Privacy Policy

This Website (www.freeproperbeer.com) is operated by Kerve Ltd, 18 Queen Square, Bath, BA1 2HN. ('Kerve', 'our', 'us' or 'we' within this Policy).

Whilst we operate this Website, and will be collecting and processing the personal data which we obtain in accordance with this Policy, the Free Proper Beer will be provided by another company. The company will, of course, be a brewery. However, in order to maintain a bit of suspense until Free Proper Beer Day (26 April 2018), the brewery's identity will remain a mystery. Rest assured though, we will not be sending any of your details their way. All they'll need to know is how much Free Proper Beer to make, and where to send it. We will therefore only send them the information set out in Section 5 of this Policy. If you want to hear from them after 26 April 2018, you can get in touch with them directly. If not, no hard feelings. We'll erase your personal data from our systems as per Section 6 of this Policy.

This Policy applies to visitors to this Website and, specifically, those visitors who request a Free Proper Beer, either via the e-mail sign-up link, or via input of a mobile number to receive an SMS.

This Policy describes

This Policy also describes other important topics relating to your data and its privacy.

Please read this privacy policy carefully to understand how we handle your personal data.

By accessing or browsing this Website, and in providing your personal data to us through the e-mail sign-up or contacting us on social media, you confirm that you have read and understood the entirety of this Privacy Policy.

The Policy is comprised of the following Sections:

1. Data Collection

We may receive some data about you directly from you. However, we may also receive data about you from third parties such as public websites (namely Facebook), agencies (namely database and software managers who maintain the list of subscribers to the Free Proper Beer campaign) and retailers (namely on-trade premises from whom you may redeem your Free Proper Beer). We refer to these parties as "Third Party Sources" throughout this Policy.

We, or our Third Party Sources, may collect and use any of the following data about you and we refer to this as “personal data” throughout this Policy:

2. Use of Data

If signing-up via e-mail, you'll receive 3 e-mails from us. If signing-up by SMS, you'll receive 4 SMS messages.

We, or our Third Party Sources acting on our behalf, collect, use and store the personal data listed above for the following reasons:

3. Legal basis for use of your personal data

We consider that the legal bases for using your personal data as set out in this Privacy Policy are as follows

4. Cookies

Some pages on this Website use cookies, which are small files placed on your internet browser when you visit the Website. We use cookies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences.

Where we use cookies on this Website, you may block these at any time. To do so, you can activate 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 the Website or to use all the functionality provided through the Website.

For detailed information on the cookies we use and the purposes for which we use them, please refer to our cookies policy here. By continuing to use this Website, you are agreeing to our use of cookies as described in the Cookies Policy.

5. Disclosure of personal data

We may share your personal data with any company that is a member of our group where it is in our legitimate interests to do so for internal administrative purposes (for example, ensuring consistent and coherent delivery of services to our customers, corporate strategy, compliance, auditing and monitoring, research and development and quality assurance). We may also share your personal data with our group where they provide products and services to us, such as information technology systems.

We will share your personal data with the following categories of third parties:

Any third parties with whom we share your personal data are limited (by law and by contract) in their ability to use your personal data for any purpose other than to provide services for us. We will always ensure that any third parties with whom we share your personal data are subject to privacy and security obligations consistent with this Privacy Policy and applicable laws

We may also disclose your personal data if we are under a duty to disclose or share it in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity.

We will also share data with the brewery which is providing beer for the Free Proper Beer campaign. This will not include your personal data, but will include statistical and anonymous data, such as the number of vouchers claimed and redeemed, the location of voucher redemption and the number of visitors to the Website.

We may also disclose and use anonymised, aggregated reporting and statistics about users of the Website and from interactions with us on social media for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable individuals to be personally identified.

Save as expressly detailed above, we will never share, sell or rent any of your personal data to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal data in a particular way, but later change your mind, you should contact us and we will stop doing so.

6. Retention of your personal data

We keep your personal data for no longer than necessary for the purposes for which the personal data is processed. In particular, this means that we will keep your personal data until 27 April 2018. On 26 April 2018, we'll tell you who is behind the Free Proper Beer campaign. Whether you choose to get in touch directly with the brewery or not, Kerve will delete all of your personal data from its records by 27 April 2018. It will however retain anonymised and statistical data, but in such a way that no individuals will be identifiable.

7. Your rights

You have certain rights in relation to your personal data. If you would like further information in relation to these or would like to exercise any of them, please contact us by email at support@freeproperbeer.com at any time. You have the right to request that we:

We will consider all such requests and provide our response within a reasonable period (and in any event any time period required by applicable law). Please note, however, that certain personal data may be exempt from such requests in certain circumstances.

If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

8. Marketing

We collect and use your personal data for undertaking marketing by email and SMS. If signing-up via e-mail, you'll receive 3 e-mails from us. If signing-up by SMS, you'll receive 4 SMS messages.

We always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your personal data to any third party for such marketing.

If you wish to stop receiving marketing communications, you can contact us by email at support@freeproperbeer.com at any time.

9. Transfers of personal data

Your personal data may be used, stored and/or accessed by staff operating outside the EEA working for us, other members of our group or Third Party Sources. This may be for the purposes listed in section 2 above, the provision of our services to you, the processing of transactions and/or the provision of support services. Further details on to whom your personal data may be disclosed are set out in section 5 above.

If we provide any personal data about you to any such non-EEA members of our group or Third Party Sources, we will take appropriate measures to ensure that the recipient protects your personal data adequately in accordance with this Privacy Policy. Further details on the steps we take to protect your personal data, in these cases is available from us on request by contacting us by email at support@freeproperbeer.com at any time.

10. Security

We are committed to protecting personal data from loss, misuse, disclosure, alteration, unauthorised access, unavailability and destruction and takes all reasonable precautions to safeguard the confidentiality of personal data, including through use of appropriate organisational and technical measures. Organisational measures include physical access controls to our premises, staff training and locking physical files in filing cabinets. Technical measures include use of encryption, passwords for access to our systems and use of anti-virus software.

In the course of provision of your personal data to us, your personal data may be transferred over the internet. Although we make every effort to protect the personal data which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal data transmitted to our website and that any such transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to prevent unauthorised access to it.

Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

11. Third party websites

This Website, mobile apps and social media pages may, from time to time, contain links to websites operated by third parties including partner networks. Please note that this Privacy Policy only applies to the personal data that we collect through the Website, apps and social media pages or which we receive from Third Party Sources, and we cannot be responsible for personal data about you that is collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal data to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies

12. Changes to our Privacy Policy

We may update our Privacy Policy from time to time. Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by post or email. Please check back frequently to see any updates or changes to our Privacy Policy. By continuing to use the services and this Website, you are confirming that you have read and understood the latest version of our Privacy Policy

13. Further questions or making a complaint

If you have any queries or complaints about our collection, use or storage of your personal data, or if you wish to exercise any of your rights in relation to your personal data, please contact support@freeproperbeer.com. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal data

You may also make a complaint to the data protection authority in the European Union country where we are based or where we process personal data that relates to offering goods or service to you in the European Union. If you are unsure which data protection authority to contact, please contact support@freeproperbeer.com who will advise you. Alternatively you may seek a remedy through local courts if you believe your rights have been breached.

The practices described in this Privacy Policy are current personal data protection policies, as of 12th April 2018