Scotch Whisky Warehousing is the trading name of Scotch Whisky International Warehousing Limited (“SWW”, “we”, “us”), a company registered in Scotland under number SC736971, with its registered office at 5 Station Road, Auchtermuchty, Cupar, KY14 7DP, and its bonded warehouse operation at Crompton Road, Glenrothes, Fife, KY6 2SF. We are part of Scotch Whisky Investments.
SWW attaches great importance to the protection of your privacy and the security of your personal data, in accordance with the UK General Data Protection Regulation and the Data Protection Act 2018. This Privacy Policy describes how we handle and protect your personal information. It covers:
- what personal data is, and how we obtain it;
- the purposes for which, and the legal bases on which, we process personal data;
- how long we keep your personal data;
- who we share your personal data with;
- how your personal data is protected;
- the cookies this website uses; and
- the rights you have in respect of your personal data.
This Privacy Policy is intended for everyone whose personal data SWW processes, including customers, prospective customers, and people who contact us through this website. It applies to scotchwhiskywarehousing.com and to correspondence with our Glenrothes team. It does not cover the websites of Scotch Whisky Investments, The Auchtermuchty Bond Ltd, or any other third party we link to, each of which publishes its own policy.
Contact us about your data
Email: sales.glenrothes@swi1.com
Phone: +44 1337 827 729
Post: Data Protection, Scotch Whisky Warehousing, Crompton Road, Glenrothes, Fife, KY6 2SF
1. What is personal data?
Personal data means any information relating to an identified or identifiable natural person. We may process the following personal data:
- Basic details such as your first name, last name and title;
- Contact details such as your email address, postal address and telephone number;
- Details about your enquiry, such as the type of business you are in, the number of casks concerned, your intended storage term and anything else you choose to tell us in the message field of our enquiry form;
- Details you give us in connection with a visit to our site, such as accessibility or dietary requirements;
- Technical data recorded automatically when you request a page, including your IP address, the date and time, the page requested, the referring page, and your browser and device type;
- any other personal data relating to you that you provide, or that we obtain, in connection with the purposes and legal bases set out below.
You provide this data, for example, by submitting our enquiry form, by emailing or calling us, by giving us your business card, or on entering into an agreement with us. We may also obtain personal data from other sources, such as a business contact, a counterparty, Companies House, or publicly available sources.
We do not ask for special category data through this website. Please do not include health, political, religious or similar information in the free-text message field.
2. Purposes and legal bases
We may use your personal data for the following purposes:
- to answer your enquiry and provide the information, quotation or advice you have asked for;
- to provide our cask storage, cask management, filling, vatting, blending and bottling services;
- to arrange and host site visits, tastings and events;
- to comply with our legal and regulatory obligations, including those arising from excise warehousing;
- to operate, secure and maintain this website.
We process your personal data on one or more of the following legal bases:
| Basis | UK GDPR | When it applies |
|---|---|---|
| Your consent | Art. 6(1)(a) | You tick the box on the enquiry form |
| Performance of a contract, or steps prior to it | Art. 6(1)(b) | Quoting for and delivering our services |
| Compliance with a legal obligation | Art. 6(1)(c) | Tax, accounting and excise records |
| Legitimate interests | Art. 6(1)(f) | Keeping records of correspondence, and running and securing this website |
Where we rely on legitimate interests, we have considered whether those interests are overridden by your rights and freedoms, and concluded that they are not. You may ask us for that assessment.
We do not use your details for marketing unless you have separately asked us to. If we ever do, every message will carry a way to opt out. We do not make automated decisions about you and we do not build visitor profiles.
3. Sharing your personal data
In certain cases we may share your personal data with third parties, including but not limited to:
- Companies within our group, being Scotch Whisky Investments and The Auchtermuchty Bond Ltd, where this is necessary to answer your enquiry or deliver a service you have asked for;
- Regulators and other authorities, including HMRC, in order to meet legal obligations;
- External suppliers in connection with the processing of your personal data for the purposes described in this Privacy Policy, such as IT suppliers, communication service providers and professional advisers to whom we outsource certain supporting services.
Sharing takes place only for the purposes named in this Privacy Policy and only on the legal bases it sets out. We do not sell your personal data and we do not share it for anyone else’s marketing.
Where a third party processes your personal data in the capacity of a processor for SWW, we enter into a processor agreement meeting the requirements of the UK GDPR. Third parties to whom we provide your personal data as a controller in their own right are themselves responsible for complying with data protection law.
3.1 Third-party content on this website
Two elements of this website are served by third parties. When your browser loads them, that third party receives your IP address and basic technical information, because that is how the content is delivered:
- Google Fonts (Google Ireland Limited / Google LLC) supplies the typefaces used on this site.
- Vimeo (Vimeo.com, Inc.) supplies the background film in the page header. We load the Vimeo player with Do Not Track enabled, which instructs Vimeo not to track the viewing session or use it for analytics or advertising.
Their own privacy notices apply to that processing.
3.2 Where your data is held, and transfers outside the UK
This website and its contact form are hosted on Microsoft Azure in the West Europe region, in the Netherlands. The Netherlands is covered by UK adequacy regulations, so no additional transfer safeguards are required for that hosting. The site is delivered through a content delivery network, which means a request may be handled by an edge location outside the UK.
Google and Vimeo are established in the United States, and the technical data described above may be transferred there. Where we transfer personal data to a country outside the UK, we ensure that the transfer complies with applicable law — through UK adequacy regulations, the UK Extension to the EU–US Data Privacy Framework, or the UK International Data Transfer Addendum to the European Commission’s standard contractual clauses, together with appropriate safeguards.
4. How long we keep your personal data
We keep your personal data no longer than necessary for the purposes for which it was collected, and in accordance with UK GDPR standards.
| Data | Retention |
|---|---|
| Enquiries that do not lead to a business relationship | 24 months from your last contact with us |
| Records relating to customers | 6 years after the end of the relationship, to meet UK tax, accounting and excise requirements |
| General correspondence | 24 months, unless it forms part of a customer record |
| Website server logs | 90 days |
Your personal data is deleted if it becomes apparent that your email address is no longer in use, if we process it on the basis of consent and you withdraw that consent, or if the legitimate interest on which we process it falls away — for example if your business ceases to exist. Where a legal duty requires us to keep records for longer, such as under excise warehousing rules, we keep them for as long as that duty requires.
5. How your personal data is protected
We hold personal data on access-controlled systems, serve this website over an encrypted connection (HTTPS), and limit access to staff who need it to do their job. Cask ownership and management records held in Vapour, our cask management platform, are accessible only to the relevant customer and to authorised staff. No system is entirely secure, but we take appropriate technical and organisational measures to protect your information.
6. Cookies
This website does not set any cookies of its own. We use no analytics cookies, no advertising cookies and no tracking pixels, and we store nothing in your browser’s local or session storage. There is therefore no cookie banner to accept or reject.
The third-party content described in section 3.1 may set cookies that are strictly necessary to deliver that content, for example to play the header film. Strictly necessary cookies do not require consent under the Privacy and Electronic Communications Regulations.
You can block or delete cookies at any time through your browser settings. Doing so may stop the header film from playing but will not otherwise affect the site.
7. Your rights
Under UK data protection law you have the right to:
- be informed about how we use your data — this policy;
- access the personal data we hold about you;
- rectify data that is inaccurate or incomplete;
- erase your data, where there is no continuing reason for us to hold it;
- restrict processing while a concern is being resolved;
- object to processing based on legitimate interests, and to direct marketing at any time;
- data portability — to receive certain data in a portable format;
- withdraw consent at any time where we rely on it, without affecting the lawfulness of processing carried out beforehand.
To exercise any of these rights, contact us using the details at the top of this policy. We will respond within one month. There is no charge, and we may ask you to confirm your identity first.
Complaints. If you are unhappy with how we have handled your data, please tell us first so that we can put it right. You also have the right to complain to the Information Commissioner’s Office at ico.org.uk/make-a-complaint, or on 0303 123 1113.
8. Changes to this policy
We review this policy periodically. If we make a material change we will update the effective date above and, where appropriate, tell you directly. This version replaces any earlier version.