Privacy Notice

WHO WE ARE

This Privacy Notice (‘Notice’) is issued on behalf of the William Grant & Sons Group so when we mention "Company", "we", "us" or "our" in this Privacy Notice, we are referring to the relevant company in the William Grant & Sons Group responsible for processing your data on this website. William Grant & Sons Group is made up of different legal entities and you can find more information in the ‘List of Companies’ section of this Notice.

We own and operate www.thebalvenie.com

We are committed to protecting your personal data; your privacy matters to us. That is why we have developed this Privacy Notice to explain how we collect, use, share and store your personal information when you use this website, and to inform you about how we will look after that information. This includes any information you may provide us with when you visit this website, sign-up to keep in touch with us, take part in any competitions that we might run, supply, or consume the goods/services we offer or engage with us otherwise.

It is important that you take some time to read and familiarise yourself with this Notice, together with our Website Terms and Conditions, Cookie Notice and any other privacy or fair processing policies that we may provide on specific occasions when we are collecting or processing personal data about you. This will help you to be fully aware of how and why we are using your information. If you do not agree with any term in this Notice, please do not use the website or submit any personal information to or through it.

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:

HOW WE USE YOUR PERSONAL INFORMATION

In general terms, we collect and use personal information to:

• deliver our services and meet our legal responsibilities

• verify your identity where this is required

• contact you by post, email, or telephone

• understand your needs and how they may be met

• maintain our records

• process financial transactions

• send you information on our offers and promotions

• share our newsletters with you

• understand your preferences and choices about our brands

• improve our products and services

More specifically, 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.

FURTHER INFORMATION ON DIRECT MARKETING:

We will get your express opt-in consent before directly sending you marketing communications. If you wish to opt-out, use the unsubscribe options in our mailing lists or email us at dataprotection@wgrant.com.

We will also get your express opt-in consent before sharing your personal information with any third party so that they can send direct marketing communications to you. In this case, the privacy notice of such third party will apply. You can unsubscribe and/or opt-out per those notices.

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.

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 entering into any competitions that we may run on this site or completing online questionnaires or if you contact us directly, for example, regarding career vacancies, enquiries or other feedback.

• 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. This may include cookies, pixels, and other similar technologies on our websites to collect information and provide you with the services that you have requested or participate in and to provide targeted advertising.

• Data we collect when you use our services e.g. payment and transaction information, identity and contact information, etc.

• Data from third parties that we work with e.g. our marketing, communications and PR agencies, our distributors, etc.

ADVERTISEMENT TECHNOLOGY

• As described above, we may use service providers to help us manage, carry out and improve our advertising. These parties set cookies at our direction to help us collect information and provide you with advertisements that we believe would be relevant for you. In some instances, these parties may also assist us by providing certain statistical and analytics information in relation to our marketing practices.

• We also may share information collected through cookies (and other tracking technologies) with third parties to use for their own analytics and marketing purposes. These third parties may serve targeted advertising to you about our brand and other WG&S brands based on your consent.

• Other technologies such as tracking pixels may also be used on our websites, in email messages and in other areas of our business. These technologies are used to improve our products and services as well as our marketing efforts. We use pixels to help us determine the success of our advertising campaigns, such as to give us insight into whether you opened, deleted, or forwarded an email, or clicked on a link contained in the email.

We and our service providers may serve targeted advertisements through the data we collect from you, first-party or third-party cookies, pixels and web beacons when you visit our website. We do this to provide you with advertising that we believe may be relevant for you as well as improve our own products and services, including the functionality and performance of our websites. This means that you may see our banners and ads when you are on other websites such as on social media. We manage this through a variety of digital marketing networks and advertising technologies explained above. These banners and ads are based on the data we hold of you, your previous use of our website, or through our banners and ads that you clicked on.

If you are using these third-party functions, you are also protected by the privacy policies of these third parties. To learn more about opting out of certain types of targeted advertising, please see the Cookie Notice at www.thebalvenie.com/cookie-policy

INFORMATION YOU POST ON PUBLIC AREAS OF OUR SITE AND SOCIAL MEDIA

Information that you post on or through any public areas of the website (such as chatrooms, bulletin boards or discussion forums) and on any social media pages that we operate is publicly available information. This means that it is generally accessible to, and may be collected by, others and may be used by them to send you unsolicited messages. We do not have control over if or how other people may use that information therefore you should use caution and ensure not to disclose personal information when using public web areas or social media. We will not be responsible for any postings that you make with personal information in them. Please read this section in conjunction with our www.thebalvenie.com/terms-and-conditions.

WHO WE SHARE YOUR INFORMATION WITH:

We may share your personal information with the following third parties:

• Payment processors and providers

• Members of our group of companies

• Agencies or third parties that we are partnering with to deliver events and services

• Third parties for the purpose of marketing, in line with this Notice

• Security providers

• Health & Safety providers

INTERNATIONAL DATA TRANSFERS AND PERSONAL INFORMATION HELD INTERNATIONALLY

As we operate via a global network of corporate offices, it may be necessary to transfer your information, for example, information collected in connection with a brand, joining one of our emailing lists or interacting with us through our websites, emails, or our other digital channels to a country outside of the country where it was originally collected or outside of your country of residence or nationality. The information that you provide us may be transferred to any of our WG&S owned or affiliated entities around the world for the purposes of carrying out or facilitating these services and in compliance with the applicable laws. We will take steps to make sure such transfer is carefully managed to protect your privacy rights.

Further, we will only transfer personal information to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied those alternative arrangements are in place to protect your privacy rights. We will also make sure that any requests for information we receive from law enforcement or regulators will be carefully validated before personal information is disclosed, where permitted by the applicable law.

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. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to any of our affiliated websites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We will only keep 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 obligations that we may have. We will only keep personal data for longer where there is a legal requirement for us to do so.

To determine how long we should keep your information for, we will consider the amount, type, and sensitivity of the personal information involved as well as the potential risk of harm if it is lost or used or disclosed without authorisation. We will also consider the purposes for which we process your personal data and whether we can achieve those purposes through other means without the need to keep your data.

In some circumstances you can ask us to delete your data (see section on "Your rights" below for more information).

In some circumstances, we may also anonymise your personal data so that it can no longer be associated with you, for example for statistical purposes. Where we do this, we may use this information indefinitely without further notice to you.

YOUR RIGHTS

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 is 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.

SPECIFIC PROVISIONS FOR CALIFORNIA

If there is any inconsistency between the rights in this section and this Privacy Notice, the specific rights of this section shall prevail in respect of California.

Notwithstanding the information, disclosures, and obligations set forth above, if you are a California resident, California law may provide you with additional rights regarding our use of your personal information, as follows

1. Sale of Data

We do not sell any of your data. However, you have the right to know if any personal information of yours was sold (as defined by the California Consumer Protection Act) to a third party (including the identity of those third parties, the method of sale and what rights they were granted in the personal information). To submit any request, under the California Consumer Protection Act, please write to us on dataprotection@wgrant.com.

Sale of Personal Information: We do not sell your personal information in exchange for monetary compensation. We may allow certain third parties (such as certain advertising partners) to collect your personal information via automated technologies on our websites in an effort to serve you content and advertisements that may be of interest to you. This kind of sharing may be considered a “sale” or “sharing” under California law when the personal information is exchanged for non-monetary consideration. The categories of personal information that may have been disclosed in this manner during the 12-month period prior to the date of this Notice include: identifiers, protected classifications, commercial information, online activity, and inferences. We share these categories of personal information for online advertising purposes as described in this Notice as well as in our Cookie Notice. You have the right to opt out of these disclosures of your information, by contacting us on dataprotection@wgrant.com.

2. Do Not Track

We do not respond to Do Not Track (DNT) signals or requests. However, general sites including ours do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, some browsers allow you to set the DNT signal so that third parties know you do not want to be tracked.

3. Data Requests

You may also submit requests for access, correction, erasure, objection, or restriction by emailing us at dataprotection@wgrant.com. You must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. You do not need to create an account with us to submit a request. We will only use personal information provided in the request to verify the requestor's identity or authority to make it

4. Shine the Light Requests

California Civil Code Section 1798.83 permits you to opt out of the disclosure of your personal information by William Grant & Sons Group to third parties for the third parties’ direct marketing purposes. To make an opt-out request of such disclosures, please send an email to dataprotection@wgrant.com.

5. Additional Information

If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

SPECIFIC PROVISIONS FOR PEOPLE’S REPUBLIC OF CHINA (EXCLUDING FOR THE PURPOSES OF THIS NOTICE HONG KONG SAR, MACAU SAR AND TAIWAN) (“PRC”)

If there is any inconsistency between the rights in this section and this Privacy Notice, the specific rights of this section shall prevail in respect of PRC.

A. Data controller

For the PRC, William Grant & Sons Liquor Trading (Shanghai) Limited, is the data controller. For more details, please see the ‘List of Companies’ section. For questions or concerns related to your personal information or related to the Privacy Notice, please contact asiadataprotection@wgrant.com.

B. Consent

We will obtain your consent (where applicable, separate consent) to collect, use, share, transfer (including but not limited to overseas transfer), disclose or otherwise process your personal information if and to the extent required by the applicable laws.

C. Sensitive personal information

Certain of the types of personal information described in this Privacy Notice are considered "sensitive" and, depending on your jurisdiction of work or residence and applicable law, additional rules will apply in respect of this personal information (including obtaining your separate consent). References to personal information in this Privacy Notice shall be deemed to include reference to sensitive personal information (if any) where applicable.

“Sensitive personal information” as defined under PRC laws and regulations which we may collect and use for the purposes described in the above Privacy Notice may include information relating to:

• payment card information;

• stay records;

• biometric information;

• pin or password;

• your precise geolocation;

• web browsing history

D. International data transfers

With your separate consent, we may share, transfer or store your personal information outside of China for processing pursuant to legally acceptable mechanisms that are aimed at ensuring an adequate level of protection as regards your personal information under the applicable laws.

E. How we store and protect your personal information

We will store your personal information for as long as necessary to achieve the purposes described in this Privacy Notice and for as long as you use our services, and as otherwise required by applicable law. We take reasonable security measures to protect your personal information in accordance with industry standards and are committed to using various technologies and initiatives to protect your personal information from unauthorized access, use, modification, disclosure and damage, such as the use of encryption technology to protect your personal information. We will deal with personal information security incidents in accordance with applicable laws and regulations and conduct training and dissemination of personal information protection to relevant personnel to enhance their awareness of the importance of personal information and responsibilities related to personal information protection.

F. Personalized marketing

In order to provide you with personalized push notifications, we may collect information about the device information.

You can opt out or turn off personalized push notifications in the notification settings on your device. You can opt out of email marketing in the ways described in this privacy Notice.

SPECIFIC PROVISIONS FOR BRAZIL

If there is any inconsistency between the rights in this section and this Privacy Notice, the specific rights of this section shall prevail in respect of Brazil.

Brazil data subjects have legal rights under Brazil’s Federal Law nº 13.709/2018 (LGPD), as well as any other applicable laws in relation to your personal information. To exercise any of your rights, please contact us at dataprotection@wgrant.com.

A. To access personal information

You can ask us to confirm whether we have and are using your personal information and for a copy of your information.

B. To correct personal information

You can ask us to correct any information about you that is incorrect, inaccurate or outdated. We will be happy to rectify such information but would need to verify the accuracy of the information first.

C. To erase/anonymise personal information

You can ask us to erase, anonymise or block your information if you think we no longer need to use it for the purpose for which we collected it from you, or if such data is excessive or is processed in violation of applicable law. You can also ask us to erase your information if you have withdrawn your consent to us using your information (if we originally asked for your consent to use your information). We may not always be able to comply with your request, for example where we need to keep using your information to comply with our legal obligations or where we need to use your information to establish, exercise or defend legal claims.

D. To object to how we use your information

You can object to any use of your information that we have justified on any legal bases other than consent, only in case of infringement of the applicable law. If you raise an objection, we may continue to use your information if we can demonstrate that we have a legal basis to continue to use the information.

E. To ask us to transfer your information to another organisation

You can ask us to provide your personal information to you or you can ask to have it transferred directly to another data controller (e.g., another company).

F. Other rights

• You may at any time revoke your consent to the processing of your personal data, whenever you have given it.

• You may file a claim before competent governmental authorities, such as the national data protection authority.

• You may ask us to provide information about any public and private entities with which we have shared your data.

• You may request a review of decisions taken solely on the basis of automated personal data processing that affects your interests, including decisions intended to define your personal, professional, consumer and or aspects of your personality.

We may ask you for proof of identity when making a request to exercise any of these rights. We do this to make sure that we only disclose information where we know we are dealing with the right individual.

We may not always be able to do what you have asked, for example if it would impact the duty of confidentiality we owe to others, or if we are otherwise legally entitled to deal with the request in a different way.

SPECIFIC PROVISIONS FOR SINGAPORE

Data Protection Officer Contact Details

We have appointed a Data Protection Officer (DPO). If you wish to contact them for questions or concerns related to your personal information or related to the Privacy Notice, please contact:

Bird & Bird Privacy Solutions,

Bird & Bird DPO Services SRL

dataprotection@wgrant.com

+65 6534 5266

CHANGES TO OUR PRIVACY NOTICE

We keep this privacy Notice under regular review and will place any updates on this website. We recommend that you check this page regularly to ensure that you have read the most recent version.

This Privacy Notice was last updated on 26^th September 2024.

CONTACT INFORMATION AND FURTHER ADVICE

For any questions or concerns regarding this Notice or our data privacy practices, please contact us by email: dataprotection@wgrant.com.

COMPLAINTS

You have a right under the local laws to lodge a complaint with us or with your local data protection supervisory authority at any time. However, we ask that you please try to resolve any issues with us first before referring your complaint to the supervisory authority.

FOR UK, you will contact the Information Commissioner’s Office- https://ico.org.uk/contact-us

By phone: 0303 123 1113

By post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF

For EU, you will contact the competent Data Protection Authority of any of the EU member states.

LIST OF COMPANIES