Privacy Statement
Who we are
This is the privacy statement of Abercromby Power Limited, incorporated in Scotland under the Companies Act 2006 with its registered office at 32A Abercromby Place, Edinburgh, EH3 6QE (Company Number: SC504413) (“Abercromby Power”, “we”, “us” or “our” in this privacy statement). We are the controller and are responsible for your personal information.
Types of personal information we collect
We may collect, use and store different types of personal information about you, which we have grouped together as follows:
| Types of personal information | Description |
|---|---|
| Personal identifying information | Your first name and last name. |
| Technical information | Information sent to us as a result of connecting to our website, including internet protocol (IP) address, 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. |
| Financial information | Your bank account and payment card details |
| Transaction information | Details about payments to and from you and other details of products and services you have purchased from us. |
| Contact information | Your billing and delivery addresses including postcode, your contact email and telephone numbers |
| Usage information | Information about how you use our website, products and services |
| Marketing and Communications information | Information about your preferences in receiving marketing from us and your communication preferences. |
We also collect, use and share Aggregated Data such as statistical or demographic information for any purpose. Aggregated Data could be derived from your personal information but is not considered personal data in law as this information will not directly or indirectly reveal your identity. For example, we may aggregate your Usage information to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we will treat the combined data as personal information, which will be used in accordance with our privacy statement.
We do not collect any Special Categories of personal information 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 any criminal convictions or offences.
How we use your personal information
The table below explains how we use your personal information and the reasons that we rely on in doing so. Where these reasons include legitimate interests, we explain what these legitimate interests are.
| What we use your information for | Our reasons | Our legitimate interests |
|---|---|---|
|
To deliver our services To make and manage customer payments To manage fees, charges and interest due on customer accounts To collect and recover money that is owed to us |
Contractual performance Legitimate interests Legal obligations |
Being efficient about how we fulfil our legal and contractual duties Complying with regulations that apply to us |
|
To manage our relationship with you which may include asking you to leave a review of take a survey or notifying you about changes to our terms or privacy statement. |
Contractual performance Legal obligations Legitimate interests |
Keeping 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 |
Contractual performance Legitimate interests. |
Being able to study how customers use our products/services, to develop them and to grow our business. |
|
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising that we serve to you |
Legitimate interests |
To study how customers use our products/services to develop them, to grow our business and to improve our marketing strategy |
|
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
Legitimate interests |
Defining 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 run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, corporate governance and audit |
Legitimate interests Legal obligations |
Being efficient about how we fulfil our legal duties Complying with regulations that apply to us |
|
To exercise our rights set out in contracts and agreements |
Contractual performance |
|
|
To make suggestions and recommendations to you about goods or services that may be of interest to you |
Legitimate interests |
Developing our products/services and to be able to grow our business |
Where we collect your personal information from
We may collect personal information about you (or your business) from the following sources:
Data you give to us e.g. by filling in registration forms on our site, including where you have subscribed to our mailing list or upon entry into any competitions that we may run on this site or if you contact us directly, for example, regarding job vacancies.
Data provided to us by third parties e.g. if an individual chooses to purchase our goods as a gift for you, they may provide us with your name and contact information so that we can deliver our goods to you directly.
Technical Data e.g. your IP address, 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.
Data we collect when you use our services: e.g. Payment and transaction information, identity and contact information, etc.
Who we share your information with
We may share your personal information with the following third parties:
Stripe Inc. for payment processing purposes.
Ardgowan Distillery Company Limited, who prepare and despatch all goods sold via the shop on the Abercromby Power website
Delivery services associated with postage and despatch of goods.
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 information for specified purposes and in accordance with our instructions.
International Transfers
We share your personal information with Stripe. As Stripe are based in both Canada and the US, this will involve transferring your information outside the European Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. Please be aware that Canada is included within this list of countries that provide an adequate level of protection.
Where we use providers based in the US (such as Stripe), we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
To find out more information about how Stripe process your personal information, please see their privacy policy https://stripe.com/gb/privacy
Information Security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information 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.
Marketing
We aim to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We will get your express opt-in consent before directly sending you marketing communications or before sharing your personal information with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a product purchase or any other transactions with us.
If you choose not to give your personal information
If you choose not to give your personal information it may prevent us from being able to provide our services to you.
How long we keep your personal information
We will not retain your personal information for longer than necessary for the purposes set out in this privacy statement, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other applicable requirements.
If you wish to have your personal information deleted or removed please contact us at info@abcpwr.com or in writing at the address below.
In some circumstances we will anonymise your personal information (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.
Using our website
We collect and process the following information from our website:
details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access;
IP addresses – we will automatically receive your IP address when you visit the site; and
cookies – we will use cookies in accordance with our Cookie Policy unless you configure your browser not to accept them. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
Where this website contains links to other sites, Abercromby Power is not responsible for the privacy policies or practices of any third party. By 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 policy of every website you visit.
Your rights
You have a number of rights under the Data Protection Laws in relation to the way we process your personal data, namely:
Access to your information – You have the right to request a copy of the personal information about you that we hold.
Correcting your information – We want to make sure that your personal information is accurate, complete and up to date and you may ask us to correct any personal information about you that you believe does not meet these standards.
Deletion of your information – You have the right to ask us to delete personal information about you where:
You consider that we no longer require the information for the purposes for which it was obtained
We are using that information with your consent and you have withdrawn your consent – see Withdrawing consent to using your information below
You have validly objected to our use of your personal information – see Objecting to how we may use your information below
Our use of your personal information is contrary to law or our other legal obligations
Objecting to how we may use your information – You have the right at any time to require us to stop using your personal information for direct marketing purposes. In addition, where we use your personal information to perform tasks carried out in the public interest or pursuant to the legitimate interests of us or a third party then, if you ask us to, we will stop using that personal information unless there are overriding legitimate grounds to continue.
Restricting how we may use your information – in some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold or assessing the validity of any objection you have made to our use of your information. The right might also apply where this is no longer a basis for using your personal information but you don't want us to delete the data. Where this right to validly exercised, we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.
Portability – if we process personal information that you provide to us on the basis of consent or because it is necessary for the performance of a contract to which you are party, and in either case that processing is carried out by automated means, then you have the right to have that personal information transmitted to you in a machine readable format. Where technically feasible, you also have the right to have that personal information transmitted directly to another controller.
Automated processing – if we use your personal information on an automated basis to make decisions which significantly affect you, you have the right to ask that the decision be reviewed by an individual to whom you may make representations and contest the decision. This right only applies where we use your information with your consent or as part of a contractual relationship with you
Withdrawing consent using your information – Where we use your personal information with your consent you may withdraw that consent at any time and we will stop using your personal information for the purpose(s) for which consent was given.
Please contact us in any of the ways set out in the Contact information and further advice section if you wish to exercise any of these rights.
Changes to our privacy statement
We keep this privacy statement under regular review and will place any updates on this website. Paper copies of the privacy statement may also be obtained by contacting us using the details provided below.
This privacy statement was last updated on 2020-06-10.
Contact information and further advice
If you have any questions about this policy or Abercromby Power’s treatment of your personal information, please contact us at info@abcpwr.com or write to us at:
Suite G01 Gyleview House
3 Redheughs Rigg
Edinburgh EH12 9DQ
Complaints
We seek to resolve directly all complaints about how we handle personal information but you also have the right to lodge a complaint with the Information Commissioner’s Office:
Online: https://ico.org.uk/global/contact-us/email/
By phone: 0303 123 1113
By post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF