Privacy Policy

PRIVACY POLICY

Policy version: 24/03/2026

This is DrinksBox Limited's ("we"/"us"/"our"/"DrinksBox") data protection and privacy policy that explains who we are, and how and why we process your personal information (also referred to here as personal data) through your use of our website, https://www.drinksbox.com including any sub-domains (together, the “Website”).

We may collect personal information when you contact us with enquiries, request a meeting, subscribe to our newsletter, or otherwise interact with the Website.

We are the controller in relation to the personal data processed in accordance with this policy (except where this policy explains otherwise) meaning that we are responsible for deciding how we hold and use your personal data. This policy sets out your rights in relation to our processing of your personal data and how to contact us if you need to.

This policy sets out:

  • How we collect information about you

  • How we use your information

  • Who we give your information to

  • Where we store your information

  • How we protect your information

  • How long we keep your information

  • Your rights

  • Third-party links

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. The Website is not intended for children and we do not knowingly collect data relating to children.

How we collect information about you

Personal data means any information about an individual from which that person can be identified.

We use different methods to collect personal data from and about you including through:

  • Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

    • subscribe to our services, publications or newsletters;

    • request marketing to be sent to you;

    • enter a competition, promotion or survey;

    • request a meeting or submit a booking enquiry; or

    • give us feedback or contact us.

  • Automated technologies or interactions. As you interact with the Website, we will automatically collect information about your equipment, browsing actions and patterns.

  • Information from third parties or publicly available sources. We may receive personal data about you from third parties and publicly available sources where this is necessary to provide our services, including where you act on behalf of a supplier, buyer or other organisation that interacts with us.

Much of the personal data we process relates to individuals acting on behalf of suppliers, buyers or other organisations that use the Website. References to “you” in this policy may therefore include individuals interacting with us in a professional capacity on behalf of their employer or organisation.

Personal data relating to you that we process

We collect, use, store and transfer the following different kinds of personal data when you interact with the Website. Often this information will relate to your employer:

  • Identity Data includes first name, last name, who you work for, your role or job title, and any other identifying information where required.

  • Contact Data includes your email address, telephone numbers or other contact details. These details may relate to your work or to you personally, depending on the nature of our relationship with you or the company that you work for.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences, and records of communications with us including enquiries, feedback and support requests.

    When you browse the Website we may also automatically collect, use and share:

  • Technical Data includes 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, device ID and other technology on the devices you use to access the Website.

  • Usage Data includes information about how you use the Website, including interactions with, account activity and features used on the Website.

As far as possible this data is aggregated, statistical or demographic data which is not personal data as it does not reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the Website and our service offering. We use cookies to understand site usage, maintain functionality, and improve performance. Our use of cookies and other similar technologies to process personal data is explained in our Cookies Policy.

We will also receive personal data about you from various third parties as set out below:

  • Technical Data is collected from the following parties:

    • analytics providers;

    • advertising networks; and

    • search information providers.

  • Identity and Contact Data is collected from data brokers or aggregators.

  • Identity and Contact Data is collected from publicly available sources or from third parties acting on behalf of suppliers, buyers and other organisations using the Website.

Where you provide personal data about another individual (for example where you act on behalf of a supplier, buyer or other organisation), you must ensure that you have the authority to provide that information and that the individual has been informed of this privacy policy and how their personal data will be used.

How we use your information

Lawful basis

The law requires us to have a lawful basis for collecting and using your personal data. We primarily rely on one or more of the following lawful bases:

  • Performance of a contract with you: Where we need to process your personal data to perform a contract we are about to enter into or have entered into with you. In many cases, the contract will be the organisation you represent rather than you personally, but we may still need to process your personal data in order to provide the Website and related services to that organisation.

  • Legitimate interests: Where it is necessary to process your personal data for our legitimate interests (or those of a third party), provided that those interests are not overridden by your fundamental rights and interests. This may include operating, maintaining, and improving the Website, managing relationships with suppliers and buyers, and ensuring the security of our services.

  • Legal obligation: Where it is necessary to process your personal data to comply with a legal obligation that we are subject to, including regulatory and compliance requirements.

  • Consent: Where you have given your specific and informed consent. We rely on consent only where we have obtained your agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter. You may withdraw your consent at any time.

    In some cases, more than one lawful basis may apply depending on the circumstances in which we process your personal data.

    Purpose and lawful basis for processing of personal data

Purpose/Use Type of data Lawful basis for processing
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Dealing with your requests, complaints and queries		 (a) Identity
(b) Contact
(c) Marketing and Communications		 (a) Performance of a contract with you (the Website Terms of Use)
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey (a) Identity
(b) Contact
(c) Marketing and Communications
(d) Usage
(e) Marketing and Communications		 (a) Performance of a contract with you (the terms and conditions of the competition)
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical		 (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(d) Usage
(e) Marketing and Communications
(f) Technical		 (a) Performance of a contract with you (the Website Terms of Use)
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Website, products or services, marketing, customer relationships and experiences (a) Technical
(b) Usage		 Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Marketing and Communications		 Necessary for our legitimate interests (to develop our products/services and grow our business)
To monitor and protect the security of the Website and prevent fraud or misuse (a) Identity
(b) Contact
(c) Technical
(d) Usage		 Necessary for our legitimate interests (to ensure the security and integrity of the Website)

Where permitted by law, we may use your personal information to carry out marketing analysis and to send you promotional communications about our products or services. Where required by law, we will obtain your consent before sending such communications. In other cases we rely on our legitimate interests to promote and develop the Website.

You can opt out of receiving marketing communications from us at any time by contacting us at support@drinksbox.com or by using the unsubscribe link included in our marketing emails.

You may also request that we send marketing communications to a non-personal email address instead of one which identifies you as an individual.

Who we give your information to

When we share your personal data with third parties who act as our service providers, we only disclose personal data that is necessary for them to provide their services. We require all such third parties to respect the security of your personal data and to treat it in accordance with applicable law. We do not permit our service providers to use your personal data for their own purposes and only allow them to process it for specified purposes and in accordance with our instructions.

We may share your personal data with:

  • Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy.

  • Appropriate third parties including:

    • our business partners and sub-contractors in the performance of any contract we enter into, or other dealings we have in the normal course of business with you or the organisation you represent;

    • our auditors, legal advisors and other professional advisors or service providers;

    • third-party scheduling or booking service providers who facilitate meeting requests submitted through the Website;

    • our advertisers and advertising networks that require the data to select and serve relevant adverts to you and others; and

    • analytics and search engine providers that assist us in the improvement and optimisation of the Website, subject to our Cookie Policy.

In some cases, the organisations we share data with may act as independent controllers of your personal data. In those circumstances, they will be responsible for their own processing of your personal data in accordance with their own privacy policies and applicable data protection laws.

Other disclosures we may make

We will disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;

  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, such as to the police, HMRC or any other public authority; or

  • In order to enforce or apply our terms and other agreements with you or the company you work for; or to protect the rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

Where we store your information

The data that we process in relation to you may be transferred to, and stored at, a destination outside the United Kingdom ("UK") or European Economic Area ("EEA") that may not be subject to equivalent data protection law. It may also be processed by staff situated outside the UK or EEA who work for us or for one of our suppliers.

Where your information is transferred outside the UK or EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as one or more of the following:

  • the transfer is to a country which has been granted adequacy status by the UK Secretary of State under the UK GDPR;

  • we have entered into the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses with the recipient; or

  • another lawful transfer mechanism recognised under applicable data protection law applies.

You may request further information about the safeguards we have in place for international transfers, including copies of any relevant transfer agreements, by contacting support@drinksbox.com.

How we protect your information

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a legitimate business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long we keep your information

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. We generally do not retain personal data for longer than 6 years unless a longer retention period is required or permitted by law.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see the "Your rights" section below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your rights

You have the right under certain circumstances:

  • to be provided with a copy of your personal data held by us;

  • to request the rectification or erasure of your personal data held by us;

  • to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);

  • to object to the further processing of your personal data, including the right to object to marketing (as mentioned in 'Our promotional updates and communications' section);

  • to request that your provided personal data be moved to a third party.

Your right to withdraw consent:

Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us as outlined below. You can also change your marketing preferences at any time as described in 'Our promotional updates and communications' section.

How to exercise your rights

You can exercise the rights listed above at any time by contacting us at support@drinksbox.com.

You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (https://ico.org.uk/). We would, however, appreciate the opportunity to address your concerns before you approach the ICO. The ICO will expect you to have done this before reviewing your complaint.

Third-party links

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

We may also share personal data where necessary to establish, exercise or defend legal claims.

Changes to this privacy policy

We may update this privacy policy from time to time. Any changes we make will be posted on the Website and, where appropriate, notified to you by email or through the Website.

The date at the top of this policy indicates when it was last updated. We encourage you to review this policy periodically to stay informed about how we use and protect your personal data.

Contact us

If you have any questions about this privacy policy or about how we process your personal data, please contact us at:

Email: support@drinksbox.com

Address: DrinksBox Limited, Suite 5, Fulham Business Exchange, London, SW6 2TL.

If you are contacting us to exercise your data protection rights, please provide sufficient information to allow us to verify your identity and locate the personal data to which your request relates.