Last updated 27 November 2019.
We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org
When you use the Drink Holy Platforms, you trust us with your information. We take your privacy very seriously. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Policy that you do not agree with, please discontinue use of the Drink Holy Platforms.
1. CHANGES TO THIS POLICY OR YOUR PERSONAL INFORMATION
We review this Policy regularly and it is your responsibility to check regularly and determinate whether this Policy has changed. If you do not agree to any change to this Policy then you must immediately stop using the Drink Holy Platforms. In the event we make any significant changes to this Policy we will use our best endeavours to notify you of such changes.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes for example if you change your email address.
2. ABOUT US
The Drink Holy Platforms are owned and operated by Holy Industries Limited (trading as Drink Holy) a company registered in England and Wales (company number 12003075) and our registered office is at Norvin House, 45/55 Commercial Street, London, United Kingdom, E1 6BD) (Drink Holy/we/us/our). Drink Holy is the controller (also known as a data controller) and is responsible for your personal information. The term “you” refers to the user wishing to access and/or use the Drink Holy Platforms.
3. WHAT INFORMATION DO WE COLLECT?
In Short: We collect personal information that you provide to us such as name, address and contact information.
We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about us or our products and services, when participating in activities on the Drink Holy Platforms or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Drink Holy Platforms, the choices you make and the products and features you use. The personal information we collect can include the following:
· Name and Contact Data. We collect your first and last name, email address, , phone number, and other similar contact data.
· Usage Data includes information about how you use the Drink Holy Platforms. This includes your browsing patterns and information such as how long you might spend on one of our webpages on the Drink Holy Platforms and what you look at and for, the page that referred you to the Drink Holy Platforms and the click stream during your visit to our website, page response times and page interaction information (clicks you make on a page).
· Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
· other information relevant to services, customer surveys and/or offers that we provide you.
Information automatically collected
In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit the Drink Holy Platforms.
We automatically collect certain information when you visit, use or navigate the Drink Holy Platforms. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Drink Holy Platforms and other technical information. This information is primarily needed to maintain the security and operation of the Drink Holy Platforms, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookies Policy.
Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners, and other outside sources.
We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information; marketing leads and search results and links, including paid listings (such as sponsored links).
4. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via the Drink Holy Platforms for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
· To fulfil and manage any services or goods in connection with the Drink Holy Platforms (Contractual. We may use your personal information to fulfil and manage your services, payments and any interaction in connection with any Drink Holy Platforms
· To send administrative information to you for Business Purposes, Legal Reasons and/or possibly Contractual. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms and policies.
· To send you marketing and promotional communications for Business Purposes and/or with your Consent. We and/or our brand partners may use your personal information for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails, see below for further details.
· To post testimonials with your Consent. We may post testimonials on the Drink Holy Platforms that may contain your personal information, for example your name. Prior to posting a testimonial, we will obtain your written consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at email@example.com and be sure to include your name, testimonial location, and contact information.
· Administer promotions for our Business Purposes and/or with your Consent.
· Request Feedback for our Business Purposes and/or with your Consent. We may use your personal information to request feedback and to contact you about your use of the Drink Holy Platforms.
· To protect the Drink Holy Platforms for Business Purposes and/or Legal Reasons. We may use your personal information as part of our efforts to keep the Drink Holy Platforms safe and secure (for example, for fraud monitoring and prevention).
· To enforce our terms and policies for Business Purposes, Legal Reasons and/or possibly Contractual.
· To request Feedback for our Business Purposes and/or with your Consent. We may use your information to request feedback and to contact you about your use of the Drink Holy Platforms. To respond to legal requests and prevent harm for Legal Reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
· For other Business Purposes. We may use your personal information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve the Drink Holy Platforms, products, services, marketing and your experience.
5. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfil business obligations.
We only share and disclose your information in the following situations:
· Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
· Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
· Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Drink Holy Platforms, which will enable them to collect data about how you interact with the Drink Holy Platforms over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
· Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
· Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Drink Holy Platforms. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
· With your Consent. We may disclose your personal information for any other purpose with your consent.
6.WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, the Drink Holy Platforms.
7.HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your personal information for as long as necessary to fulfil the purposes outlined in this Policy unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
When we have no ongoing legitimate reason to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
8.HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from the Drink Holy Platforms is at your own risk. You should only access the services within a secure environment.
9.DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 16 years of age.
We do not knowingly solicit data from or market to children under 16 years of age. By using the Drink Holy Platforms, you represent that you are at least 16 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Drink Holy Platforms. If we learn that personal information from users less than 16 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 16, please contact us at firstname.lastname@example.org.
10.YOUR CONSENT TO PROCESSING
You will be required to give Consent to certain processing activities before we can process your personal information. Where applicable, we will seek Consent from you when you first submit Information to or through the Drink Holy Platforms.
If you have previously given your Consent you may freely withdraw such Consent at any time. You can do this by emailing email@example.com.
If you withdraw your Consent, and if we do not have another legal basis for processing your personal information, then we will stop processing your personal information. If we do have another legal basis for processing your personal information, then we may continue to do so subject to your legal rights.
Please note that if we need to process your personal information in order for you to use the Drink Holy Platforms and you object or do not provide Consent to us processing your personal information, the Drink Holy Platforms may not be available to you.
11.MARKETING AND OPTIING OUT
If you have given Consent to marketing we may contact you about our products, services, promotions and special offers. If you no longer wish to receive such information you can withdraw your Consent at any time by sending an email to firstname.lastname@example.org or unsubscribing from the communications you no longer wish to receive.
If you have given Consent, we may share your personal information with carefully selected third-party organisations and business partners and they may contact you directly. If you prefer not to receive direct marketing communications from the third-party please contact them directly to withdraw the Consent.
12.WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In European Economic Area, you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
We may need to request specific information from you to help confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that your personal information is not disclosed to a person who does not have the right to receive it. We may also contact you to ask you for further information in relation to your request to speed up your response. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
13.HOW CAN YOU CONTACT US ABOUT THIS POLICY?
We welcome your feedback and questions on this Policy. If you wish to contact us about this Policy, about our Information or any other questions, please email us at email@example.com.
You have the right to make a complaint at any time to the Information Commissioner’s Office (the ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/concerns/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.