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Privacy Policy

Updated: October 04, 2023

Your privacy is important, so we created this privacy policy (“Privacy Policy”) to help you understand how Mark Anthony Presents..., its subsidiaries, and affiliates (collectively, “Mark Anthony”, “we”, “our”, or “us”) collect, store, use, or disclose your Personal Information. This Privacy Policy applies both offline (for example, if we interact with you in person, over the phone, or by mail) and when we interact with you through our online services, including but not limited to our websites, chatbot, email correspondence, and any other online services that we link to this Privacy Policy (our website, products, services, and social media pages, collectively, the “Services”). We operate several similar websites, and this Privacy Policy applies to all websites that link to it. This Privacy Policy does not apply to Personal Information Mark Anthony collects from its employees.

This Privacy Policy is structured in a way that first provides general information applicable to all users and then country-specific information for users in specific countries, in particular US and EEA/UK. You should navigate to the sections that are relevant to you. If you are a California, Connecticut, Colorado or Virginia resident, see Additional Privacy Notice and Rights for United States residents section for information provided pursuant to the State privacy laws, including how to request that we not “sell” or “share” your Personal Information. If you are an EEA/UK resident, see Additional Privacy Notice for UK and EEA residents for more details.

 

Our Privacy Policy

1. What We Mean by Personal Information

Personal Information means information that identifies, relates to, describes, or can reasonably be associated with you or your household.  The laws of some countries have different definitions of Personal Information or equivalent terms, and, in this Privacy Policy, we give this the same meaning as applies under the data protection laws that apply to our processing of your Personal Information.  Your name, e-mail address, and IP address are all examples of data that may be considered Personal Information. Some information collected by “cookies” may also be considered Personal Information. Please see our Cookie Policy to review detailed information about our use of cookies and similar technologies and how to opt-out.

We do not consider Personal Information to include information that has been de-identified so that it does not allow information to be linked to a specific individual or that does not allow a specific individual to be singled out. We may collect non-Personal Information related to your interaction with or use of the Services.

2. Categories of Personal Information We Collect

We collect the following categories of Personal Information when you interact with us on our Services:

3. Categories of Sources of Personal Information  

4. How We Use Your Personal Information

We use the above categories of Personal Information to provide you with the Services that you request.  We also use your Personal Information for the following business and commercial purposes:

5. How Long We Retain Your Personal Information

6. Disclosure of Your Personal Information              

Third Parties and Services Providers
We may disclose Personal Information to certain United States and other foreign third parties to enable them to provide services to us. In the preceding 12 months, we have disclosed the categories of Personal Information along with the categories of service providers noted below to assist us in various functions, including providing technological support and performing security and anti-fraud services, providing you with our services and products (including helping us to administer contests and promotions), and providing you with communications and marketing information on our behalf. We have disclosed the below categories of Personal Information to the with the specified categories of service providers, contractors, and third parties:

Please refer to section ‘Categories of Personal Information We Collect’ for examples of the information we collect from these categories of Personal Information.

Corporate Affiliates
We may also disclose your Personal Information within the Mark Anthony Group of Companies, which may use Personal Information for purposes consistent with this Privacy Policy. Such purposes include, but are not limited to providing technological support, performing security and anti-fraud services, processing payments, facilitating marketing campaigns and recruitment, and administering contests and promotions.   To see the family of our affiliated brands, please visit our brand page.

Social Media Networks
Our websites include certain features (such as plug ins which link to Mark Anthony’s social media pages on those respective platforms or chatbots that help you communicate with us) made available by third-party social media platforms and networks (these include Facebook, Instagram, Twitter, TikTok, Pinterest, and YouTube).  Your Personal Information may be disclosed to and collected by those third parties. The use of your Personal Information by social media platforms and networks is governed by their respective privacy policies.

For Legal Purposes
Depending on the jurisdiction in which you reside, we and our United States and other foreign service providers may disclose your Personal Information in order to comply with laws or regulations, or in response to a subpoena, warrant, court order, legal order, government investigation or other legally valid inquiry or request, to protect our rights or the rights of others, or to comply with relevant laws and regulations. We may also provide your Personal Information to another organization under certain circumstances for the purposes of investigating a breach of an agreement or contravention of law, or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable, United States, Canadian, or other law or legal process, which may include lawful access by United States or foreign courts, law enforcement or other government authorities. Your Personal Information may also be disclosed where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

For Security and Safety Purposes
We may disclose your Personal Information to law enforcement, legal advisors, information security and forensics professionals, our insurers to protect the safety and security of our Services, including to detect and protect against fraud and to take action regarding possible illegal activities or violations of our policies.

Certain Corporate Transactions
We may disclose your Personal Information as part of a prospective or completed transaction, financing, due diligence or for other business needs. For example, if we sell or transfer our business operations or assets, we may share your Personal Information with the party to that transaction. In addition, in the event we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver, or administrative receiver may sell, license or otherwise dispose of such information in a transaction approved by the court.

Aggregated Data
We may create and use aggregated or de-identified data at our discretion, such as by sharing it with marketing agencies, media agencies and analytics providers.

Other Purposes
We may disclose your Personal Information for other reasons we may describe to you from time to time or as permitted or required by law.

7. Your Choices About How We Use Your Personal Information

8. Third-Party Links

Our websites may include links to other websites, including social media, that we do not own or operate. We provide links to such third-party websites as a convenience to the user. If you click on these links, you are leaving our website and the collection, use and disclosure of your Personal Information will be subject to these third parties’ privacy practices, terms of use, and other contractual documentation listed on such websites. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat Personal Information. We encourage you to read the privacy policy of every website you visit.

9. Your Use of Chatbot Features 

Some of our websites allow you to interact with us through Facebook Messenger. Once you are logged-in to your Facebook messenger account, you can interact with us through a chatbot. Our chatbot works with artificial intelligence, which means it is not operated by a human. It responds to you based on previous interactions and programmed algorithms.

When you interact with the chatbot, it can collect your information, including your, location, the language you use, your IP address or a unique identifier from your device, as well as how you feel about our products or your interests, depending on the conversation you are having with this chatbot. It is our policy to limit the information collected to only the minimum information required to complete a user’s request. Our intention is not to seek any sensitive information through the chatbot unless legally required. We suggest that you do not provide sensitive information through the chatbot, such as information relating to race or ethnic origin, political opinions, religious or other similar beliefs, trade union membership, physical or mental health, sexual life or criminal record.

If you subscribe to promotional messages through the chatbot, you will be prompted to share your name, birthdate, and postal code. This is used to personalize the chatbot messages, such as to identify events in your area.

This chatbot may retain the identifying information described above in order to show you relevant content in the future. As with other interactions on Facebook, you are also subject to Facebook’s privacy policy when using Messenger. You can read it by going to their respective Privacy Policies.  

10. We Process and Store Information in the United States and other Foreign Jurisdictions

If you are accessing this website from jurisdictions outside the United States, please be advised that you may be transferring your Personal Information to us in the United States where data protection and privacy laws may be less stringent than the laws of your country. When we share your Personal Information with our partners and third parties, they may store some of your Personal Information in their databases in the United States, or elsewhere in the world. Our service providers may be located in the United States or in other foreign jurisdictions.

11. We Use Standard Security Measures    

We maintain reasonable and appropriate organizational, physical, electronic, and procedural/administrative safeguards designed to help protect your Personal Information in our custody or control against theft, loss, and unauthorized access, use, modification and disclosure. The Internet is not 100% secure. We cannot promise that your use of our Services, websites, apps, or services will be completely safe. Any transmission of your Personal Information to our websites or apps is at your own risk. We encourage you to use caution when using the Internet

12. Children Under 13 and Users under 21 

The website is not directed to, and we do not knowingly collect Personal Information from, persons under the age of 21. We do not knowingly collect or store Personal Information from anyone under the age of 21. ANY PERSON WHO VISITS ANY PORTION OF THE WEBSITE REPRESENTS TO US THAT HE OR SHE IS 21 YEARS OF AGE OR OLDER AND MUST IMMEDIATELY LEAVE THE WEBSITE IF UNDER THE AGE OF 21.

If we learn that we have collected Personal Information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please notify us at privacy@markanthony.com.

13. Access to and Correction of Your Personal Information

Subject to applicable law, you have the right to access, update, delete and correct inaccuracies in your Personal Information in our custody or control. You may request access, updating and corrections of inaccuracies in your Personal Information in our custody or control by emailing or writing to us at the contact information set out below in this Policy. We may request certain Personal Information for the purpose of verifying the identity of the individual seeking access to his or her Personal Information records.

If you are subject to the UK GDPR or the EEA GDPR, please refer to our section on 'Additional Privacy Notice for UK and EEA' for details regarding your specific rights. If you are a resident of California, Colorado, Connecticut, or Virginia, please refer to our section on ‘Additional Privacy Notice and Rights for US Residents section

14. Notice of Financial Incentive

From time to time, we may offer different sort of perks (examples such as branded items, discounts codes etc.) for users that opt-in through various promotions, incentives, loyalty programs, and other programs. These discounts or perks are a way for us to show that we are excited that you want to be part of our program, receive email communication, and enjoy our products.

The details of each program are contained in the program offering but in general, we may invite you to provide us with your name, email address, birthdate and zip code. We may send marketing communications to you which may include a discount code or a perk like a branded item. If you are subject to the UK GDPR or the EEA GDPR, please also refer to our section on Additional Privacy Notice for UK and EEA for more details surrounding opt-in consent and your rights regarding marketing communications.  We may also contact you around your birthdate to offer additional discounts or perks to celebrate you.

How to Opt-In. You can opt in by following the instructions provided at the time the program or incentive is provided, including in any accompanying terms and conditions. From time to time the program or incentive provided may require an email marketing opt-in as part of the registration process. Consumers can unsubscribe from these communications by the unsubscribe link in the email. 

Right to Opt-Out. You can withdraw consent to participate in any program or incentive at any time by following the instructions provided in the program or incentive communications to accompanying terms and conditions.

Categories of Personal Information Collected, Sold, or Shared.  In order to offer the program, we may need to collect certain categories of your Personal Information.  This may include your name, email address, and date of birth. We also collect Internet or Other Electronic Network Activity Information click here.  We may disclose this information to our third-party United States and other foreign service providers that help us run and administer the program or incentive.  If you request to delete your Personal Information, we may no longer be able to offer some or part of the program and program benefits to you because that information is necessary to determine your eligibility for the benefit or to communicate the benefit to you (for example, if you request that we delete your email address, we will no longer be able to send you discounts or offers). 

Program Partners. From time to time some of our program benefits may be offered by our partners. We will update our list of partners and potential benefits here. Please keep in mind that not all benefits may be available at all times.

Value of Financial Incentive. Under applicable laws, the incentives we offer in exchange for the opportunity to market to you may be considered financial incentives. The incentive may be a discount coupon that can be used when you buy products from us or a branded item. Details of the incentive will vary depending on market conditions at the time the incentive is offered. The value of the Personal Information you provide us in relation to the program or incentive will vary based on the value of the free products, rewards, discounts and other benefits you may receive, less the cost of administering the program or incentive. Retail prices for our products and branded items vary.  

15. Additional Privacy Notice and Rights for US Residents

California, Colorado, Connecticut, and Virginia require additional disclosures and offer additional rights for you to access your data.  

Right to Know and to Access
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months.  This information is disclosed in the section ‘Categories of Personal Information we Collect’ of this Privacy Policy.

You also have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and other United States and other foreign service providers with whom we share it. You may submit such a request as described below. To protect our customers’ Personal Information, we are required to verify Your identify before we can act on your request.

Right to Portability
You have the right to request that we provide a copy of the Personal Information we have collected about you, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. Once we receive your request and confirm your identity, we will provide to you a copy of your data as required under the applicable data protection laws. We may provide this data to you through your user account with us, or via email to the email address you have provided with your request.

Right to Delete
Subject to certain exceptions, you have the right to request that we delete any of your Personal Information. Once we receive your request and confirm your identity, we will review your request to see if an exception under applicable law allowing us to retain the information applies. We will delete or deidentify Personal Information not subject to one of these exceptions from our records.

Right to Correct
Subject to certain exceptions, you have the right to request that we correct inaccurate Personal Information that we have collected about you. Once we receive your request and confirm your identity, we will review your request, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information to see if we can correct the data. We may also request additional information showing that the information you want to correct is inaccurate.

Right to Limit Use of Sensitive Personal Information
You have the right to request that we limit the use of your Sensitive Personal Information (as defined under the law). Please note we do not collect or process Sensitive Personal Information for the purpose of inferring characteristics about you. 

Submit a Request for Access, Deletion, or Correction of Your Information
Consumers may submit a privacy rights request, including a request to exercise their right to opt-out of the sale of their Personal Information, by:

When you make a privacy rights request under applicable law, we may require that you provide information and follow procedures so that we can verify the request and your jurisdiction before responding to it. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain Personal Information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests. 

We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps we take may differ depending on the request you make, if you have an account with us, and the sensitivity of the Personal Information. We will match the information that you provide in your request to information we already have on file to verify your identity. If we can verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us verify your request. We may also utilize a third-party verification provider to assist with verifying your identity.

You may be asked to provide your first and last name with email address and may also be asked to provide your date of birth, or other identifying information so that we can verify the request. Please provide as much of the requested information as possible to help us verify the request. We will use the information received in a request for the purposes of responding to the request.

Right to Opt-out
You have the right to opt-out of processing of your Personal Information for the purpose of (i) targeted advertising, (ii) sale of Personal Information, or (iii) profiling to provide you with tailored content, including suggested advertising. We use your data for the purposes describe n the ‘Categories of Personal Information we Collect’ section above, some of which may be considered to be targeted advertising, “sale”, or “profiling” under applicable law, and you have the right to request to opt-out of such data uses using the methods described above. To exercise your opt-out rights, you can also write to us at privacy@markanthony.com , or set your browser Global Privacy Controls to send this signal when you visit our Services.

Authorized Agents
You may designate an authorized agent to submit a request on your behalf to access or delete your Personal Information. To do so, you must: (1) provide that authorized agent written and signed permission to submit such request; and (2) verify your own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

If you have been designated as an authorized agent to submit a request on behalf of another customer, you must make the appropriate selection when you submit a Request to privacy@markanthony.com.

Non-Discrimination
We will not discriminate against you for exercising any of your data privacy rights.

Additional Information for California Residents
We collect the categories of Personal Information set forth in the ‘Categories of Personal Information We Collect’ section above.
The sources from which we obtain Personal Information are described in more detail in ‘Categories of Sources of Personal Information’ section above.

For information on the business and commercial purposes for which we collect and use Personal Information, see the ‘How we Use Your Personal Information’ section above.

We disclose the following categories of Personal Information for business or commercial purposes to the categories of recipients listed below:

Please see ‘Disclosure of Your Personal Information’ section for more details on our service providers, third parties, and business partners, as well as how we disclose your Personal Information and for what business and commercial purposes.

Sale or Sharing

In the preceding 12 months, we have sold Personal Information for valuable consideration or shared Personal Information for purposes of targeted or behavioral advertising with the following categories of third parties and for the following business purposes:

We do not knowingly collect Personal Information about users under the age of 16 and we do not knowingly sell or share Personal Information of Children under the age of 16.

California Shine the Light

California Civil Code Section 1798.83 permits California residents to make an annual request for information regarding the disclosure of categories of your Personal Information that Mark Anthony Brands has shared with a third-party for the third-party’s direct marketing purposes.  To make this request, please send us an email, or write to us at the address listed below. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry.

Supplemental Notice for Virginia, Colorado, and Connecticut Residents

Right to Appeal

If you make a request to exercise any of the above data access rights and we are unable to comply with your request, you may request to appeal our decision. To appeal any data privacy request decision, please contact us by emailing at privacy@markanthoy.com with the subject line “Data Access Request Appeal.” If after you complete the appeal process with us, you are still not satisfied with our response, you may contact your Attorney General to file a complaint.
 

16. Additional Privacy Notice for UK and EEA Residents

UK and EEA individuals should review further UK and EEA specific information below.

This privacy notice describes how Mark Anthony Presents.., its subsidiaries, and affiliates treat Personal Information you provide to us or that we collect about you.

This includes any information that identifies you personally (such as your name, title, email address or phone number) that is supplied to us both offline (for example, if we interact with you in person, over the phone, or by mail) and when we interact with you through our online services, including but not limited to our websites, chatbot, email correspondence, and any other online services that we link to this Privacy Policy (our website, products, services, and social media pages, collectively, the “Services”), as well as information we generate regarding your use of the website or the Service, in either case, including information that can be linked with such information to identify you directly or indirectly (for the purposes of this section referred to as "Personal Information"). 

This notice describes our practices in connection with Personal Information that we collect from you through the website(s) and / or Services that link to this notice.

Who is the controller(s) of your Personal Information?

The Mark Anthony Companies listed below will be responsible as Controllers of the Personal Information we collect in relation to our Services:

Data Controller

Registered Address

Mark Anthony Brands UK Limited

6th Floor 125 London Wall LONDON, EC2Y 5AS United Kingdom

Mark Anthony Brands International Unlimited Company

Donnybrook House, 36-42, Donnybrook Rd, Donnybrook, Co. Dublin

Glendalough Irish Whiskey Company Limited

UNIT 9, 714019, Ireland

 

If you have any questions about which of the above companies is the controller of your Personal Information or their exact controller relationship, please contact us using the contact details below.

What information does Mark Anthony collect and how is this information used?

We collect Personal Information from the sources listed in section ‘Categories of Sources of Personal Information’ of this Privacy Policy. This includes collecting Personal Information directly from you or automatically from you or your device when you interact with the Services, from business partners, social media networks, and other sources as detailed in section ‘Categories of Sources of Personal Information’ above.

Information collected Purposes of processing  Lawful basis relied on

Personal Identifiers: We may collect your name, email address, social media handles, shipping address, billing address, zip or postal code, telephone number, unique personal identifier, online identifier, Internet Protocol (IP) address, account name, or other similar identifiers. If you create an account, we also collect your username and password.   

Provide our services. We use this Personal Information to provide products and services. For example, to process your orders, process payments, and deliver our products to you where applicable, such as branded or personalized products merchandise that you may purchase through an e-commerce platform. We also use this Personal Information to create, maintain, and otherwise manage your account and profile. We also use your Personal Information to maintain your transaction history and verify eligibility to access our Services. 

For marketing purposes. If you expressly authorize us to do so, we may use Personal Information for marketing and advertising purposes, such as providing you with information about our products and services and the products and services of our partners and other third parties. If you join our mailing list, we will send you promotional information on our products. We may also use your Personal Information to personalize your experience on our website, in email, on third party websites, and on social media. We may use Personal Information to offer and administer special promotions, discounts, purchase incentives, loyalty programs, prize promotions, invites or other similar offers and promotions. We may use Personal Information to display advertisements related to products we think may interest you on our websites, in e-mail communications you consent to receive, on other websites that work with our advertising partners, and on social media platforms.  You may decline to receive [email/text] marketing from us by selecting the emailing us at privacy@markanthony.com  which will be contained in any such [email/text] you receive. 

To respond to your requests and communicate with you. We use your Personal Information to communicate with you, such as to respond to and/or follow-up on your requests, inquiries, issues, or feedback, and to provide customer service. We may invite you to participate in surveys on your satisfaction with our products and services. We also use Personal Information to communicate with you about changes to our business practices, policies, programs, and terms and conditions. If you are navigating our website, you may interact with our chatbot through Facebook Messenger and/or Twitter, in which case, this bot will answer your questions based on the information that it collects about you. Facebook and/or Twitter may also collect information about you through cookies and pixels on it’s the Facebook/Twitter platforms, subject to Facebook/Twitter’s privacy policies.

To improve our products and services. We may use your information to make our services, platforms, offerings, marketing campaigns, communications, and products better, including to understand how you use our products and services. We might use your information to conduct research and analysis, as well as develop new services and products. 

To administer our websites, platforms, services, and programs. We use your Personal Information manage, maintain, administer, and troubleshoot our website, apps, and other platforms, including to understand how you interact with our services, platforms, and other communications with you and. We also use Personal Information to administer, maintain, and communicate with you about contests and promotions in which you have chosen to participate, including publishing winner information in winner lists and sharing winners list with third parties and /or regulators as required for prize distributions and regulatory purposes respectively.

To comply with our obligations. We may use Personal Information to fulfill our legal obligations, resolve disputes, defend our legal rights, and enforce our agreements. We may also use Personal Information to verify you can legally access our Services. We may also use Personal Information to fulfill contractual obligations we may have to you. 

For security and safety purposes and prevent fraud. We use Personal Information to detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity and protect our websites, apps, or services. We may also use Personal Information to investigate, prevent, and enforce against violations of our terms and policies. We may use Personal Information to protect our company, properties, our trademark, customers, business partners and their respective personnel.

For analytics purposes. We may use Personal Information such as customer IDs/internal identifier for analytics purposes, specifically to understand which pages you have visited, elements of the website you have clicked on, products purchased, advertisements that you have liked or rated in any way, how you reacted to contests, surveys, sweepstakes and other promotions.

To personalize your experience. We may use Personal Information such as name, e-mail address, address, location, telephone, birth information, demographic information and online identifiers to personalize your experience with our Services, our communications to you, and the marketing and advertising that you receive via the agreed channels or which you see on our websites, including to provide personalized recommendations about our products and services, events, promotions, and loyalty programs.

Some of these uses rely on cookies, in particular those related to marketing, bot services and personalization. To the extent that they do rely on cookies, please see our Cookie Policy for further information.

Consent – for individuals who sign up to our mailing list, or when you subscribe to marketing communications, targeted advertisements and otherwise where appropriate or as required by law. We also obtain your consent whenever we wish to use cookies and similar technologies (unless applicable data protection laws permit us to rely on our legitimate interests instead). Legitimate interests - we have a legitimate business interest in:

- providing, managing, administering and facilitating your use of our Services in accordance with our commercial interests and legal rights (such as developing user profiles and analyzing customer feedback to better understand our users and how they access and use our Service, and safeguarding Service security)

- running an effective and sustainable business (such as ensuring our fees are paid)
pursuing business development initiatives and keeping you informed of relevant offerings
- taking measures to ensure that the Service is only accessed by authorized users and in accordance with our terms of use

 

Legal obligation – for any processing in accordance with an applicable legal obligation

 

Demographic Information: We may collect your age, date of birth, gender, address, zip code, marital status other household information, education level, employment status, race, ethnicity, estimated income, and other similar demographic data, some of which may include characteristics of protected classifications under local law.

Education information: We may collect your education level, for example when you take one of our surveys.

We may collect this information when you chose to provide it to us as part of your profile, when registering to use our Services, to confirm if you are over the legal age so that you can interact with our Services, enroll you in our campaigns, promotions, sweepstakes, loyalty programs or through our marketing and analytics partners and United States and other foreign service providers. 

We may also use this information for analytics and to personalize your experience – please see above for details.

Legitimate interests - we have a legitimate business interest in:

- providing, managing, administering and facilitating your use of our Services in accordance with our commercial interests and legal rights (such as developing user profiles and analyzing customer feedback to better understand our users and how they access and use our Service, and safeguarding Service security)
- running an effective and sustainable business (such as ensuring our fees are paid)
- taking measures to ensure that the Service is only accessed by authorized users and in accordance with our terms of use

Legal obligation – for any processing in accordance with an applicable legal obligation

Explicit consent – we obtain your explicit consent whenever we wish to process any Personal Information that is categorized as “special category data” under applicable data protection laws

Commercial Information: We collect information such as products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies. This includes information about the transaction, such as product details and the date and location of the purchase/return.  

We may use this information:

- For marketing purposes – please see details above;
- To respond to your requests and communicate with you – please see details above
- To improve our products and services - please see details above

Legitimate interests - we have a legitimate business interest in:

- providing, managing, administering and facilitating your use of our Services in accordance with our commercial interests and legal rights (such as developing user profiles and analyzing customer feedback to better understand our users and how they access and use our Service, and safeguarding Service security)
- running an effective and sustainable business (such as ensuring our fees are paid)
- pursuing business development initiatives and keeping you informed of relevant offerings

Consent – for individuals who sign up to our mailing list, or when you subscribe to marketing communications, targeted advertisements and otherwise where appropriate or as required by law

Payment Information: We collect billing information, such as your account number, credit card number, expiration date, card verification number, billing address if you make a purchase, and other financial information required to allow you to acquire our products. We make sure to use PCI DSS compliant third parties when processing your credit card information. 

We may use this information to provide you with our services – please see details above.

Performance of contract – to perform our contract with you or your employer or a third party (such as an affiliate or partner of your employer), including sending Service-related communications

Legitimate interests - we have a legitimate business interest in:

- providing, managing, administering and facilitating your use of our Services in accordance with our commercial interests and legal rights (such as developing user profiles and analyzing customer feedback to better understand our users and how they access and use our Service, and safeguarding Service security)
- running an effective and sustainable business (such as ensuring our fees are paid)

Internet or Other Electronic Network Activity Information: We collect details of your visits to our websites and information generated in the course of using our Services (including the timing, frequency and pattern of service use) including, but not limited to, traffic data, location data, weblogs and other communication data, the resources that you access, and how you reached our site. We also collect details regarding the device you use to access our Services, including, but not limited to, your IP address, operating system and browser type, device ID, and Personal Information collected from cookies and similar technology when you open our emails and visit our website (for more information about cookies, how we use them, and your related choices, please see our Cookie Policy).  

We may use this information:

  • To provide you with our services – please see details above
  • To improve our products and services - please see details above
  • To administer our websites, platforms, services and programs - please see details above
  • For security and safety purposes and prevent fraud – please see details above
  • For analytics and to personalize your experience - please see details above

Consent – we obtain your consent whenever we wish to use cookies and similar technologies (unless applicable data protection laws permit us to rely on our legitimate interests instead).

Legitimate interests – we have a legitimate business interest in understanding:

  • how our website is accessed
  • how it is used
  • any problems users have with accessibility and usage across multiple devices

Location Data: For example, you can enter your zip code to know where to find your favorite products near you. We may also collect your IP address automatically when you use our Services. We may be able to determine your general location based on the IP address. 

We may use this information:

  • To provide you with our services – please see details above
  • To improve our products and services - please see details above
  • To administer our websites, platforms, services and programs - please see details above
  • For security and safety purposes and prevent fraud – please see details above
  • For analytics and to personalize your experience - please see details above

Legitimate interests - we have a legitimate business interest in:

  • providing, managing, administering and facilitating your use of our Services in accordance with our commercial interests and legal rights (such as developing user profiles and analyzing customer feedback to better understand our users and how they access and use our Service, and safeguarding Service security)
  • running an effective and sustainable business (such as ensuring our fees are paid)
  • taking measures to ensure that the Service is only accessed by authorized users and in accordance with our terms of use

Audio, Electronic, Visual, or Similar Information: We may record audio during customer service calls. We also collect audio or visual information you post to our sites, like photos or videos. We also collect video surveillance at our in-person events. 

We may use this information:

  • To provide you with our services – please see details above
  • To improve our products and services - please see details above
  • To administer our websites, platforms, services and programs - please see details above
  • For security and safety purposes and prevent fraud – please see details above
  • For analytics and to personalize your experience - please see details above

Consent – for individuals who sign up to our mailing list, or when you subscribe to marketing communications, targeted advertisements and otherwise where appropriate or as required by law

Legitimate interests - we have a legitimate business interest in:

  • providing, managing, administering and facilitating your use of our Services in accordance with our commercial interests and legal rights (such as developing user profiles and analyzing customer feedback to better understand our users and how they access and use our Service, and safeguarding Service security)
  • running an effective and sustainable business (such as ensuring our fees are paid)

Inferences Drawn to Create a Profile About You Reflecting Your Preferences Or Characteristics: We analyze your purchases, preferences, or other interactions and may create a profile for you to suggest other products you may be interested in. For example, we collect membership data, such as contact preferences, and preference data, such as the flavors that you prefer and products you have purchased. 

We may also combine Personal Information from the Services together and with other information we obtain from our business records. We may also combine information we collect offline with information we collect online.  Additionally, information collected about you from a particular browser or device may be linked to information collected from another computer or device that we believe relates to you. We may combine information we get from another party with information we already have. We may also aggregate your information with other consumers’ information to understand preferences and trends over time.

We may use this information:

  • To improve our products and services - please see details above
  • To administer our websites, platforms, services and programs - please see details above
  • For analytics and to personalize your experience - please see details above
  • These activities do not involve automated decision making about you. The Personal Information is used to create models for retargeting you (for example sharing targeted and specific invites to events in accordance with your preferences, sharing specific promotions related to the product of your choice etc.), and understanding purchase behaviors for building your customer journey. 

Legitimate interests - we have a legitimate business interest in:

  • providing, managing, administering and facilitating your use of our Services in accordance with our commercial interests and legal rights (such as developing user profiles and analyzing customer feedback to better understand our users and how they access and use our Service, and safeguarding Service security)
  • running an effective and sustainable business (such as ensuring our fees are paid)

Employment related Information: If you apply for employment with us, we may collect information such as your name, email address, telephone number, home address, resume/CV, cover letter, education information, employment history, and job preferences. To the extent you participate in an interview process with us, we may also collect information from you via video and/or audio interview(s). We may also share your Personal Information with third parties for the purposes of conducting interview assessments and conducting background/reference checks with respect to your employment and related credentials as part of our hiring process.

We may use this information:

  • For recruitment purposes
  • Conduct interviews and assessments
  • Conduct background checks for hired candidates
  • To comply with our obligations

Consent – for individuals who sign up to careers page, or when you provide your Personal Information to other recruitment partners for hiring purposes

Legitimate interests - we have a legitimate interest in ensuring we adhere to our hiring process and comply to employment related obligations.

Legal obligation – for any processing in accordance with an applicable legal obligation

Other Personal Information: We may collect certain Personal Information that has the potential of being more sensitive. For example, we will collect your social security number or government issued identification to verify your age and, when required to comply with the law.  We may also collect your precise geolocation when you use out product finder tool. 

 

We may use this information:

  • To provide you with our services – please see details above.
  • To comply with our obligations
  • For security and safety purposes and prevent fraud

 

 

Legitimate interests - we have a legitimate business interest in:

  • providing, managing, administering and facilitating your use of our Services in accordance with our commercial interests and legal rights (such as developing user profiles and analyzing customer feedback to better understand our users and how they access and use our Service, and safeguarding Service security)
  • running an effective and sustainable business (such as ensuring our fees are paid)
  • pursuing business development initiatives and keeping you informed of relevant offerings
  • taking measures to ensure that the Service is only accessed by authorized users and in accordance with our terms of use

Legal obligation – for any processing in accordance with an applicable legal obligation

Explicit consent – we obtain your explicit consent whenever we wish to process any Personal Information that is categorized as “special category data” under applicable data protection laws

 

Where we are relying on consent to process your Personal Information, you will have the right to withdraw your consent at any time in accordance with the ‘What rights do I have regarding the use of my Personal Information?’ section below.

How long do we retain your Personal Information?

Please refer to section ‘How Long We Retain Your Personal Information’ of our Privacy Policy.

Does Mark Anthony share Personal Information with any third parties?

Please refer to section ‘Disclosure of Your Personal Information’ of our Privacy Policy for details regarding how we share your Personal Information with third parties.

International transfers of your Personal Information

We may transfer your Personal Information outside the United Kingdom and European Economic Area, including to other companies in the Mark Anthony Group, third-party service providers and partners, and we put adequate safeguards in place when we do so. This includes only transferring Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information, or by otherwise using an appropriate safeguard to ensure the ongoing protection of Personal Information, such as standard contractual clauses approved by the applicable regulatory authority. You may request further information on the safeguards we use by contacting us via the contact details in the main Privacy Policy or contact at privacy@markanthony.com

Please also refer to section ‘We Process and Store Information in the United States and in other foreign jurisdictions’ of our Privacy Policy regarding data transfers to the United States.

What rights do I have regarding the use of my Personal Information?

Individuals located in UK and the EEA, have certain rights regarding their Personal Information, as set out in more detail below. Some of these rights, e.g., the right to be forgotten or the right to request that we transfer your information to another company, will only apply in certain circumstances. Most rights are also subject to certain exceptions and exemptions that may mean that we are not always legally required to comply with your request in part or in full.

You have the right to object to us using your Personal Information where we rely on “legitimate interests” as a lawful basis for processing your Personal Information or where we use your Personal Information for direct marketing purposes (i.e., if you no longer want to receive direct marketing communications from us).

 

Rights

What does this mean?

The right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Information and your rights. This is why we are providing you with the information in this notice.

The right of access

You have the right to obtain access to your Personal Information (if we are processing it), and certain other supplementary information (like the information provided in this notice). This is so you are aware and can check that we are using your Personal Information in accordance with data protection law.

The right to rectification

You are entitled to have your Personal Information corrected if it is inaccurate or incomplete.

The right to erasure

This is also known as ‘the right to be forgotten’ and, basically, enables you to request the deletion or removal of your Personal Information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.

The right to restrict processing

You have rights to ‘block’ or suppress further use of your Personal Information. When processing is restricted, we can still store your Personal Information, but may not use it further. We keep lists of people who have asked for further use of their Personal Information to be ‘blocked’ to make sure the restriction is respected in future.

The right to data portability

You have the right to receive your Personal Information in a structured, commonly used and machine-readable format and to request that this data is transmitted to another controller where this is technically feasible. This right only applies to Personal Information you have provided to us yourself (not any other information), that we process by automated means based on your consent or for the performance of a contract with you.

The right to object

You have the right to object to the use of your Personal Information in some circumstances, such as where we don’t have to process your Personal Information to meet a contractual or other legal obligation. For example, you may object to the use of your Personal Information for direct marketing purposes.

The right not to be subject to a decision based solely on automated processing, including profiling

You have the right not to have your Personal Information used to make solely automated decisions about you that you impact you. For example, you have the right not to have your Personal Information used to create a profile of you that automated decisions are later based on without there being any human involvement in that processing.

The right to withdraw consent

If you have given your consent to anything we do with your Personal Information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your Personal Information with your consent up to that point is unlawful). This includes the right to withdraw consent to us using your Personal Information for marketing purposes.

 

If you would like to exercise, or discuss, any of these rights, please contact privacy@markanthony.com  to exercise your rights.

How to contact us about this Privacy Policy or make a complaint?

Our Data Protection Officer
You can contact us at privacy@markanthony.com

ICO
If you have a query or complaint about how your Personal Information is being used, you can also contact the Information Commissioners Office, the supervisory authority that regulates Personal Information in the UK, by writing to them at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, or by visiting their website: https://ico.org.uk. You can also contact them by telephone: at 0303 123 1113. Further details can be found here.

EEA Data Protection Authorities
You have the right to lodge a complaint about the way we handle or process your Personal Information with your relevant national data protection regulator. See details of the EEA data protection regulators here.

17. Updating this Privacy Policy     

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We may let you know via email and/or a prominent notice on our Service, if we make any material changes to this Privacy Policy, to the extent required by law. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

18. Contact Us

If you have any questions or comments about this Privacy Policy or the manner in which we or our service providers treat your Personal Information, please contact us by e-mail privacy@markanthony.com and our privacy officer will get back to you as soon as possible.

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