Privacy Policy & Cookie Policy

Got a question? Email us [email protected]



1.    Introduction

a.    Welcome to WHISKY BULL AUCTIONS Limited's Privacy Policy. We are committed to protecting personal data that we collect when providing our website and our services to you.

b.    This Privacy Policy tells you how we process your personal data and about your privacy rights. Please read it carefully

2.    Controller

a.    Whisky Bull Auctions Limited, a company incorporated and registered in England and Wales with company number 11477600  whose registered office is at 1st Floor, 4 Davis Way, Fareham, PO14 1JF. Whisky Bull Auctions Limited  ("we", "us", "our") is the controller and responsible for your personal data.

b.    If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the following details: [email protected]

3.    Changes to our Privacy Policy and your duty to inform us of changes

a.    We keep our Privacy Policy under regular review and we may change it from time to time. You should check this Privacy Policy every time you use our website.

b.    It is important that the personal data we hold about you is accurate and up-to-date. If your personal data changes during your relationship with us, please let us know by using the contact details above.

4.    The data we collect about you

a.    For us to provide our service, we need to collect certain personal data about you. The personal data that we collect is as follows:

                                          i.    name;

                                        ii.    email address;

                                       iii.    username and password;

                                       iv.    date of birth;

                                        v.    proof of age, such as a copy of your passport or other photographic ID;

                                       vi.    billing address and delivery address if you are successful in winning an auction lot;

                                      vii.    telephone number;

                                     viii.    bank details so that we can make payments to you to which you are entitled when acting as a seller;

                                       ix.    transaction data including details about payments made to and from you and details of products you have purchased through our website;

                                        x.    any personal data you choose to include in communications you send to us, including through the contact form on our website or by email;

                                       xi.    technical data such as your IP address, login data, browser type and version, time zone setting and location; and

                                      xii.    data about how you use our website, including pages you have clicked on and how long you have spent on them.

b.    We collect data from you via various different methods, including:

                                          i.    when you set up an account with us;

                                        ii.    when you contact us via post, email, telephone or otherwise;

                                       iii.    when you purchase products or services through our website; and

                                       iv.    through automated technologies or interactions.

5.    How we use your personal data

a.    We use your personal data for the following purposes:

                                          i.    to register you as a new customer;

                                        ii.    to run and manage your account;

                                       iii.    to provide you with your membership and allow you to sell and/or purchase whisky via our online auction.

                                       iv.    to deliver any successful purchase via our online auction;

                                        v.    to send you service communications about services and products you purchase, for example communicating with you to introduce you to our company, sending you confirmation emails, notifying you of winning bids and informing you if your bid is not successful;

                                       vi.    to pay you money to which you are entitled, for example as a result of the sale of your whisky at auction;

                                      vii.    to administer and protect our business and our website, including troubleshooting, data analytics, testing, system maintenance, support, reporting and hosting of data;

                                     viii.    where you consent to us doing so, to send you marketing communications.

b.    When we use your data to send you marketing communications, we will obtain your consent to do so. You can opt out at any time by clicking the "unsubscribe" link in any communication or by contacting us on the details set out above.

c.    Data protection laws require us to tell you the legal basis on which we rely in order to process your personal data.

                                          i.    In relation to the purposes set out at clause above, we process this data on the basis that it is necessary for the purposes of entering into or performing a contract with you.

                                        ii.    In relation to the purposes set out at 5a.vii above, we process this data on the basis that it is necessary for the purposes of our legitimate interests in ensuring that we can troubleshoot and improve our website and continue to provide a functional and useful website to our users.

                                       iii.    In relation to the purposes set out at 5a.viii above, we process this data on the basis that it is necessary for the purposes of our legitimate interests in promoting our business and our products and services.


6.    Disclosures of your personal data[DP1] 

a.    We share your personal data with our parent company, Fah Mai Holdings, in Thailand. Please see section 7 below for further information.

b.    We also share your information with third parties in the following circumstances:

                                          i.    with service providers who provide services to us, for example payment services providers to aid payments relating to your activities on the website, IT service providers (including our website developers) and communications service providers. Our service providers are subject to data protection obligations to ensure they protect your personal data appropriately;

                                        ii.    to comply with legal or regulatory requirements we are obliged to meet; and

                                       iii.    if we sell all or part of our business or assets and we need to disclose your personal data to a prospective or actual purchaser for the purposes of the sale.


7.    Location of your personal data[DP2] 

a.    Whenever we store or send personal data outside the EEA, we are required to take additional measures to ensure that your personal data is protected in the same way it would be within the EEA. This section sets out when we transfer personal data outside the EEA and what additional measures are in place to protect it.

                                          i.    We store all of your personal data on secure servers. Our servers are hosted in the USA and our hosting provider is subject to EU-U.S. PRIVACY SHIELD FRAMEWORK.

                                        ii.    Our parent company, Fah Mai Holdings, is based in Bangkok, Thailand and has access to your personal data for the purposes of allowing us to run and manage your account. We have executed European Commission approved standard contractual clauses with Fah Mai Holdings which require Fah Mai Holdings to protect your personal data appropriately.

b.    Please contact us on the details set out above for more information about the additional measures outlined in this section.


8.    Security and retention of your personal data

a.    The information we collect is stored securely on our computer systems.

b.    We will retain any information collected following the closure of your account for a period of no less than five years but for no more than eight years after which time your information will be permanently removed from our computer systems.


9.    Your rights

a.    Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are:

                                          i.    A right to request access to your personal data.

                                        ii.    A right to request a correction of personal data we hold about you that is inaccurate.

                                       iii.    A right to request erasure of your personal data.

                                       iv.    A right to object to processing of your personal data where we are relying on "legitimate interests" as our legal basis.

                                        v.    A right to request restriction of processing of your personal data.

                                       vi.    A right to request the transfer of your personal data to you or a third party.

b.    If you would like to exercise any of these rights, please contact us using the details above.


10. Cookies

a.    We use cookies on our website. For more information please see our Cookies Policy.