At Adnams we respect your privacy.
This policy explains how Adnams plc, whose registered office is at East Green, Southwold, Suffolk, IP18 6JW (“we”) collect, process, use and store personal data and your rights in relation to your personal data. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the retained EU law version of the General Data Protection Regulations ((EU) 2016/679) 2016, the Data Processing Act 2018 and any and all other applicable laws and regulations relating to the processing of personal data and privacy (“the Data Protection Legislation”), we act as the data controller.
- Information we collect
1.1 We may collect and process the following data about you:
1.1.1 information about you that you give us by filling in details on our websites located at the domain names www.adnams.co.uk or any of our managed pubs and hotels’ individual websites (“our Websites”) or by corresponding with us by phone, email, Linkedin, social media (including, but not limited to, Facebook, Twitter, Pinterest, Instagram), in person when visiting one of our managed pubs and hotels or our retail stores or otherwise. The information you give us may include your name, address, email address and phone number, gender, date of birth, financial and credit card information, dietary requirements, interests and personal preferences, information about you current working arrangements such as the name of your employer, your job title and your location of work, emergency contact information, language and communication preferences, car registration number and other relevant information;
1.1.2 if you contact us, we may keep a record of that correspondence;
1.1.3 if you complete surveys that we use for research purposes (although for the avoidance of doubt you do not have to respond to such surveys), the information which you provide in response to that survey;
1.1.4 if you visit one of our managed pubs or hotels or one of our retail stores, we may collect CCTV footage of your visit;
1.1.5 technical information regarding your visits to our Websites including, but not limited to, the Internet protocol (IP) address used to connect your computer to the Internet, geographical location, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
1.1.6 information about your visit to our Websites, including the full Uniform Resource Locators (URL), clickstream to, through and from our Websites (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), language preference, methods used to browse away from the page, and any phone number used to call us.
For more information on how we collect information through our Websites, please see our Cookies Policy.
- How we use your personal data
2.1 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:
2.1.1 where we need to perform the contract we are about to enter into or have entered into with you;
2.1.2 where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
2.1.3 where we need to comply with a legal obligation;
2.1.4 where we have your consent. You have the right to withdraw consent to marketing at any time by contacting us at email@example.com.
2.2 More specifically, we may use the information which we collect and hold about you in the following ways:
2.2.1 to provide you with goods and services that you request from us in order to perform our contract with you including to provide you with any prizes you may with through entering competitions with us;
2.2.2 to verify your age or identity to comply with our legal obligations;
2.2.3 to maintain our business relationship with you, including to keep an up to date record of our interactions (such as meetings) and communications with you, often storing such information on internal databases and to update you on changes to our terms and conditions and privacy notice. We do this to perform our contract with you and because we have a legitimate interest in keeping our records up to date and to grow our business;
2.2.4 to provide you with information or services we offer that are similar to those that you have already been provided with or which we feel may interest you and with news or industry updates, offers, upcoming events or other information. We have a legitimate interest in keeping you up to date and letting you know about products or services that you may like to develop our products and services and grow our business. If at any time you decide you don’t want to receive this information by one or all communication methods, you can opt out by emailing firstname.lastname@example.org;
2.2.5 to use data analytics to improve our website, products/services, marketing, customer relationships and experiences. We have a legitimate interest in defining types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy;
2.2.6 for security and health and safety purposes. We have a legitimate interest in protecting our staff, our customers, the general public our stock and our premises from criminal or unsafe activities;
2.2.6 to administer our Websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes so as to allow us to provide you with the best possible service and experience and as is necessary for our legitimate interests of running our business, provision of administration and IT services, network security and to prevent fraud and to comply with our legal obligations.
- Providing your personal data to others
3.1 We may share your personal information with selected third parties including:
3.1.1. business partners, suppliers and sub-contractors for the performance of any contract we enter into with you or where it is in our legitimate interests to do so for example:
188.8.131.52 if you place an order from us online, we need to process that order, which will mean passing your name and address on to our fulfilment provider or our trusted logistics or courier third parties;
184.108.40.206 we also work with data analysis firms, consumer insight agencies and market research agencies to help us understand our customers to ensure that we continue to meet their needs and serve them most efficiently, the majority of this data is statistical/analytical and it is not possible to identify you from this information;
220.127.116.11 we also work with authorisation agencies, customer support specialists, website developers and webhosting companies, web session recording and analysis companies and marketing fulfilment companies (e.g. companies that coordinate mailings (including by post and email));
18.104.22.168 in limited circumstances we work with other parties (who will also be controllers of personal data, i.e. using the data for their own purposes) to gather information where both parties have a separate justification for collecting the personal data. For example, we have partnered with More2 to help us ensure we are serving the right offers, at the right time, to the right individuals;
22.214.171.124 we use a trusted third party supplier, Microsoft Clarity. Clarity is a user behaviour analytics tool that helps us understand how users interact with our website. Supported features include: Session Recordings, Heatmaps (or heat maps), ML Insights. For more information, see the Microsoft Privacy Statement;
3.1.2 In the event that we sell or buy any business or assets, including if Adnams is acquired by a third party or its business merges with another business, we may disclose your personal data to the prospective seller or buyer of such business or assets and their professional advisors.
3.1.3 If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of Adnams, our customers, our employees or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction as it is in our legitimate interests to do so.
4. Where we store your personal data and international transfers of your data
4.1 Where we provide personal data to third parties, many of them are based in countries which provide an adequate level of protection such as the UK and the European Economic Area. When we need to transfer your personal data to a trusted third party based in a country where data protection laws are not considered to offer the same level of protection, we ensure adequate data protection safeguards such as using the Standard Contractual Clauses authorised by the ICO.
4.2 All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Websites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
4.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Websites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
- Data Security
5.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
5.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- Retaining and deleting personal data
6.1 We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
- Your rights
7.1 You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by not checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at Adnams, East Green, Southwold, Suffolk IP18 6JW, by emailing us at email@example.com or by clicking the unsubscribe link on any marketing communication we send to you by email.
7.2 You can exercise the right to request any amendments or rectifications to your personal data by contacting us at the above postal or email address and can use these addresses to notify us if you would like us to delete or erase your data or, in certain circumstances, if you would like us to restrict the manner in which we process your data. Please note in certain circumstances we may not be able to delete or erase your personal data such as where this is still required for the purpose for which it was provided or where we have overriding legitimate interests in retaining your data.
7.3 Our Websites may, from time to time, contain links to and from external websites as a service to our visitors. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. The provision of a link on our Websites to an external website should not be taken as an endorsement by us of that external website, its owners or their products / services.
- Access to information
8.1 The Data Protection Legislation gives you the right to access information held about you. Your right of access can be exercised in accordance with the Data Protection Legislation by contacting us at Adnams, East Green, Southwold, Suffolk, IP18 6JW or at firstname.lastname@example.org
8.2 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.
10.1 If you are unhappy with the way in which we have collected or processed your personal data or have any other complaint in relation to our handling of your personal data, you can make a complaint to the Information Commissioner. Further information can be found on the Information Commissioner’s website at www.ico.org.uk or via their helpline on 0303 123 1113.