The following privacy policy applies to the use of our online offering at www.orkney360.com (hereinafter "website"). We attach great importance to data protection. The collection and processing of your personal data is carried out in compliance with the applicable data protection regulations, in particular the General Data Protection Regulation (GDPR).

1 | Responsible person

The controller for the collection, processing and use of your personal data within the meaning of Art. 4 No. 7 GDPR is Chris Rickert, Newhouse, Germiston Road, KW16 3HD, Orphir, Orkney, Scotland, Internet: www.orkney360.com, Mail: orkney360@bedandwhisky.com, Mobile: 0044-(0)7521-192562 If you wish to object to the collection, processing or use of your data by us in accordance with these data protection provisions as a whole or for individual measures, you can address your objection to the controller. You can save and print out this privacy policy at any time.

2 | General purposes of processing

We use personal data for the purpose of operating the website and to make it easier for you to work, place orders and obtain information.

3 | What data we use and why

3.1 Hosting

The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space
and database services, security services and technical maintenance services that we use for the purpose of operating the website.
Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of
customers, interested parties and visitors to this website on the basis of our legitimate interests in an efficient and secure provision of our website
in accordance with. Art. 6(1)(f) GDPR. 1f)GDPR in conjunction with. Art.28DSGVO.

3.2 Access data

We collect information about you when you use this website. We automatically collect information about your usage behavior and your
interaction with us and register data about your computer or mobile device. We collect, store and use data about every access to our website
(so-called server log files). The access data includes 

- Name and URL of the retrieved file
- Date and time of retrieval
 -Amount of data transferred
- Message about successful retrieval (HTTP response code)
- Browser type and browser version
- Operating system
- Referer URL (i.e. the previously visited page)
- Websites that are accessed by the user's system via our website
- Internet service provider of the user
- IP address and the requesting provider

We use this log data without allocation to your person or other profiling for statistical evaluations for the purpose of operation, security and
optimization of our website, but also for anonymous recording of the number of visitors to our website (traffic) and the extent and type of use
of our website and services, as well as for billing purposes to measure the number of clicks received from cooperation partners. Based on this
information, we can provide personalized and location-based content and analyze traffic, troubleshoot and fix errors, and improve our services.
This is also our legitimate interest pursuant to Art. 6 para. 1 sentence 1 f) GDPR.

We reserve the right to check the log data retrospectively if there is a justified suspicion of unlawful use based on concrete evidence. We store
IP addresses in the log files for a limited period of time if this is necessary for security purposes or for the provision or billing of a service, e.g. if you use one of our offers. After canceling the order process or after receipt of payment, we delete the IP address if it is no longer required for security purposes. We also store IP addresses if we have a concrete suspicion of a criminal offense in connection with the use of our website. We also store the date of your last visit as part of your account (e.g. when registering, logging in, clicking on links, etc.).

3.3 Cookies

We use so-called session cookies to optimize our website. A session cookie is a small text file that is sent by the respective servers when you visit a website and is temporarily stored on your hard disk. This file as such contains a so-called session ID, with which various requests from your
browser can be assigned to the joint session. This allows your computer to be recognized when you return to our website. These cookies are deleted after you close your browser. They are used, for example, to enable you to use the shopping cart function across several pages.
We also use a small number of persistent cookies (also small text files that are stored on your end device), which remain on your end device and
enable us to recognize your browser the next time you visit. These cookies are stored on your hard disk and delete themselves after the specified
time. Their lifespan is 1 month to 10 years, which enables us to present our website to you in a more user-friendly, effective and secure manner
and, for example, to display information on the site that is specifically tailored to your interests.

Our legitimate interest in the use of cookies in accordance with Art. 6 para. 1 sentence 1 f) GDPR is to make our website more user-friendly,
effective and secure.

The following data and information are stored in the cookies:

- Log-in information
- Language settings
- search terms entered
- Information about the number of visits to our website and the use of individual functions of our website.

When the cookie is activated, it is assigned an identification number and your personal data is not assigned to this identification number. Your
name, IP address or similar data that would allow the cookie to be assigned to you are not stored in the cookie. Based on the cookie
technology, we only receive pseudonymized information, for example about which pages of our store have been visited, which products have
been viewed, etc.

You can set your browser so that you are informed in advance about the setting of cookies and can decide in individual cases whether you want to
exclude the acceptance of cookies for certain cases or in general, or that cookies are completely prevented. This may limit the functionality of the
website.

3.4 Data for the fulfillment of our contractual obligations

We process personal data that we require to fulfill our contractual obligations, such as name, address, email address, products ordered, invoice and payment data. The collection of this data is necessary for the conclusion of the contract.

The data will be deleted after the warranty periods and statutory retention periods have expired. Data linked to a user account (see below) will in any case be retained for the duration of the management of this account. The legal basis for the processing of this data is Art. 6 para. 1S. 1b)GDPR, because this data is required so that we can fulfill our contractual obligations to you.

3.5 User account

You can create a user account on our website. If you wish to do so, we need the personal data requested when you log in. When you log in later,
only your e-mail or user name and the password you have chosen will be required.

For new registrations, we collect master data (e.g. name, address), communication data (e.g. e-mail address) and payment data (bank
details) as well as access data (user name and password).

To ensure your proper registration and to prevent unauthorized logins by third parties, you will receive an activation link by e-mail after your
registration to activate your account, and we will only store the data you have transmitted permanently in our system after successful registration. Once you have created a user account, you can have it deleted by us at any time without incurring any costs other than the transmission costs according to the basic rates. A message in text form to the contact details mentioned under point 1 (e.g. e-mail, fax, letter) is sufficient for this. We will then delete your stored personal data, unless we still need to store it to process orders or due to statutory retention obligations. The legal basis for the processing of this data is your consent in accordance with Art. 6 Para. 1S. 1a)GDPR.

3.6 Newsletter

To register for the newsletter, the data requested in the registration process is required. Registration for the newsletter is logged. After
registering, you will receive a message to the email address provided asking you to confirm your registration ("double opt-in"). This is necessary
so that third parties cannot register with your email address. You can revoke your consent to receive the newsletter at any time and
thus unsubscribe from the newsletter.

We store the registration data for as long as it is required for sending the newsletter. We store the logging of the registration and the dispatch
address as long as there is an interest in proving the consent originally given; as a rule, these are the limitation periods for civil law claims, i.e. a
maximum of three years.

The legal basis for sending the newsletter is your consent pursuant to Art. 6 para. 1S. 1a) in conjunction with Art. 7 GDPR in conjunction with
Section 7 (2) No. 3 UWG, the legal basis for logging the registration is our legitimate interest in proving that the newsletter was sent with your
consent.

You can cancel the registration at any time without incurring any costs other than the transmission costs according to the basic rates. A message
in text form to the contact data mentioned under point 1 (e.g. e-mail, fax, letter) is sufficient for this. Of course, you will also find an unsubscribe link in every newsletter.

3.7 Product recommendations

We will send you regular product recommendations by e-mail independently of the newsletter. In this way, we send you information
about products from our range that you may be interested in based on your recent purchases of goods or services from us. We do this strictly in
accordance with legal requirements. You can object to this at any time without incurring any costs other than the transmission costs according to
the basic rates. A message in text form to the contact details mentioned under point 1 (e.g. e-mail, fax, letter) is sufficient for this. Of course, you will also find an unsubscribe link in every e-mail. The legal basis for this is the legal permission pursuant to Art. 6 para. 1
sentence 1 f) GDPR in conjunction with Section 7 para. 3 UWG.

3.8 E-mail contact

If you contact us (e.g. via contact form or e-mail), we will process your data to process the request and in the event that follow-up questions
arise.

If the data processing is carried out for the performance of pre-contractual measures, which are carried out at your request, or, if you are already our customer, for the performance of the contract, the legal basis for this data processing is Art. 6 para. 1 sentence 1b) GDPR.
We only process other personal data if you consent to this (Art. 6 (1) (1a) GDPR) or if we have a legitimate interest in processing your data (Art. 6 (1) (1f) GDPR), e.g. a legitimate interest lies in responding to your email.

4 | Google Analytics

We use Google Analytics, a web analytics service provided by Google Inc ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about the use of this website by site visitors is usually transmitted to a Google server in the USA and stored there.

This is also our legitimate interest pursuant to Art. 6 para. 1 sentence 1 f) GDPR.

Google has submitted to the Privacy Shield agreement concluded between the European Union and the USA and is certified. This means that Google undertakes to comply with the standards and regulations of European data protection law. You can find more information in the following linked entry:https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.

We have activated IP anonymization on this website (anonymizeIp). As a result, however, your IP address will be shortened by Google within
member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. Google will use this information on our behalf to evaluate your use of the website, to compile reports on website activity and to provide us with other services relating to website activity and internet usage.

The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. You may refuse the use of
cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full
functionality of this website.

You can also prevent the transmission of the data generated by the cookie and related to your use of the website (including your IP address) to
Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link:
http://tools.google.com/dlpage/gaoptout?hl=de.

5 | Storage duration

Unless specifically stated, we only store personal data for as long as is necessary to fulfill the purposes pursued.
In some cases, the legislator provides for the retention of personal data, for example in tax or commercial law. In these cases, the data will only be stored by us for these legal purposes, but will not be processed in any other way and will be deleted after the statutory retention period has
expired.

6 | Your rights as a data subject affected by data processing Under the applicable laws, you have various rights regarding your
personal data.

If you wish to exercise these rights, please send your request by e-mail or by post, clearly identifying yourself, to the address
given in section 1. Below you will find an overview of your rights.

6.1 Right to confirmation and information

You have the right to clear information about the processing of your personal data.

In detail:
You have the right to obtain confirmation from us at any time as to whether personal data concerning you is being processed. If this is the
case, you have the right to request information from us free of charge about the personal data stored about you, together with a copy of this
data. You also have the right to the following information:

1. the purposes of processing;
2. the categories of personal data that are processed;
3. the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third
countries or international organizations;
4. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that
period;
5. the existence of a right to rectification or erasure of personal data concerning you or to restriction of processing by the controller or a
right to object to such processing;
6. the existence of a right of appeal to a supervisory authority;
7. if the personal data are not collected from you, all available information about the origin of the data;
8. the existence of automated decision-making, including profiling, in accordance with Art. 22 (1) and (4) GDPR and - at least in these
cases - meaningful information about the logic involved and the scope and intended effects of such processing for you.

If personal data is transferred to a third country or to an international organization, you have the right to be informed of the appropriate
safeguards pursuant to Art. 46 GDPR in connection with the transfer. 6.2 Right to rectification You have the right to demand that we correct and, if necessary, complete your personal data.

In detail:
You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the
purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

6.3 Right to erasure ("right to be forgotten")

In a number of cases, we are obliged to delete personal data concerning you.

In detail:
In accordance with Art. 17 para. 1 GDPR, you have the right to demand that we delete personal data concerning you immediately, and we are
obliged to delete personal data immediately if one of the following reasons applies:

1. The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
2. You withdraw your consent on which the processing is based according to Art.6 para.1S. 1a)GDPR or Art.9 para.2 a)GDPR and there is no other legal basis for the processing.
3. You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR.
4. The personal data was processed unlawfully.
5. The deletion of personal data is necessary to fulfill a legal obligation under Union law or the law of the Member States to which we are subject.
6. The personal data was collected in relation to information society services offered in accordance with Art. 8 para. 1 GDPR. If we have made the personal data public and are obliged to erase it in accordance with Article 17(1) GDPR, we shall take reasonable steps, including technical measures, taking into account the available technology and the cost of implementation, to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, that personal data.

6.4 Right to restriction of processing

In a number of cases, you are entitled to demand that we restrict the processing of your personal data.

In detail:
You have the right to demand that we restrict processing if one of the following conditions is met:

1. the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data,
2. the processing is unlawful and you have objected to the erasure of the personal data and have instead requested the restriction of the use of the personal data;
3. we no longer need the personal data for the purposes of the processing, but you require the data for the establishment, exercise or defense of legal claims, or
4. you have objected to processing pursuant to Art. 21 (1) GDPR pending the verification whether the legitimate grounds of our company override yours.

6.5 Right to data portability

You have the right to receive, transmit or have us transmit personal data concerning you in machine-readable form.

In detail:
You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machinereadable format and you have the right to transmit those data to another controller without hindrance from us, where
1. the processing is based on consent pursuant to Art.6 para.1S.
1a)GDPR or Art.9 Para.2 a)GDPR or on a contract pursuant to Art.6 Para.1S. 1b)GDPR and
2. the processing is carried out using automated procedures.

In exercising your right to data portability pursuant to paragraph 1, you have the right to have the personal data transmitted directly from us to
another controller, where technically feasible.

6.6 Right of objection

You have the right to object to the lawful processing of your personal data by us if this is based on your particular situation and our interests in the processing do not outweigh yours.

In detail:
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which
is based on Article 6(1)(e) or (f) GDPR, including profiling based on those provisions. 1e) or f) GDPR; this also applies to profiling based on these
provisions. We will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which
override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

Where personal data are processed by us for direct marketing purposes, you have the right to object at any time to processing of personal data
concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

You have the right to object, on grounds relating to your particular situation, to the processing of personal data concerning you which is
carried out for scientific or historical research purposes or for statistical purposes in accordance with Article 89(1) GDPR, unless the processing is
necessary for the performance of a task carried out in the public interest.

6.7 Automated decisions including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects
concerning you or similarly significantly affects you. Automated decision-making based on the personal data collected does not take place.

6.8 Right to withdraw consent under data protection law

You have the right to withdraw your consent to the processing of personal data at any time.

6.9 Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or
place of the alleged infringement if you consider that the processing of personal data relating to you is unlawful.

7 | Data security

We make every effort to ensure the security of your data within the framework of the applicable data protection laws and technical possibilities.

Your personal data is transmitted to us in encrypted form. This applies to your orders and also to the customer login. We use the SSL (Secure
Socket Layer) coding system, but would like to point out that data transmission on the Internet (e.g. when communicating by e-mail) can have security gaps. Complete protection of data against access by third parties is not possible.

To secure your data, we maintain technical and organizational security measures in accordance with Art. 32 GDPR, which we constantly adapt to
the state of the art. 

We also do not guarantee that our service will be available at certain times; disruptions, interruptions or failures cannot be ruled out. The servers we use are carefully backed up on a regular basis. 

8 | Transfer of data to third parties, no data transfer to non-EU countries

In principle, we only use your personal data within our company. If and insofar as we involve third parties in the fulfillment of contracts
(such as logistics service providers), they will only receive personal data to the extent that the transfer is necessary for the corresponding service.
In the event that we outsource certain parts of data processing ("order processing"), we contractually oblige processors to use personal data only
in accordance with the requirements of data protection laws and to ensure the protection of the rights of the data subject.

Data transfer to bodies or persons outside the EU outside the case mentioned in this declaration in section 4 does not take place and is not planned.

9 | Data Protection Officer

If you have any questions or concerns about data protection, please contact our data protection officer:

Chris Rickert
orkney360@bedandwhisky.com
Mobile: +44-(0)7521-192562