HIGHLAND WHISKY AUCTIONS LTD
This website is operated by Highland Whisky Auctions Limited. We are a company registered in Scotland with company number SC696994 whose registered office is at Unit 4, Blackburn Industrial Estate, Woodburn Road, Blackburn, Aberdeenshire, AB21 0RX, Scotland. Our VAT registration number is 382 9068 65.
The privacy of our users is extremely important to us and therefore we encourage all users to read this policy very carefully because it contains important information regarding:
- who we are;
- how and why we collect, store, use and share personal information;
- your rights in relation to your personal information;
- how to contact us and supervisory authorities in the event that you have a complaint.
This privacy notice applies to all information collected when you access the Website (www.highlandwhiskyauctions.com) and enter auctions, as well as, any related services, sales, marketing or events.
Who we are
HIGHLAND WHISKY AUCTIONS LTD ('we' or 'us') collect, use and are responsible for storing certain personal information about you. When we do so, we are regulated under the Data Protection Act 2018 and we are responsible as a 'controller' of that personal information for the purposes of those laws.
The personal information we collect and use
a. Personal information you provide to us
We collect your personal information when you interact with us or use our services, such as when you enter an auction or access our Website.
We collect the following personal information that you provide to us:
- Personal details including your name, address, contact details and date of birth;
- banking details;
- social media profiles;
- locations and/or your device information you are visiting our site through;
- account details (username/password) for our site;
- details given to us through feedback;
- details of businesses as well as their employees which may purchase goods from us or deal with us.
Some specific examples of when we collect this information include:
- when you access our website;
- register with us;
- contact us via email, write to us or telephone;
- send us feedback or complete a survey;
- purchase via our Site;
- post material to our Site or pages;
- sign up to receive marketing information;
- visit our social media accounts;
- participate in promotions or auctions via our Site or pages.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information
b. Personal information you provide about third parties
If you give us information about another person, you confirm that the other person has appointed you to act on their behalf and agreed that you:
- shall consent on their behalf to the processing of their personal data;
- shall receive any data protection notices on their behalf; and
- shall consent on their behalf to the transfer of their personal data abroad.
c. Monitoring and recording communications
We may monitor communications such as emails and telephone calls for the following purposes:
- Calls and emails may be recorded for training and quality purposes and for auditing any requests that might be made by you to us.
d. Cookies and similar technologies
A cookie is a small text file which is placed onto your computer or electronic device when you access our website. Similar technologies include web beacons, action tags, local shared objects ('flash cookies') and single-pixel gifs. Such technologies can be used to track users' actions and activities, and to store information about them. We use these cookies and/or similar technologies on this website.
In addition it should be noted that in some cases our cookies or similar technologies may be owned and controlled by third parties who will also collect personal information about you.
This information helps us to build a profile of our users. Some of this information may be aggregated or statistical, which means that we will not be able to identify you individually.
For further information on cookies generally visit www.aboutcookies.org or www.allaboutcookies.org.
How we use your personal information
We will only process the data we collect about you if there is a reason for doing so, and if that reason is permitted under data protection law. We will have a lawful basis for processing your information: if we need to process your information in order to provide you with the service you have requested or to enter into a contract; we have your consent; we have a justifiable reason for processing your data; or we are under a legal obligation to do so.
- We may process or share your data that we hold based on the following basis:
- Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order (including in response to public authorities to meet national security or law enforcement requirements).
- Business Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
We use the information we collect or receive:
- To deliver and facilitate delivery of Services to the user. We may use your information to provide you with the requested service
- To post testimonials. We post testimonials on our Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us using the details provided below and be sure to include your name, testimonial location, and contact information.
- Request feedback. We may use your information to request feedback and to contact you about your use of our Website.
- To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
- To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).
- To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
- To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
- To send you marketing and promotional communications. We and/ or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Website, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time.
For other business purposes
Who your information may be shared with
We are very careful and transparent about who else your information is shared with.
We may share your information with:
- Law enforcement agencies in connection with any investigation to help prevent unlawful activity;
- Mtc media (web-designer);
- Stripe Pay ( Payment provider)
We will not share you personal information with any other 3rd parties.
We may also share your information:
- if we are under a duty to disclose or share your information in order to comply with legal obligation or regulatory requirement.
- in order to enforce our contractual terms with you and any other agreement;
to protect the rights of Competitions Limited or others, including to prevent fraud.
We would like to send you information about products, services, offers, competitions and our business which may be of interest to you. Such information could be sent by post, email, telephone or text message.
We will ask whether you would like us to send you marketing messages on the first occasion that you provide any relevant contact information (i.e. on purchase, signing up to a newsletter, entering a competition etc). If you do opt in to receive such marketing from us you can opt out at any time (see 'What rights do you have?' below for further information). If you have any queries about how to opt out, or if you are receiving messages you do not want you can contact us using the details provided below.
How long your personal information will be kept
We will hold your personal information for the following periods:
These periods are no longer than necessary in each case.
Keeping your information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We will also use technological and organisation measures to keep your information secure. These measures may include the following examples:
- We store backups of data stored by us for use in disaster recovery. This includes personal information and all necessary data for providing you our services. Backups are encrypted and stored in a high security data centre offsite.
We are certified to ISO 27001. This family of standards helps us manage your information and keep it safe and secure.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Indeed, while we will use all reasonable efforts to secure your personal data, in using the site you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us using the details below.
Transfers of your information out of the EEA
We will not transfer your personal information outside of the EEA at any time.
What rights do you have?
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- fair processing of information and transparency over how we use your use personal information
- access to your personal information and to certain other supplementary information that this Privacy Poilcy is already designed to address
- require us to correct any mistakes in your information which we hold
- require the erasure of personal information concerning you in certain situations
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal information concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal information
- otherwise restrict our processing of your personal information in certain circumstances
- claim compensation for damages caused by our breach of any data protection laws
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner's Office (ICO) on individual's rights under the General Data Protection Regulations (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/)
If you would like to exercise any of these rights please:
- email, call or write to us;
- let us have enough information to identify you;
- let us have proof of your identity (a copy of your driving license, passport or a recent credit card/utility bill);
- let us know the information to which your request relates.
From time to time we may also have other methods to unsubscribe (opt-out) from any direct marketing including for example, unsubscribe buttons or web links. If such are offered, please note that there may be some period after selecting to unsubscribe in which marketing may still be received while your request is being processed.
Do you need extra help?
If you would like this policy in another format (for example: audio, large print, braille) please contact us using the details below.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The Data Protection Act 2018 also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
- Posting updates of changes on Highland Whisky Auctions website homepage.
If you have any questions about this policy, please contact us by:
- e-mail: [email protected]
- post: Unit 4, Blackburn Industrial Estate, Woodburn Road, Blackburn, Aberdeenshire, AB21 0RX, Scotland.
This policy is up to date as of: 23 August 2021.