Scope of Personal Data and Context
By using our Digital Media, we may collect and process personal data relating to you, which may include:
- your name and contact details, including your address, phone number and email address;
- your age;
- your credit/debit card or bank account details;
- your IP address;
- any other information relating to you that you provide to us or that we generate about you in connection with your use of our Digital Media.
In accessing and using this Digital Media, we may utilise different technologies which collect and provide information about your use thereof, subject at all times to applicable law restrictions. We may also receive and or use demographic information about the users of our Digital Media, from third parties such as Google or other social media that you use (“Usage Information”). This Usage Information may include information on pages you viewed, the time you viewed them, which beverage information or other content you accessed or provide, in what language, including demographic information about you (such as your age, gender and interest areas, where available) and what pages you looked at before viewing the current page, etc.
Portmagee Distilling and Brewing Company Ltd. may from time to time utilise tracking technologies such as cookies, IP Addresses or Log files. These tracking technologies help us tailor our Digital Media to your personal needs.
We may also track Internet Protocol (IP) addresses – a number used by computers on the network to identify your computer when logging into the internet. This serves a number of purposes, including: (i) to troubleshoot technical concerns, (ii) maintain website safety and security, (iii) restrict access to our Digital Media to comply with applicable law or contractual restrictions, and, (iv) better understand how our Digital Media is used.
We (or a third party on our behalf) may from time to time collect information such as logs files that record activity on the Digital Media and statistics on users’ browsing habits. These entries are generated anonymously, and help us gather information such as (i) a user’s browser type and operating system, (ii) information about a user’s session (such as the URL they came from, the date and time they visited our Digital Media, and which pages they’ve viewed on our Digital Media and for how long), and, (iii) other similar navigational or click-stream data. We may also use information captured in log file for our internal marketing and demographic studies, so we can constantly improve and customize the online services we provide you. Log files are used internally only, and are not associated with any particular user.
Usage of Personal Data
The information that we collect on you on our Digital Media or otherwise as noted in this policy is done for limited purposes as follows:
- Facilitates Digital Media use: when you register with or sign-up to our Digital Media, your Personal Data is used to provide you with the relevant features and services you subscribe to, and to offer you the appropriate benefits to accompany your registration (e.g. receiving the communications you select at the time of registration, being invited to events etc.).
- Enable you to purchase products on our websites: we use your Personal Data to manage your order and deliver your products. We can also implement technical solutions to detect fraudulent payment and secure the payment of your purchases on our websites.
- Respond to your questions and comments: if you contact us via an online contact form, such as our “Contact Us” form your Personal Data is used to respond to your query or comment.
- Send you transactional or administrative communications: (e.g. confirmation email when you sign up for, or unsubscribe from, emails/marketing materials), as well as certain service-related announcements (e.g., notices about updates to our privacy notices, changes to our website/Digital Media or other related changes.
- Send you promotional and marketing information, subject to any preferences that you express when we collect your contact details or subsequently as notified by you to us.
- In addition to the purpose for which you submitted your Personal Data, you may also be given the option (through a check box or otherwise) to have your Personal Data used for an activity or service different from the primary activity or service that you are requesting. You can opt out of receiving these promotional and marketing materials from us at any time by contacting firstname.lastname@example.org
- When you use a QR Code or equivalent feature displayed on Portmagee Distilling and Brewing Company Ltd. products: we use your Personal Data to send you more information on the products where the QR code or equivalent feature is displayed or other products.
- Generate and analyse statistics of regarding usage of our Digital Media.
- Prevent, investigate and detect fraud.
We process this Personal Data on the following legal basis under Irish law:
- That this is necessary for the performance of our contract with you, or to take steps prior to entering into a contract with you;
- That this is necessary for compliance with a legal obligation that applies to us;
- That this is necessary for the purposes of our legitimate interests or the legitimate interests of a third party:
- We, and/or the third party will only process your personal data for the purposes of our/their legitimate interests where we are of the view that to do so would not constitute an unwarranted interference with your own interests or fundamental rights and freedoms.
The legitimate interests for which we process your personal data include our legitimate interests in:
- conducting our business in a responsible and commercially prudent manner;
- promoting our products and services; and
- pursuing our corporate and social responsibility objectives.
- In certain circumstances, that you have given your consent to the processing.
Profiling and Automated Decision Making
- We may process Personal Data involving automated decision making, including for the performance of a contract (e.g. avoid fraudulent payment) or subject to your explicit consent, to better serve your needs in accordance with your preferences.
- Please note that the automated tools used are regularly checked to ensure that the Personal Data is processed fairly. Specific measures such as data minimization are implemented when creating profiles.
Disclosure of Personal Data to third parties
Portmagee Distilling and Brewing Company Ltd. may be required to share your Personal Data with third parties from time to time, but only in the following circumstances:
- Marketing purposes - where consent has been provided.
- Service Provider/Agent Support purposes - we may use service providers, agents or contractors to provide support for the internal operations of our Digital Media and to assist us with administering them or the various functions, programs and promotions available on it. Any such third party shall at all times provide the same levels of security for your Personal Data as Portmagee Distilling and Brewing Company Limited and, where required, are bound by a legal agreement to keep your Personal Data private, secure and to process it only on the specific instructions of Portmagee Distilling and Brewing Company Ltd.;
- Joint/Co-Sponsored Programme – In the event that we run a joint or co-sponsored program or promotion on our Digital Media with another company, organization, or other reputable third party; and, as part of this event, collect and process Personal Data, we may share your Personal Data with our partner or sponsor, subject to your consent when required. If your Personal Data is being collected by (or is shared with) a company other than Portmagee Distilling and Brewing Company Limited as part of such promotion, we will let you know this at the time your Personal Data is collected;
- Litigation and safety purposes – Where required by law, or in good faith judgement we may also disclose your Personal Data if such action is reasonably necessary to comply with legal processes, to respond to any claims, or to protect the safety or rights of Portmagee Distilling and Brewing Company Ltd., its customers, or the public;
In the event of a merger/sale/disposition/acquisition or other such restructuring ofall or part of Portmagee Distilling and Brewing Company Ltd. we would be required to grant access to the information maintained by that Portmagee Distilling and Brewing Company Ltd. business, which could include Personal Data, subject to applicable law to the relevant counterparty in such transaction. Personal Data may also be transferred as part of a corporate restructure, insolvency proceeding, or other similar event, if permitted by and done in accordance with applicable law.
Transfer of Personal Data outside the EEA
Portmagee Distilling and Brewing Company Ltd. operates globally and your Personal Data may be transferred outside the European Economic Area (EEA), including to a country which has a different level of data protection than the one existing in the country from where you submitted your Personal Data. If and to the extent that your Personal Data is transferred outside the EEA, Portmagee Distilling and Brewing Company Ltd. will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers. These may include entering into a contract governing the transfer that contains the ‘standard contractual clauses’ approved for this purpose by the European Commission or, in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework.
Term of Storage
Accordingly, we may retain your Personal Data after you stop using Portmagee Distilling and Brewing Company Ltd. services or our Digital Media according to the statute of limitations.
Your Personal Data Rights under Irish Law
- If your Personal Data has been processed on the basis of your consent, you can withdraw your consent at any time.
- You can request to access your Personal Data
- You can request to rectify your Personal Data if it is inaccurate, incomplete or out of date
- You can request the erasure of your Personal Data (i) if your Personal Data is no longer necessary for the purpose of the data processing, (ii) you have withdrawn your consent on the data processing based exclusively on such consent, (iii) you objected to the data processing, (iv) the Personal Data processing is unlawful, (v) the Personal Data must be erased to comply with a legal obligation applicable to Portmagee Distilling and Brewing Company Ltd. Portmagee Distilling and Brewing Company Ltd. will take reasonable steps to inform the other entities of the Portmagee Distilling and Brewing Company Ltd. of such erasure.
- You can request the restriction of the processing (i) in the event the accuracy of your Personal Data is contested to allow Portmagee Distilling and Brewing Company Ltd. to check such accuracy, (ii) if you wish to restrict your Personal Data rather than deleting it despite the fact that the processing is unlawful, (iii) if you wish PDL to keep your Personal Data because you need it for your defence in the context of legal claims (iv) if you have objected to the processing but Portmagee Distilling and Brewing Company Ltd. conducts verification to check whether it has legitimate grounds for such processing which may override your own rights (v) if the data processing is based on the legitimate interest of Portmagee Distilling and Brewing Company Ltd.
- You can request the portability of the Personal Data you provided to us, in particular if the Personal Data processing is based on your consent or the performance of a contract.
- You always have the option not to share any of your Personal Data with us. If you choose this option, you may be limited in the activities and features we can provide you.
- You have the right to object to the processing of your Personal Data by us, including for marketing purpose based on profiling.
Personal Data of Minors
Our Site is restricted for children under the legal drinking age (“Minor”), so we do not knowingly collect personal data from Minors. You must be at least eighteen years old to create an account and engage in activities and transactions on our Digital Media. If we are notified or learn that a Minor has submitted Personal Data to us through our Digital Media, we will delete such Personal Data.
If you choose not to submit any Personal Data where requested, you may not be able to participate in certain activities and personalized features, or the Digital Media services and special offered to you may be limited. For example, if you refuse to share your email address, you will not be able to receive our newsletters or otherwise register on our Digital Media. However, to simply browse our Digital Media and learn more about Portmagee Distilling and Brewing Company Ltd. and our products, you do not need to give us any Personal Data. In any event, we will always inform you of the Personal Data that is necessary in order to benefit from a service.
Portmagee Distilling and Brewing Company Ltd.,
or sending an email to: email@example.com
You can also a complaint with the Supervisory Authority of the country where you are located if you have any concern about the conditions of processing of your Personal Data by Portmagee Distilling and Brewing Company Ltd.