Privacy
LAST UPDATED JANUARY, 17 2024
WHO WE ARE
Wyoming Whiskey, Inc. is a private limited liability company with a principal place of business at 100 S. Nelson Street – Kirby, WY 82430. Wyoming Whiskey is part of The Edrington Group Limited, a private limited company (registered in Scotland No. SC036374), and our registered office is at 100 Queen Street, Glasgow G1 3DN (Edrington). Processing of personal information relating to Wyoming Whiskey is also undertaken by other group companies of Edrington – details of these companies can be found here.
In this Privacy Policy, Wyoming Whiskey, Inc. and the relevant Edrington group companies are referred to as Wyoming Whiskey, we, us or our.
Wyoming Whiskey is the controller in relation to the processing of your personal information described in this Privacy Policy. We have a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your rights in relation to your personal information, please contact us at the details set out below.
OVERVIEW
Wyoming Whiskey is committed to protecting and respecting the privacy of its consumers’ personal information. Looking after the personal information 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 information we collect;
- How we collect personal information;
- The purposes we collect personal information for, including how we use it to make our products better and to offer better services and experiences to our consumers;
- The circumstances in which we may share it with other organisations that support our operations, including the types of organisations involved;
- Where we store your personal information;
- How long we keep personal information for; and
- The rights and choices you have with regards to your personal information.
It is important that you read this Privacy Policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your information. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT ABOUT OUR CUSTOMERS?
- Your name, age/date of birth (for age verification and due diligence purposes) email address, postal address (if you are happy to provide this), zip code, location and a visual inspection of your identification documentation may be required for due diligence checks;
- Details about payments to and from you and other details of purchases, orders made by you, including your purchase history and ballots you have submitted for the purchase of Wyoming Whiskey’s products;
- When you make a purchase or place an order with us, your payment card details (only collected on our behalf by our third-party payment provider);
- Details of any event or experience bookings you have made, including details you have provided or we may have collected from you in connection with your attendance at any events or experiences we have arranged with you (such as any accessibility or dietary requirements or other interests related to the event or experience);
- If we are required to carry out due diligence, details of any criminal convictions or sanctions, illegal activity, adverse media or whether you are a politically exposed person, which is publicly available;
- Your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the website (Technical Data);
- Information about how you use our website, products and services (Usage Data);
- Your correspondence and communications with Wyoming Whiskey;
- Personal information, which you have maybe shared via a public platform (such as on Wyoming Whiskey’s Facebook or Instagram feed);
- Your preferences in receiving marketing from us and our third parties and your communication preferences;
- Your image may be captured on CCTV when you visit our estate or at events or experiences you attend where filming or photography is taking place for promotional activities, which may be used on Wyoming Whiskey’s global owned channels and by third-party press unless you have notified us otherwise;
- Information about any experiences, gifts, special invitations or benefits made available to you;
- Your interests, preferences, feedback and survey responses; and
- Online browsing activities on Wyoming Whiskey website.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal information but is not considered personal information in law as this information will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Policy.
Other than the information listed above, we do not collect any Special Categories of Personal Information or Sensitive Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal information by law, under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (e.g. to provide you with services). In this case, we may have to cancel an experience you have with us but we will notify you if this is the case at the time.
To see the categories of personal information we collect, please click here.
HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
We collect your personal information by different methods, including:
- Direct interactions: This includes personal information you provide when:
- You subscribe to receive our newsletter;
- You attend one of our events or visit one of our sites;
- You may an online purchase or place an order online for a Wyoming Whiskey product or merchandise;
- You enter a ballot or competition related to Wyoming Whiskey or one of Wyoming Whiskey’s products;
- You interact with one of our representatives;
- You communicate with us through telephone, text messaging, or other app-based or social media direct messaging; and
- You contact us, for whatever reason.
- Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies and other similar technologies. Please see our Cookies Policy for further details.
- Third-party sources of information: We may obtain information about you from the following third-party sources:
- Where you interact with a third-party acting on our behalf (e.g. a representative of one of our distributors or joint venture partners);
- Our professional advisors (e.g. lawyers, accountants and bankers);
- Publicly available sources (e.g. how you share your experiences and passion for Wyoming Whiskey with others on social media and retailers of Wyoming Whiskey); and
- Where we carry out customer due diligence, we use a third-party due diligence screening provider who searches publicly available information.
- Technical Data: We also collect Technical Data from the following parties:
- Analytics providers (such as Google);
- Advertising networks;
- Search information providers; And
- Due diligence screening providers.
- To provide you with information, products or services that you request from us, or which we feel may interest you. This is only done when you’ve given your consent to be contacted by us, or where we are permitted to contact you in accordance with data protection law;
- To verify your identity and your age;
- Where you make a purchase above a certain value or we have or are building a relationship with you, carry out due diligence checks using our third-party due diligence system;
- For crime and fraud prevention, detection and related purposes;
- To enable Wyoming Whiskey to manage any customer service interactions with you;
- 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, when you choose to do so; and
- Where we have a legal right or duty to use or disclose your information (e.g. in relation to an investigation by a public authority or in a legal dispute).
- the pursuit of our legitimate interests (as set out below);
- the purposes of complying with our duties and exercising our rights under a contract for the sale of goods to a consumer; or
- complying with our legal and regulatory obligations.
- selling and supplying goods to our consumers;
- promoting, marketing and advertising our products, services, events, experiences and brand partnerships;
- understanding our consumers’ behavior, activities, preferences, and needs;
- improving existing products and developing new products;
- handling consumer contacts, queries, complaints, or disputes; and
- preventing, investigating, and detecting crime, fraud, or anti-social behaviour and prosecuting offenders, including assisting authorities with such investigations.
- to access your personal information (commonly referred to as a “data subject access request”) – this enables you to access the personal information we hold about you and to receive confirmation of how we are processing it;
- to have your personal information rectified if it is inaccurate or incomplete – this enables you to have any incomplete or inaccurate information we hold about you and to receive confirmation of how we are processing it;
- in certain circumstances, to have your personal information deleted or removed – this enables you to ask to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Please note however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
- in certain circumstances, to restrict the processing of your personal information – this enables you to ask us to suspend the processing of your personal information in the following scenarios:
- if you want us to establish the information’s accuracy;
- where our use of the information is unlawful but you don’t want us to erase it;
where you need us to hold the information even if we no longer required it as you need it to establish, exercise or defend legal claims; or
you have objected to our use of your information (see below) but we need to verify whether we have overriding legitimate grounds to use it, - a right of data portability, namely to obtain and reuse your personal information for your own purposes across different services. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to information which you initially provided consent for us to use or where we used the information to perform a contract with you;
- to object to the processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
not to be subject to automated decision-making (including profiling), where it produces a legal effect or a similarly significant effect on you; - the right to withdraw your consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you your consent. If you withdraw your consent, we may not be able to provide you with certain products of services. We will advise you if this is the case at the time you withdraw your consent; and
- to claim compensation for damages caused by a breach of the data protection laws.
- vendors who will process your personal information on our behalf and under our written instructions to carry out their services during the course of our business, such as IT, delivery and marketing service providers, financial institutions, customer relationship management vendors and other cloud-based solutions providers that are used by Wyoming Whiskey in the conduct of our business. We contract with such vendors to ensure that they only process your personal information by implementing the appropriate technical and organisational measures for such processing;
- vendors that process your personal information in order to assist us to better understand our consumers and how we can improve our consumer engagement, such as Ascent 360 and MyEmma;
when you order products or services from our online shop, we will share your details with our fulfilment partners (currently Stripe), who will process your orders as set out in our terms and conditions of sale; - where you make a purchase above a certain value or we have or are building a relationship with you, we will share your name and date of birth with our due diligence service provider to carry out due diligence checks;
- marketing service providers to administer services on our behalf, such as sending communications to our consumers, administering any promotions or ballots which we run;
- translation service providers to administer services on our behalf, such as translating communications received and sent in different languages;
- other agencies and fulfilment partners to administer events, competitions and brand programs that you have opted into;
- our professional advisors (e.g. lawyers, accountants and bankers);
- Wyoming Whiskey and other entities in the Edrington group of companies; and
- Wyoming Whiskey’s third-party distributors and joint venture partners.
- receive consultancy, marketing and IT services (e.g. cloud storage services, database development and management services, email/webmail services and customer relationship management services) from vendors located in non-US jurisdictions, such as the UK/EEA, South Africa and Australia; and
- provide special invitations, products, services, experiences and other benefits to you, from other Edrington group companies, or selected third party distributors or joint venture partners.
- by transferring the information to a country that the relevant authorities have deemed as providing an adequate level of data protection (an “adequacy decision”);
- by implementing an appropriate international transfer mechanism under data protection law, such as standard contractual clauses or a data transfer agreement / addendum approved for this purpose by the relevant authorities;
- by relying on a “transfer derogation” under data protection laws (e.g. where the transfer is based on your consent); or
- where we are otherwise permitted to make the transfer under data protection laws.
- Account management;
- Prevention, detection, investigation and prosecution of fraud;
- Complaint handling and resolution;
- Measuring the quality of the call;
- Internal training on call handling.
- Access: you have the right to request access to the personal information that we collect, use, and disclose about you;
- Deletion: you have the right to request that we delete your personal information, subject to some exceptions under applicable law;
- Correction: you can request that we correct any inaccuracies in your personal information; and
- Portability: you can request a copy of your personal information in a portable format.
ONLINE ANALYTICS
We use various types of online analytics, including Google Analytics, a web analytics service provided by Google, Inc. (Google), on our website. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the website, compile reports on the related activities, and provide other services related to website and app activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website or app. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google click here.
SURVEYS
From time to time, and subject to your consent where required by applicable local law, we may provide you with the opportunity to participate in surveys, some of which might be sponsored or conducted by a third party. Participation in these surveys is completely voluntary. If you choose to participate, we will request certain personal information from you. If there is a third-party sponsor involved in the survey, we may provide certain personal information to the third-party sponsor. Please make sure to review the sponsor’s privacy policy and be aware that any surveys offered by us may be governed by specific rules and terms and conditions that are separate from and in addition to this Privacy Policy. By participating in any such surveys you will become subject to those rules, including but not limited to receiving emails containing survey communications.
HOW DO WE USE YOUR PERSONAL INFORMATION?
Wyoming Whiskey (and trusted partners acting on our behalf) use your personal information:
To send you personalised communications based on your preferences, and use of Wyoming Whiskey’s products;
We may also combine your personal information collected through various sources, including information collected through our website and services, and develop a profile that will be used for the purposes above.
WHAT IS OUR LEGAL REASON FOR HOLDING YOUR PERSONAL INFORMATION?
Data protection laws require us to state our legal reason for processing your personal information.
Where we have requested your consent, we will rely on this consent to send you marketing communications about Wyoming Whiskey. We may also send you marketing communications about Wyoming Whiskey where you have requested information from us and have not opted out of receiving such communications.
You can withdraw your consent to receive these communications at any time by using the unsubscribe button included in the communications we send you, or by contacting us at [email protected]. Where you opt out of receiving marketing communications, this will not remove any personal information that we need to retain following your attendance at an event or experience.
Wyoming Whiskey also collects and uses your personal information because it is necessary for:
OUR LEGITIMATE INTERESTS
The normal legal basis for processing consumer information, is that it is necessary for the legitimate interests of Wyoming Whiskey, including:
protecting consumers, employees and other individuals and maintaining their safety, health and welfare;
Where we process your personal information in pursuit of our legitimate interests, you have the right to object to us using your personal information for the above purposes. If you wish to object to any of the above processing, please contact us at [email protected]. If we agree and comply with your objection, this may affect our ability to undertake the tasks above for your benefit.
CHANGE OF PURPOSE
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you require any further information on how the processing for the new purpose is compatible with the original purpose, please contact us using the details below.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use please see our Cookies Policy.
DO NOT TRACK
Some devices and browsers support a “Do Not Track” (or DNT) feature, a privacy preference that you can set in certain browsers, which is intended to be a signal to websites and services that you do not wish to be tracked across different websites or online services you visit. Please note that we cannot control how third-party websites or online services you visit through our website respond to Do Not Track signals. Check the privacy policies of those third parties for information on their privacy practices.
Our website does not currently change the way it operates upon detection of a Do Not Track or similar signal.
WHAT ARE YOUR RIGHTS?
You have a number of rights under applicable data protection laws in relation to the way we process your personal information, namely:
If you wish to exercise any of these rights, please contact [email protected].
WHO DO WE SHARE YOUR PERSONAL INFORMATION 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 information. These include:
our subsidiary companies who are involved in customer services and marketing activities related to
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 of sale; (ii) comply with any legal claims raised against Wyoming Whiskey; (iii) protect the rights, property, or safety of Wyoming Whiskey; (iv) protect the rights, property or safety of the public; or (v) assist with investigations to prevent and detect crime, fraud or anti-social behavior.
In accordance with applicable law, we may also transfer or assign your personal information to third parties as a result of, or in connection with, a sale, merger, consolidation, acquisition, change in control, bankruptcy, reorganisation, liquidation 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, 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.
To see the categories of personal information we share, please click here.
WHERE WE STORE YOUR PERSONAL INFORMATION
We may transfer your personal information outside the United States. This is primarily to allow us to:
Where your personal information is transferred outside of the US, we will ensure your personal information is afforded an adequate level of data protection (as required by data protection laws), including:
Please contact us if you would like further information on the specific mechanism used by us when transferring your personal information out of the US.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
We will not retain your personal information for longer than necessary for the purposes set out in this privacy policy, including for the purposes of maintaining our relationship with you as well as satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
Different retention periods will apply to different types of information. To determine the appropriate retention period for personal information, we consider any ongoing relationship we have with you, the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purpose for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting and other requirements.
When we no longer need to use your personal information, we will remove it from our systems and records, and/or take steps to anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations we are subject to).
In certain circumstances, you can ask us to delete or remove your information (see the section entitled “What rights do you have?” above for further information on your rights).
We may use your personal information collected by recording phone calls and retaining a transcript of our live chats with you through our website (including where these are handled by our third-party technical services provider) for the following purposes:
We have a legitimate interest in retaining calls and live chats in order to offer our consumers a good service and to protect our business. If you object to the call recording, you may choose to end the call when you are informed that calls may be recorded. If you use our live chat function to get in touch with us, you will be informed that we will keep a record of the discussion at the start of the chat and you will be able to end the chat at any time. You will have the option to contact us through alternative means. All calls and live chat records will be retained for a period of one year.
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
Wyoming Whiskey is committed to keeping your personal information safe and secure. To prevent unauthorised access, maintain data accuracy and ensure the correct usage of personal information, we monitor and adjust our physical, electronic and managerial procedures to safeguard and secure the personal information we collect online.
YOUR CALIFORNIA PRIVACY RIGHTS
Please be aware that we do not sell or rent personal information.
If you are a California resident, you have the following rights regarding your personal information:
We do not share personal information with third parties for their own direct marketing purposes without your consent. California residents under 18 years old, in certain circumstances, may request and obtain removal of personal information or content that you have posted on our website. Please be mindful that this would not ensure complete removal of the content posted by you on our services. To make any request pursuant to California privacy law, please contact us at [email protected] or insert toll-free number. We will not discriminate or retaliated against you for exercising such rights under California privacy law.
THIRD PARTY WEBSITES AND APPS
Our website and services may contain links to other websites or apps operated by third parties. Please be advised that the practices described in this privacy policy do not apply to information gathered through these third-party websites and apps. We have no control over, and are not responsible for, the actions and privacy policies of third-parties and other websites and apps.
QUESTIONS
If you have any questions or concerns about the way in which your personal information is processed, please contact us at [email protected].
CHANGES
Wyoming Whiskey may update this Privacy Policy from time to time as our privacy practices change, or as required by applicable legal or regulatory requirements. Where it is practicable, we will notify you of any significant changes. However, the last update date is given above and Wyoming Whiskey encourages you to review this Privacy Policy periodically so you remain informed of how we use your personal information.
CALIFORNIA PRIVACY LAW APPENDIX
This appendix provides additional information to residents of California and supplements the information provided in the privacy policy above.
To learn more about the categories of personal information we collect, how we collect it, why it is collected, with whom we share the information, and how long we retain it, please see the chart below.
| Category | Details |
| Identifiers |
What we collect: Name, mailing address, email address, phone number, and other contact information. How we collect it: Collected online or offline when you provide it to us, through your use of our website, services, or from third parties. Why we collect it: We collect this information for the purposes listed in the What Is Our Legal Reason For Holding Your Personal Information section above. With whom we share it: Shared with our affiliates, partners, vendors, and service providers as described in the Who Do We Share Your Personal Information With section above. How long we retain it: We retain information as described in the How Long Do We Keep Your Personal Information section above. |
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) |
What we collect: Name, mailing address, email address, phone number, and other contact information. How we collect it: Collected online or offline when you provide it to us, through your use of our website, services, or from third parties. Why we collect it: We collect this information for the purposes listed in the What Is Our Legal Reason For Holding Your Personal Information section above. With whom we share it: Shared with our affiliates, partners, vendors, and service providers as described in the Who Do We Share Your Personal Information With section above. How long we retain it: We retain information as described in the How Long Do We Keep Your Personal Information section above. |
| Protected classification characteristics under California or federal law |
What we collect: Age. How we collect it: Collected online or offline when you provide it to us, through your use of our website, services, or from third parties. Why we collect it: We collect this information for the purposes listed in the What Is Our Legal Reason For Holding Your Personal Information section above. With whom we share it: Shared with our affiliates, partners, vendors, and service providers as described in the Who Do We Share Your Personal Information With section above. How long we retain it: We retain information as described in the How Long Do We Keep Your Personal Information section above. |
| Commercial information |
What we collect: Payment information and transactional information such as the products or services purchased. How we collect it: Collected online or offline when you provide it to us, through your use of our website, services, or from third parties. Why we collect it: We collect this information for the purposes listed in the What Is Our Legal Reason For Holding Your Personal Information section above. With whom we share it: Shared with our affiliates, partners, vendors, and service providers as described in the Who Do We Share Your Personal Information With section above. How long we retain it: We retain information as described in the How Long Do We Keep Your Personal Information section above. |
| Biometric information | Not collected. |
| Internet or other similar network activity |
What we collect: IP address, browser type and version, browser plug-in types and versions, operating system and platform, device type and device identifiers. How we collect it: Collected online or offline when you provide it to us, through your use of our website, services, or from third parties. Why we collect it: We collect this information for the purposes listed in the What Is Our Legal Reason For Holding Your Personal Information section above. With whom we share it: Shared with our affiliates, partners, vendors, and service providers as described in the Who Do We Share Your Personal Information With section above. How long we retain it: We retain information as described in the How Long Do We Keep Your Personal Information section above. |
| Geolocation data | Not collected. |
| Sensory data | Not collected. |
| Professional or employment-related information | Not collected. |
| Non-public education information | Not collected. |
| Inferences drawn from other personal information |
What we collect: Information generated from your use of our website and your interactions with us reflecting your preferences. How we collect it: Collected online when you provide it to us, through your use of our website, services, or from third parties. Why we collect it: We collect this information for the purposes listed in the What Is Our Legal Reason For Holding Your Personal Information section above. With whom we share it: Shared with our affiliates, partners, vendors, and service providers as described in the Who Do We Share Your Personal Information With section above. How long we retain it: We retain information as described in the How Long Do We Keep Your Personal Information section above. |
| Sensitive personal information | Not collected. |
