Privacy Policy

INTRODUCTION
Titanic Brewery Co Limited (“we”, “us” or “our”) respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

This privacy notice applies to information we collect about:

Visitors to our website;
Visitors to our premises;
Customers (current and past);
Suppliers (current and past); and
Titanic Brewery loyalty card holders.
This version was last updated in June 2022.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

IMPORTANT INFORMATION AND WHO WE ARE
We are the controller and responsible for your personal data.

Our Marketing Manager is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights outlined at section 7 of this privacy policy, please e-mail our marketing team at marketing@titanicbrewery.co.uk

Our full details are:

Full name of legal entity: Titanic Brewery Co Limited

Registered Company Number: 04771970

Name of data privacy manager: David Glenwright

Email address:titanic@titanicbrewery.co.uk

Postal address: Unit 4 Callender Place, Lingard Street, Burlsem, Stoke on Trent, ST6 1JL

Telephone number: 01782 823447

THE DATA WE COLLECT ABOUT YOU

What is personal data?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature, or the number of customers purchasing certain products. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:

Online
Cookies
When you interact or visit our website, your data such as Technical Data may be gathered through the use of cookies. Cookies are small files which are downloaded onto your computer when you visit our website. The cookie allows us to gather data which will help us improve our website for users.

You may reject cookies from our website by altering the settings on your browser.

For more information about the cookies we use, please see our Cookie Policy.

Third party cookies
Any third party advertisement may also incorporate cookies for which we have no control.

We use a third party service to collect standard internet log information and details of visitor behaviour patterns and Technical Data. We collect this information to establish how many of our visitors use particular areas of our website. The information collected will only be used in a way that shall not identify you. We do not allow our third-party service to identify you if you have visited our website. The services providers we use are Google Analytics for our website tracking and Facebook for advertising.

For more information about the cookies we use, please see our Cookie Policy.

Online accounts and purchases
When you set up an online account, submit a query or other correspondence through our website or place an order via our website, we will request personal data from you. Information held is likely to include your name, contact details, delivery address, payment details, date of birth, information about your purchase, order or query and any additional information we may need to help meet your specific requirements.

This personal data will be used to verify your identity for setting up your account, responding to your query or correspondence or processing you order. This information will be used when you interact with us through our website.

Your personal data will be kept for a period of 24 months from the date that you last logged into the website if you have an account and you are a member of our loyalty club or have subscribed to our communications/updates. For purchases, please see paragraph 6.2 of this Privacy Notice. If you do not want us to use your personal data, e-mail us at titanic@titanicbrewery.co.uk requesting your personal data is deleted.

When you register online for a Titanic Brewery Loyalty card (Standard Card or First Class Card) with us, we will ask you to confirm your e-mail address. We may also ask you to provide us with, and we may collect:
Your personal details, including title, full name, postal / billing address, email address, phone number(s), date of birth and gender;
Your account login details, such as your username, email address and an encrypted record of the password that you have chosen;
Details of your orders, purchases and receipts;
Your personal preferences, including but not limited to requests for additional or replacement card(s), how and if you wish to receive marketing communications.
You can view and change your personal data by logging in to your Titanic online account.

Direct interactions
We may collect personal data from direct interactions with you by filling in forms or by corresponding with us by post, phone, email or by coming in to one of our pubs or bods. This includes personal data you provide when you:

create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
give us feedback or contact us;
enter a competition, promotion or survey;
Sign up to receive updates from us on our latest news and offers
enter one of our pubs or bods which operates a CCTV systems;
details of your visits to our establishments; or
any information supplied by you when you directly interact with us. This may include through correspondence, telephone calls (which are recorded) and any other direct interactions.
When you use your Titanic Brewery Loyalty card (Standard Card or First Class Card) in our pubs or bods, we may collect:

Transaction information (for example, what you have bought, when and where you bought it and how you paid for it – used to record your transactions and provide you with an electronic receipt);

Card identification number – used as a reference number to identify your transactions and provide you with electronic receipts and to provide you with card benefits;

Other personal data that you provide whilst communicating with us from time to time.

HOW IS YOUR PERSONAL DATA USED?
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:

Where we need to perform the contract we are about to enter into or have entered into with you – for example, if you are purchasing goods from us we will use the details that you give to provide those good to you. This information is likely to include your name, date of birth, contact details, delivery address, payment details, information about your order and any additional information we may need to help meet your specific requirements and to provide the goods you have ordered;
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.
Where we need to comply with a legal obligation – We may use and disclose your personal data for compliance purposes, as required by any legal, regulatory, law enforcement, professional or taxation authority and to the extent that we are required to do so by law, regulation or court order.
We have set out below what a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Marketing
We may use your personal data for marketing purposes. This may include:

supplying information to you from us relating to the products and services which we offer, which may be of interest to you; and
contacting you to notify you of any changes to our website which may affect the service we offer you.
Third-party Marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. These third parties may supply you with information of products and services that may be of interest to you.

. .

Opting-Out or consent
You can ask us or third parties to stop sending you marketing messages at any time. To opt out please email us at titanic@titanicbrewery.co.uk or if you are a loyalty card holder please email us at loyaltycard@titanicbrewery.co.uk.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

You may also expressly instruct us to pass your information to or share your information with a third party.

Disclosure to third parties
We may share your personal data with third parties. This may include:

organising the delivery of your products.
Service providers who provide IT and service administration support and any other third parties who we may need to work with to deliver services or goods or fulfil orders on your behalf, for example payment providers and credit/ debit card companies.
Professional advisers including legal advisors, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
Third parties to whom we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We may also use and disclose your personal data without your permission:-

in connection with any legal proceedings or claims or prospective legal proceedings or claims,
to legal, judicial, regulatory, law enforcement, public health, professional standards and taxation authorities,
to prevent crime;
to take legal advice; and
to establish, exercise, protect, enforce or defend our legal rights
If we use external third-party processors based outside the United Kingdom so their processing of your personal data will involve a transfer of data outside or United Kingdom.

Whenever we transfer your personal data to a third party outside the UK, we ensure that a similar degree of protection is afforded by ensuring that at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection as it is afforded in the UK; or
If we transfer your personal data to service providers outside the United Kingdom, then we will always use a lawful method to do so. In the case of transfers to other countries outside the European Economic Area then this will be an agreement in a legally approved form.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us: titanic@titanicbrewery.co.uk.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How is your personal data stored?
Data security
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.

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.

How long will we store your data?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

By law, we have to keep basic information about you as our customers (including Contact, Identity, Financial and Transaction Data) for six years after you cease being our customers for tax purposes.

We will also keep your purchase history for the duration of any warranty period applicable to the goods or services purchased, which may be in excess of the period stated above.

Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are summarised below:

Request access to your personal data (commonly known as a “data subject access request”).
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you.
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data.
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data
Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms you may object to our processing of your personal data. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.

Request restriction of processing of your personal data.
This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party.
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time
Where we are relying on consent to process your personal data you may withdraw this consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

How to exercise your rights
If you wish to exercise any of the rights set out above, please contact us: titanic@titanicbrewery.co.uk. If you are submitting a data subject access request it would be helpful if you could complete a copy of our subject access request form which can be found here. This will enable us to identify and deal with your request much more quickly, however this is not mandatory to complete should you wish to submit a subject access request.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Your right to complain to the Information Commissioner’s Office.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us: titanic@titanicbrewery.co.uk in the first instance.