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.
The Policy is comprised of the following Sections:
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:
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:
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:
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.
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.
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 firstname.lastname@example.org 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.
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 email@example.com at any time.
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.
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.
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 firstname.lastname@example.org. 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 email@example.com who will advise you. Alternatively you may seek a remedy through local courts if you believe your rights have been breached.