Privacy & Cookie Policy

This Privacy & Cookie Policy explains how Cipher Brands Limited, trading as ZeroDrinks
(“ZeroDrinks”, “we”, “us”, “our”), collects, uses and protects your personal data when you
visit zerodrinks.ie, contact us, or place an order.

We are committed to protecting your privacy and complying with applicable data protection laws,
including the EU/UK GDPR and Irish data protection law.

Who we are

Cipher Brands Limited t/a ZeroDrinks, Registered in Ireland

For the purposes of data protection law, Cipher Brands Limited is the “data controller” of your personal data.

What data we collect

Depending on how you interact with us, we may collect and process the following categories of personal data:

Identity and contact details

• Name
• Email address
• Billing address and delivery address
• Phone number

Account and order details

• Username and password (hashed, not stored in plain text)
• Order history and purchased products
• Delivery instructions or preferences
• Communications relating to your orders

Payment and transaction data

• Payment method details (we do not store full card numbers; this is handled by our payment providers)
• Transaction amounts and timestamps

Website and technical data

• IP address
• Browser type and version
• Device type and operating system
• Pages visited, time and date of visits, referring URLs
• Cookie IDs and similar identifiers

Marketing and communication data

• Newsletter subscriptions (e.g. The Zero List)
• Your marketing preferences
• Information about how you interact with our emails (opens, clicks), where supported by our email platform

Any other data you provide

• Information you include when you contact us via email, contact form or social media
• Responses to surveys, feedback, reviews or competition entries

How we collect your data

Information you provide directly

You may give us data when you:

• Create an account on zerodrinks.ie
• Place an order
• Sign up to our mailing list
• Fill out a contact form or email us
• Enter a competition, promotion or survey
• Request trade, venue or event information

Information we collect automatically

When you browse zerodrinks.ie we may automatically collect certain technical
and usage data using cookies and similar technologies. This helps us keep the site secure, operate the cart
and checkout, understand performance and improve your experience.

Information from third parties

We may receive limited data from:

• Payment providers (e.g. confirmation that your payment was successful or failed)
• Delivery partners (e.g. delivery status updates)
• Analytics and marketing tools (aggregated or pseudonymised usage and campaign data)

Why we use your data and our legal bases

We use your personal data for the purposes below and rely on the listed legal bases:

To process and deliver your orders

• Creating and managing your account
• Taking payment and issuing invoices
• Picking, packing and delivering your order
• Handling returns, refunds and order-related issues

Legal basis: performance of a contract; legitimate interests (to run our business)

To communicate with you about your orders and our services

• Sending order confirmations, shipping updates and service messages
• Responding to your questions and customer support requests

Legal basis: performance of a contract; legitimate interests (to provide good customer service)

To send you marketing communications (where permitted)

• Sending email newsletters when you sign up
• Sending offers and updates about products and events that may interest you

Legal basis: consent (for newsletter sign-ups); legitimate interests / soft opt-in where allowed
for existing customers, subject to your right to opt out at any time.

To personalise and improve our website and services

• Understanding how visitors use zerodrinks.ie
• Improving navigation, content and product offering
• Measuring the performance of marketing campaigns

Legal basis: legitimate interests; consent for non-essential cookies and marketing technologies

To keep our website and business secure

• Monitoring and protecting the security and integrity of our systems
• Detecting and preventing fraud or misuse of our services

Legal basis: legitimate interests; legal obligation

To comply with law

• Keeping records for tax and accounting purposes
• Responding to lawful requests from public authorities

Legal basis: legal obligation

We do not use your personal data to make decisions based solely on automated processing that have legal or similarly significant effects on you.

Marketing communications

If you subscribe to The Zero List or otherwise opt in to marketing, we will send you emails about:

• New alcohol-free and non-alcoholic products
• Bundles, offers and promotions
• Events, community activity and Discovery content

You can unsubscribe at any time by:

• Clicking the “unsubscribe” link in any marketing email, or
• Contacting us at support@zerodrinks.ie

If you are an existing customer, we may send you occasional marketing emails about similar products or services,
in line with applicable law. You can opt out of these at any time.

Cookies and similar technologies

We use cookies and similar technologies on zerodrinks.ie. Cookies are small text files stored on your device that
help us:

• Run essential site features (e.g. cart and checkout)
• Remember your preferences
• Understand how the site is used
• Tailor content and marketing (where you consent)

Types of cookies we may use

Strictly necessary cookies

Required for the site to function properly. For example:

• Remembering your cart and checkout progress
• Keeping you logged in
• Security-related cookies

These are always active when you use the site and do not require consent.

Performance and analytics cookies

Help us understand how people use our website (for example, which pages are visited most often) so we can improve it.
These may be provided by tools such as Google Analytics.

Functionality cookies

Remember choices you make, such as language, region or saved preferences, to enhance your experience.

Marketing and advertising cookies

Used to show you relevant adverts and measure the performance of campaigns (for example, tags from Meta or Google Ads),
only where you have given consent.

Managing cookies

When you first visit zerodrinks.ie, you may see a cookie banner that allows you to accept or manage your cookie preferences for non-essential cookies.

You can also control cookies via your browser settings, by:

• Deleting existing cookies
• Blocking some or all cookies
• Setting preferences for certain sites
• Managing cookies using the tool at the bottom of this page

If you block strictly necessary cookies, parts of the website (especially the shop and checkout) may not function correctly.

Who we share your data with

We do not sell your personal data.

We may share your personal data with:

Service providers and partners

• Payment processors and payment gateways
• Delivery and logistics partners
• Web hosting and e-commerce platform providers
• Analytics and marketing platforms
• Email service and CRM providers
• Professional advisers (legal, accounting, etc.)

These providers only process your data on our instructions and are required to keep it secure.

Authorities and legal requirements

We may disclose your personal data if required to do so by law, regulation, legal process or governmental request,
or to protect our rights, property and the safety of our users and others.

Business transfers

If all or part of Cipher Brands Limited is involved in a merger, acquisition, asset sale or similar event, your
personal data may be transferred as part of that transaction, subject to appropriate protections.

International transfers

Some of our service providers may be located outside the European Economic Area (EEA). Where your personal data is
transferred outside the EEA, we will ensure appropriate safeguards are in place, such as:

• The country being recognised as providing an adequate level of data protection; or
• The use of Standard Contractual Clauses approved by the European Commission; or
• Other appropriate safeguards permitted by data protection law.

How long we keep your data

We keep personal data only for as long as necessary for the purposes described in this policy, including:

• Order and account data: generally retained for as long as your account is active and for a period afterwards to comply
  with legal and tax obligations, resolve disputes and enforce our agreements.
• Marketing data: retained while you remain subscribed or until we determine it is no longer needed, or you withdraw
  consent / unsubscribe.
• Technical and analytics data: retained for a period that allows us to analyse and improve our website and services,
  as defined by our analytics providers’ settings.

When personal data is no longer required, we will delete or anonymise it.

How we protect your data

We take appropriate technical and organisational measures to protect your personal data, including:

• SSL/HTTPS encryption for data in transit between your browser and our website
• Secure hosting and regular security updates
• Access controls and authentication for our systems
• Limiting access to personal data to staff and service providers who need it

However, no method of transmission or storage is completely secure. While we strive to protect your data, we cannot
guarantee absolute security.

Your rights

You have certain rights in relation to your personal data, subject to conditions and exceptions in law:

• Right of access: to obtain confirmation whether we process your personal data and a copy of that data.
• Right to rectification: to have inaccurate or incomplete personal data corrected.
• Right to erasure: to request deletion of your personal data in certain circumstances.
• Right to restrict processing: to request we limit how we use your data in certain situations.
• Right to data portability: to receive your personal data in a structured, commonly used and machine-readable
  format and transmit it to another controller, where applicable.
• Right to object: to object to certain types of processing, including direct marketing.
• Right to withdraw consent: where processing is based on consent, you can withdraw it at any time
  (this will not affect processing that has already taken place).

To exercise any of these rights, contact us at
{support@zerodrinks.ie}. We may ask you to verify your identity before
acting on your request.

12. Complaints

If you are concerned about how we handle your personal data, please contact us first at
{support@zerodrinks.ie} and we will do our best to resolve your concern.

You also have the right to lodge a complaint with the Data Protection Commission in Ireland:

Data Protection Commission
6 Pembroke Row
Dublin 2
D02 X963
Ireland
Website:
www.dataprotection.ie

Changes to this policy

We may update this Privacy & Cookie Policy from time to time to reflect changes in our practices, legal
requirements or the operation of zerodrinks.ie.

When we make changes, we will update the “Last updated” date at the top of this page. We encourage you to review
this policy periodically.

How to contact us

If you have any questions about this Privacy & Cookie Policy or how we handle your personal data, you can contact
us at:

Cipher Brands Limited
Trading as ZeroDrinks
Email: {support@zerodrinks.ie}