Additional Privacy Notice for UK and EEA Residents

UK and EEA individuals should review further UK and EEA specific information below.

This privacy notice together with the Global Privacy Policy describes how Mark Anthony Presents..., its subsidiaries, and affiliates treat Personal Information you provide to us or that we collect about you.

This includes any information that identifies you personally (such as your name, title, email address or phone number) that is supplied to us both offline (for example, if we interact with you in person, over the phone, or by mail) and when we interact with you through our online services, including but not limited to our websites, chatbot, email correspondence, and any other online services that we link to this Privacy Policy (our website, apps, platforms, services, and social media pages, collectively, the “Services”, as well as information we generate regarding your use of the Services, in either case, including information that can be linked with such information to identify you directly or indirectly (for the purposes of this section referred to as "Personal Information").

Minor Children and Users Under Legal Drinking Age

For UK/EEA, our Services are not directed to, and we do not knowingly collect Personal Information from persons under the age of 18.

If we learn that we have collected Personal Information from individuals under legal drinking age, we will delete that information where necessary. If you believe that we might have any information about an individual under legal drinking age, please notify us at [email protected].

Who is the controller(s) of your Personal Information?

Mark Anthony Presents.... is responsible as controller of the Personal Information we collect in relation to our Services. Please refer to the Contact section for further details.

What Information Does Mark Anthony Collect and How Is This Information Used?

We collect Personal Information from the sources listed in of this Privacy Policy. This includes collecting Personal Information directly from you or automatically from you or your device when you interact with the Services, from business partners, social media networks, and other sources as detailed in Categories of of Personal Information above.

Information collected

Purposes of processing

Lawful basis relied on

Personal Identifiers: We may collect your name, email address, social media handles, shipping address, billing address, zip or postal code, telephone number, unique personal identifier, online identifier, Internet Protocol (IP) address, account name, or other similar identifiers. If you create an account, we also collect your username and password.  

Provide our services. We use this Personal Information to provide products and services. For example, to process your orders, process payments, and deliver our products to you where applicable, such as branded or personalized products merchandise that you may purchase through an e-commerce platform. We also use this Personal Information to create, maintain, and otherwise manage your account and profile. We also use your Personal Information to maintain your transaction history and verify eligibility to access our Services. 

Performance of a contract. To fulfil our contractual obligations to you, your employer or a third-party, for example to provide the services described above.

For marketing purposes. If you authorize us to do so, we may use Personal Information for marketing and advertising purposes, such as providing you with information about our products and services and the products and services of our partners and other third parties. If you join our mailing list, we will send you promotional information on our products. We may also use your Personal Information to personalize your experience on our Services, in email, on third-party websites, and on social media. We may use Personal Information to offer and administer special promotions, discounts, purchase incentives, loyalty programs, prize promotions, invites or other similar offers and promotions. We may use Personal Information to display advertisements related to products we think may interest you on our Services, in e-mail communications you consent to receive, on other websites that work with our advertising partners, and on social media platforms. You may decline to receive [email/text] marketing from us by submitting a request here or by following the unsubscribe link contained in the [email/text].

To respond to your requests and communicate with you. We use your Personal Information to communicate with you, such as to respond to and/or follow-up on your requests, inquiries, issues, or feedback, and to provide customer service. We may invite you to participate in surveys on your satisfaction with our products and services. We also use Personal Information to communicate with you about changes to our business practices, policies, programs, and terms and conditions. If you are navigating our Services, you may interact with our chatbot through Facebook Messenger and/or X, in which case, this bot will answer your questions based on the information that it collects about you. Facebook and/or X may also collect information about you through Cookies and pixels on its the Facebook/X platforms, subject to Facebook/X’s privacy policies.

To improve our products and services. We may use your information to make our services, platforms, offerings, marketing campaigns, communications, and products better, including to understand how you use our products and services. We might use your information to conduct research and analysis, as well as develop new services and products.

To administer our Services. We use your Personal Information to manage, maintain, administer, and troubleshoot our Services, including to understand how you interact with our services, platforms, and other communications with you. We also use Personal Information to administer, maintain, and communicate with you about contests and promotions in which you have chosen to participate, including publishing winner information in winner lists and sharing winners list with third parties and /or regulators as required for prize distributions and regulatory purposes respectively.

To comply with our obligations. We may use Personal Information to fulfill our legal obligations, resolve disputes, defend our legal rights, and enforce our agreements. We may also use Personal Information to verify you can legally access our Services. We may also use Personal Information to fulfill contractual obligations we may have to you.

For security and safety purposes and prevent fraud. We use Personal Information to detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity and protect our Services. We may also use Personal Information to investigate, prevent, and enforce violations of our terms and policies. We may use Personal Information to protect our company, properties, our trademark, customers, business partners and their respective personnel.

·       For analytics purposes. We may use your Personal Information such as customer IDs/internal identifier for analytics purposes, specifically to understand which pages you have visited, elements of the Services you have clicked on, products purchased, advertisements that you have liked or rated in any way, how you reacted to contests, surveys, sweepstakes and other promotions.

·       To personalize your experience. We may use your Personal Information such as name, e-mail address, address, location, telephone, birth information, demographic information and online identifiers to personalize your experience with our Services, our communications to you, and the marketing and advertising that you receive via the agreed channels or which you see on our Services, including to provide personalized recommendations about our products and services, events, promotions, and loyalty programs.

Some of these uses rely on Cookies, in particular those related to marketing, bot services and personalization. To the extent that they do rely on Cookies, please see our Cookie Policy for further information.

Consent – for individuals who sign up to our mailing list, or when you subscribe to marketing communications, targeted advertisements and otherwise where appropriate or as required by law. We also obtain your consent whenever necessary to use Cookies and similar technologies (unless applicable data protection laws permit us to rely on our legitimate interests instead).

Legitimate interests - we have a legitimate business interest in:

-    providing, managing, administering and facilitating your use of our Services in accordance with our commercial interests and legal rights (such as developing user profiles and analyzing customer feedback to better understand our users and how they access and use our Services, and safeguarding Services security)

-    running an effective and sustainable business (such as ensuring our fees are paid)

-    pursuing business development initiatives and keeping you informed of relevant offers

-    taking measures to ensure that the Services are only accessed by authorized users and in accordance with our terms of use

Legal obligation – for any processing in accordance with an applicable legal obligation for example obtaining information to enable us to meet our tax and accounting obligations

Demographic Information: We may collect your age, date of birth, gender, address, zip code, marital status other household information, education level, employment status, race, ethnicity, estimated income, and other similar demographic data, some of which may include characteristics of protected classifications under local law.

Education information: We may collect your education level, for example when you take one of our surveys.

We may collect this information when you chose to provide it to us as part of your profile, when registering to use our Services, to confirm if you are over the legal age so that you can interact with our Services, enroll you in our campaigns, promotions, sweepstakes, loyalty programs or through our marketing and analytics partners and service providers.

We may also use this information for analytics and to personalize your experience – please see above for details.

Legitimate interests - we have a legitimate business interest in:

-    providing, managing, administering and facilitating your use of our Services in accordance with our commercial interests and legal rights (such as developing user profiles and analyzing customer feedback to better understand our users and how they access and use our Services, and safeguarding Services security)

-    running an effective and sustainable business (such as ensuring our fees are paid)

-    pursuing business development initiatives and keeping you informed of relevant offers

-    taking measures to ensure that the Services are only accessed by authorized users and in accordance with our terms of use

Legal obligation – for any processing in accordance with an applicable legal obligation

Explicit consent – we obtain your explicit consent whenever we wish to process any Personal Information that is categorized as “special category data” under applicable data protection laws

Commercial Information: We collect information such as products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies. This includes information about the transaction, such as product details and the date and location of the purchase/return.  

We may use this information:

-    For marketing purposes – please see details above;

-    To respond to your requests and communicate with you – please see details above

To improve our products and services - please see details above

Legitimate interests - we have a legitimate business interest in:

-    providing, managing, administering and facilitating your use of our Services in accordance with our commercial interests and legal rights (such as developing user profiles and analyzing customer feedback to better understand our users and how they access and use our Service, and safeguarding Service security)

-    running an effective and sustainable business (such as ensuring our fees are paid)

-    pursuing business development initiatives and keeping you informed of relevant offers

Consent – for individuals who sign up to our mailing list, or when you subscribe to marketing communications, targeted advertisements and otherwise where appropriate or as required by law

Payment Information: We collect billing information, such as your credit card number, expiration date, card verification number, billing address if you make a purchase, and other financial information required to allow you to purchase our products. We make sure to use PCI DSS compliant third parties when processing your credit card information.

We may use this information to provide you with our Services – please see details above.

Performance of contract – to perform our contract with you or your employer or a third-party (such as an affiliate or partner of your employer), including sending Service-related communications

Legitimate interests - we have a legitimate business interest in:

-    providing, managing, administering and facilitating your use of our Services in accordance with our commercial interests and legal rights (such as developing user profiles and analyzing customer feedback to better understand our users and how they access and use our Service, and safeguarding Services security)

running an effective and sustainable business (such as ensuring our fees are paid)

Internet or Other Electronic Network Activity Information: We collect details of your visits to, and information generated in the course of using, our Services (including the timing, frequency and pattern of service use) including, but not limited to, traffic data, location data, weblogs and other communication data, the resources that you access, and how you reached our Services. We also collect details regarding the device you use to access our Services, including, but not limited to, your IP address, operating system and browser type, device ID, and Personal Information collected from Cookies and similar technology when you open our emails and visit our Services (for more information about Cookies, how we use them, and your related choices, please see our Cookie Policy).  

We may use this information:

-    To provide you with our Services - – please see details above

-    To improve our products and Services - please see details above

-    To administer our Services - please see details above

-    For security and safety purposes and prevent fraud – please see details above

For analytics and to personalize your experience - please see details above

Consent – we obtain your consent whenever necessary to use Cookies and similar technologies (unless applicable data protection laws permit us to rely on our legitimate interests instead).

Legitimate interests – we have a legitimate business interest in understanding:

-    how our Services are accessed

-    how our Services are used

any problems users have with accessibility and usage across multiple devices

Location Data: For example, you can enter your zip code to know where to find your favorite products near you. We may also collect your IP address automatically when you use our Services. We may be able to determine your general location based on the IP address. 

We may use this information:

-    To provide you with our Services – please see details above;

-    To improve our products and Services - please see details above;

-    To administer our Services - please see details above;

-    For security and safety purposes and prevent fraud – please see details above;

For analytics and to personalize your experience - please see details above

Legitimate interests - we have a legitimate business interest in:

-    providing, managing, administering and facilitating your use of our Services in accordance with our commercial interests and legal rights (such as developing user profiles and analyzing customer feedback to better understand our users and how they access and use our Service, and safeguarding Service security)

-    running an effective and sustainable business (such as ensuring our fees are paid)

taking measures to ensure that the Services are only accessed by authorized users and in accordance with our terms of use

Audio, Electronic, Visual, or Similar Information: We may record audio during customer service calls. We also collect audio or visual information you post to our Services and social media platforms, like photographs or videos. We also collect video and photographs at our in-person events. 

We may use this information:

-    To provide you with our services – please see details above;

-    To improve our products and services - please see details above

-    To administer our Services - please see details above

-    For security and safety purposes and prevent fraud – please see details above

For analytics and to personalize your experience - please see details above

Consent – for individuals who sign up to our mailing list, or when you subscribe to marketing communications, targeted advertisements and otherwise where appropriate or as required by law

Legitimate interests - we have a legitimate business interest in:

-    providing, managing, administering and facilitating your use of our Services in accordance with our commercial interests and legal rights (such as developing user profiles and analyzing customer feedback to better understand our users and how they access and use our Service, and safeguarding Service security)

running an effective and sustainable business (such as ensuring our fees are paid)

Inferences Drawn to Create a Profile About You Reflecting Your Preferences or Characteristics: We analyze your purchases, preferences, or other interactions and may create a profile for you to suggest other products you may be interested in. For example, we collect preference data, such as contact preferences, the flavors that you prefer and products you have purchased.

We may also combine Personal Information from the Services together with other information we obtain from our business records. We may also combine information we collect offline with information we collect online.  Additionally, information collected about you from a particular browser or device may be linked to information collected from another computer or device that we believe relates to you. We may combine information we get from another party with information we already have. We may also aggregate your information with other consumers’ information to understand preferences and trends over time.

We may use this information:

-    To improve our products and Services - please see details above

-    To administer our Services - please see details above

-    For analytics and to personalize your experience - please see details above

These activities do not involve automated decision making about you. The Personal Information is used to create models for retargeting you (for example sharing targeted and specific invites to events in accordance with your preferences, sharing specific promotions related to the product of your choice etc.), and understanding purchase behaviors for building your customer journey.

Legitimate interests - we have a legitimate business interest in:

-    providing, managing, administering and facilitating your use of our Services in accordance with our commercial interests and legal rights (such as developing user profiles and analyzing customer feedback to better understand our users and how they access and use our Service, and safeguarding Service security)

running an effective and sustainable business (such as ensuring our fees are paid)

Employment related Information: If you apply for employment with us, we may collect information such as your name, email address, telephone number, home address, resume/CV, cover letter, education information, employment history, and job preferences. To the extent you participate in an interview process with us, we may also collect information from you via video and/or audio interview(s). We may also share your Personal Information with third parties for the purposes of conducting interview assessments and conducting background/reference checks with respect to your employment and related credentials as part of our hiring process.

We may use this information:

-          For recruitment purposes

-          Conduct interviews and assessments

-          Conduct background checks for hired candidates

To comply with our obligations

Consent – for individuals who sign up to careers page, or when you provide your Personal Information to other recruitment partners for hiring purposes

Legitimate interests - we have a legitimate interest in ensuring we adhere to our hiring process and comply with employment-related obligations.

Legal obligation – for any processing in accordance with an applicable legal obligation

Other Personal Information: We may collect certain Personal Information that has the potential of being more sensitive. For example, we will collect your social security number or government issued identification to verify your age and, when required to comply with the law.  We may also collect your precise geolocation when you use our product finder tool. 

We may use this information:

-          To provide you with our services – please see details above.

-          To comply with our obligations

For security and safety purposes and prevent fraud

Legitimate interests - we have a legitimate business interest in:

-    providing, managing, administering and facilitating your use of our Services in accordance with our commercial interests and legal rights (such as developing user profiles and analyzing customer feedback to better understand our users and how they access and use our Service, and safeguarding Service security)

-    running an effective and sustainable business (such as ensuring our fees are paid)

-    pursuing business development initiatives and keeping you informed of relevant offers

-    taking measures to ensure that the Service is only accessed by authorized users and in accordance with our terms of use

 

Legal obligation – for any processing in accordance with an applicable legal obligation

 

Explicit consent – we obtain your explicit consent whenever we wish to process any Personal Information that is categorized as “special category data” under applicable data protection laws

 

Please note that when we process Personal Information to meet our legitimate interests, we ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you by contacting us.

Where we are relying on consent to process your Personal Information, you will have the right to withdraw your consent at any time in accordance with the ‘What rights do I have regarding the use of my Personal ’ section below.

How Long Do We Retain Your Personal Information?

Please refer to of our Privacy Policy.

Does Mark Anthony Share Personal Information with Any Third Parties?

Please refer to Disclosure of Your Personal Information of our Privacy Policy for details regarding how we share your Personal Information with third parties.

International Transfers of Your Personal Information

We may transfer your Personal Information (referred to in the table above) outside the United Kingdom and European Economic Area, including to any jurisdiction where Mark Anthony Group operates, to other subsidiaries and affiliates., third-party service providers and partners, and we put adequate safeguards in place when we do so. This includes only transferring Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the European Commission or UK Parliament, or by otherwise using an appropriate safeguard to ensure the ongoing protection of Personal Information, such as standard contractual clauses approved by the applicable regulatory authority. You may request further information on the safeguards we use by contacting us via the contact details in the main Privacy Policy or contact at [email protected]

Please also refer to of our Privacy Policy regarding data transfers to the United States.

What Rights Do I Have Regarding the use of my Personal Information?

Individuals located in UK and the EEA, have certain rights regarding their Personal Information, as set out in more detail below. Some of these rights, e.g., the right to be forgotten or the right to request that we transfer your information to another company, will only apply in certain circumstances. Most rights are also subject to certain exceptions and exemptions that may mean that we are not always legally required to comply with your request in part or in full.

If you would like to exercise, or discuss, any of these rights, please click here.

Rights

What does this mean?

The right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Information and your rights. This is why we are providing you with the information in this notice.

The right of access

You have the right to obtain access to your Personal Information (if we are processing it), and certain other supplementary information (like the information provided in this notice). This is so you are aware and can check that we are using your Personal Information in accordance with data protection law.

The right to rectification

You are entitled to have your Personal Information corrected if it is inaccurate or incomplete.

The right to erasure

This is also known as ‘the right to be forgotten’ and, basically, enables you to request the deletion or removal of your Personal Information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.

The right to restrict processing

You have rights to ‘block’ or suppress further use of your Personal Information. When processing is restricted, we can still store your Personal Information, but may not use it further. We keep lists of people who have asked for further use of their Personal Information to be ‘blocked’ to make sure the restriction is respected in future.

The right to data portability

You have the right to receive your Personal Information in a structured, commonly used and machine-readable format and to request that this Personal Information is transmitted to another controller where this is technically feasible. This right only applies to Personal Information you have provided to us yourself (not any other information), that we process by automated means based on your consent or for the performance of a contract with you.

The right to object

You have the right to object to the use of your Personal Information in some circumstances, such as where we don’t have to process your Personal Information to meet a contractual or other legal obligation. For example, you may object to the use of your Personal Information for direct marketing purposes.

The right not to be subject to a decision based solely on automated processing, including profiling which produces legal effects or similarly significantly affects you

You have the right not to have your Personal Information used to make solely automated decisions about you that may impact you. For example, you have the right not to have your Personal Information used to create a profile of you that automated decisions are later based on without there being any human involvement in that processing.

The right to withdraw consent

If you have given your consent to anything we do with your Personal Information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your Personal Information with your consent up to that point is unlawful). This includes the right to withdraw consent to us using your Personal Information for marketing purposes.

 

How to Contact Us About This Privacy Policy or Make a Complaint

Our Data Protection Officer

You can contact our Data Protection Officer at [email protected].

ICO

If you have a query or complaint about how your Personal Information is being used, you may contact your relevant national data protection regulator. In the EEA, details for each national data protection regulator are available . The UK's supervisory authority is the Information Commissioner's Office (ICO), which can be contacted by writing to Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, by telephone at 0303 123 1113, or by visiting their website:https://ico.org.uk .