Privacy Policy

1. Who We Are

Gaugers Share Limited ("we", "us", "our") is the data controller for your personal data. We are registered in Scotland and operate the website gaugersshare.com.

Contact:
Gaugers Share Limited
Ayre Road, Kirkwall, Orkney, KW15 1QX
Email: info@gaugersshare.com

2. What Data We Collect

We collect the following categories of personal data:

• Account information: name, email address, password (hashed — never stored in plain text).
• Order data: delivery address, order history, payment reference (we do not store full card numbers — payments are handled by Stripe).
• Age verification: a cookie confirming you have confirmed you are 18 or over.
• Usage analytics: anonymous visit data collected by Fathom Analytics (no personal identifiers).
• Correspondence: emails, trade enquiries and other messages you send us.
• QR scan data: if you scan a bottle QR code, we record the scan event (no personal data required; we use anonymised identifiers).

3. Legal Basis for Processing

Processing Activity	Legal Basis
Account creation and management	Contract (Article 6(1)(b))
Processing orders and payments	Contract (Article 6(1)(b))
Marketing emails (with opt-in)	Consent (Article 6(1)(a))
Age verification	Legal obligation (Article 6(1)(c))
Responding to enquiries	Legitimate interests (Article 6(1)(f))
Analytics (Fathom, cookieless)	Legitimate interests — no personal data processed

4. How Long We Keep Your Data

We retain your personal data only as long as necessary:

• Account data: until you request deletion, or 3 years after your last login if your account is inactive.
• Order records: 7 years for tax and legal compliance purposes.
• Marketing consent: until you withdraw consent.

5. Third Parties

We share data with trusted third-party processors only as necessary to deliver our services:

• Convex Inc. — our backend database and cloud functions provider.
• Stripe Inc. — payment processing (subject to Stripe's own privacy policy).
• Fathom Analytics — privacy-first, GDPR-compliant website analytics with no personal data collection.
• Vercel Inc. — website hosting.

We do not sell your data. We do not share it with advertisers.

6. Cookies

We use minimal cookies:

• Session cookie: required for account login. This is a functional cookie — no consent required.
• Age verification cookie: stores your acknowledgement that you are 18+. Functional — no consent required.
• Analytics: Fathom Analytics is cookieless and does not require consent.

We do not use advertising cookies, tracking pixels or third-party marketing cookies.

7. Your Rights

Under UK GDPR, you have the right to:

• Access the personal data we hold about you.
• Rectification — correct inaccurate data.
• Erasure ("right to be forgotten") — subject to legal retention obligations.
• Portability — receive your data in a machine-readable format.
• Restriction of processing in certain circumstances.
• Object to processing based on legitimate interests.
• Withdraw consent at any time where processing is consent-based.

To exercise any of these rights, please email info@gaugersshare.com. We will respond within one calendar month.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO).

8. Data Security

We implement appropriate technical and organisational measures to protect your data, including TLS encryption in transit, hashed password storage, and access controls limiting who can view personal data.

9. Changes to This Policy

We may update this policy from time to time. We will notify you of significant changes by email or by a prominent notice on our website. The date at the top of this page shows when it was last updated.