GDPR Data Privacy


Introduction Swallow (Soft Drinks Beer & Cider Wholesalers) Ltd (“We”) are committed to protecting and respecting your privacy.

This policy (together with our terms of use available to view at and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

1. Definitions

Data controller – A controller determines the purposes and means of processing personal data.

Data processor – A processor is responsible for processing personal data on behalf of a controller.

Data subject – Natural person

Categories of data: Personal data and special categories of personal data

Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2. Who are we?

Swallow (Soft Drinks Beer & Cider Wholesalers) Ltd is the Data Controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: Stonehouse Lane, Bartley Green, Birmingham B32 3AH, Telephone 0121 428 6850. For all data matters contact Tracy Land, our Data Protection Officer or Mary Bowen our Data Representative.

3. The purpose(s) of processing your personal data

We use your personal data for the following purposes:

  • For the purpose of our daily business enabling us to deal with purchases and deliveries and associated matters.
  • To enable us to collect payments from our customers.
  • To enable us to make payments to our suppliers.
  • To ensure compliance with the Inland Revenue Alcohol Wholesaler Registration Scheme (AWRS).
  • To inform individuals of products, news, events or activities.
  • To maintain our own accounts and records.

4. The categories of personal data concerned

With reference to the categories of personal data described in the definitions section, we process the following categories of your data: 

  • Contact details such as name, address, telephone numbers, fax numbers, e-mail addresses.
  • Identification information such as signature, date of birth, gender, nationality, residency, national identity number such as a passport number, driving licence, income and financial details, bank or building society account details, credit card details, credit rating, marital status, occupation, employment status, employer and job title, VAT registration number, company registration number, AWRS registration number.

We have obtained your personal data from: 

  • Information you have given us about you and your business by filing in forms or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to place an order.
  • We may receive information from companies we use to verify your identity and/or to prevent fraud such as credit reference agencies (please note such companies may record the details of the search) including the electrical register and credit information.
  • We may obtain personal data from public sources such as Companies House.
  • We may also receive information from third parties who contact us such as H M Revenue & Customs, or other government agencies.

5. What is our legal basis for processing your personal data?

Personal data (article 6 of GDPR)

Our lawful basis for processing your general personal data:

Consent of the data subject
Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract
Consent form
To confirm your identity, to communicate with you, to authorise and complete sales order transactions.

Consent of the data subject
Processing necessary for compliance with a legal obligation
Consent form
To comply with H M Revenue & Customs regulations.

Consent of the data subject
Processing necessary to protect the vital interests of a data subject or another person
Consent form
To establish, exercise or defend our legal rights. To prevent fraud.

Sharing your personal data

Your personal data will be treated as strictly confidential, and will be shared only with third party providers such as product suppliers, banking establishments, in house marketing, transport security. We will always require those third parties to respect the security of your data and to treat it in accordance with the law and only for the purpose for which we obtained it.

6. How long do we keep your personal data?

We keep your personal data for no longer than reasonably necessary and we only retain your data for the following purposes and use the following criteria to determine how long to retain your personal data

  • Data is kept for the purposes for which is was obtained, as detailed in Clause 3.
  • Data is stored in locked filing cabinet while the account is active.
  • Once the account becomes inactive, data is archived for the statutory 6 year period.

7. Providing us with your personal data

We require your personal data as it is a requirement necessary to enter into a contract.

8. Your rights and your personal data

  • Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: 
  • The right to request a copy of the personal data which we hold about you;
  • The right to request that we correct any personal data if it is found to be inaccurate or out of date;
  • The right to request your personal data is erased where it is no longer necessary to retain such data;
  • The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
  • The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).

9. Transfer of Data Abroad

We do not transfer personal data outside the EEA.

10. Automated Decision Making

We do not use any form of Automated Decision Making in our business.

11. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

12. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

13. How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact Tracy Land, Data Protection Officer, Swallow (Soft Drinks Beer & Cider Wholesalers) Ltd, Stonehouse Lane, Bartley Green, Birmingham B32 3AH, Telephone on 0121 428 6850.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.

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