PRIVACY POLICY

WHO WE ARE

The Macallan is owned by The Macallan Distillers Limited, a private limited company (registered in Scotland No. 024068), with registered office at The Macallan Distillery, Craigellachie, Banffshire, AB38 9RX, and operational address in Singapore at Edrington Singapore Pte Ltd 80 Robinson Road #02-00, Singapore 068898.

Le Clos (MMI LLC)) is operated by Le Clos (MMI LLC)), a company incorporated in UAE, with registered office is at: Level 5, Emirates Holidays Building, Sheikh Zayed Road, Dubai, U.A.E.

OVERVIEW

The Macallan and Le Clos are committed to protecting and respecting the privacy of its consumers’ personal information. Looking after the personal data that we collect on our consumers is a priority for us and we want you to be confident that your information is in safe hands.  We’ve developed this Privacy Policy to let you know:

• What types of personal data we collect;
• How we collect personal data;
• When and why we share it with other organisations, including the types of organisations involved;
• How long we keep personal data for; and
• The rights and choices you have with regards to your personal data.

WHAT TYPES OF PERSONAL DATA DO WE COLLECT ABOUT OUR CUSTOMERS?

• Your name, age/date of birth (for age verification purposes) and location;
• Your contact details: postal addresses including billing and delivery addresses, contact telephone numbers;
• Details of purchases and orders made by you;
• When you make a purchase or place an order with us, your payment card details;
• Your correspondence and communications with The Macallan;
• Personal data which you may have shared via a public platform (such as on The Macallan’s Facebook or Instagram feed);
• Your communication and marketing preferences;
• Your interests, preferences, feedback and survey responses;
• Online browsing activities on The Macallan website and mobile application (“app”).

HOW DO WE COLLECT YOUR PERSONAL DATA?

We collect your personal data when:

• You subscribe to receive our newsletter;
• You make an online purchase or place an order online for a Macallan product or merchandise;
• You enter a ballot or competition related to The Macallan or one of The Macallan’s products;
• When you attend one of our events or visit one of our sites or app;
• When you contact us, for whatever reason.

We generally do not collect your personal data unless:

1. it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after:
   1. you (or your authorised representative) have been notified of the purposes for which the data is collected; and
   2. you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes; or
2. collection and use of personal data without consent is permitted or required by the PDPA or other laws.

Where required, we will seek your consent before using any additional personal data that we may collect about you that is for a purpose which has not already been notified to you.

HOW DO WE USE YOUR PERSONAL DATA?

The Macallan, Le Clos and our trusted partners acting on our behalf may use your personal data:

• With your agreement, to provide you with information, products or services that you request from us, or which we feel may interest you;
• To send you personalised communications based on your preferences, and use of The Macallan’s products;
• To verify your identity and your age;
• For crime and fraud prevention, detection and related purposes;
• To perform obligations in the course of or in connection with the provision of goods and/or services requested by you;
• To comply with our duties or exercise our rights under a contract for the sale of goods to a consumer;
• To process payment or credit transactions;
• To comply with our legal and/or regulatory obligations;
• To protect our consumers, employees and other individuals including to maintain their safety, health and welfare;
• To promote, market and advertise our products in accordance with applicable law;
• Subject to applicable law, to understand our consumers’ behaviour, activities, preferences and needs, improve existing products and develop new products,
• To enable The Macallan and Le Clos to manage any customer service interactions with you, including handling any queries or complaints from and/or disputes with our consumers;
• To ensure that our web content is presented in the most efficient way for you and your computer;
• To allow you to participate in interactive features on our website and/or app, when you choose to do so; and
• Where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).

WHAT IS OUR LEGAL REASON FOR HOLDING YOUR PERSONAL DATA?

Data protection laws  require us to collect, use, or disclose personal data about an individual only for purposes:

1. that a reasonable person would consider appropriate in the circumstances; and
2. that the individual has been informed of.

We rely on your consent to send you marketing communications about The Macallan.  You can withdraw your consent to receive these communications at any time by using the unsubscribe button included in the communications we send you.

WHAT ARE YOUR RIGHTS?

You have a number of rights under data protection laws in relation to the way we process your personal data, namely:

• subject to certain specified exceptions, to access your data;
• to have your data rectified if it is inaccurate or incomplete;
• to object to direct marketing;

If you wish to exercise any of these rights, please contact info@leclos.net

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

To effectively fulfil our obligations to you, and to provide you with certain benefits, we use a number of trusted and reliable third parties to carry out functions which involve the processing of your personal data.  These include IT, delivery and marketing service providers, and other companies or employees associated with The Macallan and Le Clos.

• When you order products from our online shop, we will share your details with our fulfilment partner, who will process your orders as set out in our Terms and Conditions.
• We use marketing service providers to administer services on our behalf, such as sending communications to our consumers, and administering any promotions or ballots which we run.
• Other agencies and fulfilment partners to administer events, competitions and brand programmes that you have opted into.

Some of the third party service providers we use may be based outside of Singapore and UAE, but we will only transfer personal data to these service providers where we are satisfied that adequate levels of protection and security controls are in place to protect your personal data.  We impose contractual obligations on service providers relating to data protection and security which means that they can only use your personal data to provide services to The Macallan or to you, and no other purpose.

The Macallan is part of a group of companies, and The Macallan Distillers Limited’s headquarters are in Scotland.  Your personal data will be shared with employees of The Macallan, based outside of Singapore, and also with employees of companies associated with The Macallan which are part of the same group of companies as The Macallan.

We may provide information to others (such as governmental or law enforcement agencies) in the good faith belief that such action is necessary to: (i) enforce or apply our Terms and Conditions; (ii) comply with any legal claims raised against The Macallan; (iii) protect the rights, property or safety of The Macallan; or (iv) protect the rights, property or safety of the public.

If The Macallan becomes involved in a merger, acquisition, bankruptcy or other transaction involving the sale of some or all of our assets, user information, including personal information collected from you through your use of our Website and/or app, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you, either through email and/or a prominent notice on the Website and/or app.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will not retain your personal data for longer than necessary for the purposes set out in this Policy or if we no longer have a legal or business purpose for retaining it.  Different retention periods will apply to different types of data. If you wish to have your data deleted or removed please contact info@leclos.net.

HOW DO WE PROTECT YOUR PERSONAL DATA?

The Macallan is committed to keeping your personal data safe and secure.  To prevent unauthorised access, maintain data accuracy and ensure the correct usage of personal data, we monitor and adjust our physical, electronic and managerial procedures to safeguard and secure the personal data we collect online.

QUESTIONS

If you have any questions or concerns about the way in which your personal data is processed, please contact info@leclos.net.

CHANGES

This policy may change from time to time. If we change anything important we will notify or contact you.