Privacy Policy - House of Rum

Privacy & Cookies Policy

INTRODUCTION

This is House of Rum Ltd privacy notice.

House of Rum Ltd respects your privacy and is committed to protecting your personal data. In this privacy notice, we inform you of 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.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice if you need to.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Imperative Training Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you opt in to receive our newsletter, request a quote, use our contact us form, our live chat or purchase a product or service.

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

House of Rum Ltd is the data controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).

CONTACT DETAILS

Our full details are:

Full name of legal entity: House of Rum Ltd

Email address: [email protected]

Postal address: Excalibur House, 630 Liverpool Road, Irlam, Manchester, M44 5AD

Telephone number: 0161 776 7422

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

This version was last updated on 01 July 21.

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.

2. THE DATA WE COLLECT ABOUT YOU

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 your first name, last name, username or similar identifier, marital status, 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 and services 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 this website.
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 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. 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.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

3.1 Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

make an enquiry via our Contact us form;
using our live chat facility;
requesting a quotation;
registering the expiry details in relation to defibrillators;
apply for our products or services;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us some feedback.
- Technical Data from the following parties:
  - analytics providers such as Google based outside the EU;
  - advertising networks such as Google based outside the EU; and
  - search information providers such as Google based outside the EU and LinkedIn.
- Identity and Contact Data from data brokers or aggregators.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To respond to an enquiry you make via our website	(a) Identity (b) Contact	Necessary for our legitimate interests (to respond to your request/enquiry as a potential customer of ours and/or in anticipation of entering into a contract with you, to grow our business and to inform our marketing strategy)
To register you as a new customer	(a) Identity (b) Contact	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	(a) Identity (b) Contact (c) Financial (d) Transaction (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: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (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	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing & 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) Identity (b) Contact (c) Technical	(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 content and advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage e) Marketing & Communications (f) Technical	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	(a) Technical (b) Usage	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	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

3.2 Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

3.3 Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

4. HOW WE USE YOUR PERSONAL DATA

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.
Where to need to respond to your query or provide you with information that you have asked us to provide.
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 or regulatory obligation.

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 Contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

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.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.:

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 and, in each case, you have consented to receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any other company or business for marketing purposes.

WITHDRAWING YOUR CONSENT (OPTING OUT)

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by Contacting us at any time.

Where you withdraw your consent to receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, expiry reminders, product recalls/serial number storage, product/service experience or other transactions.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy below.

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.

5. DISCLOSURES OF YOUR PERSONAL DATA

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.

External Third Parties as set out in the Glossary.
Specific third parties such as Magemail.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our 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 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.

6. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA).

7. DATA SECURITY

All information you provide to us is stored on our internal server based at our Head Office, on our secure servers with UK Fast and on secure cloud-based systems.

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.

8. DATA RETENTION

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.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, 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.

10. GLOSSARY

10.1 LAWFUL BASIS

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.

10.2 THIRD PARTIES

External third parties means:

Service providers acting as processors based in the UK who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

10.3 YOUR LEGAL RIGHTS

You have the right to:

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. Please Contact us if you wish to request access to your personal data.

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. Please Contact us if you wish to request correction of your personal data.

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. Please Contact us if you wish to request erasure of your personal data.

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 situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. 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 override your rights and freedoms. Please Contact us if you wish to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party).

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. Please Contact us if you wish to request restriction of processing of your personal data.

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. Please Contact us if you wish to request the transfer of your personal data.

Withdraw consent at any time where we are relying on consent to process your personal data. 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. Please Contact us if you withdraw consent at any time where we are relying on consent to process your personal data.

INFORMATION ABOUT OUR USE OF COOKIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good user experience when you browse our website and also allows us to improve our website.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Except for essential cookies, all cookies will continue for a duration which is no longer than then deemed necessary.

Add This

Name	1st / 3rd Party	Company	Used For
uid	3rd Party	addthis.com	Add this is used to provide social sharing features on our website allowing you to share out product pages on social networks.
loc
uvc
ssc
ouid
na_id
_gid
bku
na_tc
sshs
mus
ssh
_ga

YouTube

Name	1st / 3rd Party	Company	Used For
_ga	3rd Party	YouTube	YouTube is used throughout our website to provide product information and education videos.
OTZ
HSID
YSC
SID
SAPISID
SSID
VISITOR_INFO1_LIVE
LOGIN_INFO
APISID
PREF
SIDCC
NID
1P_JAR
IDE
DSID

HotJar

Name	1st / 3rd Party	Company	Used For
__hssc	3rd Party	HotJar	We use Hot Jar to measure the performance and usability of our website. More information can be found at : https://www.hotjar.com/legal/policies/cookie-information
__hssrc
__hstc
_hjClosedSurveyInvites
_hjDonePolls
_hjMinimizedPolls
_hjDoneTestersWidgets
_hjMinimizedTestersWidgets
_hjIncludedInSample

Google

Name	1st / 3rd Party	Company	Used For
OTZ	3rd Party	Google	Google is used to track visitor information.
_ga
SSID
SIDCC
NID
HSID
SID
SAPISID
APISID
1P_JAR
CONSENT
__utma
__utmb
__utmc
__utmv
__utmz
DV

Response Tap

Name	1st / 3rd Party	Company	Used For
__rasel0	3rd Party	Response Tap	Response tap is used to personalise the telephone number which you see on screen which allows us to track our call centre activity.
__ratel0
__rasesh
__rafm
__racnt
__ratel1
__rasel1

Pardot

Name	1st / 3rd Party	Company	Used For
visitor_id	3rd Party	Pardot	Tracking pages visited on sites by prospects in our CRM system.
visitor_id_hash
dtCookie
__cfduid
lpv96112
lpv396982

Pure Chat

Name	1st / 3rd Party	Company	Used For
_PCCSID	3rd Party	Pure Chat	Providing Live Chat customer service on the website.
_PCCID

Facebook

Name	1st / 3rd Party	Company	Used For
fr	3rd Party	Facebook	Social sharing via Facebook

Name	1st / 3rd Party	Company	Used For
_ga	3rd Party	Pinterest	Social sharing via Pinterest
_pinterest_cm
_gid

Internal Cookies

Name	1st / 3rd Party	Company	Used For
viewedOuibounceModal	1st Party	House of Rum Ltd	Asks you to leave your email when you leave the site, if you want to stay in touch.
__agreedcookies	1st Party	House of Rum Ltd	This cookie records if you have provided consent to using cookies on our website via the cookie popup confirmation message you will see on first visit.
CART	1st Party	House of Rum Ltd	The association with your shopping cart.
CATEGORY_INFO	1st Party	House of Rum Ltd	Stores the category info on the page, that allows to display pages more quickly.
COMPARE	1st Party	House of Rum Ltd	The items that you have in the Compare Products list.
CURRENCY	1st Party	House of Rum Ltd	Your preferred currency
CUSTOMER	1st Party	House of Rum Ltd	An encrypted version of your customer id with the store.
CUSTOMER_AUTH	1st Party	House of Rum Ltd	An indicator if you are currently logged into the store.
CUSTOMER_INFO	1st Party	House of Rum Ltd	An encrypted version of the customer group you belong to.
CUSTOMER_SEGMENT_IDS	1st Party	House of Rum Ltd	Stores the Customer Segment ID
EXTERNAL_NO_CACHE	1st Party	House of Rum Ltd	A flag, which indicates whether caching is disabled or not.
FRONTEND	1st Party	House of Rum Ltd	You sesssion ID on the server.
GUEST-VIEW	1st Party	House of Rum Ltd	Allows guests to edit their orders.
LAST_CATEGORY	1st Party	House of Rum Ltd	The last category you visited.
LAST_PRODUCT	1st Party	House of Rum Ltd	The most recent product you have viewed.
NEWMESSAGE	1st Party	House of Rum Ltd	Indicates whether a new message has been received.
NO_CACHE	1st Party	House of Rum Ltd	Indicates whether it is allowed to use cache.
PERSISTENT_SHOPPING_CART	1st Party	House of Rum Ltd	A link to information about your cart and viewing history if you have asked the site.
RECENTLYCOMPARED	1st Party	House of Rum Ltd	The items that you have recently compared.
STF	1st Party	House of Rum Ltd	Information on products you have emailed to friends.
STORE	1st Party	House of Rum Ltd	The store view or language you have selected.
USER_ALLOWED_SAVE_COOKIE	1st Party	House of Rum Ltd	Indicates whether a customer allowed to use cookies.
VIEWED_PRODUCT_IDS	1st Party	House of Rum Ltd	The products that you have recently viewed.
WISHLIST	1st Party	House of Rum Ltd	An encrypted list of products added to your Wishlist.
WISHLIST_CNT	1st Party	House of Rum Ltd	The number of items in your Wishlist.