privacy policy.

In this Privacy Policy we set out how we collect, manage and protect your personal information. We also set out the rights you have to control and manage the personal information that we hold about you.

This Privacy Policy applies to SLG Group’s business activities globally. “SLG” therefore includes any company directly or indirectly owned or controlled by us together with any parent or holding company.

Personal Data collected or shared with us from the UK and EEA is controlled by SLG Brands Limited (for UK data subjects) and jointly controlled by SLG Brands Limited and SLG Ireland (for EEA data subjects), in each case at the addresses set out at the end of this Privacy Policy. Where we act as joint controllers, we have entered into arrangements setting out our respective responsibilities for compliance with data protection obligations.

This Privacy Policy applies to the processing of Personal Data by us or on our behalf globally, subject to applicable local data protection laws including UK GDPR, EU GDPR, and relevant US state privacy laws.  If you have purchased SLG products through a third-party website, we suggest that you read the Privacy Policy published by them.

Personal Data and personal Information

Personal Data is information that does or may identify you.

You do not have to share your Personal Data with us, but if you choose not to, we may not be able to provide you with our products and services or answer any enquiry you may have.

We may collect your Personal Data from a variety of sources. These include:

Personal data you provide to us directly.

Order information.  The information you provide when you place an order (where applicable);

Shopping history. We may collect personal information about the items you viewed, added to your cart, purchased or returned.

Contact information.  When you subscribe to receive one of our newsletters or information about our products, offers and promotions.

Competitions. When you complete a survey or to enter one of our competitions.

Enquiries. When you submit an enquiry through our contact us page or contact our consumer care team.

Product & Consumer Insights: When you submit content collected through online rating and review platforms.

Social Media information.  We may collect personal information you post on any social media account operated by us or when you interact with our social media pages. This may include your social media profile, information posted on your page, and information you share when entering competitions or engaging with our content. We act as a controller for this data. Please note that social media platforms are separate controllers for data they collect, and you should review their privacy policies. When you interact with our social media pages, both we and the platform may process your data, and we have entered into arrangements with these platforms regarding our respective responsibilities as joint controllers where applicable.

Some of the Personal Data we collect may be special category data. We will only process special category data where we have your explicit consent or where another legal basis under Article 9(2) UK/EU GDPR applies, such as where processing is necessary for reasons of substantial public interest.

We also collect personal data in the following circumstances:

Business contacts, suppliers and contractors

We process Personal Data about business contacts including contacts at suppliers, customers and contractors together with individuals associated with them. We may collect certain details from publicly available sources including LinkedIn and professional networks. When collecting data from public sources, we ensure that such processing is fair and transparent, and we will inform you of the source of your data when we first communicate with you or, at the latest, within one month of obtaining your data.

Personal Data relating to our business contacts is used to support the legitimate interests of SLG, which include, but are not limited to the following. We have conducted a legitimate interest’s assessment (LIA) to ensure that our processing does not override the rights and freedoms of data subjects:

• Managing relationships;
• Business development;
• Carrying out market research;
• The provision of core services to SLG and its consumers.

Visitors to our offices

CCTV is in operation at our head office and appropriate signage is displayed to inform visitors. We use CCTV images for the legitimate purpose of promoting the security and safety of our employees/personnel, preventing and detecting crime and establishing and exercising any legal claim. CCTV footage is retained for 30 days unless required for ongoing investigations or legal proceedings. Access to CCTV footage is restricted to authorised personnel only.

We may disclose CCTV images to law enforcement bodies as requested and as permitted by data protection law.

Recruitment applicants

This section of our Privacy Policy sets out how we collect and use personal data in connection with recruitment.

The majority of Personal Data we collect as part of our recruitment process will be provided by you and may include:

• Contact details (name, address, email and mobile number);
• CV, experience, education, academic and professional qualifications;
• Diversity and equal opportunities data (which may include special category data such as information about race, ethnic origin, health, or disability). This data is processed separately from your application, on the basis of your explicit consent or for reasons of substantial public interest (compliance with equality legislation) and is used solely for monitoring purposes to ensure fair recruitment practices.

Successful applicants’ data will be processed subject to our Employee Privacy Policy.

Recruitment applicant Personal Data is processed on the following legal bases: (i) to take steps at your request prior to entering into an employment contract; (ii) for compliance with legal obligations (such as equal opportunities monitoring); and (iii) for our legitimate interests in attracting and recruiting appropriate talent, which includes:

• The need to attract and recruit appropriate talent;
• To process and manage applications for advertised roles;
• To screen and select talent by evaluating your suitability for employment at SLG, including through interviews and assessments and conducting background checks;
• To onboard successful applicants and carry out appropriate reference checks.

Information collected automatically.

We use cookies and tracking technologies (commonly referred to as “Tagging”) to obtain Personal Data when your web browser accesses our websites or advertisements and other content served on our behalf on other websites. We may collect your IP address, device ID, location data, computer and connection information such as browser type and version, time zone setting, browser plug-in types and versions, operating systems and purchase history. For detailed information about the cookies we use, their purposes, and how to manage your cookie preferences, please see our Cookie Policy. We obtain your consent before placing non-essential cookies in accordance with the Privacy and Electronic Communications Regulations (PECR).

This helps us ensure that we deliver relevant content to you and to better understand what is of genuine interest to you.

Interest-based advertising

We engage in interest-based advertising to deliver online advertising that may be more relevant to your interests, subject to your consent where required by law. We permit third party online advertising networks, social media companies and other third-party services to collect information about your use of our websites over time so that they may play or display ads on our website, on other websites, apps, or services you may use and on other devices you may use. You can manage your advertising preferences and opt-out of interest-based advertising through our cookie preference centre or through industry opt-out tools such as the Digital Advertising Alliance's opt-out page or the Network Advertising Initiative's opt-out page.

Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies, subject to your consent. We may share a common account identifier (such as an email address or user ID) or hashed data with our third-party advertising partners to help identify you across devices or serve you ads on social media sites you may use, where you have consented to such sharing. We and our third-party partners use this information to make advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. A list of our advertising partners and links to their privacy policies can be found in our Cookie Policy.

You may be able to opt-out or limit interest-based advertising by changing the settings on your mobile device.

Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block or reject cookies, not all of the tracking described here will stop.

Personal data from other sources

Additionally, we receive information about you and other visitors’ interactions with our advertising to measure whether our advertising is relevant and successful. We also collect information about you and your activities from a third party when we jointly offer services or products.

Children under 13

Our websites are intended for use by people over 13 years of age. We do not knowingly collect or solicit any information from anyone under the age of 13 through our website. If we learn that we have inadvertently collected personal information from a child under the age of 13, we will delete that information as quickly as possible. Please contact us at: datacontroller@slgbrands.com.

How we use your Personal Data

We only collect, process and disclose your Personal Data for specific and limited purposes. These include:

• To administer any order you have placed with us.
• To administer any competition that you may have entered.
• To send you Brand newsletters.
• To provide you with information about Brand products and offers that we believe will be on genuine interest to you.
• To direct you to content within our site that we think is relevant to you.
• To provide tailored product recommendations and targeted advertising based on what you have shared with us.
• To allow you to participate in any interactive features, survey or quizzes on our site.
• To share with associate brands where they offer services or products we think may be of interest to you.
• To authenticate that we are talking to the right person should we need to get in touch with you;
• To answer any enquiry, you may send to us.
• To help us to understand and react to the changing interests and needs of our consumers so that we can improve our websites and our products.

Where required, we will obtain your consent to process your Personal Data. Where you have given consent, you may withdraw your consent at any time. Please see below.

How we share your Personal Data

We do not sell your Personal Data to any third party.

We share your Personal Data internally within SLG and with selected third parties in the following circumstances:

• To courier and logistics providers who ship products you may have ordered, or to ship samples or prizes.
• With payment processors who administer secure payment options.
• With parties who host and process Personal Data on our behalf in accordance always with applicable laws and regulations.
• To partners with whom we collaborate on competitions and events.
• With other businesses within the SLG group of companies.
• As otherwise set out in this policy.

How we protect your Personal Data

We take the security of your Personal Data very seriously. We take every effort to protect your Personal Data from misuse, interference, loss, unauthorized access, modification or disclosure.

Access to your Personal Data is only permitted among our employees and agents on a need-to-know basis and subject to strict contractual confidentiality obligations when processed by third parties.

Storage of information

Personal Data will or may be transferred and stored outside of your country of residence (if not the United Kingdom).

You understand and agree that we may transfer your Personal Data to the United Kingdom.

How long we keep your personal data

We will keep your Personal Data for as long as we need it for the purpose it is being processed for. For example, where you have purchased one of our products online, we will keep your Personal Data related to the purchase, so we can perform the specific contract you have entered and after that, we will keep the Personal Data for a period which enables us to handle or respond to any complaints, queries or concerns relating to the purchase.

Your rights as a data subject – UK and EEA

This is a summary of your rights relating to the Personal Data we hold about you.

The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Data and your rights. Therefore, we’re providing you with the information in this charter.
The right to access and rectification. You have the right to access, correct or update your Personal Data at any time. We understand the importance of this and should you want to exercise your rights, please contact us as set out below.
The right to data portability. The Personal Data you have provided us with is portable. This means it can be moved, copied or transmitted electronically under certain circumstances.
The right to be forgotten. Under certain circumstances, you have the right to request that we delete your Personal Data. If you wish to delete the Personal Data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with legal requirements. If the personal data we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to delete, destroy or permanently de-identify it.
The right to restrict processing. Under certain circumstances, you have the right to object to certain types of processing, including processing for direct marketing (i.e. receiving emails from us notifying you or being contacted with varying potential opportunities).
The right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint Information Commissioners Office about how we process our Personal Data.
The right to withdraw consent. If you have given your consent to anything we do with your Personal Data, you have the right to withdraw your consent at any time by contacting the details below.
Rights related to automated decision-making. You have the right not to be subject to any decision which is based solely on automated processing in certain circumstances.

State specific disclosures – US only

This section applies to residents of states with comprehensive consumer privacy laws, including California, Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Indiana, Kentucky, Rhode Island, Maryland, and Minnesota. Additional states may enact similar laws, and we will update this policy accordingly. The specific rights and protections available to you may vary depending on your state of residence and the requirements of applicable state law.

Subject to certain exceptions and limitations under applicable state law, if you are a resident of a state with a comprehensive privacy law, you may have the following rights:

Right to Know/Access: You have the right to confirm whether we are processing your personal data and to access the specific pieces of personal data we have collected about you.

Right to Delete: You have the right to request deletion of personal data we have collected from you, subject to certain exceptions.

Right to Correct: You have the right to request correction of inaccurate personal data we maintain about you.

Right to Data Portability: You have the right to obtain a copy of your personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

Right to Opt-Out of Sales: You have the right to opt out of the "sale" of your personal data (as defined under applicable state law).

Right to Opt-Out of Sharing for Targeted Advertising: You have the right to opt out of the sharing of your personal data for targeted advertising purposes.

Right to Opt-Out of Profiling: You have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

Right to Limit Use of Sensitive Personal Information: Where applicable, you have the right to limit our use and disclosure of your sensitive personal information to only what is necessary to perform the services or provide the goods reasonably expected by an average consumer.

Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights, including by denying goods or services, charging different prices or rates, providing a different level or quality of goods or services, or suggesting that you will receive a different price or level of quality.

Categories of Personal Information Collected: We collect the following categories of personal information: identifiers (such as name, email address, postal address, phone number, online identifiers, IP address, and account names); commercial information (such as purchase history and shopping preferences); internet or network activity (such as browsing history, search history, and interactions with our websites and advertisements); geolocation data; audio, electronic, visual, or similar information (such as CCTV recordings and customer service call recordings); professional or employment-related information; education information; and inferences drawn from the above to create profiles about preferences and characteristics. We may also collect sensitive personal information as described in this Privacy Policy.

Sale or Sharing of Personal Information: We do not sell personal information for monetary consideration. However, we may share personal information with third parties for targeted advertising purposes, which may constitute a "sale" or "share" under certain state laws. You have the right to opt out of such sales or sharing. To opt out, please email datacontroller@slgbrands.com.

Exercising Your Rights: To exercise any of these rights, please contact us at datacontroller@slgbrands.com. We may need to verify your identity before processing your request. You may also designate an authorized agent to make a request on your behalf, subject to proof of authorization. We will respond to your request within the timeframes required by applicable state law, typically within 45 days of receipt. If we deny your request, you have the right to appeal that decision by contacting us at the same email address.

Universal Opt-Out Mechanisms: We recognize universal opt-out preference signals, such as the Global Privacy Control (GPC), as valid requests to opt out of the sale or sharing of your personal information for targeted advertising purposes, where required by applicable state law.

Contact information

If you wish to contact us about your Personal Data, including where you wish to withdraw consent or restrict certain processing activities, please email:  datacontroller@slgbrands.com.

Data controller principal addresses:

SLG Brands Limited (Company number: 01911296)

Studio 19 The Brewery Quarter

Unit H2

High Street

Cheltenham

GL50 3FF

We reserve the right to update this Privacy Policy from time to time.