Effective Date: December 1, 2025

Data Controller: Curraghmore Whiskey Ltd (and associated trading entities)

Address: 10 Stalls, Curraghmore Estate, Portlaw, Co. Waterford, X91 X598

1. Introduction Curraghmore Whiskey (“We”) are committed to protecting and respecting your privacy. This policy outlines how we collect, use, store, and safeguard the personal data we collect from you, or that you provide to us, whether through our website (www.curraghmorewhiskey.com), social media lead forms (such as LinkedIn), or direct communication.

2. Information We Collect We may collect and process the following data about you:

• • Information You Give Us: You may give us information by filling in forms on our site, submitting LinkedIn Lead Gen forms, subscribing to our newsletter, or corresponding with us by phone or email. This includes:
    • Full Name
    • Email Address
    • Phone Number
    • Job Title & Company Name (specifically via LinkedIn)
    • Billing/Shipping Address (if purchasing)
  • Information We Collect Automatically: When you visit our site, we may automatically collect technical information, including:
    • Internet Protocol (IP) address.
    • Browser type, version, and time zone setting.
    • Operating system and platform.
    • Information about your visit (clickstream data, pages viewed, page response times).

3. How We Use Your Data We use your data for the following specific purposes:

• • Marketing & Lead Fulfillment: To send you the information you explicitly requested (such as Investment Memorandums, brochures, or samples) and to contact you regarding whiskey investment opportunities or cask offers.
  • Newsletters: To send you periodic updates regarding estate news, distillery updates, and whiskey releases (only where you have consented to receive them).
  • Order Processing: To fulfill orders placed through our shop and handle shipping/billing.
  • Website Administration: To improve our site, troubleshoot issues, and ensure content is presented effectively for your device.

4. Legal Basis for Processing (GDPR) We process your personal data based on the following legal grounds:

• • Consent: When you tick a box on a form (website or LinkedIn) asking to be contacted or to download a brochure, you are giving explicit consent.
  • Contractual Necessity: When you buy a product or cask, we need your data to fulfill that contract.
  • Legitimate Interest: We may use your data to analyse the performance of our marketing or improve our website security.

5. Data Retention We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

• • Marketing Data: We retain your contact details for marketing purposes for a period of 24 months from the date of your last interaction with us. If you do not engage with our communications during this period, your data will be securely deleted or anonymized.
  • Investment & Sales Records: Data related to financial transactions or investment inquiries is retained for 6 years to comply with statutory legal and financial record-keeping obligations in Ireland.

6. Disclosure of Your Information We do not sell your personal data to third parties. We may share your data with:

• • Service Providers: Trusted third parties who help us operate our business, such as email marketing platforms (e.g., Mailchimp, HubSpot), payment processors (Stripe/PayPal), and analytics providers (Google Analytics).
  • Legal Obligations: If we are under a duty to disclose your data to comply with a legal obligation or to protect the rights, property, or safety of Curraghmore Whiskey.

7. International Transfers Some of our external third parties may be based outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring specific contracts (Standard Contractual Clauses) approved by the European Commission are in place.

8. Cookies Policy Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

• • Analytical Cookies: We use Google Analytics and Hotjar to recognise and count the number of visitors and see how they move around the site.
  • Functionality Cookies: These are used to recognise you when you return to our website.
  • Managing Cookies: You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies, you may not be able to access all or parts of our site.

9. Your Rights Under GDPR, you have the right to:

• • Access: Request a copy of the personal data we hold about you.
  • Rectification: Request that we correct any inaccurate data.
  • Erasure: Request that we delete your personal data (“Right to be forgotten”).
  • Object/Restrict: Object to our processing of your data for marketing purposes.
  • Lodge a Complaint: You have the right to lodge a complaint with the Irish supervisory authority, the Data Protection Commission (DPC), if you believe your rights have been violated.

10. Contact Us Questions, comments, and requests regarding this privacy policy are welcome.

Email: info@curraghmorewhiskey.com

Phone: +353 51 387101