Privacy, cookie & analytics policy
Background
Clearbev Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.clearbev.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it before using Our Site.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
- “Cookie” means a small text file placed on your computer or device by Our Site;
- “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.
2. Information About Us
Our Site is operated by Clearbev Ltd, a limited company registered in England under company number 14725819. Registered address: 128 City Road, London EC1V 2NX, United Kingdom.
3. What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site is intended for adults of legal drinking age and may be visited from countries outside the UK; wherever you are, we handle your personal data as described here and in line with UK data protection law. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
4. What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as “any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier”.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- a. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
- b. The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- c. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- d. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
- e. The right to restrict (i.e. prevent) the processing of your personal data.
- f. The right to object to us using your personal data for a particular purpose or purposes.
- g. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- h. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- i. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15. It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
6. What Data Do You Collect and How?
Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies. We do not knowingly collect any personal data relating to children, and we do not collect data relating to criminal convictions and/or offences.
| Data collected | How we collect the data |
|---|---|
| Identity and contact information: your name and email address | You give it to us through our contact form |
| Business information: company or venue name, and the type of enquiry (distribution, trade, press or other) | You give it to us through our contact form |
| The content of your message, and your consent to us using it to reply | You give it to us through our contact form |
| The website or link that brought you to our contact form, for example one of our brand websites | Sent automatically with your message |
| Correspondence with you, if you email or write to us after your first enquiry | You give it to us directly |
| Technical information: IP address, browser type and version, operating system, pages requested | Collected automatically by our web server, as every website does |
| How you use Our Site: pages visited, time spent, the type of device and browser, and roughly where you are (country or city) | Google Analytics Cookies, only if you accept analytics Cookies (see Part 14) |
| Your age check: country and year (and sometimes month) of birth | Checked in your own browser only. It is never sent to us or stored; we keep only a cookie saying the check was passed (see Part 14) |
7. How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis or legitimate interest for using personal data. The following table describes how we may use your personal data, and our lawful bases or legitimate interest for doing so:
| What we do | Our lawful basis |
|---|---|
| Replying to your enquiry and handling any follow-up | Your consent (given on the contact form) and our legitimate interest in answering enquiries |
| Taking steps towards, and managing, a business relationship with you (for example as a distributor, retailer or venue) | Performance of a contract, or steps taken at your request before entering one |
| Administering, securing and improving Our Site, including checking visitors are of legal drinking age | Our legitimate interests, and our legal obligations as a business marketing alcohol responsibly |
| Understanding how Our Site is used, so we can improve it | Your consent (analytics Cookies), which you can withdraw at any time |
| Keeping records we are required to keep by law | Legal obligation |
| Sending you news about our brands, where you have asked us to | Your consent, which you can withdraw at any time |
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
With your consent, Our Site uses Google Analytics, a service provided by Google, to understand how visitors use it. Google Analytics Cookies are only set if you accept analytics Cookies, as explained in Part 14.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. As a guide, we keep enquiries that do not lead to a business relationship for up to 24 months, and records relating to customers and suppliers for as long as the law requires (normally six years after the relationship ends).
9. How and Where Do You Store or Transfer My Personal Data?
We aim to store your personal data in the UK. Some of the service providers we use to run Our Site and our email (for example website hosting and email providers, and Google Analytics if you accept analytics Cookies) may process data outside the UK. Where personal data is transferred outside the UK, we make sure it is protected by appropriate safeguards required by the Data Protection Legislation, such as a UK adequacy decision for the country concerned or the International Data Transfer Agreement (or Addendum) approved by the Information Commissioner’s Office.
10. Do You Share My Personal Data?
We will not sell your personal data, and we will not share it with any third parties for their own purposes, subject to the following exception(s). We do use trusted service providers (such as our website host, our email provider and, if you accept analytics Cookies, Google Analytics) who process data on our behalf and only on our instructions.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How Can I Control My Personal Data?
- a. In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us, which you may do by unsubscribing using the links provided in our emails).
- b. You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the postal address shown in Part 15, or through our contact form. You do not need to use any particular form; please tell us your name, how we can contact you, and what information you would like.
There is not normally any charge for a subject access request. If your request is “manifestly unfounded or excessive” (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 14 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
14. How Do You Use Cookies?
Our Site uses a small number of first-party Cookies, placed by us and used only by us. Cookies that are strictly necessary for Our Site to work do not need your consent under the Cookie Law. With your consent, we also use Google Analytics Cookies, set by Google, to understand how Our Site is used. We do not currently use advertising Cookies.
| Cookie | What it does | How long it lasts |
|---|---|---|
| cb_age_ok | Remembers that you have passed our age check, so we do not ask you again on every page. It contains no personal information. | Until you close your browser, or 30 days if you tick “Remember me” |
| cb_consent | Remembers your choices in our cookie banner. | 6 months |
| _ga, _ga_L95ZZ98JJG (Google Analytics) | Set only if you accept analytics Cookies. They tell visits apart and count pages viewed, without telling us who you are. If you later switch analytics off, we delete them. | 2 years |
| wordpress_*, wp-settings-* | Set only for our own staff when they sign in to edit Our Site. Visitors do not receive them. | Session, or up to 1 year |
When you first visit Our Site we show a cookie banner. Analytics Cookies stay switched off unless you choose “Accept all” or switch them on under “Manage choices”. Google may process analytics data outside the UK, under safeguards approved for UK data protection law; you can read how Google uses it at policies.google.com/technologies/partner-sites. You can change your choices at any time using the “Cookie settings” link at the bottom of every page.
You can also block or delete Cookies in your browser settings. If you block the essential Cookies, you may be asked to confirm your age on each visit.
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
For the attention of: Web Compliance Officer
Postal address: Clearbev Ltd, 128 City Road, London EC1V 2NX, United Kingdom
Online: our contact form
16. Changes to this Privacy Policy
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.
This Privacy Policy was last updated on 15 October 2026.