This privacy policy (“Privacy Policy”) applies to personal data that we collect from you as a user of this Site or as a membership applicant, member or customer (“you” or “your” being interpreted accordingly). It provides information on what personal data we collect, why we collect the personal data, how it is used and the lawful basis on which your personal data is processed, and what your rights are under the applicable data protection and privacy laws, including the Personal Data Protection Act 2012 (“PDPA”) which became applicable to us and you as of 01 April 2023. ‘Personal data’ as used in this Privacy Policy means any information that relates to you from which you can be identified. By using our Site or submitting your personal data you are taken to accept the terms of this Privacy Policy, so please read it carefully.

Membership Application: The personal details you provide when submitting a membership application. This includes your name, address, e-mail address; business address and phone number; gender and date of birth; country; potentially a picture of yourself; information about your work and other information that you elect to provide to support your application.

• Reservation Information: Personal data collected in relation to reservations, such as your first and last name, email address, billing and payment information (for further details please also refer to the section below headed “Payment Information”) will be processed in accordance with a privacy policy provided at the time of requesting a reservation or booking so please ensure that you read our privacy notice on the reservation website that we may provide to you when we collect or process your personal data.

• Other Information: Personal details you choose to give when corresponding with us by phone or e-mail, participating in user/customer/member surveys or otherwise visiting and interacting with this Site or any other websites we operate, and personal data that you provide to us when you visit our Club.

• Log Data: When you visit our Site, our servers record information (“log data”), including information that your browser automatically sends whenever you visit the Site. This log data includes your Internet Protocol (“IP”) address (from which we understand the country you are connecting from at the time you visit the Site), browser type and settings, the date and time of your request.

• Our Site uses cookies (small text files placed on your device) and similar technologies to distinguish you from other users. This is to provide you with a good user experience when you browse our Site and allows us to improve its features. For detailed information on the cookies and similar technologies we use, please see our cookie policy.

We use your personal data in the following ways:

• To acknowledge, confirm and deal with your membership application (and where necessary put you on our waiting list). Such use of your data is necessary in order to implement your request to become a member.

• Where you are a member, provide you with membership services, administer your membership account and contact you regarding your use of the services. Such use is necessary to respond to or implement your request and for the performance of the contract between you and us.

• To complete and fulfil your reservation, for example to process your payment and provide you with related customer service. Such use is necessary for the performance of the contract between you and us.

• To contact you in connection with user/customer/member surveys and use any information you choose to submit in response, provided that you gave us your consent to being contacted in this way at the time you provided us with the personal data.

• The Grande Whisky Museum may provide you, or permit selected third party service providers to provide you, with information about goods or services, events and other promotions we feel may interest you as a member or membership applicant. We (or such third party providers) will contact you by email only with your consent, which was given at the time you provided us with the personal data.

• As necessary for certain legitimate business interests, which include the following:

- where we are asked to deal with any enquiries or complaints you make.

- to administer our Site, to better understand how visitors interact with our websites and ensure that our Site is presented in the most effective manner for you and for your computer/device.

- to conduct analytics to inform our marketing strategy and enable us to enhance and personalise the experience we offer to our members and our communications, including by creating customer or member profiles to enable personalised direct marketing communications.

- to provide postal communications which we think will be of interest to you.

- if you ask us to delete your data or to be removed from our marketing lists and we are required to fulfil your request, to keep basic data to identify you and prevent further unwanted processing.

- to share personal data among our affiliated businesses for administrative purposes, for providing membership services and in relation to our sales and marketing activities.

- we may anonymise, aggregate and de-identify the data that we collect and use such anonymised, aggregated and de-identified data for our own internal business purposes, including sharing it with our current and prospective members, business partners, our affiliated businesses, agents and other third parties for commercial, statistical and market research purposes, for example to allow those parties to analyse patterns among groups of people, and conducting research on demographics, interests and behaviour.

- for internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our Site, network and information systems secure.

- to

(a) comply with legal obligations,

(b) respond to requests from competent authorities; enforce our Club Rules

(c) protect our operations or those of any of our affiliated businesses;

(d) protect our rights, safety or property, and/or that of our affiliated businesses, you or others; and

(e) enforcing or defending legal rights, or preventing damage.

• We may use your personal data for other purposes which you have consented to at the time of providing your data. As used in this Privacy Policy, “legitimate interests” means the interests of Soho Whisky Club in conducting and managing our organisation. When we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object at any time to processing of your personal data that is based on our legitimate interests, on grounds relating to your particular situation (for more information on your rights, please see “Your Data Protection Rights” section below).

We may arrange that card or payment data you submit in support of any booking or application is stored for the purpose of processing your booking and application. For membership application fee, if your initial application is successful (or if you are put on to a membership waiting list, please note that this data may be stored for later use to initiate your membership and subscription). We store and use this card or payment information for the purpose of processing any future payments that you make as a member for additional goods and services. We will store this data in accordance with our legal obligations under applicable law and only for so long as legally permitted. You may choose to opt out of us holding your card or payment data although this means that you will need to re-supply us with card/payment details to initiate your membership subscription fee or for the purpose of making any future purchases.

Unfortunately, the transmission of information over the internet or public communications networks can never be completely secure. We will take appropriate technical and organisational security measures to protect the personal data that you submit to us against unauthorised/unlawful access or loss, destruction or damage, although we cannot 100% guarantee the security of personal data that you provide to us online.

We will keep your personal data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy, or for the duration required by any legal, regulatory, accounting or reporting requirements, whichever is the longer. In particular, we retain membership records for one year after expiration or termination of your membership. We retain information submitted through the Site and the other websites we operate for one year following account closure or contact with you, as applicable. When you consent to receive marketing communications, we will keep your data until you unsubscribe. To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the purposes for which we process your personal data, applicable legal requirements or operational retention needs, and whether we can achieve those purposes through other means. Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data.

Certain applicable data protection laws give you specific rights in relation to your personal data. In particular, if the processing of your personal data is subject to the PDPA, you have the following rights in relation to your personal data:

• Right of access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data along with certain other details such as the purpose of the data processing. If you require additional copies, we may need to charge a reasonable fee.

• Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your personal data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.

• Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your personal data in certain circumstances, such as where you contest the accuracy of the personal data or object to us processing it. We will tell you before we lift any restriction on processing..

• Right to object: You may ask us at any time to stop processing your personal data, and we will do so:

a) If we are relying on a legitimate interest to process your personal data — unless we demonstrate compelling legitimate grounds for the processing or

b) If we are processing your personal data for direct marketing.

• Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.

Any changes we may make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or modifications. If required by the applicable law, we will notify you of any material or substantive changes to this Privacy Policy.