Privacy Policy

STILL SPIRIT PRIVACY NOTICE

1. Introduction
1. This Privacy Notice (Notice) explains the personal information we collect from you, either directly or indirectly including on our website at www.stillspirit.com, (the 'site') and how we will use it. Personal information is any information that can be used to identify you or that we can link to you. The Notice also explains the choices you can make about the data we collect, and how you can control these decisions.
2. Still Spirit Limited is the controller and responsible for your personal data. "we", "our", " Still Spirit" and "us" refers to Still Spirit Limited.
3. Questions about this Notice should be sent to us at sales@stillspirit.co.uk.
4. We reserve the right to amend this Notice from time to time without notice and at our sole discretion. You should review this Notice at regular intervals.
5. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
2. The types of personal information we collect and how we use it
   1. Where we need to perform the contract we are about to enter into or have entered into with you.
   2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
   3. Where we need to comply with a legal obligation.
1. In this Notice we use the term personal information to mean any information that relates to an identifiable individual. It does not include data where the identity has been removed (anonymous data).
2. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
3. The table below shows what personal information we collect, where we get it from, how we use it and our legal basis for doing so.

1. We also collect, use and share aggregated data such as statistical or demographic data for any purpose. aggregated data could be derived from your personal information but will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Notice.
2. Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

1. Marketing
1. Still Spirit uses the data we collect to provide you with the services we offer, which includes using data to improve and personalise your experiences. We also use the data to communicate with you, for example, informing you about our monthly auctions.
2. We provide you with choices regarding certain personal data uses, particularly around marketing and advertising. For information about managing email subscriptions and promotional communications, please visit your ‘My Still Spirit’ account.
2. Change of purpose
1. We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
2. If we need to use your personal information for an unrelated purpose, we will inform you and we will explain the legal basis which allows us to do so.
3. How we may share personal information
   1. Third party vendors: Still Spirit uses a variety of third-party vendors to carry out services like site management and hosting, shipping of items won on auction to buyers, debit/credit card processing and email communications. We only share your personal information as necessary. In this case, your personal information will be shared with these agents or contractors but only for the purpose of performing services on behalf of Still Spirit and in accordance with this Notice.
   2. Still Spirit affiliates: Where you have provided your consent, we will share your contact details with our affiliated companies, including Whisky Hammer, for marketing purposes. We will also share your information with our affiliated companies for the purposes of aggregated analytics or where an affiliated company is engaged by us to provide you with services.
   3. Compelled disclosure: When legally required, strictly necessary for the performance of the services or to protect our rights, or the rights of our affiliates or users, we disclose your personal information to law enforcement authorities, HM Revenue and Customs (for similar bodies in other countries), debt collectors, investigative organisations, our affiliates or in legal proceedings.
   4. Sale or merger: We may share your personal information in the event of a merger, acquisition, or sale of all or a portion of our assets. We will inform you of any transfer via email and/or a prominent notice on our site and inform you of your rights.
   5. Sharing and disclosure of aggregate data: We share data in aggregate form and/or in a form which does not enable the recipient of such data to identify you, with third parties, for example, for industry analysis.
   6. The above (1-5) excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.
1. Still Spirit does not and will not sell personal information about our customers to other organisations for marketing purposes. We only disclose your data as described in this Notice.
2. We may share information with the following types of third parties:
3. 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 information for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
4. International transfers
   1. Stripe
   2. PayPal
   3. Opayo
   4. Global Payments
1. When you make a payment to us, we will direct you through one of our third party payment providers. These third parties which facilitate payments to us may be based outside the UK or EEA and so please see the privacy notices linked below for each of the providers we use to find out more:
5. Security
1. Still Spirit is committed to protecting the security of your personal information. However, while we take reasonable precautions to guard the personal information we collect, no security system is impenetrable.
2. Still Spirit takes precautionary measures to help prevent information about you from loss, theft, misuse and unauthorised access, disclosure, alteration and destruction. For example, your data is protected with encryption during transition over the Internet. Please note, your password is stored using one-way hash, which means that it cannot be recovered (or disclosed) by anyone, including Still Spirit, it can only be reset.
3. You can only access your Still Spirit account information and our service through the use of an individual user login and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please inform us immediately if you believe your password has been misused. You should always log out and close your browser when you finish your session. We will never ask you to disclose your password in an unsolicited phone call or email.
4. If you have any questions about the security of your personal information, please contact us.
6. Retention
1. Still Spirit will retain your personal information for as long as it is necessary to enable you to use the site and your Still Spirit service, to provide services to you, to comply with applicable laws (including those regarding document retention), resolve disputes with any parties and otherwise as necessary to allow us to conduct our business. All personal information we retain will be subject to this Privacy Notice and our internal retention guidelines. If you have a question about a specific retention period for certain types of personal information we process about you, please contact us.
2. We do not store any debit or credit card information.
7. Your Rights
   1. you can ask us for a copy of the personal information we hold about you;
   2. you can inform us of any changes to your personal information, or if you want us to correct any of the personal information we hold about you;
   3. in certain situations, you can ask us to erase, block or restrict the personal information we hold about you, or object to particular ways in which we are using your personal information; and
   4. in certain situations, you can also ask us to send the personal information you have given us to a third party.
1. We want you to be in control of how your personal information is used by us. Under certain circumstances, you can do this in the following ways:
2. Where we are using your personal information on the basis of your consent, you are entitled to withdraw that consent at any time. Moreover, where we process your personal information based on legitimate interest or the public interest, you have the right to object at any time to that use of your personal information.
3. We rely on you to ensure that your personal information is complete, accurate and up to date. Please do inform us promptly of any changes to or inaccuracies in your personal information by contacting us.
4. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
8. Your Choices
1. Still Spirit account: If you wish to access, edit or remove profile information, change your password, close your account or request deletion of your personal data, you can do so by logging in to your ‘My Still Spirit’ account or contacting us.
2. Your communication, marketing and advertising preferences: You can opt out of receiving direct marketing communications from Still Spirit by following the instructions included in every email sent to you via the “Unsubscribe” tab. You can also opt out of email subscriptions by updating your Contact Options in your ‘My Still Spirit’ account. We respect your choice, and we will stop sending you promotional emails once you unsubscribe.
3. Please note, regardless of your communication settings, we will continue to communicate with you regarding changes to terms and conditions, policy updates, routine customer service messages such as information about current or past purchases, delivery of products, service interruptions, data breaches or other significant information, such as safety issues.
4. You can adjust the amount of interest-based advertising you may receive by changing your cookie settings. If you have opted out of receiving emails from us, we will not use your email for interest-based advertising activities.
9. Complaints
1. We are committed to working with you to obtain a fair resolution of any complaint or concern you may have about our use of your personal information. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to file a complaint with the Information Commissioner's Office (ICO), the UK regulator for data protection issues ( www.ico.org.uk).
2. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
10. If you are outside the UK
    1. sending an email to DataRep at datarequest@datarep.com quoting <Still Spirit Ltd> in the subject line,
    2. contacting us on our online webform at www.datarep.com/data-request, or
    3. mailing your inquiry to DataRep at the most convenient of the addresses below – which should be addressed toStill Spirit Limited.
       
1. If you live outside the UK and have any questions or complaints related to data protection please contact our representative in the European Union ('EU"), Datarep, so that you can contact them directly in your home country. DataRep has locations in each of the 27 EU countries and Norway & Iceland in the European Economic Area ('EEA'), so that Still Spirit Ltd's customers can always raise the questions they want with them.
2. If you want to raise a question to Still Spirit Ltd, or otherwise exercise your rights in respect of your personal data, you may do so by: