Privacy and cookies

Introduction 

Our consumers are at the heart of what we do. This Privacy and Cookie Notice applies to personal information collected by or on behalf of a company within the Diageo group of companies. It sets out what we do with your personal information, how we keep it secure and explains the rights that you have in relation to your personal information.

Particularly interested in how we use cookies? Please see the dedicated Cookie section of this notice.

Last revised: [June 2020]

 

Who we are 

Diageo is the world’s leading premium drinks business. Details of Diageo’s different brands can be found here.

This website and/or mobile app is operated by a member of the Diageo group of companies, the ultimate holding company of which is Diageo plc (registered in England and Wales with company number 23307 and registered address at Lakeside Drive, London, NW10 7HQ, United Kingdom). Information on our subsidiaries can be found in our latest annual report, which is available here.

All references to ‘our’, ‘us’, ‘we’, or ‘company’ within this notice are deemed to refer to Diageo plc, its subsidiaries, affiliates, and/or associates, as appropriate.

 

Are you of legal purchase age? 

You must not provide us with your personal information if you are not of legal age to purchase alcohol in the jurisdiction in which you reside and (if different) in the jurisdiction in which you are accessing the website or app.

We do not intend to collect personal information from any individuals under the legal purchase age, or to market alcoholic beverages to anyone under the legal purchase age.

If we receive notice or believe that someone under the legal purchase age has provided us with personal information we will make every reasonable effort to remove such personal information from our records.

 

What types of personal information do we collect? 

Personal information is information about an identifiable individual, as defined by applicable  law. The personal information we collect includes: 

(a) information you provide to us; and 

(b) information we automatically collect/generate or information we obtain from third  parties.

We have set out below more details regarding these types of personal information:

• Information you provide to us: These types of personal information may include: o contact details (such as your name, postal addresses, phone numbers and email  addresses),  
  • demographic information (such as your date of birth, age or age range and  gender),
  • online registration information (such as your password and other authentication  information),  
  • payment information (such as your credit card information and billing address), 
  • information provided as part of online questionnaires (such as responses to any  customer satisfaction surveys or market research), 
  • competition entries/submissions, and
  • in certain cases your marketing preferences. 

• Information we automatically collect/generate or obtain from third parties: These types  of personal information may relate to your device (such as your PC, tablet or other mobile  device), your use of our websites and apps (as well as certain third party websites with  whom we have partnered), and/or your personal preferences, interests, or geographic  location. Examples of these types of information include: 
  • name and age (or predicted age range), 
  • information about your device, operating system, browser and IP address,  o unique identifiers associated with your device, 
  • details of web pages that you have visited, 
  • which products you have looked at online (including information about products  you have searched for or viewed, purchased or added to an online shopping  basket), 
  • how long you spend on certain areas of a website or app together with the date  and time of your visit/usage, 
  • personal information contained within user-generated content (such as blogs and  social media postings), 
  • social media user name or ID, and
  • social media profile photo and other social media profile information (such as  number of followers). 

 

How/when do we collect personal information? 

• Information you provide to us: There are various situations in which you may directly  provide personal information to us. These include when you: 
  • enter a competition or take advantage of a promotion,
  • fill in an online questionnaire (such as a customer satisfaction survey), 
  • provide credit card details (such as when purchasing products from us), 
  • contact us with an enquiry or ask us to provide you with information, 
  • register on a website or app or leave any reviews or comments,
  • attend any of our promotional events,
  • forward an item to a friend,
  • inform us of your marketing preferences, and/or
  • communicate with us via social media websites, third party apps or similar  technologies. 

We will indicate where any personal information we have requested is mandatory or  optional. We will also explain the consequences should you decide not to provide  information which we have indicated is mandatory. In some circumstances this may  mean we are unable to provide you with a certain service or product. 

• Information we automatically collect/generate: When you browse or use our websites  or apps (as well as certain third party websites with whom we have partnered) we (and  our partners) use cookies and similar technologies to collect information automatically  from one or more of your devices associated with you (see below for more details  regarding the use of cookies and similar technologies).

We also use certain automated techniques and technologies to infer or generate  additional information about you, for example by analysing or predicting certain personal  aspects such as your personal preferences or interests.

In addition, we receive IP addresses from all users because this information is  automatically reported by your browser each time you view a web page. For most users  accessing the internet, the IP address will be different every time you log on. IP addresses  are generally recorded in files called “log files”. 

• Information we obtain from third parties: In addition to the information we collect as  described above, we may also partner with and use the services of various third parties to  collect personal data about you from other sources, We will only obtain such information  where we have your consent and/or another legal ground to do so. This information may  include: 
  • Data from other organisations who have obtained your permission to share  information about you with us; 
  • Data we receive when someone refers you for our products and services (please  see below for more); 
  • Data we may require from other organisations to fulfil our legal obligations;  and/or
  • Where your information is publicly available. 

Here are a few places third party data may come from: 

• Public information sources, such as the Electoral Roll. 
• Third party social media platforms. 
• Other third party websites that we have partnered with. 

 

Purposes for which your personal information is used 

The different purposes for which we use your personal information are set out below: 

Marketing Communications: We may use your personal information to communicate  with you through channels such as email, SMS and post about our products and services,  and those of our subsidiaries, affiliates, and parent companies, and any of their related  businesses. This may also include using your date of birth to send you special offers around  your birthday. You have the right to opt out at any time from receipt of further marketing  communications as described in “Your Rights” section. 

Marketing analysis: We may use your personal information for marketing analysis, for  example, to assess trends amongst our consumers and what people are saying about our  products, to evaluate the impact and effectiveness of our marketing campaigns and  promotions, and to analyse the number and types of visitors to our websites and/or users  of our apps (including the locations from which such visitors/users access our websites  and apps). We often aggregate personal information for these purposes so that it no  longer identifies any particular individual. 

Online interest-based advertising: We use techniques such as “online behavioural  advertising” and “programmatic advertising” which involve the use of personal  information (and the sharing of it with our service providers) to display the most  appropriate and relevant advertising to you either on our websites, apps or third party  websites (including social media platforms). We may also use your personal information (and share it with our service providers as  described below) in order to determine if you are a member of a particular social media  platform so that we can display our advertising to you on that service or to identify  consumers who share similar interests and characteristics with you for the purposes of  making our advertising more relevant to consumers – examples of this are Facebook’s  “Custom Audiences” and “Lookalike Audiences” products which we may use in certain  countries subject to local law. 

See the section on Cookies below for more details about online interest-based advertising. You have the right to opt-out at any time from the use of your personal information for  online interest-based advertising. 

Online ad verification: We use personal information to monitor our digital advertising to  ensure that it does not appear on unsuitable websites or near inappropriate content, and  also to ensure that our advertising is visible and seen by real people online (as opposed to  ‘bots’ or similar fraudulent techniques).  

Forward to a friend: When you provide us with information regarding another individual,  such as when you request that we send someone information from one of our websites, 

we will send that individual only the information you specifically requested that we send.  We will not send them additional communications based on your providing us with their  information. You must confirm that your friend is of Legal Purchase Age in the jurisdiction  where they are located in order for us to transmit the requested information and that  they are happy to receive any such communications. 

Authentication and access control: We may use your personal information to  authenticate your access to our websites or apps and to determine which content to  provide you and/or whether you should be granted access to certain content (for example  checking your age or location to ensure you are of Legal Purchase Age in the jurisdiction  where you are located). We may also use your personal information to verify your identity  when responding to any requests to exercise your rights under applicable law. 

Comply with legal obligations and protect against legal claims or liability: We may use  your personal information to comply with our legal obligations, protect us against legal  claims, or to detect, protect, or defend us and/or other third parties against error,  negligence, breach of contract, theft, fraud, or other illegal or harmful activity, to comply  with our audit and security requirements, or to audit compliance with our corporate  policies, procedures, legal, or contractual obligations. 

Customer service: We will use your personal information to provide specific services that  you request from us, as well as to provide additional services that may be of interest. We  will also use your personal information to maintain your accounts, and manage  transactions such as credit card payments for any products that you order from us or our  agents, or for the fulfilment of such transactions (e.g. delivery) or to answer any questions  you may have. We may also use your personal information to notify you about changes to  our services, our terms and conditions or this Privacy and Cookie Notice. 

Corporate transactions: We may use your personal information in the event of a sale,  merger, consolidation, change in control, transfer of substantial assets, financing,  reorganization, or liquidation whereby we transfer, sell, or assign to a third party  information concerning your relationship with us. 

Technical maintenance: We use personal information for system administration purposes  and to diagnose service or technology problems reported by our users or engineers, these  types of problem may be associated with the IP addresses controlled by a specific web  company or ISP. 

 

Legal basis for the processing of personal information 

We will only process your personal information where we have a legal basis to do so. The legal  basis will depend on the purposes for which we have collected and use your personal  information. In almost every case the legal basis will be one of the following:  

Consent: For example, where you have provided your consent to receive certain  marketing from us. You can withdraw your consent at any time, including by clicking on  the “unsubscribe” link at the bottom of any marketing email we send you. 

Our legitimate business interests: Where it is necessary for us to understand our  customers, promote our services and operate effectively as a multinational beverages company, provided in each case that this is done in a legitimate way which does not  unduly affect your privacy and other rights. For example we will rely on this legal basis  when we conduct certain market analysis to understand our consumers in sufficient detail  so we can create new products and improve the profile of our brands. 

Performance of a contract with you: This would also apply where we need to take steps  prior to entering into a contract with you. For example, where you have purchased a  product from us and we need to use your contact details and payment information in  order to process your order and send the product to you. 

Compliance with law: Where we are subject to a legal obligation and need to use your  personal information in order to comply with that obligation. 

 

Disclosure of your personal information 

We value your personal information and only share it with third parties in certain  circumstances. From time to time we may disclose personal information to: 

1. a) third parties where you have provided your consent. For example we will obtain your permission before we allow a third party that is not an affiliate to send you any marketing  and promotional information relating to that third party’s products or services;  
2. b) our service providers and subcontractors, including our affiliates, and/or third party  websites(such as social media platforms or search engines) retained to perform functions  on our behalf, or to provide services to us (such as warehousing and delivery) marketing  and advertising (including by delivering online interest-based advertising on third party  websites and social media platforms where you have consented to the use of advertising  cookies set by Diageo or our partners); credit card and data processing; age verification;  monitoring our digital advertisements to ensure that they do not appear on unsuitable  websites or near inappropriate content and also to ensure that our advertising is visible  and seen by real people online (as opposed to ‘bots’ or similar fraudulent techniques);  software development; website hosting and management; information technology and  office services; legal, accounting, audit and other professional service providers; and other  services related to our business), provided such service providers and subcontractors have  entered into written agreements with us and do not collect, use, or disclose the personal  information for any purpose other than to perform such functions on our behalf, to  provide services to us, or as otherwise required or permitted by law;  
3. c) third parties who, in our reasonable judgment, are providing or seeking the information  as your authorised or appointed legal agent; 
4. d) a person or entity, including our affiliates, in the event of a sale, merger, consolidation,  change in control, transfer of substantial assets, financing, reorganisation, or liquidation  whereby we transfer, sell, or assign to such third party information concerning your  relationship with us, including without limitation, personal information that you provide  and other information concerning your relationship with us; and  
5. e) law enforcement, governmental or regulatory agencies, or other third parties in order to  comply with applicable law, or where we believe such action is necessary in order to  comply with applicable law, or to detect, protect, or defend us and/or other third parties against error, negligence, breach of contract, theft, fraud, or other illegal or harmful  activity, to comply with our audit and security requirements, or to audit compliance with  our corporate policies, procedures, legal, or contractual obligations. 

 

International data transfers 

Please note that your personal information may be transferred to, and stored at, a destination  outside the country in which you reside, including countries, which have less strict, or no data  protection laws, when compared to those in your country. 

Whenever we transfer your information as described in the paragraph above, we will take  steps which are reasonably necessary to ensure that adequate safeguards are in place to  protect your personal information and to make sure it is treated securely. In these cases, we  rely on approved data transfer mechanisms (for example, the EU “Standard Contractual  Clauses” or the EU-US “Privacy Shield”) to ensure your information is subject to adequate  safeguards in the recipient country. If you are located in the EEA, you may contact us using  the contact details below for a copy of the safeguards which we have put in place to protect  your personal information and privacy rights in these circumstances.  

 

Public areas of our websites and apps 

Information that you post on or through the public areas of our websites and apps (e.g., chat  rooms, bulletin boards, discussion groups), or on social media platforms generally is accessible  to, and may be collected and used by, others, and may result in unsolicited messages or other  contact from others. You should not provide personal information about yourself in public (or  interactive) areas of our websites, apps or social media pages. 

 

Information security 

We take information security seriously and take precautions to keep your personal  information secure. We have put in place appropriate physical, technical, and organisational  measures to safeguard the information we collect. However, we have no control over the  privacy of any communication while it is in transit to us. We therefore recommend that you  do not include confidential, proprietary, or sensitive information in any such communications. 

Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is  no longer secure (for example, if you feel that the security of any account you might have with  us has been compromised), please immediately notify us of the problem by contacting us at  the contact details below. 

In the unlikely event that we believe that the security of your personal information in our  possession or control may have been compromised, we may seek to notify you of that  development. If such a notification is appropriate, we will endeavour to do so as promptly as  possible under the circumstances, and, to the extent we have your email address, we may  notify you by email.

You are reminded that, in accordance with the Conditions of Use for this website and/or app,  you are responsible for maintaining the strict confidentiality of your account password, and  you are responsible for any activity under your account and password. It is your sole  responsibility to control the dissemination and use of your password, access to and use of  your account, and to notify us when you wish to cancel your account. We will not be  responsible or liable for any loss or damage arising from your failure to comply with  this obligation. 

 

Your rights 

Depending on the jurisdiction in which you are located, you have certain rights in relation to  your personal information. These rights may include: 

o the right to withdraw your consent to any processing of your personal information  (where you had provided consent); 

o the right to object to the processing of your information for certain purposes; 

o the right to access your personal information, and the ability to erase, restrict or in  certain cases receive a machine-readable copy of your personal information; 

o the right to ask us to rectify any information about you that you think is inaccurate;  and 

o the right to unsubscribe from any of our marketing communications at any time. 

If you wish to exercise any of these rights you may contact us (using the contact details  provided below). We will handle any request to exercise your rights in accordance with  applicable law in your country and any relevant legal exemptions.  

 

How to make a complaint 

You have the right to complain to a data protection authority if you think we have processed  your personal information in a manner which is unlawful or infringes your rights.  

However if you have such concerns we suggest that you initially contact us (using the contact  details below in the “How to contact us” section) so that we can investigate, and hopefully  resolve, your concerns. 

 

How long will we retain your personal information for? 

We will retain your personal information for the period necessary to fulfill the purposes  outlined in this Privacy and Cookie Notice unless a longer retention period is required or  permitted by law. After this period it will be deleted or in some cases anonymised. 

For example, where you have made a purchase with us, we will keep a record of your purchase  for the period necessary for invoicing, tax and warranty purposes. We may also keep a record  of correspondence with you (for example if you have made a complaint) for as long as is  appropriate to protect us in the event of a legal claim.  

Where we have collected the personal information based on your consent and we have no  other lawful basis to continue with that processing, if you subsequently withdraw your  consent then we will delete your personal information. However, please note that where you unsubscribe from our marketing communications, we will keep a record of your contact details to ensure we do not send you further marketing communications in future. 

 

Interfaces with Third-Party Websites and Services 

Our websites and apps may contain links, references, and content from other websites and  services outside of our control. Please be aware that we have no control over these websites  and services and our Privacy and Cookie Notice does not apply to them.  

We will not be liable to you for any issues arising in connection with their use of your  information and we encourage you to read the Privacy and Cookie Notices and Conditions of  Use of any linked, referenced, or interfacing websites and services you visit or use. 

 

Cookies and similar technologies 

Like many other websites and apps, we use cookies, scripts, pixel tags, etags, web beacons  and similar technologies (collectively referred to as “cookies”) to help us gather and store  information about visitors to our websites and apps and certain third party websites with  whom we have partnered.  

This section explains what cookies are and gives details of the specific cookies we use on our  website. It also sets out why we use these cookies and provides information on the cookie  choices that you and all our website visitors have. 

We use a range of cookies on our website, including strictly necessary cookies, performance /  analytics cookies, functional cookies and advertising cookies (see more details under ‘What  do we use our cookies for?’ below). The cookies may be set by us or by a third party, including  advertising cookies, which are used by our advertising partners to show online adverts based  on your activity. When you first visit our website, you will be asked via our Cookie Preference  Centre (the ‘CPC’) if you agree to non-essential cookies – and we will not use these cookies  unless and until you provide your consent. You can also change your mind at any time using  the CPC or the settings on your internet browser or device (see more details under ‘How to  manage cookies’ below). 

If you have any questions about our use of cookies, please get in touch with us using the details  at the end of this notice.  

 

What is a cookie? 

A cookie is a text-only string of information that a website transfers to the cookie file of the  browser on your device’s hard disk. A cookie will typically contain the name of the domain  from which the cookie has come, the “lifetime” of the cookie, and a value, usually a randomly  generated unique number. The other technologies we use serve a very similarly function but work slightly differently.  

We use two broad types of cookies: 

• First party cookies, served directly by us to your device when you visit our website;  and 
• Third party cookies, served by a third party on our behalf when you visit our website  and certain third party websites with whom we have partnered.

These cookies can be divided into session cookies and persistent cookies. Session cookies are  temporary cookies that remember your user choices and preferences and are then deleted as  soon as you leave the site. Persistent cookies stay in one of your browser’s subfolders until  you delete them manually or until they expire. 

Cookies are useful because they allow a website to recognise a user’s device. You can find  more information about cookies at: www.allaboutcookies.org.  

 

How does this website use cookies?  

This website uses the following cookies for the following purposes: 

• Category of cookie:
  • More information 

• Strictly Necessary cookies:
  • These cookies are essential to enable you to move around the website and  use its features, such as accessing secure areas of the website. Without  these cookies, our website cannot function properly and services you have  asked for, like shopping baskets or e-billing, cannot be provided.Examples of Strictly Necessary Cookies we may use on this website include  Content Management Cookies which are required by the site for the content  management system to work and Template Preference Cookies which are  necessary for mobile sites and enable the site to look and feel the way it is  intended to.

• Performance and Analytics cookies:

  • These cookies collect information about how visitors use a website, for  instance which pages visitors go to most often, and any error messages  visitors receive from web pages. These cookies don’t collect information that  directly identifies a visitor. Information collected by these cookies is often  aggregated and therefore becomes anonymous. It is only used to improve  how a website works, and understand how most people use our website. 

    One example of this is Google Analytics, which we use to help analyse use of  the site. This analytical tool uses cookies to collect standard internet log  information and visitor behaviour information which is then aggregated so  that it does not identify any individuals. The information about your use of  the website and your IP address is transmitted to Google and is used by us  to evaluate visitors’ use of the website, compile statistical reports on website  activity and create a profile of aggregated visitors based on demographics  and interests. We also use a tool called Google Display Network Impression  Reporting to help us understand which adverts we place on other websites  in the Google Display Network are better at attracting visitors to our website.  View an overview of Google Analytics’ privacy commitments here. To opt  out of being tracked by Google Analytics across all websites visit here.

• Functional cookies:

  • These cookies allow the website to remember choices you make (such as  your user name, language or the region you are in) and provide enhanced,  more personal features. These cookies can also be used to remember  changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have  asked for such as watching a video or posting a comment. The information  these cookies collect may be anonymised and they cannot track your  browsing activity on other websites. 

    We may place a cookie to remember your preferences (Preference Cookie)  so that you do not need to re-enter your details (country/age and language  preferences) on our gateway page. You can choose this by selecting  ‘Remember me on this device’, but it is not suitable if you share your  computer with someone else. This cookie does not collect your date of birth  and expires automatically after 12 months.

• Advertising  cookies  
  • Advertising  cookies 

    These cookies are used to deliver content that is more relevant to you and  your interests based on your previous browsing across the web as well as  keywords we may be able to gather from the URLs of webpages from which  you accessed this website, your IP address and any search engine used to  reach this website. Also, these cookies may be used to deliver online  interest-based advertising to you (either within this website or when you visit third party websites, including third party social media platforms) or to  limit the number of times you see an advertisement. They stay on your  computer unless you delete them and they remember that you have visited  a website.  

    Marketing cookies we use include Third Party Cookies set by Google, The  Trade Desk and Facebook, whom we use for online interest-based  advertising. You can read Google’s privacy policy here and The Trade Desk’s  privacy policy here. We use also certain Facebook advertising tools (such as  Facebook “pixel”) for online interest-based advertising purposes – you can  read Facebook’s data privacy policy here. 

    We may also use certain service providers to set cookies on our behalf via  third party partner websites. These cookies enable us to analyse visits to  specific sections of those websites and collect certain information regarding  purchases of our products. The types of information collected by such  cookies may include: shopping cart information, what product pages have  been viewed, whether a purchase of our product has been made, which of  our products have been searched for. 

    We may also use social sharing plugins and cookies. The Social Sharing plugin  works by linking you with social media sites such as Facebook, Twitter,  Instagram and Pinterest and allows interaction between your activity on  social media sites and on our website through your direction. For example,  using your Facebook username and password to login to our website, and  using the Facebook ‘Like’ and ‘Share’ buttons on our site. Social Sharing  cookies are used to remember that you are logged in to our site.  

    If you visit a page which we maintain on a social media site such as Facebook,  it is likely that cookies will also be set on your device. These cookies are set by the social media network and so, to change the cookies that you receive  from these sites, even on our pages, you will need to change use the settings  provided by the social media site. 

 

Active cookies?  

 

How can you manage cookies?  

There are a number of ways you can manage our website’s cookies. 

 

Our Cookie Preference Centre (‘CPC’)  

When you first visit our site, and where applicable based on your jurisdiction, we will ask you  for your cookie preferences via our CPC. Through the CPC, you can choose to provide or  withhold your consent to non-essential cookies and we will only use these cookies if and when  we have your consent to do so. You can disable these cookies later or change your mind at  any time via the CPC or through your browser settings (see below).  

 

Your browser settings 

If you are using a web browser (e.g. Google Chrome, Mozilla Firefox or Microsoft Edge), you  have the ability to accept or decline cookies by modifying the settings in your browser. Please  refer to your browser instructions or help screen to learn more about the functions which your  browser provides to manage cookies. If you use different browsers and/or different devices  you may need to ensure that each browser is adjusted to suit your cookie preferences. For  instructions on how to manage cookies in your browser, please read the information available  here. Please note that you may not be able to use all the interactive features of our site if all  cookies are disabled. 

If you are using a mobile app, the operating system of your mobile device (e.g. Apple iOS,  Google Android or Microsoft Windows) provides privacy settings which let you manage how  mobile apps use technologies similar to cookies to recognise your device and in certain cases  make interest-based advertising available within mobile apps you use. Please refer to the  instructions or help pages of your mobile operating system to learn more about the functions  which it provides to manage these privacy settings. 

You also have the ability to opt out of online interest-based advertising using the AdChoices  icon as further described below. 

 

How do I opt out of online interest- based advertising?  

If you see any of our advertising with the logo on it, you’re able to take control of whether  you get these types of ads. This is the AdChoices icon provided by the European Interactive  Digital Advertising Alliance (EDAA). 

When you click through the Icon, you’ll get information about the companies that provide  interest-based ads on the sites you visit. You’ll learn about how it works, how this type of  advertising supports free content, and about other privacy choices. 

If you don’t want this type of advertising, you can click through to the consumer choice page  to opt out from the companies that participate in the Icon program.

For further information about how to manage or delete online interest-based advertising  cookies in this way visit here. 

 

How to contact us 

We are committed to safeguarding your privacy. If you have any comments, queries, or  complaints about our collection or use of personal information please contact us via: 

Post: Global Data Privacy Officer, Global Legal Team, Diageo plc, Lakeside Drive, Park Royal,  London, NW10 7HQ 

Email: consumer.privacy.queries@diageo.com  

You may also contact your local data protection regulator in the event of any complaints. The  details of the UK Information Commissioner’s Office are here and the details of your local  regulators can be provided via the email address above.