CMBC privacy policy

We, at Carlsberg Marston’s Brewing Company, care about and respect your privacy. We’d like to explain what personal information we have about you and how we use it, as well as letting you know about our practices with regard to your privacy so that you know exactly what is happening with your data and what we are doing to keep it safe.

We are the Carlsberg Marston’s Brewing Company. You may know us as Carlsberg Marston’s Brewing Company Limited (company reg. no. 12577732), Carlsberg UK Limited (company reg. no. 00078439), Carlsberg Supply Company UK Limited (company reg. no. 08626420), Marston's Beer Company Limited (company reg. no. FC037407) or one of our other trading divisions or group companies from time to time (together the “Carlsberg Marston’s Brewing Company Group”). Where we refer to "we", "our" or "us" in this policy, we mean Carlsberg Marston’s Brewing Company Limited, Carlsberg UK Limited, Carlsberg Supply Company UK Limited, Marston's Beer Company Limited and / or any company or division in our group depending on the specific situation / activity carried out. See “Why do we need your personal data” below for further details.

If you have any questions about this policy or your privacy, you can find us or get in touch at Carlsberg Marston’s Brewing Company Limited, Marston's House, Brewery Road, Wolverhampton, WV1 4JT or by emailing [email protected].

We are registered in England & Wales with Company No. 12577732.

The Law

Data Protection within the UK is currently governed by the General Data Protection Regulation, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (“Data Protection Laws”) and we conduct our activities in line with these. In relation to this website we are the Data Controller and Bonfire Creative Intelligence Ltd (bonfireci.com) are the data processor as the host and administrator for this site. We ask you read our website terms of use in conjunction with this policy. This privacy policy supplements other notices and privacy policies and is not intended to override them. It should be read in conjunction with other privacy policies that we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

A Glossary is also included at the end of this document to explain some of the terms we use in this privacy policy.

What information do we collect?

We collect a wide variety of information and the types we collect from you will vary dependent on whether you’re an individual customer, another business, ordering a product or a service or participating in a promotion or competition (amongst other things). Here are the types of information we may collect from time to time along with sources which tell you where we may receive the data from.

Information we may gain directly from you:

• Your name, age & contact details (including phone numbers, emails and addresses);
• Your opinions, feedback, comments or views;
• Your banking details or payment card information;
• Your business details (which may include contact details, job titles and other information you would expect to share when engaging in business with us);
• Your login details (including username and password);
• Your image within photography;
• Special Request data which may include special category data such as Disability & accessibility requirements, dietary requirements or other information that may be deemed sensitive; and
• Your employment history and application data (including CV’s).

Information we may collect about you:

• Internet protocol address (IP address);
• Browser type and version;
• Time zone setting;
• Browser plug-in types and versions;
• Operating system and platform;
• The URL Clickstream to, through and from our site (including the date and time);
• Products you viewed or searched for;
• Page response times;
• Download errors;
• Length of visits to certain pages;
• Page interaction (scrolling, clicks, mouse-overs etc);
• Methods used to browse away from the page; and
• Phone numbers used to call our customer services team.

Information we may receive from other external third parties:

• Names, addresses, contact details/business details if necessary through the course of business;
• Financial information, such as the results of a credit check; and
• Advertising preferences & analytical information (in particular from social media websites, pixels, clickstream data, cookies and Google Analytics).

We strive to collect the minimum amount of data necessary in order to perform the request for a product or service being made and so in some cases, failure to enter the requested information may result in us not being able to provide the product or service.

The Carlsberg Marston’s Brewing Company Group was formed on 31 October 2020 and personal data collected before that date by us and Marston’s PLC was transferred into this Group. We may process personal data provided prior to 31 October 2020 to Marston’s PLC (and any of its group companies) or to any company that forms part of the Carlsberg Marston’s Brewing Company Group as a result of such transfer in connection with each activity mentioned under the heading “Why do we need your personal data?” below (where relevant) but only where the law permits us to do so. Our legal bases for such transfer are legitimate interests (in order to allow us to develop our business) and legal obligation.

When do we collect your information

We may collect your information in a number of ways. Here is an overview of the circumstances in which data is gathered.

• When you use our websites or a form is filled out on our websites (including from analytics);
• Correspondence via phone, email or otherwise with one of our team members;
• When you register to use our site or services;
• When you subscribe to our products or services;
• When you place an order with us;
• If you have an accident at one of our sites;
• When you or an analytics provider provide us with your marketing preferences (including where we use the services of social media platforms to determine your potential interest in a product or service);
• When you sign a contract or agreement with us;
• To participate in a discussion board or other social media function on our sites;
• To enter a competition, promotion or survey that we are running;
• When you report a problem with one of our websites;
• When you apply for a job with us;
• When we require a credit check in conjunction with your application; and
• When you visit our offices.

Why do we need your personal data?

There are a number of reasons we may request or collect your information. A summary of these can be found below:

• For the administration and support of a contract such as an order of goods, a trade agreement, an operations agreement or a service you’ve requested;
• For the administration of a job application;
• To conduct a credit check in line with your application (if required);
• To request ongoing credit reference services to ensure your ongoing suitability for credit terms (if required);
• To respond to an enquiry, feedback or complaint you may have sent to us;
• To improve the products or services we offer;
• To administer our websites including troubleshooting, data analysis, testing, research, statistical and survey purposes. Also to keep it safe, secure and accessible;
• To administer a promotion, offer or competition that you may participate in;
• To notify you about any changes to our services; and
• For the communication of marketing materials (including e-mail, advertisements on social media, and in certain circumstances, phone calls);
• For absolute clarity we do not intend our marketing materials to be received by anybody under the age of 18 due to the nature of our business. Your personal data may be used to determine whether you meet this criteria.

Marketing

We may use your details to make an informed decision on products or services we think you may be interested in. This is marketing and we will always ask for your consent before we do this where we intend to send you materials via e-mail or text. We will also always ask your consent before we pass your details to any external third parties so that they can market to you too.

We understand that you may change your mind about receiving these types of emails or texts so you can ask us to stop at any time. Just follow the unsubscribe link on any marketing communication we send to you and we will promptly remove you from our database. This will only apply to data you have supplied in accordance with signing up to marketing services. Data provided for other purposes will remain in our systems in line with this policy.

Profiling and targeted marketing

As a modern business, we utilise services that use technology in order to supply you with the best and most suitable marketing communications we can offer. This includes advertisements on third party platforms such as Facebook. This is done by using a built in Facebook Business feature called ‘Custom Audiences’. We share your email address with our third party who then utilise the feature, looking at demographics and other traits like interests taken from information that you have uploaded onto Facebook in order to bring our advertisements to the people who might be interested in them most.

We don’t believe that it will have a significant negative impact on you and in fact think you’d appreciate our more suitable ads, but, you can let us know if you don’t want to have your data used in this way and we’d be happy to make sure that we stop. You are our priority! Contact us via any of the details at the top of the page and we’ll make the required changes to our records.

More information can be found on the custom audiences feature here. You can change your Facebook settings if you would like to, by visiting the quick help menu where there are a number of privacy options that you can change to meet your preferences.

To visit the privacy options for your Facebook account, click on the question mark icon on your home page and click privacy shortcuts, which will take you to a privacy options management page.

Other social media services will have similar functions which should be easy to find on their webpages.

To opt-out of any online targeted marketing specifically please contact us via [email protected].

Promotions & competitions – Publication of winners

From time to time we may offer interactive promotions and competitions via social media platforms. When you choose to take part in these activities you should be aware that on some occasions the promoting party may choose to announce the winner of the event by ‘tagging’ them in an announcement on the relevant social media platform. We have certain obligations when running competitions or similar events including publishing details about the winner however this does not extend to identifying a particular individual via this method. If you are uncomfortable with this practice you have some options in order to conserve your right to privacy.

Use the social media platforms' settings panel

We have used Facebook as an example here but all social media platforms should have similar functions.

Log into your account and navigate to the settings menu. Then click Timeline and Tagging in the left hand options menu.

Use the options to decide who you want to be able to tag you on your timeline and on the news feed, and even activate a review system to approve tags before they are posted publicly.

Contact Us

You have the right to contact us to ask us not to publish your details in this way (or any other way). This is known as the right to object. Whilst we may not publicise your details to the general public, we may still need to inform the Advertising Standards Authority to confirm that our promotion or competition was genuine. Please contact us at [email protected].com for more information or to raise an objection. 

On what basis do we process your data?

The lawful basis for processing varies depending on the processing activity.

We rely on a combination of legitimate interest, consent, legal obligation and contract in order to process your personal data (a definition of each is provided within the glossary). Below we have defined the ways in which we may process your personal data and what the legal basis is for doing so, whilst outlining our legitimate interests where necessary. We may process your personal data based on multiple lawful basis where on occasion, circumstances may dictate this is necessary. Please contact us if you require further details on any of the points below where multiple basis have been specified. Generally we consider:

Who might receive a copy of your personal data?

Throughout the course of activities it may be necessary for an external third party to receive a copy of your personal data. All of our external third parties are thoroughly vetted and are subject to contractual requirements and assessment of security standards in order to become an approved supplier. They are only permitted to process your personal data for the specified purpose and not for their own benefit.

We are part of a global group of companies. In that connection we may share your personal data with the following group companies (known as the “CMBC Group Entities”):

1. Marston’s PLC (the ultimate parent company of our shareholder, Marston’s Trading Limited);
2. our shareholder Carlsberg UK Holdings Limited and any entity which replaces it as a shareholder (in whole or in part) from time to time (“Carlsberg Shareholder”);
3. any member of the Carlsberg Shareholder’s group, which means its other subsidiaries, its shareholders, the ultimate holding companies of its shareholders and their subsidiaries (“Carlsberg Group Entities”); and
4. any of our subsidiaries,

for the purposes stated in this policy. Each of those companies may also process and use your personal data for the purposes stated in this policy, but they do it independently on their own behalf only.

Your data may be shared with external third parties which may include any of those set out in the glossary, as relative to your circumstances.

Your data may be shared with any member of our group or trading divisions but external third parties may include any of those set out in the glossary, as relative to your circumstances.

• Business Partners, suppliers and sub-contractors where they are performing a contract we have entered into with them;
• Advertising networks and support teams of this function to select and serve the relevant ads to you (particularly where we may share some of your details with a third party to enable delivery of more suitable advertisements to your social media homepage);
• Analytics and search engine providers that assist us in optimising our site;
• Website & website services hosts including payment processors;
• Credit reference agencies;
• Agencies that assist in sending our marketing communications; and
• Authorities or organisations where there is a legal obligation for us to do so or for the prevention of fraud; and
• We may share your email address with our third party who then utilise the feature, looking at demographics and other traits like interests taken from information that you have uploaded onto Facebook in order to bring our advertisements to the people who might be interested in them most.

Where is your data stored?

Your data may be transferred to and stored at a destination outside the European Economic Area (“EEA”) where we use external third parties. It may also be processed by staff operating outside of the EEA who work for us or for one of our suppliers. These staff may be engaged in the fulfillment of your order, the processing of your payment details and the provision of support services (amongst other things).

We will only transfer personal data to countries where the GDPR applies or that have been deemed adequate by the ICO. Alternatively a transfer may occur where we have adequate contracts approved by the European Commission which protects personal data in the same way that it is protected in Europe. We may also transfer to external third parties where they subscribe to the EU-US Privacy Shield. We make a thorough check and have strict requirements (in line with the law) in order to approve this type of processing in consideration of our suppliers.

Any information provided to us is stored in our secure servers and any payment transaction data is encrypted using SSL technology. Where you have a password which enables access to certain parts of the website you are responsible for keeping the password confidential. Please do not share your password with anyone.

Unfortunately the transfer of information over the internet is not completely secure. We do our best to protect your personal data but we cannot guarantee the security of your data when it is transmitted to our site. Once we have received your information we will ensure that we strictly monitor procedures and security measures to keep it safe.

Our site may contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies which we do not accept any responsibility or liability for. Please check these policies before you submit any personal data to these websites.

If you would like specific information about where your data is stored in relation to a particular usage of your data, please contact us.

How long will we keep your data?

We will only hold on to your personal data for as long as we need it to fulfill the purposes we collected it for. This includes considering the amount, nature and sensitivity of the data and the risk of any potential harm mishandling of this data may cause. We also consider if and when we can achieve the purposes we collected it for or if we can complete this without the personal data. We also consider legal, tax and reporting requirements that impose limitations on how long we hold the data for. It may be kept for a longer period of time if we reasonably predict there will be an element of legal action within our relationship with you.

Please contact us if you would like to find out how long and why we keep your personal data.

• Specifically in relation to targeted marketing, there is no further data held by us as a result of completing this type of project. Our goal is to reach our current and prospective customers with information and offers that may be suitable for them - not to gather as much information as we can about them. We may receive anonymous statistics and trend identifications as a result of the project however. Our third party that assist us in these services delete any data within 2 weeks of the initial commencement of the project.

What are your rights?

Upon occasion, you may be entitled to certain rights under data protection law. These are laid out below but a full breakdown of their meaning is available in the glossary. You can enact any of these rights by contacting us via [email protected].

• Right of Access to your personal data
• Right to rectification of your personal data
• Right to erasure of your personal data
• Right to object to processing of your personal data
• Right to restrict processing of your personal data
• Right to data portability

There is no fee applicable to any of the above, however we may charge a fee or refuse your request if it is unfounded, excessive or repetitive.

We aim to respond to valid requests within one calendar month, however in certain circumstances it could take us longer. This may be because you have submitted a number of requests or your request is particularly complex. We will keep you updated with your request along the way if this is the case.

We may need to verify your identity and ensure your rights to the personal data we hold on occasion. We will always make sure our request is reasonable and in line with the information or right you are requesting. This ensures we are not sending the data to somebody who is not entitled to see it or acting upon a rights request that has not been legitimately made by the person who is entitled to it.

Changes

We regularly review our policy so that we can ensure it is accurate and informative. Any changes will be made on this page. Please check back frequently for updates.

It is also important that any personal data we hold about you is up to date and accurate. Please update us if any of the details we hold about you change so that we can ensure our records reflect these changes.

Contact

Questions, comments and requests regarding this policy are welcomed and should be directed to any of the contact details at the top of this page.

Alternatively, should you feel necessary, you can contact the Information Commissioner’s Office on 0303 123 1113 or online here.

Cookie policy

When you visit our websites we use cookies. Cookies allow us to identify the computer or device you're using to access our websites - but we can't identify you personally.

When you visit our websites we use cookies. Cookies allow us to identify the computer or device you're using to access our websites - but we can't identify you personally.

You can set up your web browser to refuse cookies, but this website will then fail to operate correctly.

Types of cookies we use

Here are the types of cookies our websites use and some more details about what they're used for: