Privacy Policy

Who are we

About this Policy

We are committed to protecting the privacy of individuals who interact with us and our products and services, in line with our obligations under applicable data protection laws in the countries in which we operate, including:

• the EU General Data Protection Regulation (2016/679);

• the UK General Data Protection Regulation; 

• the Swiss Federal Data Protection Act of 19 June 1992; 

• the California Consumer Privacy Act; and 

• the Australian Privacy Principles contained in the Australian Privacy Act 1988 (Cth),

(collectively, the Data Protection Laws).

This Privacy Policy describes how we collect, use, store, disclose and otherwise handle and process your personal information in connection with our activities.  It applies to you if you are:

• an individual representative of an alcohol brand who is a client or potential client of Tipple (Brand);

• an individual customer or potential customer of Brands who use the Tipple services in their business operations (Customer);

• a visitor to our website; or

• a contractor, supplier, potential employee or any other individual we may deal with in the course of running our business and providing our services.

We may need to amend this Privacy Policy from time to time. Please review it regularly so that you are up to date with any changes.

What type of personal information do we collect

The type of personal information we collect will generally depend on the nature of our relationship with you.

For customers of Brands who use the Tipple services, the personal information we collect may include your:

• name;

• contact details (email address, telephone number);

• postal/shipping address; and

• details of transactions processed via the Tipple services.

For individual representatives of any Brands, we may collect your name, contact details, and other information that’s relevant to your interactions with us. For contractors, suppliers, potential employees or any other individuals, we will typically collect information about you that helps us assess and is relevant to your engagement, employment or other interactions with us. For information we collect about visitors to our website, please see the ‘cookies’ section below.

Sensitive information is a subset of personal information subject to more stringent protection. It includes information about a person’s race, ethnic origin, health, political views or religious beliefs (among other things). We do not generally collect any sensitive information. However, if you choose to disclose sensitive information to us, we will assume that you consent to us collecting and handling it in accordance with this Privacy Policy, unless you tell us otherwise. Please be careful about what information you send to us.

How do we collect personal information

We might collect your personal information if:

• we provide you with our services, product or the Tipple services, or otherwise in the general course of running our business;

• you are a Customer;

• you visit our website, contact us or communicate with us in any way (including via email, phone, chat, post or social media); or

• you do business with us, apply for a role within our team, or have any other dealings with us.

1. Typically, we will collect personal information directly from you, but in some cases, it may be collected from other sources. This will often be where it is not practical or reasonable to collect it from you directly and may include information collected from:

• a Brand, if you are Customer;

• your authorised representative; or

• your recruitment agent, if you apply for a role within our team.

What happens if I do not provide my personal information

We need your personal information in order to provide you with information about our products/services. If we do not collect your personal information we will not be able to provide our products/services to you.

How do we use and disclose your personal information

We generally only use and disclose your personal information for the purposes you have shared it with us, including:

• enabling us to provide you or the Brand you are a customer of with our services and products;

• performing administrative functions to support business operations;

• enabling the functionality of our website and other online platforms owned by us, including our social media accounts; and

• allowing our contractors and advisers to provide the services that are necessary for us to manage our business and operations.

If you are a Customer, we will also share your personal information with Brands that you place an order with.

More broadly, we may share your personal information with third parties who process data on our behalf, but only where we place obligations on them in relation to the security of personal information and require them to use the personal information only as we instruct.

Such disclosures may involve your personal information being shared with recipients outside your country of residence, such as:

• our related corporate entities (including those that are located in a different jurisdiction); and

• our contractors and service providers who help us operate our business.

Based on our current list of Brands and service providers, and the location of our related corporate entities, this may include recipients in the UK, USA, EU and Australia and may change from time to time.

We will take reasonable steps to ensure that all recipients of your personal information comply with Data Protection Laws.

How we protect your information

Your data is securely password protected and securely held on a server, it is encrypted in transit and at rest. Our website server is protected and regularly scanned for malware and viruses. We do not store any credit/debit card details.

We understand the importance of maintaining the security of your personal information and use what we believe to be reasonable security measures to protect your personal information from misuse, loss unauthorised access modification or disclosure. However, as the internet is not a fully secure environment you should be mindful, and accept the risk, that any information you send us via online mechanisms may be accessed, tampered with or used in an unauthorised manner by third parties.

How long will we store your personal information

We will generally store your personal information for up to one year if you are a Brand Representative and do not proceed with our products/services or opt-in to receive marketing information from us. If you do become a client of ours, we will store your data for up to one year from the date of your latest purchase of our products/services.

For all other personal information (including that of Customers and other individuals who engage with us), we will otherwise only retain your personal information as required by applicable laws, regulations and professional standards.

What are your rights in relation to your personal information

In accordance with applicable Data Protection Laws, you have the following data protection rights:

• Right to access

  You have the right to request that we confirm whether we process personal information about you, and that we provide copies of such personal information at any time.

• Right to rectification

  You have the right to request that we correct any inaccurate or incomplete personal information we hold about you.

• Right to erasure

  Under some of the Data Protection Laws, you have the right to request that we delete your personal information from our records after you withdraw your consent to processing, or when we no longer need it for the purpose it was collected. Please note that we will not be able to delete your personal information whilst we are still providing our services to you. We will be able to delete your personal information once you cancel the service or once the service is completed.

• Right to restrict processing

  Under some of the Data Protection Laws, you have the right to request that we restrict how we use your personal information.

• Right to object

  Under some of the Data Protection Laws, you have the right to object to the collection and use of your personal information at any time.

• Right to data portability

  Under some of the Data Protection Laws, you have the right to obtain a copy of your personal information in a legible and compatible format such as Excel or Word.

• Right to withdraw consent

  You can withdraw consent that you have given to one or more specified purposes to process your personal information. This will not affect the lawfulness of any processing carried out before you withdraw your consent, but it may mean that we are no longer able to provide certain products or services to you. We will advise you if this is the case.

• The right to object to direct marketing

  You can object to our use of your personal information for direct marketing purposes.

Each marketing email we send you will also include an ‘unsubscribe’ link which you can follow to opt-out of future marketing communications.

How can I exercise my data protection rights

You can exercise all of your rights by contacting us on the contact details provided in the ‘Who are we’ section above.

We may need to request specific information from you to help us confirm your identity and your data protection rights. This helps us to ensure that personal information is not disclosed to any person who does not have the right to receive it. No fee is required to make a request, unless your request is clearly unfounded or excessive.

We will usually respond to your requests within 30 days. However, we reserve the right to verify your identity, and may, in the case of complex requests, require a further 60 days to respond.

To ensure that we’re able to fully comply with your request, it may also be forwarded to third-party parties who process personal information on our behalf.

In some circumstances, we may lawfully not be able to comply with your request and will inform you if this is the case.

How do I lodge a complaint about the use of my personal information

You can lodge a complaint with us directly by contacting us using the contact details provided in the ‘Who are we’ section above.

If your complaint is not resolved, you believe that we have not adequately addressed your concern, or to report any concerns that you may have about our privacy practices, you may contact the relevant supervisory authority in your country using the contact details below:

CountryAuthorityWebsiteAustraliaOffice of the Australian Information Commissionerhttps://www.oaic.gov.au/individuals/how-do-i-make-a-privacy-complaint
 European Union (EU) & European Economic Area (EEA) countries
Data Protection Commission (DPC)
(based in Ireland)https://forms.dataprotection.ie/contact ​
Switzerland
Federal Data Protection and Information Commissioner (FDPIC)
https://www.melani.admin.ch/melani/en/home/meldeformular.htm
lUnited Kingdom
Information Commissioner's Office
https://ico.org.uk/for-organisations/report-a-breach/
United States of America
State of California – Department of Justice – Office of the Attorney General
https://oag.ca.gov/contact/consumer-complaint-against-business-or-company

Cookies

Do we use ‘cookies’?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognise your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to:

Save your browsing analytical data of our website via Google Analytics. For more information as to how Google uses cookies in relation to Tipple’s services, please see “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/ or any other URL Google may provide from time to time).

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You can do this through your browser settings. Since each browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies. If you turn cookies off, some features will be disabled and it may impact your user experience.