Privacy Policies - Hong Kong

Last updated: 21 April 2026

The Privacy Policy applies to consumers of our brands.

If you are acting in another capacity, please see our corporate privacy policy here. If you are a prospective candidate, please refer to our recruitment privacy polices here.

This Privacy Policy applies in Hong Kong. If you are based within another jurisdiction, please see our global privacy policy to locate the relevant privacy policy for your region. 

WHO WE ARE

Edrington is the home of exceptional spirits with a portfolio of some of the world’s best-loved Scotch whiskies and other spirits. Our brands can be found here and our ultimate parent company, is The Edrington Group Limited, a private limited company (registered in Scotland No.SC036374), having our registered office at 100 Queen Street, Glasgow, G1 3DN. Processing of personal information for our brands’ consumers as described in this Privacy Policy is undertaken by The Edrington Group Limited and other group companies where relevant. Please refer to this link for further details.

Edrington is the controller for the processing of your personal information and we have a data privacy manager who is responsible for overseeing questions about this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your rights in relation to your personal information, please contact us at the details set out below. 

In this Privacy Policy the relevant Edrington group companies are referred to as Edrington, we, us or our. 

OVERVIEW 

Edrington is committed to protecting and respecting the privacy of our consumers’ personal information and complying with the obligations under data protection laws (including the Personal Data (Privacy) Ordinance (PDPO) applicable to the processing set out in this Privacy Policy (Data Protection Laws). Looking after our consumers’ personal information is a priority for us and we want you to be confident that your information is in safe hands. We’ve developed this Privacy Policy to let you know:

• What types of personal information we collect;
• How we collect personal information;
• The purposes we collect personal information for, including how we use it to make our products better and to offer better services and experiences to our consumers;  
• The circumstances in which we may share it with other organisations that support our operations, including the types of organisations involved;
• Where we store your personal information;
• How long we keep personal information for; and
• The rights and choices you have with regards to your personal information.

It is important that you read this Privacy Policy together with any other privacy policy or notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your personal information. This Privacy Policy supplements other notices and privacy policies and is not intended to override them, unless expressly specified otherwise.  

By providing us with your personal information, you acknowledge that our collection, use, disclosure and processing of your personal information will be in accordance with this Privacy Policy, including, for the avoidance of doubt, the cross jurisdictional transfer of your information. If you object to how we will collect, use, disclose, process and/or share your personal information as set out in this Privacy Policy, please DO NOT provide any personal information to us. 

WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT ABOUT OUR CONSUMERS? 

• Your name, age/date of birth (including for age verification and due diligence purposes), home location(s) and a visual inspection of your identification documentation may be required for due diligence checks;
• Your contact details: postal addresses including billing and delivery addresses, contact telephone numbers and email address;
• Details about payments to and from you and other details of purchases, orders made by you, including your purchase history and ballots you have submitted for the purchase of our products. This also includes tracking purchases that you have made on the resale market;
• When you make a purchase or place an order with us, your payment card details to the extent permitted by applicable law;
• Details of any event or experience bookings you have made, including details you have provided or we have collected from you in connection with your attendance at any events or experiences we have arranged with you (such as any accessibility or dietary requirements or other interests related to the event or experience);
• If we are required to carry out due diligence, details of any criminal convictions or sanctions, to the extent permitted under applicable law, illegal activity, adverse media or whether you are a politically exposed person, which is publicly available;
• Your internet protocol (IP) address, your login data, 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 the website (Technical Data);
• Information about how you use our websites, products and services (Usage Data);  
• Your correspondence and communications with us;
• Personal information, which you have maybe shared via a public platform (such as on our social media feeds);
• Your preferences in receiving marketing from us and our third parties (whether within or outside Hong Kong) and your communication preferences;
• Your image may be captured on CCTV when you visit any of our distilleries / other experiential retail premises and at events or experiences you attend where filming or photography is taking place for promotional activities, which may be used on our brands’ global owned channels and by third party press unless you have notified us otherwise;
• Information which may be collected or generated by our customer engagement personnel and/or representatives, or when you participate in an online experience, such as:
  • preferences regarding our products and offerings including any "wish list" items regarding preferred products and experiences and how you share your experiences and passion for our brands with others;
  • lifestyle preferences and interests such as preferred travel destinations, preferred restaurants / cuisines and whisky and drink preferences / collection;
  • social indicators such as your profession and connections;
  • engagement data such as when you open or click on our emails, how long you have been a consumer of our brands, and how you interact with our personnel / representatives;
  • communication channel preferences (e.g. social media handles and app-based messaging) such as LinkedIn, Facebook, Twitter, WeChat and WhatsApp;
  • your behaviours insofar as they impact our brands, including compliance with our brands’ terms and conditions of sale (please see the relevant brand website) and behaviour at events and online;
• Information about any experiences, gifts, special invitations or benefits made available to you;
• Your feedback and survey responses; and
• Online browsing activities on our websites. 

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 information but is not considered personal information in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Policy.

Other than the data listed above, we do not collect any special categories of personal data or sensitive personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions or affiliations, trade union membership, information about your health, biometric or genetic data).

Please note that you are not legally required to provide Edrington with your personal information, and any personal information you provide us, is provided of your own free will and consent. Where we need to collect personal information by law, under the terms of a contract we have with you, and you fail to provide or choose to refrain from providing that information when requested, we may not be able to engage with you, perform the contract we have or are trying to enter into with you (e.g. to provide you with goods or services) or properly handle your requests. In this case, we may have to cancel a purchase or experience you have with any of our brands but we will notify you if this is the case at the time.  

HOW DO WE COLLECT YOUR PERSONAL INFORMATION? 

We collect your personal information by different methods, including: 

• Direct interactions: This includes personal information you provide when:
  • You subscribe to receive our newsletters;
  • You subscribe to a brand’s LINE channel in Taiwan;
  • You create an account on our website or participate in one of our online experiences;
  • You make an online purchase or place an order online for a product or merchandise;
  • You enter a ballot or competition related to our brands or one of our products;
  • You attend one of our events, visit one of our sites (e.g. our distillery) or one of our experiences (e.g. whisky tastings, dinning and food, and other bespoke or exclusive experiences);
  • You interact with one of our Private Client Relationship Managers (PCRMs), brand ambassadors or other representatives;
  • You communicate with us through telephone, text messaging, or other app-based or social media direct messaging;  
  • You provide your information to us at one of our boutiques or retail outlets, such as at airports; and  
  • You contact us, for whatever reason.
• Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We may also gather statistical information on emails sent to you (e.g. opens, clicks, delivery rates, unsubscribes and forwards). This helps us to assess and improve email performance and our engagement with you. We collect this personal information by using cookies, pixels and other similar technologies. Please see the cookies policy on the relevant brand’s website for further details.
• Third party sources of information: We may obtain information about you from the following third-party sources:
  • Where you interact with a third-party acting on our behalf (e.g. a representative of one of our distributors, joint venture partners, airport boutique operators and retailers);
  • Our professional advisors (e.g. lawyers, accountants and bankers);  
  • Publicly available sources (e.g. how you share your experiences and passion for our brands with others on social media); and
  • Where we carry out customer due diligence, we use a third-party due diligence screening provider who searches publicly available information.
• Technical Data: We also collect Technical Data from the following third-parties:
  • Analytics providers (such as Google based outside the UK and/or EU);
  • Advertising networks;  
  • Search information providers; and
  • Due diligence screening providers.
• Social logins: Where you use your social media accounts to create an account and log in to our brands’ websites, you give the social media provider (such as Google, Apple and Meta) permission to share your personal information with us for this purpose. 

ONLINE ANALYTICS 

We use various types of online analytics, including Google Analytics, a web analytics service provided by Google, Inc. (Google), on our website. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the website, compile reports on the related activities, and provide other services related to website and app activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website or app. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google click here.

SURVEYS

From time to time, and subject to your consent where required by applicable local law, we may provide you with the opportunity to participate in surveys, some of which might be sponsored or conducted by a third party. Participation in these surveys is completely voluntary. If you choose to participate, we will request certain personal information from you. If there is a third-party sponsor involved in the survey, we may provide certain personal information to the third-party sponsor. Please make sure to review the sponsor’s privacy policy and be aware that any surveys offered by us may be governed by specific rules and terms and conditions that are separate from and in addition to this Privacy Policy. By participating in any such surveys you will become subject to those rules, including but not limited to receiving emails containing survey communications. 

HOW DO WE USE YOUR PERSONAL INFORMATION? 

Edrington (and trusted partners and service providers acting on our behalf) use your personal information: 

• To provide you with information, products or services that you request from us, or which we feel may interest you. This is only done when you’ve given your consent to be contacted by us, or where we are permitted to contact you in accordance with Data Protection Law (such as where you have not opted out of receiving such information from us at the time of making a purchase from us);  
• To send you personalised communications based on your preferences, and engagement with our brands, products, services or experiences;
• To verify your identity and your age;
• Where you make a purchase above a certain value or we have or are building a relationship with you, carry out due diligence checks using our third-party due diligence system;
• For crime and fraud prevention, detection and related purposes;
• To enable our brands to manage any customer service interactions with you;
• To ensure compliance with our brands’ terms and conditions of sale and protection of our brands and products;
• To ensure that our web content is presented in the most efficient way for you and your computer;
• To allow you to participate in interactive features on our website, when you choose to do so; and  
• Where we have a legal right or duty to use or disclose your information (e.g. in relation to an investigation by a public authority or in a legal dispute).  

We may also combine your personal information collected through various sources, including information collected through our website and services, and develop a profile that will be used for the purposes above. 

Marketing communications

By signing up to receive communications from our brands, you may automatically be assigned preferences to receive email communications on topics such as:

• Partnerships
• Product releases
• Events
• Experiences
• Regional communications
• Distillery updates

Where provided by a brand, you can review what types of communications you have been assigned to receive and update them at any time (e.g. to only receive emails on whisky releases) via the brand’s communications preference centre by logging into your account (where provided) on the brand’s website. 

UNDERSTANDING OUR CONSUMERS BETTER 

Edrington will also use the personal information that we receive or collect about certain of our consumers to understand our consumer profile better and to engage with our consumers more effectively.

This will involve using this personal information to consider our consumers’ preferences, characteristics, interests and activities, purchase habits and engagement with our brands and products. In identifying this information, we will use it to better understand the habits, preferences and profiles of our most valued consumers and to identify categories of valued consumers that we can better engage with and better tailor their experience of our products and brands.

Based on this better understanding of our most valued consumers, Edrington will determine how we can improve the products, services and experiences it makes available to its consumers, how we can improve our interactions and engagement with consumers, and to assess eligibility of our most valued consumers for special invitations, experiences, and other benefits.  

This processing may continue so long as you have a relationship with Edrington. This means that the way in which we provide products and services to you, interact and engage with you, or provide any special invitations, experiences and benefits to you, may change over the course of our relationship with you.  

You can ask us at any time to stop sending you marketing communications or using your personal information for marketing purposes (including profiling) at any time. Please see “What are your rights?” for further details. 

USE OF PERSONAL INFORMATION FOR DIRECT MARKETING

In connection with direct marketing, we may use your personal information collected in the section “What types of personal information do we collect about our consumers?” above for marketing and promotional purposes, including delivering to you information about any good and services, updates on latest news, offers and promotions or marketing materials in connection with our products and services.  

If we intend to use your personal information for direct marketing purposes, we will first obtain your written consent (or an indication of no objection) for those purposes.

If you do not wish us to use or provide your personal information to third parties for use in direct marketing as described above, you may exercise your opt-out right by notifying us.

If you decide that you no longer want to receive direct marketing materials after giving us your consent, please let us know by contacting our data privacy manager at [email protected]. 

WHAT IS OUR LEGAL REASON FOR HOLDING YOUR PERSONAL INFORMATION? 

Data Protection Laws may require us to state our legal reason for processing your personal information.    

Where we have requested your consent, we will rely on this consent to send you marketing communications about Edrington. Where permitted by applicable law, we may also send you marketing communications about Edrington where you have requested information from us or made a purchase and you have not opted out of receiving such communications.  

You can withdraw your consent to, or opt out of, receiving these communications at any time by using the unsubscribe button in communications we send you, contacting one of our brand representatives or using the details in the “How to contact us” section below. Where you opt out of receiving marketing communications, this will not remove any personal information provided when you made a purchase.

Where permitted by applicable law, Edrington also collects and uses your personal information because it is necessary for:

• the pursuit of our legitimate interests (as set out below);
• the purposes of complying with our duties and exercising our rights under a contract for the sale of goods or services to a consumer; or
• complying with our legal and regulatory obligations. 

Our legitimate interests

A common legal basis for processing consumer personal information, where applicable, is that it is necessary for Edrington’s legitimate interests, including: 

• selling and supplying goods and services to our consumers;
• protecting consumers, employees and other individuals and maintaining their safety, health and welfare;
• promoting, marketing and advertising our products, services, events, experiences and brand partnerships;
• understanding our consumers’ behaviour, activities, preferences, and needs, including profiling;
• improving existing products and developing new products;
• providing experiences, special invitations and other benefits to our most-valued consumers;
• protecting our brands, which may involve noting negative consumer behaviour towards our brands;
• handling consumer contacts, queries, complaints, or disputes;  
• administrative purposes (accounting, risk management and record keeping, business research, data, planning and statistical analysis and staff training); and
• preventing, investigating and detecting crime, fraud, or anti-social behaviour and prosecuting offenders, including assisting authorities with such investigations.   

Where we process your personal information in pursuit of our legitimate interests, we will ensure that this in accordance with your rights set out below, including your right to object to us using your personal information for the above purposes. If you wish to object to any of the above processing, please contact us by using the details in the “How to contact us” section below. If we agree and comply with your objection, this may affect our ability to undertake the tasks above for your benefit. Please see “What are your rights?” for further details.

Where applicable laws require us to in certain regions, we will rely on your consent as the ground to process your personal information for these purposes, rather than legitimate interests.

COOKIES 

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 our websites may become inaccessible or not function properly. For more information about the cookies we use please see the cookies policy on the relevant brand’s website for further details. 

CHANGE OF PURPOSE 

We will only use your personal information for the purposes for which we collected it, unless the law permits us and we reasonably consider that we need to use it for another reason, which is compatible with the original purpose. If you require any further information on how the new purpose is compatible with the original purpose, please contact us using the details below.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so and request for your consent where required. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

WHAT ARE YOUR RIGHTS? 

You may have rights under applicable Data Protection Laws in relation to the way we process your personal information for some of the purposes identified above in this Privacy Policy. These rights are set out below, however not all these rights will apply under the Data Protection Laws in your region:

• to access your personal information (commonly known as a “data subject access request”) – this enables you to access the personal information we hold about you and to receive confirmation of how we are processing it;
• to have your personal information rectified if it is inaccurate, incomplete, unclear or outdated – this enables you to have any incomplete, inaccurate, unclear or outdated personal information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us;
• in certain circumstances, to have your personal information deleted or removed – this enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Please note however, that we may not always be able to comply with your request of erasure for specific legal reasons (or, where applicable, if it is not feasible or suitable) which will be notified to you, if applicable, at the time of your request;
• in certain circumstances, to restrict the processing of your personal information – this enables you to ask us to suspend the processing of your personal information in the following scenarios:
  • if you want us to establish the personal information’s accuracy;
  • where our use of the personal information is unlawful but you don’t want us to erase it;
  • where you need us to hold the personal information 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 personal information (see below) but we need to verify whether we have overriding legitimate grounds to use it,
• a right of data portability, namely to transfer your personal information to a third party. We will provide to you, or a third party you have chosen, your personal information 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 personal information to perform a contract with you;
• to object to the processing of your personal information where we are relying on a legitimate interest (or those of a third party) and in other specific circumstances where permitted under applicable Data Protection Laws. You also have the right to object where we are processing your personal information for direct marketing purposes (or, subject to applicable Data Protection Laws, where you have a reasonable expectation that the personal information would not be processed in the manner you envisage). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
• not to be subject to automated decision-making (including profiling), where it produces a legal effect or a similarly significant effect on you;  
• the right to withdraw your consent at any time where we are relying on consent to process your personal information. 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent;  
• the right to lodge a complaint with a relevant authority; and
• to claim compensation for damages caused by a breach of the Data Protection Laws. 

If you wish to exercise any of these rights, please contact us by using the details in the “How to contact us” section below. 

WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH? 

To effectively fulfil our obligations to you, and to provide you with marketing and certain experiences, special invitations and benefits, we use trusted and reliable third-parties (including within or outside Hong Kong) to carry out functions, which involve your personal information. These include:

• vendors who process your personal information on our behalf and under our written instructions to carry out their services during our business, such as IT service providers, financial institutions, customer relationship management vendors marketing service providers, and other cloud-based solutions providers that are used by Edrington in the conduct of our business. We contract with such vendors to ensure that they only process your personal information under our instructions and ensure the security and confidentiality of your personal information by implementing appropriate technical and organisational measures for such processing. Some of our vendors may use AI to support our services but this will not process your personal information;
• vendors that process your personal information to assist us to better understand our consumers and how we can improve our consumer engagement, such as HubSpot, Wunderman Thompson, and Salted Stone;
• when you order products or services from our online shop, we will share your details with our fulfilment partners (currently Kerry Logistics (Hong Kong) Ltd.), who will process your orders as set out in our brands’ terms and conditions of sale;
• where you make a purchase above a certain value or we have or are building a relationship with you, we will share your name and date of birth with our due diligence service provider to carry out due diligence checks;
• when you contact us and interactions with you are handled by our third-party technical services partner, Huntswood;
• marketing service providers that administer services on our behalf, such as sending communications to our consumers, administering any promotions or ballots which we run;
• translation service providers that administer services on our behalf, such as translating communications received and sent in different languages;
• other agencies and fulfilment partners to administer events, competitions, experiences, brand programmes and other special invitations and benefits;
• where you have given your specified consent, we will share your personal details with our airport boutique operators – presently WDFG UK Limited (DUFRY), Maritime & Mercantile International LLC (Le Clos), Ever Rich DFS Corporation, DFS Group Limited and UETA, Inc – to allow you to receive marketing communications from them;
• our professional advisors (e.g. lawyers, accountants and bankers);
• other entities in Edrington group of companies; and
• Edrington’s third party distributors and joint venture partners. 

Please note that where applicable Data Protection laws require consent for sharing your personal information, by agreeing to this Privacy Policy, you provide such consent for the disclosure of your personal information.

We may provide information to others (such as governmental or law enforcement agencies or authorities) in the good faith belief that such action is necessary to: (i) enforce or apply our brands’ terms and conditions of sale; (ii) comply with any legal claims raised against Edrington; (iii) protect the rights, property or safety of Edrington; (iv) protect the rights, property or safety of the public; or (v) assist with investigations to prevent and detect crime, fraud or anti-social behaviour.

In accordance with applicable law if Edrington becomes involved in a merger, consolidation, acquisition, change in control, bankruptcy, reorganisation, liquidation or other transaction involving the sale of some or all our business or assets, user information, including personal information collected from you through your use of our website, could be included in the transferred business or assets. Should such an event occur, we will use reasonable means to notify you, either through email and/or a prominent notice on our websites.  

WHERE WE STORE YOUR PERSONAL INFORMATION 

We share your personal information within the Edrington group, which involves transferring your personal information outside of your region to other offices and organisations within our corporate group. Further, we may transfer your personal information outside Hong Kong to allow us to: 

• receive consultancy, marketing and IT services (e.g. cloud storage services, database development and management services, email/webmail services and customer relationship management services) from vendors located outside Hong Kong, such as the UK, EU, US, South Africa and Australia; and
• provide special invitations, products, services, experiences and other benefits to you, from other Edrington group companies, or selected third-party distributors, joint venture partners, or airport boutique operators. 

Where your personal information is transferred internationally, we will ensure your personal information is afforded an adequate level of data protection (as required by Data Protection Laws), including: 

• by obtaining your consent to the cross jurisdictional transfer of your information as set out above (or otherwise in accordance with one of the other transfer conditions in the PDPO, which has been satisfied);
• by transferring the information to a country that the relevant authorities have deemed as providing an adequate level of data protection (an “adequacy decision”);
• by implementing an appropriate international transfer mechanism under Data Protection Law, such as standard contractual clauses or a data transfer agreement / addendum approved for this purpose by the relevant authorities;
• by relying on a “transfer derogation” under Data Protection Law (e.g. where the transfer is based on your explicit consent, or is necessary to perform a contract with you); or
• where we are otherwise permitted to make the transfer under Data Protection Law. 

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal information internationally. 

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?  

We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Policy, including for the purposes of maintaining our relationship with you as well as satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.  

To determine the appropriate retention period for personal information, we consider any ongoing relationship we have with you, the likelihood you may want to make a further purchase from us in the future, the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.  

When we no longer need to use your personal information, we will remove it from our systems and records, and or take steps to anonymise it so that you can no longer be identified from it (unless we need to keep your personal information to comply with legal or regulatory obligations we are subject to).

In certain circumstances, you can ask us to delete or remove your personal information (see the section entitled “What rights do you have?” above for further information on your rights).

We may also use your personal information collected by recording phone calls and retaining a transcript of our live chats with you through our brands’ websites (including where these are handled by Edrington’s third-party technical services partners) for the following purposes:

1.  Account management;
2. Prevention, detection, investigation and prosecution of fraud;
3. Complaint handling and resolution;
4. Measuring the quality of the call;
5. Internal training on call handling. 

We have a legitimate interest in retaining calls and live chats to offer our consumers a good service and to protect our business. If you object to the call recording, you may choose to end the call when you are informed that calls may be recorded.  If you use our live chat function to get in touch with us, you will be informed that we will keep a record of the discussion at the start of the chat and you will be able to end the chat at any time.  You will have the option to contact us through alternative means. All calls and live chat records will be retained for a period of one year. 

HOW DO WE PROTECT YOUR PERSONAL INFORMATION? 

Edrington is committed to keeping your personal information safe and secure.  To prevent unauthorised access, maintain data accuracy and ensure the correct usage of personal information, we monitor and adjust our physical, electronic and managerial procedures to safeguard and secure the personal information we collect online. 

THIRD-PARTY WEBSITES AND APPS 

Our website and services may contain links to other websites or apps operated by third-parties. Please be advised that the practices described in this Privacy Policy do not apply to information gathered through these third-party websites and apps. We have no control over, and are not responsible for, the actions and privacy policies of third-parties and other websites and apps. 

HOW TO CONTACT US 

If you have any questions or concerns about the way in which your personal information is processed, please contact the relevant brand at the following details: 

• The Macallan ([email protected])
• Highland Park ([email protected])
• The Glenrothes ([email protected])
• Brugal ([email protected])
• Wyoming Whiskey ([email protected]) 

Our global data privacy manager can be contacted at [email protected]. If you are based in India, you may contact our grievance officer with any inquiry relating to this Privacy Policy or your personal information. Contact details for our India grievance officer are provided in the Complaints section below. 

COMPLAINTS

You have the right to complain about data protection matters to the Office of the Privacy Commissioner for Personal Data (PCPD) or to any other data protection regulator or authority having jurisdiction over us.

The PCPD was established under the PDPO as the dedicated data privacy regulator. You can find out more about the PCPD on its website (pcpd.org.hk). The PCPD can be contacted by calling 2827 2827.

We would however appreciate the chance to discuss and work with you to address your concerns before you approach the PCPD or another regulator, so please contact us in the first instance.

CHANGES 

Edrington may update this Privacy Policy from time to time as our privacy practices change, or as required by applicable legal or regulatory requirements. Where it is practicable, we will notify you of any significant changes. However, the last update date is given below and Edrington encourages you to review this Privacy Policy periodically so you remain informed of how we use your personal information.