Welcome to Global Brand’s privacy notice. Global Brands respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.
Purpose of this Privacy Notice This privacy notice aims to give you information on how Global Brands Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. Controller Global Brands Limited is made up of different legal entities, details of which can be found here. This privacy notice is issued on behalf of the Global Brands Group so when we mention “Global Brands”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Global Brands Group responsible for processing your data. Global Brands Limited is the controller and responsible for this website. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below. Contact Details Our full details are: Full name of legal entity: Global Brands Limited Name or title of data privacy manager: Carol Tellus Email Address: email@example.com Postal address: Casa 5th Floor, Lockoford Lane, Chesterfield S41 7JB 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 in the first instance. Changes to the Privacy Notice and Your Duty to Inform Us of Changes 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. Third-party Links This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
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:
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. 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 notice. 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.
We use different methods to collect data from and about you including through:
(a) analytics providers; (b) advertising networks; and (c) search information providers. (d) PR enquiries (e ) social media influences (f) application for recruitment
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:
See below to find out more about the types of lawful basis that we will rely on to process your personal data. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing firstname.lastname@example.org OR submitting your details below.
We have set out below, in a table format, a description of all 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer|
|Performance of a contract with you|
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey|
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)|
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you|
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences|
|Necessary for our legitimate interests (to define 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)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you|
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional Offers From Us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Global Brand’s group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time [by using the contact form above & unchecking the checkbox] or by contacting us at any time.
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.
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.
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.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
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 You Use My Personal Data For?
We will only retain your personal data 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.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights.
If you wish to exercise any of the rights set out, please contact us.
No Fee Usually Required
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.
What We May Need From You
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.
Time Limit to Respond
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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties
Other companies in the Global Brand’s Group and who are based in the United Kingdom and provide IT and system administration services and undertake leadership reporting.
External Third Parties
Your Legal Rights
You have the right to:
1. The promoter is: Global Brands Ltd (company no. 03366749) whose registered office is at Global Brands Ltd,. 5th Floor CASA, Lockoford Lane, Chesterfield, Derbyshire, S41 7JB, UK.
2. The competition will run from 00.00Hrs on 1st April 2020 (the “Opening Date”) to 00.00 on the 8th May 2020 (the “Closing Date”)
3. All competition entries must be shared in accordance with clause 6 below by no later than 00.00 on the Closing Date. All competition entries shared after the Closing Date are automatically disqualified.
4. The competition is not open to any employees of Global Brands Ltd (or any subsidiary or holding company) or their family members or anyone else connected in any way with the competition, including any agents or suppliers of the promoter or anyone helping or connected to the setting up of the competition and any such persons shall not be permitted to enter the competition.
5. The competition is open to anyone over 18 years old and resident of Great Britain (meaning the United Kingdom excluding Northern Ireland).
6. In entering the competition, you are confirming that you are eligible to do so and eligible to claim any prize you may win.
7. To enter the Competition entrants must purchase a VK Mixed 10 Pack from Tesco retaining a proof of purchase, ﬁnd a winning golden ticket and contact VK with an image of the unique code & proof of purchase via Facebook @VKDrink before the Closing Date. If no Facebook account then enter by email to info@vkoﬃcial.com.
8. Between the Opening Date and the Closing Date, there is a total of 10 prizes of £250 each.
9. The golden tickets each have a unique code; once this code has been redeemed it cannot be used again.
10. The prize is: £250, sent to the winner by bank transfer or other method agreed with a winner[SR1] [CL2] .
11. The golden tickets each have a unique code; once this code has been redeemed it cannot be used again.
12. The promoter reserves the right to cancel or amend the competition and these terms and conditions without notice in the event of a catastrophe, war, civil or military disturbance, act of God or any actual or anticipated breach of any applicable law or regulation or any other event outside of the promoter’s control. Any changes to the competition will be notified to entrants or where it becomes otherwise necessary to do so by notice on the website detailed in paragraph 22 as soon as possible by the promoter.
13. The promoter is not responsible for:
a. inaccurate prize details supplied to any entrant by any third party connected with this competition;
b. competition entries that are delayed or fail to be shared online, regardless of cause, including, for example, as a result of any internet failure, social media platform failure, technical malfunction, systems, satellite, network, server, computer hardware or software failure of any kind; or
c. proof of sharing, posting or transmission as proof of receipt of entry to the competition.
14. No cash alternative to the prizes will be offered. The prizes are not transferable. Prizes are subject to availability and we reserve the right to substitute any prize with another of equivalent value without giving notice[SR3] .
15. The Promoter will send the full name of the judge to anyone who writes, within one month after the Closing Date of the competition, requesting details of the judge and who encloses a self-addressed envelope to the address set out in condition 1 above.
16. The winners will be responded to by Global Brands at the earliest opportunity before the Closing Date. Proof of age will be required.
17. If you are a winner, you have 14 days from the date on which the promoter notifies you of your win to claim the prize. If you do not claim your prize in this time your claim will become invalid.
18. If the winner does not claim their prize within 14 days from the date on which the promoter notifies you of your win, the promoter reserves the right to not offer the prize to anyone else.
19. All winners must provide their name, address, postcode and contact number as well as proof of age and Great Britain residency in order to receive the prize.
20. The promoter’s decision in respect of all matters to do with the competition will be final and no correspondence will be entered into.
21. By entering this competition, you are agreeing to be bound by these terms and conditions.
22. Please see www.vkofficial.com for a copy of these competition terms and conditions.
23. Insofar as is permitted by law, the promoter, its agents or distributors will not in any circumstances be responsible or liable to compensate the winners or accept any liability for any loss, damage, personal injury or death occurring as a result of taking up any of the prizes except where it is caused by the negligence of the promoter, its agents or distributors or that of their employees. Your statutory rights are not affected.
24. All competition entrants & winners agree to the use of your name, image and competition entry in any publicity material, including the announcement of the winner and any other reasonable and related promotional purposes. Any personal data relating to the winner or any other entrants will be used solely in accordance with current [UK] data protection legislation and will not be disclosed to a third party without the entrant’s prior consent.
25. Entry into the competition will be deemed as acceptance of these terms and conditions. By entering a competition, an entrant is giving the promoter permission and granting a non-exclusive, worldwide, irrevocable licence for the full period of any intellectual property rights in the competition entry, to use, display, publish, transmit, copy, edit, alter, store, re-format, sub-license the competition entry image and name on all of VK’s Social Media channels, including but not exclusive to Instagram, Facebook, Twitter and VK’s website.
26. The competition and these terms and conditions will be governed by English law and any disputes will be subject to the exclusive jurisdiction of the courts of England.