PRIVACY POLICY

This policy is operated by The Liberation Group Limited, together with the wholly owned subsidiary companies, listed below (together ‘The Group’).

Jersey

A E Smith & Son Limited
Citann Limited
Longueville Distributors Limited
Victor Hugo Limited
The Old Court House Hotel (1972) Limited

Guernsey

Bucktrout & Co Limited
Guppy’s of Guernsey Limited
The Guernsey Brewery Co. (1920) Limited

UK
Butcombe Brewery Limited
Butcombe Brewing Co Limited
M Still Catering Limited
The Royal Oak Inn Trading Limited
The Liberation Group, registered office is at 19 Royal Square, St Helier, Jersey, JE2 4WA.

In relation to our contact and enquiry forms, loyalty clubs, events, prize draws and competitions, your personal information will be held, used and processed by or on behalf of The Liberation Group as data controller in accordance with the data protection laws of the United Kingdom, Jersey and Guernsey.

The Liberation Group and its partners and sponsors (who will be made known as part of the relevant event, prize draw or competition) are jointly referred to in this Policy as “We”, “Us” or “Our”.

This Policy sets out the purposes for which, and the manner in which, we may use personal information that is collected and obtained about you through your participation in Our events, competitions and prize draws which We operate and organise from time to time. By entering into any competition or prize draw or attending any event operated or organised by Us you consent and agree to the terms of this Policy as well as the relevant Competition Terms and Conditions and Prize Draw Terms and Conditions.

We ask that you read this Policy carefully as it contains important information about what to expect when We collect and obtain personal information about you and how We will use your personal information.

1. USE OF PERSONAL INFORMATION

Prize Draws and Competitions

When you enter into a competition or prize draw or provide your data via an enquiry form or our loyalty club, we may collect some or all of the following information about you in order for Us to administer the competition or prize draw:

  • for social media competitions & prize draws we do not collect personal data until a winner has been identified, unless otherwise specified;
  • for website competitions, we collect your email address at the point of entry into the competition; and
  • for competitions or prize draws that are run by Us or on Our behalf at Our locations

This information is collected in preparation for and as part of, and necessary for us to perform our obligations under, the contract we enter in with you in relation to the Competition Terms and Conditions and Prize Draw Terms and Conditions (as the case may be).

If you are the winner of a competition or a prize draw, We may use your name and your location (County/Parish) of residence in announcing the winner of the prize draw. We need to do this in order to comply with the Advertising Standards Authority’s requirements under the UK Code of Non-broadcast Advertising, Sales, Promotion and Direct Marketing (also known as the CAP Code). If you are the winner of a competition and have provided an image as part of the competition (e.g. a selfie in a social media competition) We may use that image in the competition winner announcement(s). This is in order for Us to pursue our legitimate interest to promote the competition results and your win, however We will always take into consideration your rights and freedoms. To the extent you do not wish Us to publish your name and your location (County/Parish) of residence, your image or would like Us to remove your name and your location (County/Parish) of residence, that image please do let Us know by contacting Us on the details provided below.

Events

When you attend an event operated or organised by us, we may collect some or all of the following information about you in order for us to administer the event: name, email address, telephone number, residential address. This information is collected in preparation for and as part of, and is necessary for us to perform Our obligations under, the contract we enter in with you in relation to the event itself. We may also collect certain health information about you in order to cater for any particular requirements you may have and also in order for us to comply with our legal requirements (e.g. relating to health and safety).

Use of CCTV and Photography

In premises owned or managed by the Group where CCTV is in operation, clear signs will be displayed to show its use and images recorded will be retained for a period of 1 month from recorded date.  These images will be disclosed to 3rd parties only in the event of criminal activity on the premises, a formal request by a law enforcement agency or for internal investigations.

The use of photography within the premises will be used on occasion for marketing and promotional purposes.  If images are taken of persons, who are the main subject of the image, consent will be obtained beforehand.  Images of groups on the premises will, on occasion be publicised on The Group’s website or social media sites and may be reused at the discretion of The Group.

If you have any questions or concerns in relation to any photograph of you or would like to request that an image of you is removed (e.g. from our website), please do let Us know by contacting Us on the details provided below.

Direct and Email Marketing

We will always ask your permission before sending you promotional marketing material. We do this by asking for your positive confirmation (e.g. by providing a tick or inserting your contact details in the relevant boxes) indicating that you wish to receive promotional marketing material. This ensures you only receive information that you have given Us permission to send and are willing to receive.

Please note that we do not want to send you information that you do not want to receive and you can opt out at any time (please see ‘The right to ask us to stop contacting you with direct marketing’ below for further information).

2. DISCLOSURE OF YOUR PERSONAL INFORMATION

Depending on how you heard about the competition, prize draw or event, it may be that We received your personal information from a third party in the first instance. For example, it may be that you heard about us through Twitter, Facebook, Instagram, YouTube or Eventbrite. In such circumstances, your relationship with such third party will govern how they process your personal information.

In relation to the competition, prize draw or event that you participate in, We may in limited circumstances share your information with specific third parties to process your personal information on our behalf. If We use any third parties to process your information, We will ensure that such third parties processors keep your information secure in accordance with data protection laws and the standards set out in this Policy.

As part of entering into a competition, prize draw or attending an event, you may give your information to (or We may give information about you to) companies and organisations for the following purposes:

  • to store and process your personal information on systems owned by third parties that may store and process your information on Our behalf (e.g. cloud providers that provide hosting services to Us, event management companies such as Eventbrite who provide the booking platform for events on Our behalf);
  • to Our employees and agents and other approved third parties to administer services provided to you by Us now or in the future (e.g. to maintain our subscriber list, distribute promotional marketing material and run campaigns for Us); and/or
  • if we have a legal right or duty to disclose such information (e.g. to protect Our customers and Us from fraud and theft, We may disclose any information and data relating to you to the police or any regulatory or government authority in response to any request, including requests in connection with the investigation of any suspected illegal activities).

Certain third party providers are based or have support services located outside the European Economic Area (“EEA”). In such circumstances, We ensure that any transfer of your personal information outside the EEA is adequately protected in accordance with data protection laws.

Please note that information that you provide directly to a third party (e.g. when you sign up to an event) will also be governed by such third party’s terms and conditions, terms of use and privacy policies. Please read those documents carefully so that you understand how such third parties process your personal data.

3. SECURITY

We will ensure that our employees, agents and third parties treat all your personal information processed as set out in this Policy in strict confidence, that only those that need access have access to your personal information and that your personal information will be processed in accordance with the necessary technical and organisational security in accordance with data protection laws.

However, the internet is not a secure medium and we cannot guarantee the security of any data you disclose online. You accept the inherent security risks of providing information and dealing online over the Internet and will not hold Us responsible for any breach of security unless this is due to our negligence or wilful default.

4. RETENTION

We do not want to keep your information for longer than necessary and as such retain your personal information for the following time periods:

  • for competitions, prize draws and events we retain your personal information for 3 months; and
  • if you are a competition or prize draw winner, we retain your personal information for one year.

5. YOUR RIGHTS

At any point whilst The Group is in possession of or processing your personal data, all data subjects have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.

If the Group refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to challenge legally.

The Group, at your request, will confirm what information it holds about you and how it is processed.

To access what personal data is held, identification will be required

The Group will accept the following forms of ID when information on your personal data is requested: a copy of your driving license, passport and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If the Group is dissatisfied with the quality, further information may be sought before personal data can be released.

All requests should be made to DPA@Liberationgroup.com or writing to us at the address below. A Data Subject Access request form can be obtained from The Group’s website, in the Policy section.  There is no fee for obtaining this information, but if the request is deemed excessive or repetitive an administration fee may apply.

The Group has four weeks to provide the requested information in a usable format, If necessary, the Group can apply to the data subject or relevant Information Commissioner for an extension of an additional four weeks.

6. COMPLAINTS

If you wish to make a compliant about how your personal data is are being processed by The Group or its partners, you have the right to complain. If you do not get a response within 28 days, you can complain to the relevant Information Commissioner.

The details for each of these contacts are:

The Liberation Group Ltd,
attention of the Data Protection Advisor, Tregear House, Longueville Road, Les Varines, St. Saviour JE2 7WF

Telephone 01534 764000 or

Email: DPA@Liberationgroup.com

Liberation Quality Drinks,
attention of the Data Protection Advisor,
Hougue Jehannet
Vale
Guernsey
GY3 5UF

Telephone: 01481 727208 or

Email: DPA@Liberationgroup.com

Butcombe Brewery Ltd,
attention of the Data Protection Advisor,
Cox’s Green
Wrington,
Bristol,
BS40 5PA

Telephone: 01934 863963 or

Email: DPA@Liberationgroup.com

Office of the Information Commissioner – Jersey
2nd Floor,
5 Castle Street,
St. Helier,
Jersey,
JE2 3BT

Telephone 01534 716530 or

Email: enquiries@dataci.org

Office of the Data Protection Commissioner – Guernsey
Information Centre
North Esplanade,
St Peter Port
Guernsey
GY1 2LQ

Telephone: +44 (0)1481 742074 or

Email: enquiries@dataci.org

Information Commissioner’s Office –
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113 or

https://ico.org.uk/concerns/handling/

7. CONTACT US

If you have any questions/comments about this Events & Competition Policy, You can email Us at DPA@Liberationgroup.com You can write to Our Data Protection Advisor at:

Data Protection Advisor, Tregear House, Longueville Road, Les Varines, St. Saviour JE2 7WF

8. CHANGES TO POLICY

We keep the Policy under regular review. We may amend and update this Policy from time to time. Any changes in the future will be accessible through the Liberation Group website.

This Events & Competition Policy was last updated on the 11th June 2019.