PRIVACY POLICY

Last updated: 2 July 2024

1. ABOUT THIS PRIVACY POLICY

1.1 The website www.tunbrewing.com (the Site) is operated by TUN BREWING COMPANY LTD.
(“we”, “us”, “our”), a company incorporated in England and Wales under company number
15811526. Our registered office is at 58 Egerton Road South, Manchester, M21 0ZH.

1.2 We are committed to protecting your privacy and complying with our data protection
obligations under the Data Protection Act 2018 (the DPA 2018), the UK General Data
Protection Regulation 2016/679 (the UK GDPR) and any other applicable UK legislation
(together, Data Protection Law).

1.3 When you interact with us or use the Site, we act as the data controller of your personal data.
This means that we are responsible for processing your personal data and deciding how to
use it. This privacy policy explains the types of personal data we may collect about you when
you interact with us, why we collect it, what we use it for and what rights you have over that
data. Personal data is any information about an identifiable person. Processing is anything we
do with your personal data, including using, storing, sharing and deleting it.

1.4 This policy was last updated on the date shown at the top. We may change this policy at any
time by posting an updated version on the Site and will make reasonable efforts to bring any
material changes to your attention. You may wish to check it before using the Site as any
changes will be effective from the date that they are made.

2. CONTACT INFORMATION

2.1 If you have any concerns or would like further information about our use of data or this policy
in general, you can contact Richard Alston at richard.alston@tunbrewing.com or on
01615158272.

3. WHAT INFORMATION DO WE COLLECT?

3.1 We collect, store and use the types of personal data set out in the table at the end of this
policy.

4. HOW WILL WE USE YOUR PERSONAL DATA?

4.1 We will use your personal data for the purposes set out in the table at the end of this policy.

4.2 We profile our customers so that we can find out more information about their purchase
preferences and market the most relevant products to them. To do this, we compile a profile of
information on you which includes your age, gender, purchase history, pages you visit and how
you respond to direct marketing communications.

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5. HOW DO WE SHARE YOUR PERSONAL DATA?

5.1 When we share personal data, we do so in accordance with Data Protection Law. We may
share certain personal data, where necessary, with employees, contractors, consultants or
advisers, to facilitate sales and for general commercial purposes.

In addition, where necessary, your personal data may be shared:

5.1.1 with parties who provide products or services to us, such as software development,
data hosting, user analytics, email services, payment processing, advertising, user
notification and feedback functionality, delivery couriers, marketing companies who
help us manage our communications with you, data insight companies, etc.

5.1.2 with government or quasi-governmental organisations, law enforcement and other
regulatory authorities or third parties when required or permitted by law, including but
not limited to in response to court orders, for the prevention and detection of crime
and to protect intellectual property and any other legal rights.

5.1.3 if the company or business is sold, transferred or integrated with another business,
with our advisers, a prospective purchaser, a prospective purchaser’s advisers or the
new owner of the company or business to facilitate the process.

5.2 We may also provide third parties with aggregated but anonymised information and analytics
about our customers. Before we do so we will make sure that it does not identify you.

5.3 In some cases when we share personal data, it will involve the transfer of that personal data
to countries outside the UK which have different data protection standards to those which
apply in the UK.

5.4 Where we transfer personal data outside the UK, we will ensure that there are adequate
safeguards to protect your privacy rights under Data Protection Law. You can request a copy
of the safeguards we have put in place by contacting us using the details in paragraph 2
above.

6. THIRD PARTY LINKS

6.1 This Site may contain links to other websites over which we have no control. We are not
responsible for and do not review or endorse the privacy policies or practices of other
websites which you choose to access from this Site. We encourage you to review the privacy
policies of those other websites, so you can understand how they collect, use and share your
personal information.

7. YOUR RIGHTS

7.1 We respect your rights to privacy and will respond to requests for access or control over
information about you in accordance with Data Protection Law. We may require you to verify
your identity before we take any action.

7.2 Depending on the reason we have your personal data, you have a right to:

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7.2.1 access the personal information we hold about you (commonly known as subject
access);

7.2.2 request that we correct or complete personal information we hold about you that is
inaccurate or incomplete;

7.2.3 request that we erase your personal information in some circumstances, or object to
our processing it as detailed at paragraph 7.5;

7.2.4 restrict how we use your personal information, in certain circumstances;

7.2.5 request that we provide you with copies of your personal information in a machinereadable
format or transfer it across different services; and

7.2.6 where we have asked for your consent to process your data, to withdraw this consent.

7.3 These rights are limited in some situations under Data Protection Law – for example, where
we can demonstrate that we are under a legal obligation to process your data.

7.4 If you wish to exercise any of these rights, please contact us using the details in paragraph 2
above.

7.5 Your right to object

You have a right to object to our processing of your personal data and ask us to stop doing
so. If we are processing your personal data for direct marketing purposes (which includes
profiling to the extent that it is related to such direct marketing) and you object to this, we will
stop processing your personal data immediately.

If our processing of your personal data, including any profiling activities, is in the public
interest or pursuant to our legitimate interests and you object to this, we will stop processing
your personal data unless we have compelling reasons which override your interests, or our
use of your personal data is for the establishment, exercise or defence of legal claims.

7.6 We hope that we can satisfy any queries you may have about the way we process your data.
However, if you have unresolved concerns you also have the right to complain to data
protection authorities (in the UK, the Information Commissioner’s Office). You can call the ICO
on 0303 123 1113 or go to their website: https://ico.org.uk/make-a-complaint/).

8. DATA RETENTION

8.1 Your personal data will only be kept for as long as necessary for our purposes. Specific
retention periods are set out in the table at the end of this policy.

8.2 At the end of the specified retention periods, your personal data will either be securely
destroyed or anonymised, unless we are required to keep it to comply with our legal
obligations.

9. DATA PROTECTION PRINCIPLES

9.1 We process your personal data in accordance with the following principles:

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9.1.1 we process your personal data lawfully, fairly and in a transparent way;

9.1.2 we collect your personal data for specified, explicit and legitimate purposes; any
further processing we do is compatible with the original purposes for which we
collected it;

9.1.3 we only process personal data that is adequate, relevant and limited to what is
necessary to achieve the purpose for which it is processed;

9.1.4 we take reasonable steps to ensure that all personal data is accurate and kept up to
date where necessary;

9.1.5 we do not store personal data in a form that identifies you for any longer than is
necessary for the purposes of our processing; and

9.1.6 we process personal data securely and in a way that protects against unauthorised or
unlawful processing, accidental loss, destruction or damage.

9.2 When we ask for your personal data we will tell you whether you are required by law or
contract to provide it, and what will happen if you do not provide the data.

9.3 Any request for consent to the processing of your personal data will be made directly to you
and will include information about why we require the personal data and what will be done
with it.

10. WHAT IS OUR LAWFUL BASIS FOR PROCESSING?

10.1 We will only process personal data when we have a lawful basis for doing that processing.
The table at the end of this policy sets out the lawful basis we rely on for each type of data we
process.

10.2 We will choose one of the lawful bases in the UK GDPR to justify how we use your personal
data. These are:

10.2.1 Consent: You have given consent to the processing of your personal data for one or
more specific purposes. You have the right to withdraw your consent at any time, as
detailed in paragraph 7.2.

10.2.2 Contract: The processing is necessary for the performance of a contract with you or
to take steps at your request before entering into a contract.

10.2.3 Legal obligation: We need to process your personal data to comply with a legal
obligation.

10.2.4 Vital interests: The processing is necessary to protect the vital interests of you or
another person.

10.2.5 Public interest: Processing is necessary for the performance of a task carried out in
the public interest or in the exercise of some official authority.

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10.2.6 Legitimate interests: Processing is necessary for the purposes of legitimate interests
pursued by us or someone else, except where such interests are overridden by your
interests or fundamental rights and freedoms requiring the protection of your personal
data.

11. ATTRIBUTION

11.1 This privacy policy was created using a template from Sparqa Legal (https://www.sparqa.com),
02 July 2024.

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