We are Bottle Exchange Ltd., a company incorporated in Scotland with registered number 686498 and having our registered office address at 272 Bath Street, Glasgpw, Scotland, G2 4JR. We are a controller for the purposes of the Data Protection Act 2018.
If you have any questions about this privacy notice, including any
requests to exercise your legal rights, please contact us using the
details set out below.
• By post: 38 Murkle View, Thurso, Caithness, Scotland, KW14 8DG
• By phone: +44714529684
• By email: info@bottleexchange.net
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.
We are committed to protecting your personal data and your privacy. This
privacy notice aims to give you information on how we collect and process
your personal data through your use of our websites https://bottleexchange.net or
any other website registered in our name ("Website"), including any
personal data that you may provide through our Website, where we have a
contract in place with you (please see our
terms and conditions
), and through your other communications with us.
It is important that you read this privacy notice when we are collecting
or processing personal data about you so that you are fully aware of how
and why we are using your personal data.
It is important that the personal data we hold about you is accurate and
current. Please keep us informed if your personal data changes during your
relationship with us.
This version of our privacy notice was last updated on 28th July 2021.
This privacy notice applies to:
• all individuals who visit our Website;
• all individuals who are or were our "individual users" where you are an
individual with a private residence, a sole trader, partner in a
traditional or limited partnership or member of an unincorporated
association;
• all individuals who are current or former employees, workers, directors,
officers, job applicants or otherwise related personnel of our corporate
users (being a corporate entity such as a limited company or limited
liability partnership) or individual user ("customer-related users");
and
• all individuals who are our "business contacts" where you or your
organisation supply goods or services to us, provide professional
services, have expressed an interest in us or have any other business
relationship with us (including where your organisation is a public
authority, an industry body or regulatory authority or similar).
This privacy notice does not apply to employees, workers or other staff of
Bottle Exchange Ltd..
Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and we are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.
Cookies are small text files that are placed on your computer by websites
that you visit. They are widely used in order to make websites work, or
work more efficiently, as well as to provide information to the owners of
the site.
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 the Website may become
inaccessible or not function properly.
Please note we use login, Google Analytics and Stripe cookies.
Our Website is not intended for children and we do not knowingly collect any personal data relating to children.
"Personal data", or personal information, means any information about an
individual from which that person can be identified. It does not include
data where an individual's identity has been removed ("anonymous data").
We do not collect or process special categories of personal data.
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 data but is not considered personal data in law as this data
will not directly or indirectly reveal your identity. For example, we may
aggregate your 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 notice.
The table set out in SCHEDULE 1 summarises the personal data we collect
and process, how we use it ("our processing purposes") and why we use it
("the lawful bases of processing").
We use different methods to collect personal data from and about you
including through:
• Direct interactions. You may give us your identity, contact, financial,
transactional or similar personal data when you correspond with us by
post, phone, e-mail or otherwise, including when you complete a form or
register for an account on our Website, otherwise contact us via our
Website or visit our offices.
● Direct interactions with business contacts, individual users and
customer-related users. You may give us your identity, contact, financial,
transactional and other personal data when you correspond with us,
including when:
• you or your organisation enter into a contract with us; or
• you or your organisation provide services or products to us or your or
your organisation receives services or products from us; or
• you provide us with your business card.
• Automated technologies or interactions. As you interact with our
Website, we may automatically collect technical data about your equipment,
browsing actions and patterns. We collect this personal data by using
cookies, and other similar technologies.
• Third parties or publicly available sources. We may receive personal
data about you from various third parties and public sources as set out
below: • where you are a business contact, your organisation or business
may provide us with your identity and contact data;
• where you are a customer-related user, your organisation or business may
provide us with your identity and contact data;
• we may obtain identity and contact data from publicly available sources
such as social media (such as LinkedIn, Facebook, Instagram or Twitter),
Companies House or other organisations’ websites;
• we may obtain contact, financial and transaction data from providers of
payment and credit card services; or
• we may obtain technical data (relating to the use of our Website) from
analytics providers or search information providers.
Where we need to collect personal data by law or under the terms of a contract we have with you (or are trying to enter into with you) and you fail to provide that data when requested, we may not be able to perform the contract. In this case, we may have to cancel a contract (but we will notify you if this is the case at the time).
If you represent another business, we may provide you with direct
marketing communications where we feel that this may be relevant to your
business (provided that you have not opted out of such communications).
When we use your personal data for such purposes, we do so on the basis
that it is in our legitimate interests to pursue direct marketing,
provided that it constitutes fair processing of your personal data to do
so.
If you are an individual user, we will only provide you with direct
marketing communications where you have consented to receive such
communication or you have contacted us directly to request specific
information about our services. You can subscribe to such marketing
communications, and you can adjust your marketing preferences at any time
by contacting us at info@bottleexchange.net.
You can also opt-out or unsubscribe from all or some of these marketing
communications at any time by contacting us at info@bottleexchange.net.
Where you opt out of receiving these marketing communications, this
opt-out will not apply to personal data provided to us for any other
purpose.
There may be circumstances in which we may also need to share your
personal data with certain third parties (strictly on a confidential,
business need-to-know basis). The third parties to which we may transfer
your personal data include:
• Your business or organisation, for the purpose of providing our services
or products to your business or organisation, or receiving products or
services from your business or organisation.
• Service providers including processors who provide IT and system
administration services.
• Couriers who ship any goods you purchase using our Website.
• Professional advisers including lawyers, bankers, accountants, auditors
and insurers who provide consultancy, banking, legal, insurance and
accounting services.
• Any relevant accreditation body or trade association.
• Any relevant regulatory authority or law enforcement agency, including
HM Revenue & Customs, courts or tribunals who require reporting of
processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer, or merge parts of
our business or our assets. Alternatively, we may seek to acquire other
businesses or merge with them. If a change happens to our business, then
the new owners may use your personal data in the same way as set out in
this privacy notice.
We require all third parties to respect the security of your personal data
and to treat it in accordance with the law. We do not allow our
third-party processor service providers to use your personal data for
their own purposes and only permit them to process your personal data for
specified purposes and in accordance with our instructions.
Any sharing of your personal data will only take place either where we are
legally obliged to do so, where it is necessary for the performance of a
contract with you or where it is in our legitimate interests to do so,
including as follows:
• to maintain network and information security;
• to provide services or products to our corporate customers;
• to develop and improve our services or products in order to remain
competitive;
• to establish, protect and defend our legal rights; or
• to pursue our commercial objectives where this does not override your
rights and freedoms as a data subject.
Your personal data is protected by legal rights, which include your rights
to:
• Request access to your personal data (commonly known as a "data subject
access request"). This enables you to receive a copy of the personal data
we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This
enables you to have any incomplete or inaccurate data we hold about you
corrected, though we may need to verify the accuracy of the new data you
provide to us.
• Request erasure of your personal data. This enables you to ask us to
delete or remove personal data where there is no good reason for us
continuing to process it. 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, following your request.
• Object to processing of your personal data 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 data for direct marketing purposes.
• Request restriction of processing of your personal data. This enables
you to ask us to suspend the processing of your personal data in the
following scenarios: if you want us to establish the data's accuracy;
where our use of the data is unlawful but you do not want us to erase it;
where you need us to hold the data even if we no longer require it as you
need it to establish, exercise or defend legal claims; or you have
objected to our use of your data but we need to verify whether we have
overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party
(data portability). We will provide to you, or a third party you have
chosen, your personal data in a structured, commonly used,
machine-readable format. Note that this right only applies to automated
information which you initially provided consent for us to use or where we
used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process
your personal data. However, this will not affect the lawfulness of any
processing carried out before you withdraw your consent. If you withdraw
your consent, we may not be able to provide certain services to you. We
will advise you if this is the case at the time you withdraw your
consent.
If you wish to exercise any of these rights, please contact us at
info@bottleexchange.net.
We may need to request specific information from you to help us confirm
your identity and ensure your right to access your personal data (or to
exercise any of your other rights). 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.
You will not have to pay a fee to access your personal data (or to
exercise any of the other rights). However, we may charge a reasonable fee
if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these
circumstances.
We try to respond to all legitimate requests within one month.
Occasionally it may take us longer than a month if your request is
particularly complex or you have made a number of requests. In this case,
we will notify you and keep you updated.
You also have the right to complain to the Information Commissioner's
Office, which regulates the processing of personal data, about how we are
processing your personal data.
Any visitor to our Website
Technical data
(including internet protocol (IP) address, 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 our Website)
Usage data (including information about your visit and how you use our Website)
To improve the user experience and administer the functionality of our
Website
To respond to general and specific enquiries
Necessary for our legitimate interests (to maintain network security
and Website relevance for visitors to our Website and respond to
enquiries from visitors to our website)
Necessary to comply with a legal obligation
Any individual, sole trader, partner in a traditional or limited partnership or member of an unincorporated association who is or was a customer
Identity data (including full name and title)
Contact data (including business and home address, email address and telephone numbers)
Employment data (not individual users who are consumers) (including job title and role)
Transaction data (including information obtained by providing services/products to you, details about services/products provided by us to you, details of payments to and from you, and other details of our interactions including correspondence and conversations)
Financial data (including bank account details and payment details)
Marketing and communications data (including your preferences in receiving marketing from us and your communication preferences)
To process and deliver services/products to you and/or your organisation including:
(a) providing information about our services/products on request;
(b) carrying out our business;
(c) managing payments, fees and charges;
(d) collecting and recovering money owed to us;
(e) dealing with any complaints and receiving feedback; and
(f) corresponding with you in connection with our business.
To manage our relationship with you
To notify you about changes to our terms and conditions or privacy notice
• Performance of a contract with you
• Necessary for our legitimate interests (to respond to your correspondence with us, to keep our records up to date, to recover debts due to us and to manage customer relationships)
• Necessary to comply with a legal obligation
• any actual, former or prospective employees, workers, consultants, job applicants and other personnel of a customer;
• any other individual related to a customer who is relevant to any services/products provided by us to such customer
Identity data (including full name and title)
Contact data (including business and home address, email address and telephone numbers)
Employment data(including job title and role)
Transaction data(including information obtained by providing services/products to our customer, and other details of our interactions including correspondence and conversations)
Financial data(including bank account details and payment details)
Marketing and communications data(including your preferences in receiving marketing from us and your communication preferences)
To process and deliver services/products to your organisation including:)
(a) providing information about our services/products on request;)
(b) carrying out our business;)
(c) managing payments, fees and charges;)
(d) collecting and recovering money owed to us;)
(e) dealing with any complaints and receiving feedback; and)
(f) corresponding with you in connection with our business.
• Necessary for us to perform contracts with our corporate customers
• Necessary for our legitimate interests (to respond to your correspondence with us, to keep our records up to date, to manage customer relationships and to recover debts due to us)
• Necessary to comply with a legal obligation
actual, former or prospective business contacts, including:
• staff or other contacts at our third party suppliers (including professional advisors)
• individuals or representatives of organisations who have expressed an interest in our business, and
• anyone else with whom we have contact in a business context
Identity data (including full name and title)
Contact data (including business address, email address and telephone numbers)
Employment(including job title and role, employer)
Transaction data(including details about products and services provided by you (or your organisation) to us, details of payments to and from you (or your organisation) and other details of our interactions including correspondence and conversations)
Marketing and communications data(including your preferences in receiving marketing from us and your communication preferences)
To manage our business relationships with suppliers and sub-contractors, professional advisors, regulatory authorities and others, which will include:
(a) seeking or maintaining business relationships with various organisations, including accreditation and regulatory authorities;
(b) assessing the suitability of any existing or potential supplier or other business relationship;
(c) negotiating and entering into appropriate contracts for the supply of products or services to us, carrying out any obligations under such contracts (including obligations of payment) and if necessary enforcing any such contracts;
(d) undertaking on-going monitoring and management of our relationship with suppliers and other professional and business contacts;
(e) interacting with other organisations or persons (including partners, other advisers or sub-contractors) in the course of providing services/products to our customers; and
(f) investigating any complaints or enquiries.
• Performance of a contract with you (where relevant)
• Necessary for our legitimate interests (to manage third party relationships, to seek supply arrangements appropriate for our business, to run our business efficiently and profitably, to enhance, modify and improve our services, and to pursue our commercial objectives where this does not override your rights and freedoms as a data subject)
• Necessary to comply with a legal obligation
We will only use your personal data 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 wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at info@bottleexchange.net. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.