Welcome to the WhiskyInvestDirect Privacy Notice

WhiskyInvestDirect Ltd is the company which owns and operates the WhiskyInvestDirect service. This information has been produced to help you understand what you need to know about how and why WhiskyInvestDirect collects, uses, and shares personal data, what your legal rights are, and how to exercise them.

You should take time to read this document. We have tried to keep it as simple as possible and to avoid jargon. If there’s anything you don’t understand, or if you have any questions, please do contact us. WhiskyInvestDirect takes its responsibility for protecting your data very seriously, and we shall make our best efforts to keep you informed if there are any changes to the way we process your personal data in the future.

Who is the Data Controller?

We are WhiskyInvestDirect Ltd

Registered address: 7th Floor, 3 Shortlands, London, England, W6 8DA

Company number: 09068458

In this document WhiskyInvestDirect may be referred to as “we”, “us”, or “our”.

What kinds of Personal Data does WhiskyInvestDirect Process?

WhiskyInvestDirect collects personal data for various purposes, either directly from yourself or from other sources, to achieve those purposes. The kinds of personal data we may collect include:

Why does WhiskyInvestDirect collect Personal Data?

Legal Obligations

WhiskyInvestDirect collects and uses your personal data to fulfil any contractual obligations that exist between you and us. Without the relevant personal data we will not be able to deliver the goods or services you want. In such cases the lawful basis of us processing the personal data is that it is necessary for the performance of a contract.

We are required by law to process personal data for purposes relating to our legal obligations, these include:

• To provide for our financial commitments, or to relevant financial authorities including sharing with our Auditors.
• To comply with regulatory requirements and any self-regulatory schemes.
• To carry out required business operations and due diligence.
• To cooperate with relevant authorities for reporting criminal activity, or to detect and prevent fraud.
• In some circumstances we are legally obliged to share information.
• To investigate any insurance claims, claims of any kind of harassment or of discrimination, or any other claim whereby the organisation may have to defend itself.

Consent

WhiskyInvestDirect may process your Personal Data for the following purposes where it has received your consent to do so.

Receiving future marketing material.

You may withdraw your consent for us to process your personal data for these purposes at any time via your client portal. Please understand that after a withdrawal of consent request is received, we may have to contact you to verify the request.

Withdrawing your consent for us to process your personal data will not affect the lawfulness of the processing which previously occurred.

Legitimate Interests

WhiskyInvestDirect may process Personal Data for any of the following purposes, which are considered to be in our legitimate business interests, including:

• To provide goods and services where it has been requested,
• To send notification on subjects to individuals who have asked to be kept informed,
• To improve the quality of the services we offer, and to better understand users’ needs by requesting feedback, or reviews of the services provided, or sending survey forms,
• To send notifications of any changes to the goods and/or services provided that may affect you,
• To understand the scale of the user base; for statistical analysis and market research,
• To allow the organisation to support and maintain our products in active service,
• To improve the organisation's website so content is delivered more efficiently.

How does WhiskyInvestDirect obtain Personal Data?

Personal Data is collected directly from you in various ways. These include you entering information directly into a form on our website or if you provide the data directly to a representative of WhiskyInvestDirect.

We may also collect some personal data from publicly accessible sources including web searches and official registers (such as Companies House in the UK).

Who may WhiskyInvestDirect share your Personal Data with?

To achieve the purposes stated above, for which we process your personal data, we may need to share your personal data with certain third parties.

We shall make all reasonable efforts to ensure that any third-party we share your personal data with is also compliant with data protection law.

The kinds of third parties we may share your personal data with include:

• Regional and/or local government authorities where we are compelled by law.

The specific types of third-party WhiskyInvestDirect may share your personal data with include:

Where will WhiskyInvestDirect store your Personal Data?

WhiskyInvestDirect will not transfer your personal data to any country other than those that have been granted an adequacy decision under the General Data Protection Regulation. Where we share your personal data with third-party organisations, we take all reasonable measures to ensure they are also fully compliant with data protection law.

How long will WhiskyInvestDirect keep your Personal Data

To meet its commitments under UK law, WhiskyInvestDirect will retain information about users for a period of at least 5 but no more than 10 years from the cessation of business (taken to be the closure of all WhiskyInvestDirect accounts held by those users), after which time any personal data regarding those users is deleted from WhiskyInvestDirect's computers. You can request deletion of your data by emailing support@whiskyinvestdirect.com.

The following criteria are what determine the period for which we will keep your personal data:

• Until we are no longer required to do so to comply with regulatory requirements or financial obligations.
• Until we are no longer required to do so by any law we are subject to.
• Until all purposes for which the data was originally gathered have become irrelevant or obsolete.

Your Rights, Our Responsibility

There are several rights granted to you immediately upon providing us with your personal information; some of these are mentioned above. We take your rights seriously and will always conduct ourselves in a way that is considerate of our responsibility to serve your legal rights.

The Right of Access

You can ask us to confirm whether or not your personal data is being processed, and to provide you with relevant details of what those processing operations are and what personal data of yours is being processed.

If you would like access to the personal data we have about you, please contact us using the details below.

The Right to Rectification

If you notice that the data we have about you is inaccurate or incomplete, you may request we rectify the mistake. We will make every effort to respond immediately.

The Right to Erasure

Otherwise known as the 'right to be forgotten', this gives you the right to request your personal data be deleted. Please note that this is not an absolute right. If you were to request that we erase your personal data, we would erase as much of that data as we could but may have to retain some information if it is necessary.

Where we have received a request for personal data to be erased, if it is necessary for us to retain some of that information, we shall ensure that the remaining data is used only when and where it is necessary.

The Right to Objection

If you wish to object to the way we use, or have used, your personal data, you may do so freely.

The Right to Complain

WhiskyInvestDirect strives to maintain the highest standards in all its operations, the better to encourage confidence and satisfaction among all our customers. To help us achieve this, we ask that any complaints you may have are first brought to our attention directly, so that we can properly and swiftly investigate and rectify as needed. If you would like to complain about WhiskyInvestDirect to a regulatory body, you may do so by contacting your local data protection supervisory authority.

To request any of these rights and to also withdraw any consents provided to WhiskyInvestDirect email us at support@whiskyinvestdirect.com.

For any other queries our contact details are:

WhiskyInvestDirect Contact Details

WhiskyInvestDirect Ltd, Unit 5, Berghem Mews, London W14 0HN.

+44 (0)20 8600 0135

support@whiskyinvestdirect.com

Who is the WhiskyInvestDirect's EU Representative?

Ametros Ltd

Unit 3D

North Point House

North Point Business Park

New Mallow Road

Cork

Ireland

gdpr@ametrosgroup.com

www.ametrosgroup.com