Privacy Policy

We at the Drunken Clan take data protection and information security very serious. The effective management of all personal data, including security and confidentiality, is the heart of our business and naturally underpins our practices and processes.

This privacy policy informs you about the type, scope and purpose of the processing of personal data we collect, use and process as a part of our services as well as our external online presences, such as our Social Media Profiles (the “Services”).

This policy applies to you, the User of our Services and us the provider of the Services and governs the processing of your personal data in context of our Services and business.

The Regulation
This Data Protection Policy applies to the services of [Company Name]. If you live in the European Economic Area, Regulation (EU) 2016/679 (General Data Protection Regulation) is the European Regulation and in the UK, it is the Data Protection Act 2018.

The Controller
Drunken Clan LTD with Company Number 13545926 of 71-75 Shelton Street, London, England, WC2H 9JQ is the Controller of your personal data.

The Supervisory Authority
The Information Commissioner’s Office (ICO) in the UK is the for us relevant authority in matters of data protection. You have the right to make a complaint at any time to the ICO (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.

What is personal data?
Personal data refers to any information relating to an identified or identifiable natural person (“Personal Data”).

Accuracy
It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.

Children Data
Our website is not intended for children and we do not knowingly collect data relating to children.

How personal data is collected
We collect personal data in the following ways:

direct interactions.
you may provide personal data when you complete online forms, request products/services, use our services, use our feedback form or otherwise or correspond with us (by post, phone or email)
automated technology.
we automatically collect personal data (technical and usage) when you browse or interact with our website, by using cookies, and other similar technologies. We may also receive technical data about you if you visit other websites which use our cookies.

Log Files and Cookies
The processing of your personal data when you merely visit and consult the Services is limited to the so-named surfing data, namely the data whose transmission to the Services is implicit in the functioning of the systems in charge of the managing of the Services and in the communications protocols peculiar to the Internet. Surfing data are, for example, the IP addresses of the devices you use to connect to the Services and other parameters relating to your device and operating system.

In principle, surfing data, such as these above specified, and for example the number of visits and the time spent on the Services, are collected and processed by us exclusively for statistical purposes and in aggregated form for purposes of measuring and enhancing the functioning of the Services. Due to the nature itself of surfing data, these data may lead to identification of users if they are associated with data held by third parties; however, we do not collect surfing data in order to associate them with identified users, except where said data may be used for purposes of assessing possible responsibilities in case of information crimes realized against the Services or through the Services to the extent permitted by law.

Besides, certain information is gathered on this Services by means of cookies and other tracking technologies as described in our Cookies Policy. By actively closing the Services Cookie Banner and by setting your cookie preferences through our tool and in your browser, you are agreeing to our use of cookies and similar technologies. If you do not agree to our use of cookies in this way, you should set your cookie preferences accordingly. You will always be able to withdraw your consent and change your cookie preferences at any time. If you disable cookies that we use, this may impact your user experience while on this Services. Please refer to our Cookies Policy for further details.

Contact
If you send us inquiries, your details from the inquiry form, including the contact details you have provided there, will be stored by us for the purpose of processing the inquiry and in the event of follow-up questions. We do not pass on this data without your consent.

The processing of this data is based on the provision of a pre-contractual or contractual measure if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries addressed to us or on your consent if this has been requested.

The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent to store it or the purpose for storing the data no longer applies (e.g. after we have completed processing your inquiry). Mandatory legal provisions - in particular retention periods - remain unaffected.

Contractual Relationship
In order to establish or implement the contractual relationship with our customers, it is regularly necessary to process the personal master, contract, and payment data provided to us. We also process customer and prospect data for evaluation and marketing purposes. This processing is carried out on the legal basis of our legitimate interest and serves our interest in further developing our offer and informing you specifically about our offers. Further data processing may take place if you have consented or if this serves the fulfilment of a legal obligation.

Commercial and business services
We process data of our contractual and business partners, e.g., customers and interested parties in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g., to answer inquiries.

We process this data to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as for business organization. We only disclose the data of the contractual partners to third parties within the scope of the applicable law to the extent that this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the contractual partners (e.g., to participating telecommunications, transport, and other auxiliary services as well as subcontractors, banks, tax and legal advisers, payment service providers or tax authorities).

Unless otherwise specified the purposes of processing are Contractual performance and service, contact requests and communication, office and organizational procedures, administration, and response to requests, visit action evaluation, interest-based and behavioural marketing. And, the Legal bases are Contractual performance and pre-contractual inquiries, Legal obligation, and our Legitimate interests.

Technical services
We process the data of our customers and clients in order to enable them to select, purchase or commission the selected services or works as well as associated activities and to pay for and deliver them or to execute or provide them. The required information is identified as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information.

Data transfer to payment service providers
In order to fulfil the contract, we pass on your data to the company commissioned with the payment, insofar as this is necessary for the payment of our services. Depending on which payment method you select, we pass on the payment data collected for this purpose to the credit institution commissioned with the payment and, if applicable, to payment service providers commissioned by us or to the selected payment service provider. In some cases, the selected payment service providers also collect this data themselves. In this case, the privacy policy of the respective payment service provider applies.The legal basis for the data processing is contract.

Data processing for the purpose of fraud prevention and optimisation of our payment processes
Where applicable, we provide our service providers with further data, which they use together with the data necessary for the processing of the payment as our processors for the purpose of fraud prevention and optimisation of our payment processes (e.g. invoicing, processing of contested payments, accounting support). This serves to protect our legitimate interests in our protection against fraud or in efficient payment management, which outweigh our interests in the context of a balancing of interests.

Use of customer data for direct marketing purposes
If you have provided us with your e-mail address when purchasing goods or services, we reserve the right to regularly send you e-mail offers for similar goods or services to those already purchased from our range. We do not need to obtain your separate consent for this. In this respect, the data processing is carried out solely on the basis of our legitimate interest in personalized direct advertising. If you have initially objected to the use of your e-mail address for this purpose, we will not send you any e-mails.

You are entitled to object to the use of your e-mail address for the aforementioned advertising purpose at any time with effect for the future by notifying the responsible person named at the beginning. After receipt of your objection, the use of your e-mail address for advertising purposes will cease immediately. If you wish to object to the data analysis for statistical evaluation purposes, you must unsubscribe from the marketing.

When you send a data subject access request
The legal basis for the processing of your personal data in the context of handling your data subject access request is our legal obligation and the legal basis for the subsequent documentation of t data subject access request is both our legitimate interest and our legal obligation.

The purpose of processing your personal data in the context of processing data when you send a data subject access request is to respond to your request. The subsequent documentation of the data subject access request serves to fulfil the legally required accountability.

Your personal data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. In the case of the processing of a data subject access request, this is three years after the end of the respective process.

You have the possibility at any time to object to the processing of your personal data in the context of the processing of a data subject access request for the future. In this case, however, we will not be able to further process your request. The documentation of the legally compliant processing of the respective data subject access request is mandatory. Consequently, there is no possibility for you to object.

Legal defense and enforcement of our rights
The legal basis for the processing of your personal data in the context of legal defense and enforcement of our rights is our legitimate interest.

The purpose of processing your personal data in the context of legal defense and enforcement of our rights is the defense against unjustified claims and the legal enforcement and assertion of claims and rights. Your personal data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected.

The processing of your personal data in the context of legal defense and enforcement is mandatory for legal defense and enforcement of our rights. Consequently, there is no possibility for you to object.

When do we disclose your Personal Data?
We disclose your Personal Data in response to your business enquiry or your request for information within our Company in order to provide the best service possible and within our legitimate interest.

We may share your information with organisations that help us provide the services described in this Data Protection Policy and who may process such data on our behalf and in accordance with this Data Protection Policy, to support this website and our services. For example, with our legal other professional advisers.

We may also share information with our secure payment gateway provider, and you may need to provide credit or debit card information directly to the provider in order to process payment details and authorise payment following a secure link. The information which you supply to in such cases is not within our control and is subject to the payment gateway provider’s own Privacy policy and Terms and Conditions.

In relation to information obtained about you from your use of our website, we may share a cookie identifier and IP data with analytic and advertising network services providers to assist us in the improvement and optimisation of our website which is subject to our Cookies Policy.

We may disclose personal information in other circumstances such as when you agree to it or if the law, a Court order, a legal obligation or regulatory authority ask us to. If the purpose is the prevention of fraud or crime or if it is necessary to protect and defend our right, property or personal safety of our staff, the website and its users.

Data retention
Unless a more specific retention period is stated within this privacy policy, your personal data will remain with us until the purpose for processing the data no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the data will be deleted once these reasons no longer apply.

SSL or TLS encryption
For security reasons and to protect the transmission of confidential content, that you send to us as the Services operator, this Services uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.

Rights of users and persons concerned and the legal bases of processing
With regard to the data processing described in more detail below, users and data subjects have the right to

to confirmation as to whether data relating to them is being processed,
to information about the data processed, to further information about the data processing and to copies of the data;
to correction or completion of incorrect or incomplete data;
to immediate erasure of the data concerning them;
to receive the data concerning them and provided by them and to transfer this data to other providers/controllers;
to lodge a complaint with the supervisory authority if they are of the opinion that the data concerning them is being processed by the provider in breach of data protection provisions.

In addition, the provider is obliged to inform all recipients to whom data has been disclosed by the provider of any correction or deletion of data or restriction of processing that takes place. However, this obligation does not apply if such notification is impossible or involves a disproportionate effort. Notwithstanding this, the user has a right to information about these recipients.

Likewise,users and data subjects have the right to object to the future processing of data concerning them, insofar as the data is processed by the provider. In particular, an objection to data processing for the purpose of direct advertising is permissible.

The above rights may be limited in some circumstances, for example, if fulfilling your request would reveal personal information about another person, if you ask us to delete information which we are required to have by law, or if we have compelling legitimate interests to keep it. We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your personal information.

We encourage you to get in touch if you have any concerns with how we collect or use your personal information.

The legal bases for processing are listed below and at least one of these must apply whenever we process personal data:

Consent: the individual has given clear consent to process personal data for a specific purpose.
Contract: the processing is necessary for a contract or because you have asked us to take specific steps before entering into a contract.
Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).
Vital interests: the processing is necessary to protect someone’s life.
Public task: the processing is necessary for us to perform a task in the public interest or for official functions, and the task or function has a clear basis in law.
Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests.

Online Meetings
We may use video teleconferencing software programs to conduct our online meetings and various types of data are processed when using an online platform for meetings. The scope of the data depends on the information you provide before or during participation in an online meeting. If you contact us in electronic form, we store and process the data you have provided us with. The legal basis for this is our legitimate interest in effective customer communication in accordance with your consent and, insofar as it concerns an enquiry to enter into or fulfil a contract, also contract. You can request information about the purpose of processing, origin and, if applicable, recipients of your personal data from us free of charge at any time.

How do we protect your Personal Data?
We protect your data using state of the art technical, and physical safeguards and operate a firm system of policies, confidentiality agreements, digital safeguards and procedures to ensure the highest level of administrative protection.

In more detail to access our database the user must be authorised, is challenged through a two-way authentication system and use an encrypted VPN. Also, the removal of Personal Data from our location is forbidden and made by using a complex encryption system very difficult. We use cutting edge antivirus and anti-malware software and up-to-date firewall protection. Moreover, authorised personnel must have a legitimate need to know interest such as being your point of contact or service your user account.

The data we collect from you may be stored, with appropriate technical and organisational security measures applied to it, on our servers in the UK. In all cases, we follow generally high data protection standards and advanced security measures to protect the personal data submitted to us, both during transmission and once we receive it.

To exercise any of your rights, or if you have any questions or complaints about our use of your Personal Data and this policy, please contact us.

Social Media
The data you enter on our social media pages, such as comments, videos, pictures, likes, public messages, etc. are published by the social media platform and are not used or processed by us for any other purpose at any time. We only reserve the right to delete content if this should be necessary. Where applicable, we share your content on our site if this is a function of the social media platform and communicate with you via the social media platform. The legal basis is our legitimate interest. The data processing is carried out in the interest of our public relations and communication.

If you wish to object to certain data processing over which we have an influence, please contact us. We will then examine your objection. If you send us a request on the social media platform, we may also refer you to other secure communication channels that guarantee confidentiality, depending on the response required. You always have the option of sending us confidential enquiries to our address stated in the imprint.

As already stated, where the social media platform provider gives us the opportunity, we take care to design our social media pages to be as data protection compliant as possible. With regard to statistics that the provider of the social media platform makes available to us, we can only influence these to a limited extent and cannot switch them off. However, we make sure that no additional optional statistics are made available to us.

Data processing by the operator of the social media platform
The operator of the social media platform uses web tracking methods. The web tracking can also take place regardless of whether you are logged in or registered with the social media platform. As already explained, we can unfortunately hardly influence the web tracking methods of the social media platform. We cannot, for example, switch this off.

Please be aware: It cannot be ruled out that the provider of the social media platform uses your profile and behavioural data, for example to evaluate your habits, personal relationships, preferences, etc. We have no influence on this. In this respect, we have no influence on the processing of your data by the provider of the social media platform.

Content Delivery Network

Our web site uses a so-called Content Delivery Network (CDN). A CDN is a network of powerful servers that cache content at various locations around the world. A CDN has two main tasks: to deliver content in the shortest possible time and to reduce the load on the web host by distributing traffic. CDNs transmit two types of content: Static and dynamic content. Static content is delivered to all website visitors in the same form, such as video content from streaming services or code frameworks (e.g. Javascript, jQuery). Dynamic content is first adapted to the user and only created at the moment of the request. This includes content that takes place via web applications, email or online shops and is personalised. In order to use the latter, information about the website visitor must first be transmitted to the CDN. The legal basis for the use of a CDN and the transmission of your data to it is our legitimate interest. The legitimate interest results from our need for a technically flawless and fast presentation of our web site and the relief of our IT infrastructure. You can object to the processing of your data on the basis of our legitimate interest at any time. To do so, please use the contact details provided.

Note on data transfer to the USA
Among other things, tools from companies based in the USA are integrated on our platform. If these tools are active, your personal data may be transferred to the US servers of the respective companies. We would like to point out that the USA is not a safe third country in the sense of EU data protection law. US companies are obliged to hand over personal data to security authorities without you as a data subject being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g. intelligence services) process, evaluate and permanently store your data located on US servers for monitoring purposes. We have no influence on these processing activities.

Google Analytics
In order to tailor our web site to your needs, we create pseudonymous user profiles with the help of Google Analytics. Google Analytics uses cookies that are stored on your terminal device and can be read by us. In this way, we are able to recognize returning visitors and count them as such.

The data processing is based on your consent pursuant to Art. 6 para. 1 p. 1 lit. a GDPR if you have given your consent via our banners.

The information generated by the cookie about your use of this platform is usually transmitted to a Google server in the USA and stored there. However, as we have activated IP anonymization on this web site, your IP address will be shortened by Google beforehand. Only in exceptional cases will the full IP address be transferred to a Google server and shortened there. Where we use providers in unsafe third countries and you consent, the transfer to a third country will be based on Article 49(1)(a) of the GDPR.

We have also concluded a contract with Google Inc. in accordance with Article 28 of the GDPR and standard data protection clauses. Accordingly, Google will use all information strictly for the purpose of evaluating the use of our platform for us and compiling reports on platform activity.

Queries and Complaints
Any comments or queries on this policy should be directed to us. If you believe that we have not complied with this policy or acted otherwise than in accordance with data protection law, then you should notify us. You can also make a referral to, or lodge a complaint with, the Information Commissioner’s Office. However, before contacting the ICO we would appreciate the opportunity to address the matter first.