Please read the following information to understand our practices with regards to your personal data and how we will treat it.
1.1 We refer to the following three separate entities:
- Global Ethics Liquor Co Ltd (“The Spirit Of One”/”One Gin”).
Global Ethics Liquor Co Ltd is an ethical drinks company. If you buy a bottle of One Gin, you will principally be dealing with Global Ethics Liquor Co Ltd, The Spirit Of One / One Gin.
- The One Foundation
The One Foundation is a registered charity, with UK Registered Charity Number 1118810, and its object is to raise money for sustainable global WASH (water and sanitation) projects. Global Ethics Liquor Co Ltd supports The One Foundation by donating profits from the sale of One Gin.
- Global Ethics Ltd (“One Water”/”One Drinks”) Global Ethics Ltd is an ethical drinks company. If you buy a bottle of One, you will principally be dealing with Global Ethics Ltd, One Water / One Drinks.
1.2 We commit ourselves to protecting and respecting your privacy when visiting our website. Global Ethics Liquor Co Ltd, Global Ethics Ltd and The One Foundation may each be data controllers of your personal data. They each have different roles, but some activities they undertake overlap and personal data may be shared internally for certain purposes. Information may be shared between them to facilitate, support and integrate their respective activities. Where possible and appropriate, we do try to be clear which entity is collecting your information and to explain which entity does what.
Global Ethics Liquor Co Ltd is the controller and is responsible for this website.
Global Ethics Liquor Co Ltd’s registered address is 13-17 Princes Road, Richmond, Surrey, TW10 6DQ.
2. PERSONAL DATA WE COLLECT AND THE PURPOSES FOR WHICH WE USE IT
2.1 What personal data do we collect and process?
The types of information we may collect and hold about you are as follows:
– your full name, your title, marital status or an indication of the gender that you most closely associate with;
– your company information, company name and your job title;
– in some circumstances, photographs and digital images of individuals;
– your email address;
– your billing address and delivery address;
– your telephone numbers;
– information about your computer, including your IP address, operating system, time zone setting, device and browser type, which enables us to be more precise in what we send to you or how we approach you. This is for system administration and to report collective information to our advertisers;
– information about how you enter into our websites and digital products and use them. This includes information provided at the time of posting material, requesting further services or subscribing to any service offered by us on the site. We might also request further information if you should report a problem with our website;
– records of your correspondence with us;
– details of why you have decided to support/contact us, how you may have heard about us and the work that we do;
– details of how you would like to be involved and what you intend to do with the information we provide;
Marketing and Communications Data
– your marketing preferences, for example what you like to hear about, or the products/projects that you are interested in;
– your communications preferences, including the channels that you have requested we contact you through (for example email, telephone, postal);
– your third party preferences;
– bank or credit card details (if you purchase something from us or donate);
– your payments and purchases (if you purchase something from us or donate);
– your donation and gift aid details (if you donate to us);
We will only process special categories of personal data (sensitive information) (e.g. passport information), with your explicit consent, for necessary reasons of the establishment, exercise or defence against legal claims. For example, if we are booking flights or processing visas on your behalf when you are travelling with us on a project trip.
2.2 How and why will we use this personal data?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
– to provide you with the information about the product or project you have requested from us, including such things as information about our products and to tell you about our charity work and fundraising;
– to provide you with other information which we feel may interest you. This may include newsletters, tips, updates, information in relation to fundraising campaigns, voluntary surveys or questionnaires for you to complete, details of relevant fundraising opportunities, and details of any promotions and competitions we are running.
– to analyse and understand how people use our websites and digital products so we can improve and personalise the experience for users and reflect your preferences and previous interactions;
– to keep a record of our relationship with you;
– to improve how we communicate with you, how we fundraise, and how we operate more generally;
– to keep in contact with you in the ways that you have requested or agreed to;
– personalise our services and communications to you;
– to provide you with information about carefully selected third party events, products, campaigns and competitions, where we are permitted to do so;
– to notify you about changes to our services;
– to administer and process payments you make for products, services and charitable donations made to any of our entities;
– to verify your identity where required to use some of our services and benefits;
– to comply with applicable laws and regulations and requests from statutory agencies including for such purposes as health and safety; the detection and prevention of crime and safeguarding; and to carry out any obligations or provide you with any other services, functionality or content which you specifically request or agree to.
2.3 For the avoidance of doubt, Global Ethics Liquor Co Ltd does not use personal data for automated decision-making, which produces legal effects or similarly significantly affects individuals. However, Global Ethics Liquor Co Ltd may use profiling techniques in certain circumstances for the purpose of evaluating personal data to provide you with more targeted advertising and for the purpose of segmenting our database of visitors and supporters so that we can communicate with you in the most relevant way possible.
2.4 Charitable giving is very important to Global Ethics Liquor Co Ltd’s (and specifically The One Foundation’s) ability to achieve its mission. We carry out a wide variety of marketing activities to seek individuals’ support for our work, ranging from appeals for small one-off donations, to large fundraising initiatives for specific projects. We want to ensure that we are contacting you with tailored and appropriate communications, and ensure we direct our resources and fundraising activities as efficiently and effectively as we can. We also want to communicate with you from time to time to thank you for your support and tell you what we have achieved with the help of your donation.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
1.Strictly necessary cookies
These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
3. Functionality cookies
These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences.
These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them below:
– Website Acceptance
We store these cookies for 1 month after every visit to the website.
To enrich our website, we sometimes embed content from sites such as Youtube or Instagram. As a result when you visit a page with embedded content, those sites may also set a cookie.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
Except for essential cookies, all cookies expire after 1 month, except anonymous Google analytics cookies which expire after 26 months.
4. WHAT LAWFUL BASES DO WE RELY ON TO USE YOUR PERSONAL DATA?
The legal bases that we rely on for processing your personal data are:
4.1 You have provided your consent to us using your personal data for a specific purpose.
We will ask for your consent to use your personal data to send you marketing emails. By subscribing to receive email newsletters via any of the forms on our website, you are consenting to receive such communications from us.
You always have the right to withdraw your consent at any time, or change the information that we hold on you. You can do this by clicking the links in the footer of any emails we send you.
4.2 It is necessary for compliance with a legal obligation to which we are subject.
This would include where we have to retain certain records, for example, to manage health and safety, for the detection and prevention of crime, safeguarding obligations, for maintaining suppression lists to ensure we comply with marketing laws, for tax reasons (such as those related to gift aid donations) and undertaking due diligence before accepting certain donations or entering into certain relationships.
4.3 It is within our legitimate interests. Applicable law allows personal data to be collected and used if it is reasonably necessary for our legitimate interests or a third party’s legitimate interests (as long as the processing is fair, balanced and does not unduly impact individuals’ rights). We will rely on this ground to process your personal data when it is not practical or appropriate to ask for your consent, and where we are confident that this will not impact your rights. For example, this may include our team contacting prospective, relevant customers in the food and beverages industry.
Where you have provided your details to us, we may contact you by post and phone for certain marketing, commercial or fundraising activities as set out in section 5 below (but we will explain this to you at the point that we collect your details). You can opt out of this activity at any time by emailing us at firstname.lastname@example.org.
We will also rely on our legitimate interests for the proper administration of Global Ethics Liquor Co Ltd and The One Foundation, and to manage our operations (for example, maintaining appropriate records and databases, for the detection and prevention of crime and safeguarding all those who access our premises and facilities).
When we process your personal data to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal data for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).
4.4 It is within our performance of contract
We will use and process your personal data when it is necessary, for example, when entering into or performing a contract, or fulfilling a contract.
5. HOW WE COLLECT PERSONAL DATA
We collect information about you:
5.1 When you give it to us directly
You may give us your personal data in order to receive information from us; buy products from us; when you fundraise for us or take part in any of our fundraising programmes (or request information about these); when you donate to us; when you respond to a survey or when you otherwise engage with us on our websites and digital products.
5.2 When a third party provides us with your personal data
5.3 When it is available publicly
We may combine personal data you provide to us with personal data available from external publicly available sources, including HMRC, the electoral register, published articles and newspapers. Depending on your privacy settings for social media services, we may also access personal data from those accounts or services. We use this personal data to gain a better understanding of you, and to improve our communications and fundraising approaches (see section 3 above).
5.4 When you use our websites and digital products, such as thespiritofone.com
We may collect personal data about you when you use our websites and digital products. Whenever you input personal data into our website (for example, if you contact us through our web form, subscribe to receive emails from us, donate to us, or purchase products), we will collect the personal data that you give to us.
We may collect other personal data from your use of the websites, such as your IP address and access times.
6. COMMUNICATIONS AND MARKETING
6.1 – Where you have provided consent, we will contact you by e-mail, to let you know about our products (and we may also mention those of third parties, particularly where they are collaborating with us) that might be of particular interest to you; with offers and promotions; to inform you about the work of The One Foundation; and to request donations and provide you with information about and the opportunity to participate in our fundraising activities. We provide the opportunity for you to opt-out from receiving our marketing communications every time we contact you.
You can opt-out from receiving our marketing communications, or update your contact preferences, at any time by clicking the links in the footer of our emails, or by emailing: email@example.com
6.2 Social media targeting
If you are a social media user, we will use certain social media tools as part of our relationship with you. These tools include such things as Facebook and Instagram Custom/Lookalike Audiences, Google Customer Match/Similar Audiences, Twitter Tailored/Lookalike Audiences and LinkedIn Matched Audiences.
Through using these tools, we will provide some of your data to the social media platform / organisation to allow them to identify your social media profile with them. The social media platform / organisation will then show you relevant advertisements relating to Global Ethics Liquor Co Ltd which we think you will be interested in seeing on your newsfeed.
7. DATA SHARING
7.1 We do not sell your information under any circumstances. We may from time to time share your personal data with third parties for them to use for marketing purposes or for us to use jointly with a third party where we are embarking upon a joint fundraising project. However, we will only ever do this where you have given us permission to do so.
Global Ethics Liquor Co Ltd and The One Foundation may share your personal data between themselves. Your personal data will only be shared between the entities for the purposes set out in section 2 of this policy.
We work with service providers and other third parties who help us to operate and to provide and improve our information, products and fundraising, and we may share information with them for this purpose. Service providers and other third parties we may share your data with include:
Service Providers, including:
– Our email service platform (ESP), Mailchimp;
– Our content management system (CMS); WordPress;
– Our analytics platform; Google;
– Our IT, systems and administration services;
Professional advisors, including:
– Lawyers, accountants, bankers, auditers and insurers;
– Market researchers, including;
– Specialist agencies including PR agencies, SEO/PPC agencies and design agencies,
Regulators and authorities, including:
– Fraud prevention;
Whilst we may allow our staff, consultants and/or external service providers acting on our behalf to access and use your personal data for the activities we have described in this policy (eg. to provide products to you, deliver mailings, to analyse data and to process payments), we only permit them to use it to deliver the relevant information, goods or services, and only if they apply an appropriate level of security protection.
We may need to disclose your personal data upon request to regulatory and government bodies as well as law enforcement agencies. We may also merge or partner with other organisations and in so doing, acquire or transfer personal data but your personal data would continue to be used for the purposes set out above.
7.2 Transfers of Data out of the European Economic Area
If we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
– We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
– Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
– Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
8. HOW WE KEEP YOUR PERSONAL DATA SAFE, AND WHO HAS ACCESS TO IT
8.1 We are committed to ensuring that there are appropriate technical controls in place to protect your personal data, including protection from misuse and unauthorised access. For example, our network is protected and routinely tested.
Your information is only accessible by staff and contractors who are bound by appropriate policies and procedures to protect your information.
9. YOUR RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
For more information, we suggest that you consult guidance from the Information Commissioner’s Office (ICO).
9.1 Right to restrict processing of your personal data
This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
9.2 Right to erasure
This enables you to ask us 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. 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.
9.3 Right of access
You have a right to ask for a copy of the personal data we hold about you (commonly known as a data subject access request). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. If you want to access your personal data, please send a description of the personal data you want to see and proof of your identity by post to The Digital Team, Global Ethics Liquor Co Ltd, 13-17 Princes Road, Richmond, Surrey, TW10 6DQ.
9.4 Right to rectification
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
We also want to make sure that your personal data is accurate and up to date. Please let us know if your details change by emailing firstname.lastname@example.org.
9.5 Right to object
You have a right 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/ fundraising purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
9.6 Right to data portability
In certain circumstances you have a right to data portability which means we will provide you (or a third party you nominate) with your personal data in a structured, commonly used and machine-readable format.
9.7 Right to Withdraw consent at any time
This is in circumstances 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 certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you are unhappy with the way in which we have handled your personal data, or have any queries or concerns about how data is processed, please contact us by emailing email@example.com.
You are also entitled to make a complaint to the Information Commissioner’s Office. For further information see the Information Commissioner’s guidance here https://ico.org.uk/for-the-public/personal-information.
10. DATA RETENTION
We keep personal data for as long as there is a need to keep it in connection with the purposes for which it was collected. 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 requirement.
We may keep your personal data after a particular matter or exchange has concluded but purely for record keeping purposes and to be able to respond to queries. In some cases, we are also obliged to retain your personal data to comply with legal or statutory obligations (for example, to keep records for gift aid purposes).
Whilst the specific time periods vary depending on the circumstances, in general we will not keep records that include personal data for more than 10 years after a particular matter or exchange has concluded. In the event that you ask us to stop sending you marketing communications, we will retain certain details, such as your name and email address, but only to ensure that you are not contacted again.
Details of retention period for different aspects of your personal data are available in our retention policy which you can request from us.
11. THIRD PARTY WEBSITES
From time to time our site may contain links to and from the websites of our partner networks, advertisers and affiliates. If you visit any of these sites please note that they have their own privacy policies and you should check these before submitting any personal data. We cannot accept any responsibility or liability for these policies.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
13. WEBSITES and DIGITAL PRODUCTS
In this policy “websites and digital products” refers to the primary Global Ethics Liquor Co Ltd website found at https://www.thespiritofone.com/ and all our digital products, such as email, applications and digital channels, including social media.