SUMMARY
- We only use your data to help improve your experience of The Scotch Malt Whisky Society & ASC IE in the UK and the EU and make our messaging more relevant to you
- We protect your data as our own and uphold high standards
- We will always look to use non-technical language to help you understand everything
- Control – we want to give you control of how you hear from us
- Keeping only the essentials. We have strict erasure policies that ensure we only keep the necessary information while it’s needed
PRIVACY AND COOKIE POLICY
The Scotch Malt Whisky Society Ltd. & The Artisanal Spirits Company. (Ireland) Ltd are committed to protecting the privacy and security of our customers and visitors. The staff at the SMWS are members too, so we appreciate the importance of keeping customers’ personally identifiable information private. If you have any questions, please contact us on dataprotection@smws.com
For all our services The Scotch Malt Whisky Society Ltd. is the data controller – the company that is responsible for your privacy.
WHAT INFORMATION DO WE COLLECT & HOW DO WE USE IT AND MOST IMPORTANTLY, WHY.
We collect, and you provide us with various pieces of personal information, which we may use in several different ways. The following tables set out what we do and why we do it.
Your name and contact details
Includes things like your name, address, email address and telephone number
How do we use your name and contact details |
Why do we use it? |
To deliver your purchases |
This information also forms part of our purchase contract with you. We must use this information to provide instruction to couriers on how to deliver your products. |
To send you service messages by Email, Post, Text or through our website and applications |
We do this to keep you up to date with the progress of your orders, or up to date with your membership entitlements and status. |
To send you information via email, SMS, post and push notifications in applications |
We use this information to keep you up to date with relevant services, offers or notifications. We need this to send you things like Unfiltered magazine and we only perform this with your permission. |
For fraud prevention and detection |
To prevent and detect fraud against either yourselves or the SMWS |
Showing you SMWS adverts as you browse the web, or through our applications |
Single casks can sell out quick, we do this, so you can be aware of the latest products available |
Finding out what you, and other customers, like and are interested in |
From time to time we may reach out to gain a better understanding of our members to ensure we are giving you what you want and striving to do more. |
Your date of birth information
How we use your date of birth |
Why? |
Fraud prevention |
To help protect your membership account and ourselves from fraudulent activity |
Legal drinking age verification |
We make every effort to check that our customers are of legal drinking age in their location. This is simply compliance to responsible retailing standards. |
To provide promotions |
We may want to give you a little gift on your birthday. |
Your gender
How we use your gender |
Why? |
To improve your Society experience |
We use gender information to help provide more personalised experiences on the website or applications or in our product recommendations and to know how to address you |
Your payment information
How we use your payment information |
Why? |
Fraud prevention |
To help protect your membership account and ourselves from fraudulent activity |
Take payment and give refunds |
We need this to perform our contract with you and fulfil customer service duties to you. |
Ensure communications are relevant |
We have customers on different payment systems with us, we want to make sure that our messaging is aligned to this and relevant to each member |
Your contact history with us
Information such as what you’ve said to us and how – i.e. over email you may have wanted to unsubscribe to a mailing list, or on social media or via the phone you may have wanted to look up an order status.
How we use your contact history |
Why? |
Provide customer service and support |
We’ve got to use information like this to provide basic customer services duties such as tracking down an order |
Train our staff |
We may use interactions with members of staff as a training example to work towards providing better customer services |
To inform marketing communications |
We take feedback seriously, we wouldn’t want to set out to irritate people and would factor feedback and data into our future planning. |
Purchase history
What you’ve bought online, via our applications and/or physically
How we use your purchase history |
Why? |
Provide customer services and support and handle returns |
We’ve got to do this to perform our contract with you and we make every effort to help provide customers with positive experiences with The Scotch Malt Whisky Society. |
Finding out what you, and other customers, like |
To make efforts to give you what you want so you can make the most of membership or your website or application experience. This information is also used to plan so our product production can be better aligned to your desires |
To provide you with recommendations of other things you might like |
We’ll help you navigate your way through, what can be, a complex world of whisky by using the website or application to help point out products you might enjoy |
Information about your device (phone, laptop, desktop or tablet) and how you use our website and applications
Information you give us as you browse the website or application, and interact with them. This may include information such as current location if you choose to share it.
How we use Information about your device (phone, laptop, desktop or tablet) and how you use our website and other applications |
Why? |
Improve our website and applications and set default experiences for you (such as language, age verification or login status) |
To seek a better understanding of what and how our website or applications are used, which we hope to use to create a better experience for you and our other customers. |
Protect our website and applications |
To prevent and detect against fraud to either you or SMWS. We will also need this to meet our legal obligations for looking after your data |
Know when you attend any of our Venues or events (if you allow location sharing) |
To provide you with a better customer experience and allow us to help you to connect with other Members through the application or website. |
Information from accounts you link to us
What we do if you linked your Amazon account or a social media account
How do we use information from accounts you link to us |
Why? |
To improve your experience of interacting with The Scotch Malt Whisky |
To make your Society experience more enjoyable. To make your interactions with us easier. |
To provide you with product recommendations |
Making it easier for you to spot things which might be of interest to you. |
Your responses to surveys, competitions and promotions
How we use your responses to surveys, competitions and promotions |
Why? |
To pick winners, take feedback onboard and improve our methods of interacting with members |
We use this information to improve the way we interact with our customers such as developing our service offering or tailoring our promotions to be more appealing. |
You don’t have to give us all this information, but some of this is required for us to be able to perform our obligations to you and to provide you with Society services. You may not be able to buy from the website, through the application, in venue or receive an optimal customer experience should you withhold service sensitive information or opt out of various communications types and methods. However, we will do our best to honour your decisions and will always work to uphold strict policies and processes to protect your data.
We also take steps to anonymise and aggregate personal information (so that it does not identify you) and use it for purposes including IT systems, research, data analysis, improving our website, applications and other online properties, and developing new products and services. We may share this with third parties who provide us support in conducting business and service improvements such as those listed above.
If you choose to sign in to our application using Biometrics, your biometric information will be stored on your phone or device, and will not be shared with us.
SHARING YOUR INFORMATION
We do not, and will not, sell any of your personal data to any third party – including your name, address, email address or payment information. We believe members are a vested part of The Scotch Malt Whisky Society and The Artisanal Spirits Company (Ireland) Ltd and want to uphold our trust.
However, we share your data with the following categories of companies as an essential part of being able to provide our services to you, as set out in this statement:
The Scotch Malt Whisky Society’s International Branches. A member of the SMWS has access to facilities and shopping in all its branches worldwide. We don’t share access to our databases between branches, but we may occasionally confirm a Member’s status and other details between branches to provide a service to a customer or improve our services for them in a location other than their home branch. EU branch transactions are made by The Artisanal Spirits Company (Ireland) Ltd, a sister company of SMWS.
- Companies that work in support of the services of the SMWS, such as payment service providers, booking service providers, warehouses, order packers, and delivery companies
- Professional service providers, such as marketing agencies, web and app development and optimisation partners, database administrators, advertising partners and website hosts, who help us run our business and need this information to help us do better things
- Government entities, law enforcement and fraud prevention agencies, so we can help tackle fraud and comply with legislation
- Companies approved by you, such as social media sites (if you choose to link your accounts to us) and payment providers who may link an account to your SMWS account
We may provide third parties with aggregated but anonymised information and analytics about our customers and, before we do so, we will make sure that it does not identify you.
MARKETING MESSAGES
If you join the Scotch Malt Whisky Society as a Member, we think receiving our award-winning Unfiltered Magazine and knowing about the upcoming release of our very limited bottlings are fundamental benefits of your membership. This is because most of our members are whisky lovers and there are far more members than bottlings – shopping can get a bit competitive on Outturn day so it’s good to be prepared if you want that special bottling. When you join, we will send you marketing messages unless you ask us not to, which you can do immediately or at any time during your membership. When your membership runs out, we will usually contact you to ask whether you’d like to renew for around 2 or 3 months after the end of membership. This is because we have found that many members would like to keep their membership going but forget to renew exactly when it finishes, and we don’t want to exclude loyal members by accident. After that, we assume you are no longer interested in membership, so we won’t contact you regularly although we might get in touch when we review our data to clean up older records (usually 2 or 3 times a year) and are about to delete or anonymise your information.
If you shop with us but do not wish to join as a Member, for example if you give us your details when you order a loved one a Gift Membership, we will only send you marketing messages if you give your consent.
We may send you marketing messages by email, post, text and push notification to keep you aware of the latest goings on at The Scotch Malt Whisky Society. You can choose whether to receive them in any of these ways by using your Account Preference Centre on our website or app or by getting in touch with us.
The marketing preferences you have given us are recorded on our website or app and when you log in to smws.com to browse, you may see marketing consent boxes that are ticked, both in your My Account pages and other locations such as the checkout – this simply reflects the information we already hold about your marketing preferences in the database and does not mean we intend to change your settings. You can change your preferences at any time by using your Account Preference Centre on the website or your Account preferences in the app, or by getting in touch with us.
How to stop Marketing Messages
If you don’t want to receive marketing messages from us, in a specific way or at all, the best way to do this is via your Account Preference Centre on our website, or your Account preferences in the app, which will help you control all your notification settings.
You can edit your marketing messaging settings by:
- Visiting your Account Preference Centre
- Using the Accounts preferences tab in the app
- Click the unsubscribe links in any emails or SMS messaging
- Contacting the Member Services team on:
- Email: memberservices@smws.com
- Telephone: 0131 555 2929 – Monday to Friday 9 am to 4:45 pm UK time
Once you have done this we will make sure your profile is updated and you don’t receive unwanted marketing materials from us. Please note, due to our technical set up the impacts of any changes may take up to 48 hours to take affect – in the meanwhile we apologise for any inconvenience caused.
SMWS ADVERTISING ONLINE
The Scotch Malt Whisky Society engages in online advertising to entice new members to join us, to keep you aware of what we’re up to and to help you find and see our products.
Like many other companies, we target banners and ads to you when you are on other websites, applications and search engines. This is done using a variety of digital marketing techniques including ad exchanges and marketing networks using several advertising technologies like web beacons, pixels, ad tags, cookies, mobile identifies, as well as specific services offered by some sites and social networks (such as Facebook’s Custom Audience services). We adhere to all advertiser policies and stick to strict rules and regulations set out by several advertising standards bodies as well as alcohol and spirits marketing policies.
The banners and ads you will see are based on information we hold about you, or your previous use of our website or applications, your previous engagement with our venues or from our events. This includes information from the products you may have browsed on the website or app, the content you have engaged with or the advertising you may have previously responded to.
KEEPING YOUR INFORMATION, DATA SHARING AND TRANSFERS
Retention
If you are or have been a Member, we will usually keep your data for the length of your membership and then up to two years[DA1] after your membership lapses. After that, data will be anonymised but some data such as order history will be kept to meet legal requirements, for example for financial and tax records, and we may use it for analysis in aggregate. If you have shopped with us without becoming a Member, we will keep your data for up to two years after you have last shopped, and it will then be treated in the same way as Member data.
We may retain information for longer if reasonably necessary to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse or enforce our terms and conditions. We may need to keep your details for longer if you have asked us not to contact you with marketing, to ensure you do not accidentally hear from us again.
Transfers
We need to share your data with other companies who process it to provide services for the SMWS. Some of our data processors will process data we provide them outside of the UK or the EU, mainly in the USA. We will protect your privacy and your rights in the contracts we hold with our processors, using the European Commission’s standard data protection clauses or the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks. More information about these is available here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu_en
YOUR RIGHTS – ACCESS AND CORRECTIONS
You have a lot of rights that relate to your personal information:
- The right to be informed about how your personal information is being used – as per this documentation
- The right to access the personal information we hold about you
- The right to request the correction of inaccurate personal information we hold about you – which will largely be editable via your account preference centre
- The right to request that we delete your data, or stop processing it or collecting it, in some circumstances (except for any legal circumstances where we must retain the information)
- The right to stop direct marketing messages, which you can do through your account, and to withdraw consent for other consent-based processing at any time
- The right to request that we transfer or port elements of your data either to you or another service provider
- The right to complain to your data protection regulator
- UK: Information Commissioner’s Office
- Austria: Datenschutzbehörde
- Belgium: CPP
- Demark: Datatilsynet
- Finland: Data Protection Ombudsman
- France: CNIL
- Germany: Die Bundesbeauftragte für den Datenschutz und die Informationsfreiheit
- Ireland: Data Protection Commissioner
- Italy: Garante per la Protezione dei Dati Personali
- Luxenbourg: Commission Nationale Pour La Protection Des Données
- Netherlands: Autoriteit Persoonsgegevens
- Sweden: Datainspektionen
- A full list for all EU countries can be found HERE
If you want to exercise these rights, have a complaint, or just have questions, please contact us.
CHANGES TO PROTECTING PRIVACY
We may make changes to this page from time to time to reflect how we are processing data. If we make significant changes we will make this clear via the website or via relevant service communications. In these circumstances we will need to use personal contact details to deliver these communications.
Cookies
We use different forms of cookies to improve your web experiences and to improve our understanding of marketing. Please see our cookie notice for more information here
HOW TO CONTACT US / HOW TO BE REMOVED
We wouldn’t want to send our customers any communications they don’t want to receive. We’d like to hear from you if you feel like we could have provided a better service or have any specific questions or concerns; about this policy or other supporting documents, would like us to stop using your information or want to exercise your rights as set out in this document or have complaints.
You can get in touch via our dataprotection@smws.com email address which will put you straight in touch with the members of staff who manage data privacy and security. Alternatively, you can contact us on the usual customer services points of contact:
- Email: memberservices@smws.com
- Telephone: 0131 555 2929 – Monday to Friday 9 am to 4:45 pm UK time
If you wish to write to us, please send a letter addressed to:
The Scotch Malt Whisky Society
The Vaults, Lower Level
87 Giles Street
Leith
Edinburgh
EH6 6BZ
United Kingdom
COOKIE POLICY
Like most websites we use cookies and similar technologies to help provide, protect and improve the Scotch Malt Whisky Society’s website, applications and online services. This policy will help explain how and why we use this technology.
A cookie is a small data file that is transferred to your device (e.g. your phone or your computer). For example, a cookie could allow us to recognise your browser and display more appropriate content, while another could store your preferences like language and help us serve you the most preferable version of the website or app. We use 2 types of cookie on our websites and applicaions: (1) “session cookies” and (2) “persistent cookies.” Session cookies normally expire when you close your browser or app, while persistent cookies remain on your device after you close your browser or app and can be used again the next time you visit the Scotch Malt Whisky Society website or application.
We also use other technologies with similar functionality to cookies, such as web beacons, pixels, mobile identifiers, and tracking URLs, to obtain data (as described in the Privacy Policy). For example, our email messages may contain web beacons and tracking URLs to determine whether you have opened a certain message or visited the website by clicking on a certain link. This type of information would then be used to improve our communications in the future.
WHY DOES THE SCOTCH MALT WHISKY SOCIETY USE THESE TECHNOLOGIES?
We use these technologies for several purposes, such as:
- To enable you to use and access the website and application (such as remembering your age for our age gate, so you don’t need to answer it on every page, or remembering what you put in your basket as you browse)
- To enable, facilitate and streamline the functioning of and your access to the Scotch Malt Whisky Society platform
- To better understand how you navigate through and interact with our web properties and applications and to improve these
- To serve you tailored communications (both on our website and applications and third party ones) that is relevant to you based on how you have interacted with us (e.g. what language you use on our website)
- To show you content (e.g. advertisements) that is more relevant to you.
- To monitor and analyse the performance, operation, and effectiveness of the Scotch Malt Whisky Society website and applications, and advertisements.
- To enforce legal agreements that govern business practices of The Scotch Malt Whisky Society’s website and applications
- For fraud detection and prevention, and investigations.
- For purposes of our own customer support, analytics, research, product development, and regulatory compliance.
THIRD PARTIES
We may also allow certain business partners to place these technologies on our website or applications, but only with our consent and knowledge. These partners use these technologies to:
- Help us analyse how you use our website and applications, such as, by noting the third-party services from which you arrived
- Market and advertise Scotch Malt Whisky Society services to you on our website, applications and third-party websites and applications, such as a product recommendation based on your purchase history
- Help us detect or prevent fraud or conduct risk assessments, or
- Collect information about your activities on our website, applications, other sites, and/or the ads you have clicked on.
We do not permit such third parties to use this technology information to serve you any other advertising or communications from other third parties and they will only be for the use, promotion and improvement of The Scotch Malt Whisky Society.
YOUR CHOICES
Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar.
Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.
Your mobile device may allow you to control cookies through its settings function. Refer to your device manufacturer’s instructions for more information.
Further information about cookies can be found at https://ico.org.uk/for-organisations/guide-to-pecr/cookies-and-similar-technologies/. Please note that by deleting or disabling future cookies, your user experience may be affected, and you might not be able to take advantage of certain functions of our site or it might not work at all.