1. Introduction

1.1 Ember Spirits is an alcohol brand and e-commerce business based at BLACKROCK, COUNTY DUBLIN, IRELAND.

1.2 For the purposes of this Privacy Policy, “we”, “us” and “our” refer to Ember Spirits, and “you”, “your” and “user” refer to the data subject.

1.3 For the purposes of applicable data protection law, Ember Spirits is the data controller of the personal data processed through this Website, unless otherwise stated.

1.4 Ember Spirits is committed to respecting your privacy and processing personal data lawfully, fairly, transparently and securely.

1.5 This Privacy Policy explains how Ember Spirits collects, uses, stores, shares and protects personal data when you use our Website, place an order, create an account, subscribe to communications, enter a promotion, contact us, or otherwise engage with our brand.

1.6 This Privacy Policy should be read together with our Website Terms & Conditions, Cookie Policy and any other policy or notice provided to you.

2. What Personal Data We Collect

Ember Spirits may collect and process the following categories of personal data:

• Identity information, including name, title and date of birth or age confirmation where required
• Contact information, including billing address, delivery address, email address and telephone number
• Account information, including username, password and order history
• Transaction information, including products purchased, payment status, order value and refund records
• Delivery information, including recipient details, delivery instructions and age-verification information where required
• Technical information, including IP address, browser type, device information, location data and Website usage information
• Marketing information, including newsletter preferences, communication preferences and campaign engagement
• Customer service records, including enquiries, complaints, returns, refund requests and correspondence
• Promotion or event information, where you enter competitions, promotions or brand activations

3. How We Collect Personal Data

We may collect personal data:

• Directly from you when you use the Website
• When you create an account
• When you place an order
• When you subscribe to marketing communications
• When you contact us
• When you enter a promotion, competition or event
• Through cookies and similar technologies
• From payment providers, delivery partners, age-verification providers, analytics providers and other service providers
• From public sources or third parties where lawful and relevant

4. Why We Use Personal Data

Ember Spirits may use personal data for the following purposes:

• To verify age eligibility and legal purchase requirements
• To process and fulfil orders
• To manage payment, refunds and transaction records
• To arrange delivery and logistics
• To communicate order updates
• To manage returns, refunds, complaints and customer support
• To prevent fraud, underage purchases, unlawful alcohol supply and misuse of the Website
• To comply with legal, tax, accounting, licensing and regulatory obligations
• To operate, maintain and improve the Website
• To analyse Website performance and customer experience
• To send marketing communications where permitted by law or where you have consented
• To manage promotions, competitions and events
• To protect Ember Spirits’ rights, property, systems, customers and users

5. Legal Bases for Processing

Where GDPR applies, Ember Spirits will only process personal data where there is a lawful basis to do so, including:

• Performance of a contract
• Compliance with a legal obligation
• Legitimate interests
• Consent
• Protection of vital interests, where relevant
• Any other lawful basis permitted under applicable data protection law

Marketing communications and non-essential cookies will be handled in accordance with applicable consent and ePrivacy requirements.

6. Age-Related Data and Underage Users

Because Ember Spirits sells alcohol, we may process age-related information to confirm that users and customers are legally permitted to access alcohol-related content, place orders, subscribe to alcohol-related communications or receive alcohol deliveries.

This may include:

• Date of birth
• Age confirmation
• Age-gate responses
• Delivery age-verification outcomes
• Records needed to demonstrate compliance

We do not knowingly sell alcohol to underage persons, market alcoholic beverages to underage persons, or knowingly collect personal data from anyone under the legal purchasing age.

If Ember Spirits becomes aware that personal data has been provided by a person under the legal purchasing age, we will take reasonable steps to delete or restrict use of that information, unless retention is required for legal, fraud-prevention or compliance purposes.

7. Cookies and Similar Technologies

Ember Spirits may use cookies and similar technologies to operate the Website, improve performance, remember preferences, analyse usage and support marketing activity.

Consent is normally required for cookies and similar technologies under Irish ePrivacy guidance, except where cookies are strictly necessary to provide a service requested by the user. Under GDPR, consent must be clear, affirmative, freely given, specific, informed and unambiguous.

Our Website should provide users with clear information about:

• The cookies or similar technologies used
• The purpose of each cookie category
• Whether cookies are necessary, analytics, preference-based or marketing-related
• How users can accept, reject or manage cookie preferences
• Where non-essential cookies are used, users should be able to:
• Accept all non-essential cookies
• Reject all non-essential cookies
• Manage cookie preferences by category

A separate Cookie Policy may be provided on the Website.

8. Direct Marketing

Ember Spirits may send direct marketing communications where you have opted in or where otherwise permitted by applicable law.

You may unsubscribe from marketing communications at any time by using the unsubscribe link in the communication or contacting us at [insert email address].

Because Ember Spirits is an alcohol brand, marketing communications should only be directed to persons who are legally permitted to receive alcohol-related marketing in their jurisdiction.

9. Sharing Your Data

Ember Spirits may share personal data with trusted third parties where necessary, including:

• Revolut and other payment providers
• Celtic Whiskey Shop, where necessary for order fulfilment and delivery
• Delivery and logistics partners
• Age-verification providers
• Website hosting providers
• IT and cloud service providers
• E-commerce platform providers
• Analytics and cookie providers
• Marketing and email service providers
• Business providers, suppliers and contractors who help us provide our products, services or Website
• Professional advisors
• Regulators, authorities or law enforcement where required
• Business partners where necessary for lawful brand, event, distribution or fulfilment purposes

Service providers are expected to process personal data securely and only for authorised purposes.

Where required, Ember Spirits will ensure appropriate processor agreements or safeguards are in place with third-party service providers.

Ember Spirits will not sell your personal data.

10. International Transfers

Where personal data is transferred outside Ireland, the European Economic Area or the United Kingdom, Ember Spirits will take reasonable steps to ensure that appropriate safeguards are in place, as required by applicable data protection law.

11. Data Retention

Ember Spirits will retain personal data only for as long as necessary for the purposes for which it was collected, including:

• Order fulfilment
• Customer support
• Legal and regulatory compliance
• Tax and accounting records
• Fraud prevention
• Age-verification compliance
• Dispute resolution
• Marketing, where consent remains valid or until you unsubscribe

When personal data is no longer required, Ember Spirits will delete, anonymise or securely dispose of it.

12. Your Data Protection Rights

Subject to applicable law, you may have the right to:

• Access your personal data
• Correct inaccurate personal data
• Request deletion of personal data
• Restrict processing
• Object to processing
• Withdraw consent
• Request data portability
• Lodge a complaint with a supervisory authority

To exercise your rights, contact: socials@emberspirits.com.

13. Safeguarding Personal Data

Ember Spirits will take reasonable technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration or destruction.

These measures may include:

• Secure hosting
• Access controls
• Encryption where appropriate
• Internal confidentiality controls
• Staff and service provider access restrictions
• Secure payment processing via Revolut
• Incident response processes

14. Data Breaches

If a personal data breach occurs, Ember Spirits will assess the breach and take appropriate action in accordance with applicable data protection law.

Where required, Ember Spirits will notify the relevant supervisory authority and affected individuals.

15. Privacy Contact

For privacy-related questions, requests or complaints, please contact:

Ember Spirits Privacy Contact:
socials@emberspirits.com
+353 83 742 9185
BLACKROCK, COUNTY DUBLIN, IRELAND

16. Updates to This Privacy Policy

This Privacy Policy may be updated from time to time.

The latest version will be published on the Website with the applicable effective date.

COOKIE POLICY NOTE

Ember Spirits may use a separate Cookie Policy to explain how cookies and similar technologies are used on the Website.

The cookie banner should allow users to:

• Accept all non-essential cookies
• Reject all non-essential cookies
• Manage cookie preferences
• Strictly necessary cookies may be used where required for the Website to function.

Non-essential cookies, including analytics, advertising, tracking and preference cookies, should not be activated unless the user has provided valid consent, where required by applicable law.

ENJOY RESPONSIBLY

Please enjoy Ember Spirits responsibly.

Ember Spirits is committed to promoting its products in a responsible way and to communicating with customers and consumers who are of legal purchasing age.

We support responsible alcohol consumption and aim to ensure that our marketing, sales activity, website content, promotions and brand communications are created for an audience of legal purchasing age and above.

Ember Spirits does not encourage underage drinking, excessive consumption, drinking and driving, or any unsafe or unlawful use of alcohol.

For more information on responsible drinking, please visit Drinkaware.ie.