Data Protection Laws require us to state our legal reason for processing your personal data.   

Where we have requested your consent, we will rely on this consent to send you marketing communications about Noble Oak. We may also send you marketing communications about Noble Oak where you have requested information from us and have not opted out of receiving such communications.

You can withdraw your consent to receive these communications at any time by using the unsubscribe button included in the communications we send you, or by contacting us at [email protected]. Where you opt out of receiving marketing communications, this will not remove any personal data that we need to retain following your attendance at an event or experience.

Noble Oak also collects and uses your personal data because it is necessary for:

• the pursuit of our legitimate interests (as set out below);
• the purposes of complying with our duties and exercising our rights under a contract for the sale of goods to a consumer; or
• complying with our legal and regulatory obligations.

OUR LEGITIMATE INTERESTS

The normal legal basis for processing consumer data, is that it is necessary for the legitimate interests of Noble Oak, including:

• selling and supplying goods to our consumers;
• protecting consumers, employees and other individuals and maintaining their safety, health and welfare;
• promoting, marketing and advertising our products, services, events, experiences and brand partnerships;
• understanding our consumers’ behavior, activities, preferences, and needs;
• improving existing products and developing new products;
• handling consumer contacts, queries, complaints, or disputes; and
• preventing, investigating and detecting crime, fraud, or anti-social behavior and prosecuting offenders.  

Where we process your personal data in pursuit of our legitimate interests, you have the right to object to us using your personal data for the above purposes. If you wish to object to any of the above processing, please contact us at [email protected]. If we agree and comply with your objection, this may affect our ability to undertake the tasks above for your benefit.

CHANGE OF PURPOSE

We will only use your personal data 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 require any further information on how the processing for the new purpose is compatible with the original purpose, please contact us using the details below.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

COOKIES

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 more information about the cookies we use please see our Cookies Policy.

DO NOT TRACK

Some devices and browsers support a “Do Not Track” (or DNT) feature, a privacy preference that you can set in certain browsers, which is intended to be a signal to websites and services that you do not wish to be tracked across different websites or online services you visit. Please note that we cannot control how third party websites or online services you visit through our website respond to Do Not Track signals. Check the privacy policies of those third parties for information on their privacy practices.

Our website does not currently change the way it operates upon detection of a Do Not Track or similar signal.

WHAT ARE YOUR RIGHTS?

You have a number of rights under the Data Protection Laws in relation to the way we process your personal data, namely:

• to access your data (commonly referred to as a “data subject access request”) – this enables you to access the personal data we hold about you and to receive confirmation of how we are processing it;
• to have your data rectified if it is inaccurate or incomplete – this enables you to have any incomplete or inaccurate data we hold about you and to receive confirmation of how we are processing it;
• in certain circumstances, to have your data deleted or removed – this enables you to ask to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
• in certain circumstances, to restrict the processing of your data – this enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • if you want us to establish the data’s accuracy;
  • where our use of the data is unlawful but you don’t want us to erase it;
  • where you need us to hold the data even if we no longer required it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data (see below) but we need to verify whether we have overriding legitimate grounds to use it,
• a right of data portability, namely to obtain and reuse your data for your own purposes across different services. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to data which you initially provided consent for us to use or where we used the data to perform a contract with you;
• to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms;
• not to be subject to automated decision-making (including profiling), where it produces a legal effect or a similarly significant effect on you;
• the right to withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with certain products of services. We will advise you if this is the case at the time you withdraw your consent; and
• to claim compensation for damages caused by a breach of the Data Protection Laws.

If you wish to exercise any of these rights, please contact [email protected].

WHO DO WE SHARE YOUR PERSONAL DATA WITH? 

To effectively fulfil our obligations to you, and to provide you with certain benefits, we use a number of trusted and reliable third parties to carry out functions which involve the processing of your Personal Data.  These include:

• vendors who will process your personal data on our behalf and under our written instructions to carry out their services during the course of our business, such as IT, delivery and marketing service providers, financial institutions, customer relationship management vendors and other cloud-based solutions providers that are used by Noble Oak in the conduct of our business. We contract with such vendors to ensure that they only process your personal data by implementing the appropriate technical and organizational measures for such processing;
• vendors that process your personal data in order to assist us to better understand our consumers and how we can improve our consumer engagement, such as HubSpot, Obviouslee and Salted Stone;
• we use marketing service providers to administer services on our behalf, such as sending communications to our consumers, administering any promotions or ballots which we run;
• we use translation service providers to administer services on our behalf, such as translating communications received and sent in different languages;
• other agencies and fulfilment partners to administer events, competitions and brand programs that you have opted into;
• our subsidiary companies who are involved in customer services and marketing activities related to Noble Oak and other entities in the Edrington group of companies; and
• Noble Oak’s third party distributors and joint venture partners.

We may provide information to others (such as governmental or law enforcement agencies) in the good faith belief that such action is necessary to: (i) enforce or apply our Terms and Conditions; (ii) comply with any legal claims raised against Noble Oak; (iii) protect the rights, property or safety of Noble Oak; or (iv) protect the rights, property or safety of the public.

In accordance with applicable law, we may also transfer or assign your personal data to third parties as a result of, or in connection with,  a sale, merger, consolidation, acquisition, change in control, bankruptcy, reorganization, liquidation or other transaction involving the sale of some or all of our assets, user information, including personal information collected from you through your use of our Website, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you, either through email and/or a prominent notice on the Website.

To see the categories of personal data we share, please see appendix below.

WHERE WE STORE YOUR PERSONAL DATA

We may transfer your personal data outside the United States. This is primarily to allow us to:

• receive consultancy, marketing and IT services (e.g. cloud storage services, database development and management services, email/webmail services and customer relationship management services) from vendors located in non-US jurisdictions, such as the UK/EEA, South Africa and Australia; and
• provide special invitations, products, services, experiences and other benefits to you, from other Edrington group companies, or selected third party distributors or joint venture partners.

Where your personal data is transferred outside of the US, we will ensure your personal data is afforded an adequate level of data protections (as required by data protection laws), including:

• by transferring the data to a country that the relevant authorities have deemed as providing an adequate level of data protection (an "adequacy decision");
• by implementing an appropriate international transfer mechanism under data protection law, such as standard contractual clauses or a data transfer agreement / addendum approved for this purpose by the relevant authorities;
• by relying on a "transfer derogation" under Data Protection Law (e.g. where the transfer is based on your consent); or
• where we are otherwise permitted to make the transfer under Data Protection Law.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the US.

HOW LONG DO WE KEEP YOUR PERSONAL DATA? 

We will not retain your personal data for longer than necessary for the purposes set out in this Privacy Policy, including for the purposes of maintaining our relationship with you as well as satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you. 

Different retention periods will apply to different types of data.  To determine the appropriate retention period for personal data, we consider any ongoing relationship we have with you, the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purpose for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting and other requirements.

When we no longer need to use your personal data, we will remove it from our systems and records, and/or take steps to anonymize it so that you can no longer be identified from it (unless we need to keep your data to comply with legal or regulatory obligations we are subject to).

In certain circumstances, you can ask us to delete or remove your data (see the section entitled “What rights do you have?” above for further information on your rights).

We may use your personal data collected by recording phone calls and retaining a transcript of our live chats with you through our Website (including where these are handled by our third party technical services provider) for the following purposes:

1. Account management;
2. Prevention, detection, investigation and prosecution of fraud;
3. Complaint handling and resolution;
4. Measuring the quality of the call;
5. Internal training on call handling.

We have a legitimate interest in retaining calls and live chats in order to offer our consumers a good service and to protect our business. If you object to the call recording, you may choose to end the call when you are informed that calls may be recorded.  If you use our live chat function to get in touch with us, you will be informed that we will keep a record of the discussion at the start of the chat and you will be able to end the chat at any time.  You will have the option to contact us through alternative means. All calls and live chat records will be retained for a period of one year.

HOW DO WE PROTECT YOUR PERSONAL DATA?

Noble Oak is committed to keeping your personal data safe and secure.  To prevent unauthorized access, maintain data accuracy and ensure the correct usage of personal data, we monitor and adjust our physical, electronic and managerial procedures to safeguard and secure the personal data we collect online.

YOUR CALIFORNIA PRIVACY RIGHTS

Please be aware that we do not sell or rent personal data.

If you are a California resident, you have the following rights regarding your personal data:

• Access to your personal data. You have the right to request access to the personal data that we collect, use, and disclose about you. You also have the right not to receive discriminatory treatment for exercising your access right. To submit a request or designate an authorized agent to make a request on your behalf, please contact us at [email protected].
• Deletion of your personal data. You have the right to request that we delete your personal data, subject to some exceptions under applicable law. You also have the right to not receive discriminatory treatment for exercising your deletion right. To submit a request or designate an authorized agent to make a request on your behalf, please contact us at [email protected]. 

We do not share personal data with third parties for their own direct marketing purposes without your consent. California residents under 18 years old, in certain circumstances, may request and obtain removal of personal data or content that you have posted on our Website. Please be mindful that this would not ensure complete removal of the content posted by you on our services. To make any request pursuant to California privacy law, please contact us at [email protected].

THIRD PARTY WEBSITES AND APPS

Our Website and services may contain links to other websites or apps operated by third parties. Please be advised that the practices described in this Privacy Policy do not apply to information gathered through these third party websites and apps. We have no control over, and are not responsible for, the actions and privacy policies of third parties and other websites and apps.

QUESTIONS

If you have any questions or concerns about the way in which your Personal Data is processed, please contact [email protected].     

CHANGES

Noble Oak may update this Privacy Policy from time to time as our privacy practices change, or as required by applicable legal or regulatory requirements.  Where it is practicable, we will notify you of any significant changes. However, the last update date is given above and Noble Oak encourages you to review this Privacy Policy periodically so you remain informed of how we use your personal data.

 

CALIFORNIA PRIVACY LAW APPENDIX

This appendix provides additional information to residents of California and supplements the information provided in the Privacy Policy above.

To learn more about the categories of personal data we collect, how we collect it, why it is collected, with whom we share the information, and how long we retain it, please see the chart below.

Category	What we collect	How we collect it	Why we collect it	With whom we share it	How long we retain it
Identifiers	Name, mailing address, email address, phone number, and other contact information. For more information please see the What Types of Personal Data Do We Collect About Our Customers section above.	Collected online or offline when you provide it to us, through your use of our website, services, or from third parties. For more information please the How Do We Collect Your Personal Data section above.	We collect this information for the purposes listed in the What Is Our Legal Reason For Holding Your Personal Data section above.	Shared with our affiliates, partners, vendors, and service providers as described in the Who Do We Share Your Personal Data With section above.	We retain information as described in the How Long Do We Keep Your Personal Data section above.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Name, mailing address, email address, phone number, and contact information. For more information please see the What Types of Personal Data Do We Collect About Our Customers section above.	Collected online or offline when you provide it to us, through your use of our website, services, or from third parties. For more information please the How Do We Collect Your Personal Data section above.	We collect this information for the purposes listed in the What Is Our Legal Reason For Holding Your Personal Data section above.	Shared with our affiliates, partners, vendors, and service providers as described in the Who Do We Share Your Personal Data With section above.	We retain information as described in the How Long Do We Keep Your Personal Data section above.
Protected classification characteristics under California or federal law	Age. For more information please see the What Types of Personal Data Do We Collect About Our Customers section above.	Collected online or offline when you provide it to us, through your use of our website, services, or from third parties. For more information please the How Do We Collect Your Personal Data section above.	We collect this information for the purposes listed in the What Is Our Legal Reason For Holding Your Personal Data section above.	Shared with our affiliates, partners, vendors, and service providers as described in the Who Do We Share Your Personal Data With section above.	We retain information as described in the How Long Do We Keep Your Personal Data section above.
Commercial information	Not collected	N/A	N/A	N/A	N/A
Biometric information	Not collected	N/A	N/A	N/A	N/A
Internet or other similar network activity	IP address, browser type and version, browser plug-in types and versions, operating system and platform, device type and device identifiers For more information please see the What Types of Personal Data Do We Collect About Our Customers section above.	Collected online when you provide it to us, through your use of our website, services, or from third parties. For more information please the How Do We Collect Your Personal Data section above.	We collect this information for the purposes listed in the What Is Our Legal Reason For Holding Your Personal Data section above.	Shared with our affiliates, partners, vendors, and service providers as described in the Who Do We Share Your Personal Data With section above.	We retain information as described in the How Long Do We Keep Your Personal Data section above.
Geolocation data	Not collected.	N/A	N/A	N/A	N/A
Sensory data	Not collected.	N/A	N/A	N/A	N/A
Professional or employment-related information	Not collected.	N/A	N/A	N/A	N/A
Non-public education information	Not collected.	N/A	N/A	N/A	N/A
Inferences drawn from other personal information	Information generated from your use of our website and your interactions with us reflecting your preferences	Collected online when you provide it to us, through your use of our website, services, or from third parties. For more information please the How Do We Collect Your Personal Data section above.	We collect this information for the purposes listed in the What Is Our Legal Reason For Holding Your Personal Data section above.	Shared with our affiliates, partners, vendors, and service providers as described in the Who Do We Share Your Personal Data With section above.	We retain information as described in the How Long Do We Keep Your Personal Data section above.
Sensitive personal information	Not collected	N/A	N/A	N/A	N/A