Privacy Policy

INTRODUCTION

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe, and how we use your data.

This Privacy Notice will be updated occasionally. We will notify you of any significant changes, but this page will always show the current version of our Privacy Notice.

WHO WE ARE?

The Heavitree Brewery PLC is a tenant and leased pub company based in Exeter.

Registered Office: Trood Lane, Matford, Exeter, Devon, EX2 8YP

Registered in England and Wales No. 30800

Throughout this notice, ‘we’ and ‘us’ means The Heavitree Brewery PLC.

LAWFUL REASONS FOR PROCESSING

When we collect your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.

Article 6 of the GDPR sets out a number of different reasons for which a company may collect and process your personal data, including:

• Consent

We collect and process your data with your consent e.g when you subscribe to a newsletter

• Contract

We may need your personal data to comply with our contractual obligations. For example if we are hosting a website, undertaking design work, or making a film.

• Legal obligation

If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity to law enforcement.

• Legitimate interests

In specific situations, we may use your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

We use tools like Google Analytics to combine anonymous data that we use to develop new services and ensure that our existing services can be delivered safely and efficiently.

We may use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.

WHEN DO WE COLLECT YOUR PERSONAL DATA?

We may collect data in the following circumstances, when you:

• Visit our website.
• Attend a meeting with us or attend an event we organise.
• Create an account with us to use with one of our services.
• Purchase a service from us or engage with us during the course of business.
• Contact us by any means with queries, complaints, compliments, requests for information etc.
• Complete any surveys we send you.
• Fill in forms, for example the contact form on our website.
• Give a third-party permission to share with us the information they hold about you.

We may also collect data from publicly-available sources when you have given your consent to share information, or where the information is made public as a matter of law. For example, before we enter into a contract with you we may need to carry out due diligence checks.

EXAMPLES OF DATA WE COLLECT

Depending on the nature of our relationship with you, we will collect information in different ways, and we may collect both identifiable information and anonymous information.

Identifiable information

• If you browse our website without signing in we will collect anonymised analytics data.
• If you fill out and submit a contact form we will use the data you give us to respond to your query, this might include your name, email, phone number, and message.
• If you subscribe to one of our newsletters we will collect your name and email address.
• Session cookies used to authenticate logged in users of our services and applications.
• If you interact with us via social media we will use your contact details to help us respond to your comments, questions or feedback.
• If we are discussing or are already in a contractual agreement we may collect notes from our conversations, meetings, emails etc. We may need to store copies of documents you provide to prove your age or identity where the law requires this. (for example your passport and driver’s licence). This could include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.

Anonymous information

• When you visit our website we may collect anonymous analytics data using services like Google Analytics. This data is used for things like performance monitoring and cannot be associated with you as an individual.
• Our servers also automatically collect log files, which are used for the purposes of security and performance monitoring. Again, this data is not personally identifiable and is automatically deleted on a regular basis.

HOW AND WHY WE USE YOUR PERSONAL DATA

We may use your personal data for the following purposes:

• To respond to you when you have contacted us. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We may do this on the basis of our contractual obligations to you, our legal obligations, or our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
• To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us
• To protect both you and our business from fraud and other illegal activities. This may include using your personal data to maintain, update and safeguard the information we old about you. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
• To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest, you are free to opt out of hearing from us by post at any time.
• To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, or legally required information. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
• To administer any competitions which you enter, based on your consent given at the time of entering.
• To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
• To comply with our contractual or legal obligations to share data with law enforcement. For example, when a court order is submitted to share data with law enforcement agencies or a court of law.

HOW WE PROTECT YOUR PERSONAL DATA

We treat all data we process with the utmost care and take all appropriate steps to protect it.

We secure access to all our websites and applications using SSL encryption. Access to personal data is password protected.

We regularly monitor our systems for possible vulnerabilities and attacks, and access to our systems is restricted to secure physical locations.

HOW LONG WILL WE KEEP YOUR PERSONAL DATA?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected, unless we need to keep it longer to comply with our legal obligations.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may share your information with selected third parties who we use to provide services. For example:

• Companies who provide or support our business systems.
• Operational companies such as couriers.
• Marketing companies who provide and manage our electronic communication with you.

In all cases, we ensure that third-party companies only receive the minimum information necessary, and ensure that:

• Your data is only used for the exact purposes specified in our contract with them.
• Your privacy is always maintained.
• Your personal data is kept securely.
• Any data held by them will either be deleted or rendered anonymous when we stop using their services.
• Your data is always processed legally under the terms of the GDPR.

In addition we may disclose your personal information to third-parties:

• If The Heavitree Brewery PLC, or substantially all of its assets, are acquired by a third-party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use, or to protect the rights, property, or safety of The Heavitree Brewery PLC, our tenants, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

WHERE YOUR PERSONAL DATA MAY BE PROCESSED

Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as Australia or the USA.

If you are based outside the UK, where necessary, we will transfer the personal data that we collect from you to the UK.

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.

We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA. If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact us.

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

WHAT ARE YOUR RIGHTS OVER YOUR PERSONAL DATA?

You have the right to request:

• Access to the personal data we hold about you.
• The correction of your personal data when incorrect, out of date or incomplete.
• That we stop using your personal data for direct marketing (either through specific channels, or all channels).
• That we stop any consent-based processing of your personal data after you withdraw that consent.
• Review of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).

You have the right to request a copy of any information about you that we hold at any time, and also to have that information corrected if it is inaccurate.

To ask for a copy of your information, to ask for your information to be updated, or to ask for your information to be deleted, please write to us or contact us by email at [email protected]. If we choose not to action your request we will explain to you the reasons for our refusal.

Whenever you have given us your consent to use your personal data you have the right to change your mind at any time and withdraw that consent.

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third-party to submit a request on your behalf, we will ask them to prove they have your permission to act.

HOW CAN YOU STOP US CONTACTING YOU?

• Click the ‘unsubscribe’ link in any email communication that we send you.
• Reply to any direct email and request that you are not contacted.
• Email us at [email protected]
• Write to us at The Heavitree Brewery PLC, Trood Lane, Matford, Exeter, Devon, EX2 8YP

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated. You may also still receive communication from us if we are required to contact you legal or contractual purposes.

CONTACTING THE REGULATOR

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office www.ico.org.uk/concerns

If you are based outside the UK you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.

QUESTIONS.

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected]