Privacy Policy

INTRODUCTION  

 

Welcome to Mynd Drinks LLC’s privacy policy for our website (the “Privacy Policy”). Mynd Drinks LLC (the “Company”, “we”, “us,” or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after personal data when you use our website (“Website”) and tell you about your privacy rights and how the law protects you.

 

  1. PURPOSE OF THIS PRIVACY POLICY 

 

This Privacy Policy provides you information on how we collect and process your personal data (“Personal Data”) through your use of our Website, including any data you may provide when you purchase a product through the Website.


This Website is not intended for children and we do not knowingly collect data relating to children or anyone under 16 years of age.


It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy 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 Personal Data. 


  1. CONTROLLER

We determine the purpose and means of processing of personal data provided to us by visitors of the Website.  Therefore, we are a “data controller” under the General Data Protection Regulation and Data Protection Act 2018 (collectively, the “Applicable Laws”). We may use the services of other service providers in order to process your data as provided by this Privacy Policy.  These service providers are “data processors” under the Applicable Laws.  


  1. CONTACT DETAILS  

If you have any questions about this Privacy Policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: Mynd Drinks Ltd Reg No 636215

Email address: info@mynddrinks.com

Postal address: Madame, Ballinacarthy, Clonakilty, Co. Cork


You 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 so please contact us in the first instance.


  1. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES  

We regularly review and update our Privacy Policy. This version was last updated on the date first provided above. We reserve the right to update or modify this Privacy Policy at any time without prior notice.  We will provide you with notice and a copy of any updated Privacy Policy.


  1. THIRD-PARTY LINKS  

At your direction, the Website may connect to third-party websites, plug-ins, or applications. We do not control these third parties and are not responsible for their privacy policies. We encourage you to read the privacy policy of every third party you connect with.


  1. THE DATA WE COLLECT ABOUT YOU 

Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).


We may collect, use, store, and transfer different kinds of personal data or personal information which we have grouped together as follows:

 

  1. Identity Data, which includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender.
  1. Contact Data, which includes billing address, delivery address, email address, and telephone numbers.
  1. Financial Data, which includes bank account details, credit information, and payment details.
  1. Transaction Data, which includes details about payments to and from you and others.
  1. Technical Data, which includes 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.
  1. Profile Data, which includes your username and password, preferences, and feedback.
  1. Usage Data, which includes information about how you use our Website.
  2. Marketing and Communications Data includes your preferences in receiving marketing or promotional communications from us and our third parties, as well as your communication preferences. 

We also collect, use, and share aggregated data such as statistical or demographic data for any legitimate business purpose. Aggregated data could be derived from your Personal Data but is not considered personal data under Applicable Laws as this data 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 Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy policy.

 

We do not collect any special categories of Personal Data 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, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. You may not submit any Personal Data that contains special categories of personal data or information about criminal convictions and offenses.  

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the agreements, contracts, or services you are trying to access. 

  1. HOW IS YOUR PERSONAL DATA COLLECTED?  

We use different methods to collect data from and about you including through:

 

  1. Direct interactions with you. 
  1. Use of the Website, including when you purchase products on our website or request any communications from us.
  2. Automated technologies or interactions while using the Website.  This may include information on your equipment, browsing data, and any features you access on the Website.  This may be performed using cookies, web beacons, tags, and similar technologies. 
  3. Third parties or publicly available sources.
  1. Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services.
  1. Identity and Contact Data from data brokers.
  1. Identity and Contact Data from publicly available sources.
  1. HOW WE USE YOUR PERSONAL DATA  

 

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

 

  1. Where we need it to perform the services you requested through our Website.
  2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  1. Where we need to comply with a legal obligation.

In general, we do not rely on consent for a legal basis for processing your Personal Data. However, we will obtain your consent before sending marketing or promotional communications to you. You also have the right to withdraw consent to marketing at any time by contacting us using the information in “3. CONTACT DETAILS.” 

  1. DISCLOSURES OF YOUR PERSONAL DATA  

We will not transfer your Personal Data to third parties except when permitted or requested by you and in accordance with Applicable Laws, or otherwise permitted by law.  This may include the disclosure of your Personal Data to our contracted service providers so that they can provide us with our services, as required by law or regulation, and in connection any fraud or security issue.


If we sell, transfer, or merge our business, or parts of our business with another business, then any new owner may use your Personal Data in the same way as set forth in this Privacy Policy.


We require all third parties respect the security and privacy of your Personal Data and to treat it in accordance with the law. We only permit our service providers to process your Personal Data for specified purposes and in accordance with our instructions.  


  1. INTERNATIONAL TRANSFERS  

We do not transfer your personal data outside the European Economic Area (EEA).


  1. DATA SECURITY  

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorised way, or otherwise altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. 


We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


  1. DATA RETENTION  

 

We will only retain your Personal Data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.


To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.


In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) and use this anonymised data for any legitimate business purpose, in which case we may use this information indefinitely without further notice to you.


  1. LEGAL RIGHTS  

 

Data subjects under the Applicable Laws, may have the following rights:


  • Right to access – you have a right to receive a copy of the Personal Data that we hold about you and to ensure that we are lawfully processing it. 
  • Right to correct – you have a right to correct any incomplete or inaccurate data we hold about you. 
  • Right to object to processing – you have a right to object to our processing of your Personal Data where we are relying on a legitimate interest and our processing impacts your fundamental rights or freedoms. You also have a right to object to our processing your Personal Data for direct marketing purposes. 
  • Right to erasure – you have a right to request that we delete or remove Personal Data where there is no legitimate reason for us to continue to process it or you successfully object to our processing of your Personal Data.  
  • Right to limit use – you have a right to restrict the processing of your Personal Data for the following reasons 
    • You want us to establish the data’s accuracy
    • Where our use of the data is not lawful, but you do not want us to erase it 
    • Where you need us to hold the data regarding a legal claim, even if we no longer have a reason to retain the data
    • Where you have objected to our use of the data but we need to verify if we have an overriding legitimate reason to use it.  
  • Right to data portability – you have a right to request we provide you or a third party with your Personal Data in a machine-readable format.  This right only applies to information you have provided to us.

 As a data controller, we will work with you and our other data processors to ensure that data subject requests are fulfilled under the Applicable Laws. If you ask us to assist you in fulfilling a data subject request, we may need to request specific information from you before we assist you. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.  Additionally, we may have a right to refuse to honor your request if we have an overriding legitimate reason.  


You will not have to pay a fee to access your Personal Data or exercise any of your other rights.  However, we have the right to charge a reasonable fee if your request is unfounded, repetitive, or excessive.