About this policy
Please read this Policy carefully. If you have any questions, get in touch with us (see Contact Us below for details).
This Policy is separate from our Cookie Policy which explains how we use cookies and related technology on our website. You can read our Cookie Policy here.
Who we are:
We’re A.G. Barr p.l.c. We’re a company registered in Scotland with the following details:
COMPANY NUMBER:
SC005653
REGISTERED OFFICE:
Westfield House, 4 Mollins Road, Cumbernauld, G68 9HD
We’re the data controller of your personal data. That means we’re responsible for your personal data under the UK’s data protection laws.
The ICO:
The Information Commissioner’s Office (the ICO for short) is the organisation responsible for overseeing the UK’s data protection laws. We refer to them throughout this Policy. You can read more about the ICO at its website click here.
How we collect your data:
We’ll collect your personal data when you use our website or provide information through our website. Some of the main ways that we may do this are when you do the following things through our website:
- Browse our website,
- Interact with our shareholder centre (if you an investor), including providing information to us in your capacity as a shareholder,
- Contact us or ask us to contact you through the ‘contact us’ section of our website, or otherwise provide us with feedback through our website, or
- Take part in a promotion, competition or survey that we run through our website.
The personal data we collect:
We limit the personal data we collect to what we need in order to achieve one or more of the purposes set out in this policy (see why we process your personal data’ below for details). Depending on how you use our website, we may collect the following personal data:
1. Personal details - this could include:
- Your name,
- Your date of birth,
- Your contact details (for example, your email, postal address, and phone number), or
- The contents (including text, images or documents) of any message you send through the ‘contact us’ section of our website.
2. Identification Information - this could include:
- Your Internet Protocol (IP) address, and details of which version of web browser you used.
Special category data is personal data that is considered to be especially sensitive under UK data protection law and so requires to be handled with particular care. We don’t need to collect any special category data from you. So, please try not to provide any special category data. We may simply delete any special category data you do provide. You can read more about special category data at the ICO’s website click here.
Why we process your personal data:
We can only process your personal data where we have a lawful basis to do so. We determine the lawful basis for processing your personal data based on the purposes for which we process it. Our purposes for processing your personal data when you use our website are as follows:
- To fulfil any prizes if you’re a winner of a promotion, prize draw or competition through our website,
- Manage or improve our website,
- Monitor the nature of, and trends in, complaints,
- Allow you to participate in interactive features of our website where you choose to do so,
- To contact you if you ask us to using the ‘contact us’ section of our website, and
- To analyse and use any information you provide if you complete a survey (for example, we might develop new products based on responses to our surveys).
In almost all cases, our lawful basis for processing your personal data will be one of the following:
Legitimate interest - this means the processing is necessary for our legitimate interests or the legitimate interests of a third party. Some examples of this type of processing include:
- To analyse or use information if you have responded to one of our surveys on our website
- To monitor how visitors use our website.
- Manage or improve our website.
- Monitor the nature of, and trends in, complaints.
- Implement changes or actions in response to your feedback.
- Retain records of how we have dealt with complaints.
- Administer our share schemes and analyse shareholding data.
Contract - this means the the processing is necessary (A) because you’ve asked us to take certain steps before entering into a contract with you, or (B) to enable us to perform a contract we’ve entered into with you. Some examples of this type of processing include:
- To enable you to take part in a prize draw, competition or promotion (in accordance with our Prize Promotion T&Cs).
- To monitor visitor compliance with our website terms of use and other policies.
Consent - this means you have given us your consent to the processing (see Consent below for details). An example would be:
- To respond to your message if you get in touch with us through the ‘contact us' section of our website.
How long we keep your personal data:
We’ll only keep your personal data for as long as is reasonably necessary to achieve the purposes for which it was collected. The retention periods we apply and take account of include:
- legal and regulatory requirements and guidance,
- limitation periods that apply in respect of taking legal action,
- our ability to defend ourselves against legal claims, and deal with complaints, good practice, and the operational requirements of our business.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely.
Examples of how long we keep your personal data:
Information you provide if you enter our prize draw, competition or promotion.
- For a period of 3 months following the closing date of the prize draw, competition or promotion (in accordance with our Prize Promotion T&Cs).
Information you provide in a message (including your contact details) to us through the ‘contact us’ section of our website.
- Except for in relation to product quality feedback, we would not normally retain the information we collect about you for more than one year. We would not normally retain product quality feedback for more than six years.
Sharing your personal data:
We may share your personal data with:
- Other companies within our group,
- Any third parties we’ve appointed to provide services for us (for example, providers of IT or marketing services, our professional advisers, or a delivery company),
- Any law enforcement agency, court, regulator, government authority or other organisation if we believe we need to in order to meet a legal or regulatory requirement, or otherwise to protect our rights or the rights of anyone else, and
- Any organisation that buys, or to which we transfer all, or substantially all, of our assets and business.
Wherever we use a third party to process your personal data on our behalf, they’ll only process it in accordance with our instructions and we’ll take steps to ensure they handle your personal data in the right way.
Storing your personal data:
We’ll store your personal data in our offices and on secure servers provided or supported by third parties acting under our instructions. Where your personal data is transferred or stored outside the UK or EEA, we’ll ensure appropriate measures are put in place to protect it. For example, we’ll only transfer your personal data outside the UK or EEA where a UK Government or European Commission approved method of validating the transfer has been put in place.
Your rights:
You have a number of legal rights when it comes to your personal data. You can read about your legal rights (including the exceptions that apply) at the ICO’s website: click here.
If you want to use any of your legal rights, email us at dataprotection@agbarr.co.uk.
We may need to request specific information from you to help us confirm your identity and ensure that your 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.
If you choose to exercise one of these rights or withdraw any consent you've previously given us (see Consent below for details), it may mean we cannot provide the services or products you've requested. We'll let you know if that's the case. In certain circumstances, even if you withdraw your consent we may still be able to process your personal information if required or permitted by law or for the purpose of exercising or defending our legal rights or meeting our legal and regulatory obligations.
Consent:
We’ll only ask for and rely on your consent to process your personal data where you’re informed and your consent can be freely given. This means that, before you give your consent, we’ll provide you with full details of the information that we require and the reason we need it.
If you choose to provide your consent, you can withdraw it any time by contacting us through the ‘contact us’ section of our website (‘General Enquiries’).
Contact us:
If you have any questions about our website generally you can contact us by sending a message through the ‘contact us’ section of our website (‘General Enquiries’)
If you have any questions about this Policy or concerns about how we handle your personal data, please email dataprotection@agbarr.co.uk.
We’d hope to be able to resolve any questions or concerns you contact us with. But, if we can’t, you have the right to complain to the ICO. We’d always welcome the opportunity to try to resolve any questions or concerns before you contact the ICO.
Changes to this policy:
We may update this Policy from time to time so we’d suggest you check it now and again. We last reviewed this Policy in March 2024.