Privacy Policy

Alcohol Ltd ("we", "us", or "our") is committed to protecting the privacy and security of your personal information. This policy describes how we collect and use personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 (DPA 2018), and our obligations as a UKAS-accredited organisation (ISO 9001 & ISO 27001 (UKAS)).

1. Identity of the Data Controller

For the purposes of the UK GDPR, Alcohol Ltd is the Data Controller. This means we are responsible for deciding how we hold and use personal information about you.

2. Lawful Basis for Processing

Under the UK GDPR, we must have a lawful basis for processing your data. We rely on the following bases:

• Legal Obligation: To comply with statutory requirements, such as reporting to the Office of the Registrar of Consultant Lobbyists (ORCL) or HMRC.
• Contractual Performance: To provide services to our members, assess expert network applications, progress contractor onboarding, or fulfil agreements with vendors.
• Legitimate Interests: To operate as a registered lobbying company, conduct industry research, maintain network security, and communicate with stakeholders. We balance these interests against your individual rights.
• Consent: Where explicitly given (e.g., for non-essential cookies). You have the right to withdraw consent at any time.

3. Digital Infrastructure, Logistics & Third-Party Processors

We utilise a specific suite of third-party processors to operate securely. We ensure all providers adhere to high data protection standards. Please note: Each of these third-party suppliers operates under their own independent Privacy Policies. They may have their own data retention schedules and may engage their own sub-processors to deliver their services. While we carefully select our partners, Alcohol Ltd does not have direct control over their internal data processing operations or their sub-processor chains. We encourage you to review their individual privacy notices for specific details on how they handle your data.

4. Advertising, Targeting & Retargeting

We may engage with third-party advertising networks to display advertisements on other websites based on your interests and online activities (targeting and retargeting). These networks use cookies, pixel tags, and other tracking technologies to collect data about your use of our website and other websites to provide you with targeted advertising.

We do not control these third-party technologies and their use is governed by the privacy policies of the third parties using such technologies. Major online advertising and marketing networks operating in the UK that we may engage with include:

• Google Ads / Google Marketing Platform: (Search, Display, YouTube)
• Meta Audience Network: (Facebook, Instagram, Messenger)
• LinkedIn Marketing Solutions: (B2B Targeting)
• X Ads: (formerly Twitter)
• TikTok for Business: (Video Advertising)
• Microsoft Advertising: (Bing, Yahoo, AOL)
• Amazon Advertising: (Retail Media)
• Taboola / Outbrain: (Content Recommendation & Native Advertising)
• Mailchimp (Intuit): (Email Marketing & Automation)

5. Public Figures & Research Data

As a registered lobbying company, Alcohol Ltd’s policy programme may involve research, analysis and published commentary on UK public policy. In that context we may process personal data relating to public figures (e.g., MPs, Civil Servants, Industry Leaders).

Open Government Licence (OGL): We frequently process public sector information licensed under the Open Government Licence v3.0. This includes data from sources such as gov.uk, parliament.uk, and other official registers. This data may contain the names, roles, and professional contact details of public officials. We process this information for the purpose of legitimate public interest research and analysis.

6. International Transfers

Some of our third-party processors (e.g., Google, Cloudflare, Pipedrive) are based outside the UK/EEA. Wherever data is transferred internationally, we ensure it is protected by:

• Adequacy Decisions: Transferring to countries deemed to have adequate data protection laws (e.g., the UK-US Data Bridge).
• Standard Contractual Clauses (SCCs): Using UK-approved contractual safeguards to ensure your data receives the same protection as in the UK.

7. External Links & Liability

Our website may contain links to external websites or load assets (such as fonts, scripts, or icons) from third-party domains as listed in Section 3. Alcohol Ltd is not responsible for the privacy practices, content, or security of these external domains. The inclusion of a link or the loading of an external asset does not imply endorsement. We encourage you to review the privacy policies of any external sites you visit or services you interact with.

8. Your Rights

Under the UK GDPR, you have the following rights:

• Right of Access: You may request a copy of the personal data we hold about you (Subject Access Request).
• Right to Rectification: You may ask us to correct data that is inaccurate or incomplete.
• Right to Erasure ('Right to be Forgotten'): You may ask us to delete your data. Note: This is not an absolute right. We may refuse your request if retention is necessary for legal compliance (e.g., HMRC records, ORCL declarations) or for the exercise of freedom of expression and information (see Section 5).
• Right to Restrict Processing: You may ask us to suspend the processing of your data in certain scenarios.
• Right to Object: You may object to processing based on legitimate interests or direct marketing.
• Right to Data Portability: You may request transfer of your data to you or a third party in a structured format.

9. Trademarks & Intellectual Property

All trademarks, logos, and brand names mentioned on this website are the property of their respective owners. Any use of third-party trademarks or brand names is for identification, compliance, or descriptive purposes only and does not imply endorsement, sponsorship, or affiliation with Alcohol Ltd.

10. Additional Information

Data Retention: We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Automated Decision-Making: You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making or profiling.

Children's Privacy: Our website and services are not intended for children. We do not knowingly collect data relating to children. Access to our services is restricted to professionals aged 18 and over.

You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO.