This disclaimer should be read carefully before making any investment decision in Inverurie Distillery Company Limited (the “Company”). If you have any doubts about the suitability of this investment, you should seek independent financial, legal, and tax advice.

High-Risk Investment Warning

This is a high-risk investment. You could lose all of your invested capital.

Investing in Inverurie Distillery Company Limited involves a significant degree of risk. Investments in early-stage, unlisted companies are speculative and carry risks that are substantially different from those associated with investments in publicly traded securities or established businesses.

Key Investment Risks

Loss of Capital

• There is a substantial risk that you will lose all of the money you invest
• You should only invest money that you can afford to lose completely without altering your standard of living
• The value of your investment may go down as well as up
• You may not get back the amount you originally invested

Illiquidity

• Shares in the Company are not listed on any stock exchange
• There is no established market for the sale of shares
• It may be extremely difficult or impossible to sell your shares
• You should consider this investment as long-term and potentially permanent
• Even if you find a buyer, you may have to sell at a significant discount to your original investment

Early-Stage Company Risk

• The Company is in its early stages of development
• The distillery has not yet commenced commercial production
• There is no operating history upon which to evaluate performance
• The Company may never achieve profitability or commercial success
• The majority of early-stage businesses fail

Dilution Risk

• The Company may raise additional capital in the future through further share issues
• Your percentage ownership may be diluted if you do not participate in future funding rounds
• Future investors may receive preferential terms that affect the value of your shares
• The Company’s Articles of Association may permit actions that could dilute your shareholding

Limited Control

• As a minority shareholder, you will have limited ability to influence Company decisions
• The directors will make day-to-day business decisions without shareholder approval
• You may not agree with all business decisions made by management
• Shareholder protections may be limited

Long Time Horizon

• Whisky must mature for several years before it can be sold
• The Company may not generate revenue for an extended period
• Returns on investment, if any, may take many years to materialize
• You should be prepared to wait 10+ years before any potential returns

Operational Risks

• Agricultural risks affecting barley production
• Production challenges and quality control issues
• Dependency on key personnel and master distiller
• Equipment failure or production delays
• Regulatory changes affecting the whisky industry
• Supply chain disruptions
• Weather and climate impacts on production and maturation

Market Risks

• Changes in consumer demand for premium whisky
• Increased competition in the whisky market
• Economic downturns affecting luxury goods spending
• Changes in export markets and international trade
• Currency fluctuations affecting international sales
• Shifts in consumer preferences away from whisky

Regulatory and Legal Risks

• Changes to alcohol production and sales regulations
• Environmental regulations affecting distillery operations
• Tax law changes including those affecting EIS relief
• Planning permission and land use restrictions
• Health and safety compliance requirements
• Intellectual property disputes

Financial Risks

• The Company may require additional funding that is not obtained
• Inability to secure necessary debt or equity financing
• Interest rate changes affecting borrowing costs
• Insufficient working capital to continue operations
• Cost overruns in construction or production
• Lower than expected revenue generation

Enterprise Investment Scheme (EIS)

Tax Relief Not Guaranteed

While the Company intends to qualify for Enterprise Investment Scheme (EIS) tax relief, this is subject to:

• HMRC approval and advance assurance
• The Company maintaining qualifying conditions
• Your individual tax circumstances and eligibility
• Compliance with all EIS requirements and holding periods

Conditions and Requirements

• EIS relief is only available to UK taxpayers
• You must hold shares for at least 3 years to retain Income Tax relief
• If qualifying conditions are not met, tax reliefs may be withdrawn
• Capital Gains Tax deferral relief is only available in specific circumstances
• Loss relief is only available if Income Tax relief has not been withdrawn
• The tax benefits depend on your individual tax position

No Guarantee of EIS Status

• The Company cannot guarantee that it will obtain or maintain EIS qualifying status
• HMRC may reject the EIS application or withdraw approval
• Changes in tax legislation may affect EIS benefits
• Your personal circumstances may affect your eligibility for relief

Seek Tax Advice

• You should obtain professional tax advice before investing
• Tax laws and their application may change
• The value of tax reliefs depends on individual circumstances
• We do not provide tax advice

No Investment Advice

Independent Professional Advice Required

• The Company and its representatives do not provide investment, financial, tax, or legal advice
• All information provided is for informational purposes only
• You should consult with independent qualified advisers before investing
• Any projections, forecasts, or targets are estimates only and may not be achieved
• Past performance of other investments or businesses is not indicative of future results

Not a Recommendation

• Nothing on our website or in our materials constitutes a recommendation to invest
• We make no representation as to the suitability of this investment for any particular investor
• You are responsible for making your own investment decision
• You should conduct your own due diligence and research

Investment Suitability

This Investment is NOT Suitable for Everyone

You should only consider investing if you:

• Can afford to lose all of your invested capital
• Have sufficient liquid assets and diversified investments
• Do not require income or liquidity from this investment
• Understand the risks involved in early-stage company investments
• Have sufficient financial knowledge and experience to evaluate the investment
• Can withstand a long investment time horizon (10+ years)
• Meet the eligibility and suitability criteria established by the Company

Regulatory Guidance The Financial Conduct Authority (FCA) considers high-risk investments of this nature to be suitable only for:

• High net worth individuals
• Sophisticated investors with relevant experience
• Individuals who can certify themselves as sophisticated investors
• Individuals who receive regulated investment advice confirming suitability

Diversification

• This investment should only form part of a diversified investment portfolio
• You should not invest more than 10% of your net investable assets in high-risk investments such as this
• Concentrating your investments in one company or sector increases risk

Forward-Looking Statements

Projections and Estimates

Any forward-looking statements, projections, forecasts, or business plans provided by the Company:

• Are based on current expectations, estimates, and assumptions
• Are subject to risks and uncertainties
• May not be achieved or realized
• Should not be relied upon as guarantees of future performance
• May be affected by factors beyond the Company’s control

No Guarantees

• The Company makes no guarantee of any return on investment
• Projected revenues, profits, and growth may not materialize
• Actual results may differ materially from projections
• Market conditions may change significantly

Information Accuracy

No Warranty of Information

While we strive to ensure all information provided is accurate and up-to-date:

• Information may become outdated or inaccurate
• We make no warranty as to the accuracy or completeness of information
• You should verify information independently
• Information should not be relied upon as the sole basis for investment decisions
• We reserve the right to correct errors or update information without notice

Conflicts of Interest

Potential Conflicts

You should be aware that:

• Directors and management have financial interests in the Company’s success
• The Company may have relationships with suppliers, contractors, or advisers that create conflicts
• Future funding rounds may involve terms that favor certain investors
• Related party transactions may occur

Changes and Amendments

Right to Modify

The Company reserves the right to:

• Modify its business plan and strategy
• Change its capital structure
• Amend its Articles of Association (subject to shareholder approval where required)
• Pursue additional funding on different terms
• Make operational changes as circumstances require

Restriction on Transfer

Limited Transferability

• Shares may not be freely transferable
• The Company’s Articles of Association may restrict share transfers
• Pre-emption rights may apply to share sales
• Finding a buyer for your shares may be extremely difficult
• Any transfer may require board approval

No Offers Outside the UK

UK Residents Only

• This investment opportunity is intended for UK residents only
• The offer has not been registered or approved in any other jurisdiction
• Persons located outside the UK should not participate
• It may be unlawful to participate if you are not a UK resident

Investor Responsibilities

Your Obligations

By investing, you acknowledge that you:

• Have read and understood this disclaimer and all investment materials
• Have sought independent professional advice or have chosen not to do so
• Understand the risks involved
• Can afford to lose your entire investment
• Meet all eligibility and suitability requirements
• Have provided accurate and truthful information
• Will comply with all applicable laws and regulations

Complaints and Disputes

Regulatory Status

• The Company is not regulated by the Financial Conduct Authority
• You will not have access to the Financial Services Compensation Scheme
• You will not have access to the Financial Ombudsman Service
• Disputes must be resolved through normal legal channels

Questions and Further Information

If you have any questions about this investment or require further information, please contact us:

Email: info@inveruriedistillery.co.uk
Address: Fetternear Stables, Kemnay, Inverurie AB51 5LY

Remember: This is a high-risk investment. Only invest money you can afford to lose. Seek independent financial advice before investing.

1. Introduction

Welcome to Inverurie Distillery Company Limited (“we”, “us”, “our”, or the “Company”). These Terms and Conditions (“Terms”) govern your use of our website at inveruriedistillery.co.uk (the “Site”) and your participation in our investment offerings and services (collectively, the “Services”).

By accessing or using our Site or Services, you agree to be bound by these Terms. If you do not agree to these Terms, please do not use our Site or Services.

2. Definitions

• “Investor” means an individual or entity who has applied for or completed an investment in the Company
• “Investment” means the purchase of shares in Inverurie Distillery Company Limited
• “Fetternear Bishops” or “Bishops” means the exclusive group of founding shareholders in the Company
• “Services” means all services provided by the Company including but not limited to investment opportunities, shareholder benefits, and related services
• “Site” means the website located at inveruriedistillery.co.uk

3. Eligibility

3.1 Age Requirement

You must be at least 18 years of age to use our Site or Services. By using the Site or Services, you represent and warrant that you are at least 18 years old.

3.2 Investment Eligibility

To invest in the Company, you must:

• Be a UK resident for tax purposes, or meet other eligibility requirements as specified
• Have the legal capacity to enter into a binding contract
• Meet any additional suitability and eligibility requirements as determined by the Company
• Comply with all applicable laws and regulations relating to investments

3.3 Jurisdiction

Our Services are intended for individuals located in the United Kingdom. If you access our Site from outside the UK, you do so at your own risk and are responsible for compliance with local laws.

4. Investment Terms

4.1 Investment Offerings

The Company offers equity investment opportunities which may include:

• Ordinary shares in Inverurie Distillery Company Limited
• Associated benefits including cask ownership and shareholder privileges
• Eligibility for Enterprise Investment Scheme (EIS) tax relief, subject to HMRC approval and individual circumstances

4.2 Investment Process

• All investment applications are subject to our approval and acceptance
• We reserve the right to reject any investment application at our sole discretion
• Investment applications must be completed accurately and truthfully
• You may be required to provide additional documentation for identity verification and compliance purposes
• Investment confirmations will be provided once your application is accepted and payment is received

4.3 Risk Acknowledgment

By applying to invest, you acknowledge and accept that:

• Investments in early-stage companies carry significant risk
• You may lose all of your invested capital
• Investments are illiquid and cannot be easily sold or transferred
• The value of your investment may go down as well as up
• There is no guarantee of any return on your investment
• Past performance is not indicative of future results
• Tax reliefs (including EIS) depend on your individual circumstances and may be withdrawn if qualifying conditions are not met

4.4 Investment Advice

• We do not provide investment, financial, tax, or legal advice
• You should seek independent professional advice before making any investment decision
• All investment decisions are made at your own risk
• We are not responsible for any losses you may incur as a result of your investment

4.5 Cooling-Off Period

You may have statutory cancellation rights under the Financial Services and Markets Act 2000. Details of any cooling-off period will be provided in your investment documentation.

5. Payment Terms

5.1 Payment Processing

• All payments are processed securely through our payment processor, Stripe
• You agree to provide accurate and complete payment information
• You authorize us to charge your chosen payment method for the investment amount
• All prices are quoted in British Pounds (GBP) unless otherwise stated

5.2 Payment Confirmation

• You will receive confirmation once your payment has been successfully processed
• If payment fails, we will notify you and your investment application may be rejected

5.3 Refunds

• Investment payments are generally non-refundable except as required by law or as specified in your investment documentation
• Any refunds will be processed through the original payment method
• Refunds may take 5-10 business days to appear in your account

6. Shareholder Rights and Responsibilities

6.1 Share Ownership

Upon successful completion of your investment:

• You will become a shareholder in Inverurie Distillery Company Limited
• Your name will be entered into the Company’s register of members
• You will receive a share certificate or electronic confirmation of ownership
• You will be entitled to the rights and subject to the obligations set out in the Company’s Articles of Association

6.2 Shareholder Communications

• We will communicate with shareholders via email, post, or through a dedicated shareholder portal
• You are responsible for keeping your contact details up to date
• Important notices and documents will be sent to your registered address or email

6.3 Shareholder Benefits

• Specific benefits available to Fetternear Bishops will be communicated separately
• Benefits may include cask ownership, distillery access, and other privileges
• Benefits are subject to change and may be modified or withdrawn at the Company’s discretion
• Benefits are non-transferable unless otherwise specified

7. Account Registration and Security

7.1 Account Creation

• You may be required to create an account to access certain Services
• You must provide accurate, complete, and current information
• You are responsible for maintaining the confidentiality of your account credentials
• You must not share your account credentials with any third party

7.2 Account Security

• You are responsible for all activities that occur under your account
• You must notify us immediately of any unauthorized use of your account
• We are not liable for any loss or damage arising from your failure to maintain account security
• We reserve the right to suspend or terminate accounts that violate these Terms

8. Intellectual Property Rights

8.1 Ownership

All content on the Site, including but not limited to text, graphics, logos, images, videos, software, and designs, is the property of Inverurie Distillery Company Limited or its licensors and is protected by copyright, trademark, and other intellectual property laws.

8.2 Limited License

We grant you a limited, non-exclusive, non-transferable license to access and use the Site for personal, non-commercial purposes in accordance with these Terms.

8.3 Restrictions

You may not:

• Copy, modify, distribute, sell, or lease any part of our Services or content
• Reverse engineer or attempt to extract source code from our Site
• Use any content from our Site for commercial purposes without our written permission
• Remove or alter any copyright, trademark, or other proprietary notices

8.4 Trademarks

“Inverurie Distillery”, “Fetternear Bishops”, and associated logos are trademarks of Inverurie Distillery Company Limited. You may not use these trademarks without our prior written consent.

9. User Content and Communications

9.1 User Submissions

If you submit content to our Site (including reviews, comments, or communications), you grant us a worldwide, non-exclusive, royalty-free license to use, reproduce, modify, and display such content in connection with our Services.

9.2 Content Standards

You agree not to submit content that:

• Is illegal, harmful, threatening, abusive, harassing, defamatory, or obscene
• Infringes any intellectual property rights
• Contains viruses or other harmful code
• Violates any applicable laws or regulations

9.3 Monitoring

We reserve the right (but have no obligation) to monitor, edit, or remove any user content at our sole discretion.

10. Prohibited Uses

You agree not to:

• Use the Site or Services for any unlawful purpose
• Attempt to gain unauthorized access to our systems or networks
• Interfere with or disrupt the Site or Services
• Use automated systems (bots, scrapers) to access the Site without permission
• Impersonate any person or entity
• Collect personal information about other users
• Engage in any activity that could damage our reputation or business
• Manipulate or attempt to manipulate any investment process
• Make false or misleading statements about the Company or investments

11. Third-Party Links and Services

11.1 Third-Party Links

Our Site may contain links to third-party websites or services. We are not responsible for the content, privacy practices, or terms of these third-party sites.

11.2 Third-Party Services

We use third-party service providers (including Stripe for payment processing) to facilitate our Services. Your use of these services may be subject to their own terms and conditions.

12. Disclaimers and Limitations of Liability

12.1 Service “As Is”

The Site and Services are provided “as is” and “as available” without warranties of any kind, either express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, or non-infringement.

12.2 No Investment Warranty

We make no warranties or representations regarding:

• The performance or success of the Company or your investment
• The accuracy or completeness of information provided
• The availability or reliability of the Site or Services
• The suitability of any investment for your particular circumstances

12.3 Limitation of Liability

To the maximum extent permitted by law:

• We shall not be liable for any indirect, incidental, special, consequential, or punitive damages
• Our total liability shall not exceed the amount you paid to us in the 12 months preceding the claim
• We are not liable for losses arising from your investment decisions
• We are not liable for failures caused by circumstances beyond our reasonable control

12.4 Investment Losses

We are not liable for any losses you incur as a result of your investment in the Company, including but not limited to:

• Loss of invested capital
• Failure to achieve expected returns
• Changes in tax treatment or loss of tax reliefs
• Inability to sell or transfer your shares

12.5 Technical Issues

We are not liable for:

• Interruptions or errors in the Site or Services
• Loss of data or communications
• Failures of third-party service providers
• Computer viruses or other harmful code

13. Indemnification

You agree to indemnify, defend, and hold harmless Inverurie Distillery Company Limited, its directors, officers, employees, agents, and affiliates from any claims, liabilities, damages, losses, costs, or expenses (including reasonable legal fees) arising from:

• Your use of the Site or Services
• Your violation of these Terms
• Your violation of any rights of third parties
• Any content you submit or transmit through the Services
• Your investment in the Company

14. Regulatory Compliance

14.1 Financial Promotions

Any financial promotions on our Site are intended for UK residents only and comply with UK financial promotion regulations.

14.2 Anti-Money Laundering

We comply with UK anti-money laundering regulations and may require you to provide documentation to verify your identity and source of funds.

14.3 Data Protection

We process your personal information in accordance with our Privacy Policy and applicable data protection laws including the UK GDPR.

14.4 Tax Compliance

You are responsible for determining and fulfilling your own tax obligations in relation to your investment. We may be required to report information about your investment to HMRC or other tax authorities.

15. Changes to Terms

15.1 Modifications

We reserve the right to modify these Terms at any time. We will notify you of material changes by:

• Posting the updated Terms on our Site
• Updating the “Last updated” date
• Sending you an email notification where appropriate

15.2 Acceptance of Changes

Your continued use of the Site or Services after changes are posted constitutes your acceptance of the modified Terms. If you do not agree to the changes, you must stop using the Site and Services.

16. Termination

16.1 Termination by You

You may stop using our Site or Services at any time. However, termination does not affect your obligations as a shareholder or your investment in the Company.

16.2 Termination by Us

We reserve the right to suspend or terminate your access to the Site or Services at any time, with or without notice, for any reason, including if:

• You violate these Terms
• You engage in fraudulent or illegal activity
• We are required to do so by law
• We cease operations

16.3 Effect of Termination

Upon termination:

• Your right to access the Site and Services will cease immediately
• Any provisions of these Terms that by their nature should survive will remain in effect
• Your investment in the Company and shareholder rights will continue unless shares are transferred or redeemed in accordance with the Company’s Articles of Association

17. Dispute Resolution

17.1 Governing Law

These Terms are governed by and construed in accordance with the laws of England and Wales.

17.2 Jurisdiction

Any disputes arising from these Terms or your use of the Services shall be subject to the exclusive jurisdiction of the courts of England and Wales.

17.3 Informal Resolution

Before initiating formal proceedings, we encourage you to contact us to seek an informal resolution of any dispute.

18. General Provisions

18.1 Entire Agreement

These Terms, together with our Privacy Policy and any investment documentation, constitute the entire agreement between you and the Company regarding the Services.

18.2 Severability

If any provision of these Terms is found to be invalid or unenforceable, the remaining provisions will remain in full force and effect.

18.3 Waiver

Our failure to enforce any provision of these Terms does not constitute a waiver of that provision or any other provision.

18.4 Assignment

You may not assign or transfer your rights or obligations under these Terms without our prior written consent. We may assign our rights and obligations without restriction.

18.5 No Partnership

Nothing in these Terms creates a partnership, joint venture, employment, or agency relationship between you and the Company.

18.6 Force Majeure

We shall not be liable for any failure or delay in performing our obligations due to circumstances beyond our reasonable control.

18.7 Notices

All notices to the Company should be sent to info@inveruriedistillery.co.uk or Fetternear Stables, Kemnay, Inverurie AB51 5LY.

18.8 Language

These Terms are written in English. Any translations are provided for convenience only, and the English version shall prevail in case of any conflict.

19. Contact Information

If you have any questions about these Terms, please contact us:

Email: info@inveruriedistillery.co.uk
Address: Fetternear Stables, Kemnay, Inverurie AB51 5LY
Website: inveruriedistillery.co.uk

This Privacy Policy describes how Inverurie Distillery Company Limited (also referred to as “we”, “us”, or “our”) collects, uses, and discloses your personal information when you visit, use our services, or make an investment from inveruriedistillery.co.uk (the “Site”) or otherwise communicate with us regarding the Site (collectively, the “Services”). For purposes of this Privacy Policy, “you” and “your” means you as the user of the Services, whether you are an investor, potential investor, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the Site, update the “Last updated” date and take any other steps required by applicable law.

How We Collect and Use Your Personal Information

To provide the Services, we collect personal information about you from a variety of sources, as set out below. The information that we collect and use varies depending on how you interact with us.

In addition to the specific uses set out below, we may use information we collect about you to communicate with you, provide or improve the Services, comply with any applicable legal obligations, enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

What Personal Information We Collect

The types of personal information we obtain about you depends on how you interact with our Site and use our Services. When we use the term “personal information”, we are referring to information that identifies, relates to, describes or can be associated with you. The following sections describe the categories and specific types of personal information we collect.

Information We Collect Directly from You

Information that you directly submit to us through our Services may include:

• Contact details including your name, address, phone number, and email
• Investment application information including your name, billing address, payment confirmation, email address, phone number, and investment details
• Account information including your username, password, security questions and other information used for account security purposes
• Eligibility and suitability information including information about your tax status, investment experience, risk tolerance, and connection to the company
• Customer support information including the information you choose to include in communications with us, for example, when sending a message through the Services

Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.

Information We Collect about Your Usage

We may also automatically collect certain information about your interaction with the Services (“Usage Data”). To do this, we may use cookies, pixels and similar technologies (“Cookies”). Usage Data may include information about how you access and use our Site and your account, including device information, browser information, information about your network connection, your IP address and other information regarding your interaction with the Services.

Information We Obtain from Third Parties

Finally, we may obtain information about you from third parties, including from vendors and service providers who may collect information on our behalf, such as:

• Companies who support our Site and Services
• Our payment processors (Stripe), who collect payment information (e.g., bank account, credit or debit card information, billing address) to process your payment in order to fulfil your investment application and provide you with services you have requested, in order to perform our contract with you
• Identity verification services that help us comply with anti-money laundering and know-your-customer regulations

When you visit our Site, open or click on emails we send you, or interact with our Services or advertisements, we, or third parties we work with, may automatically collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third-party libraries, and cookies.

Any information we obtain from third parties will be treated in accordance with this Privacy Policy. Also see the section below, Third Party Websites and Links.

How We Use Your Personal Information

Providing Products and Services. We use your personal information to provide you with the Services in order to perform our contract with you, including to process your payments, fulfil your investment applications, to send notifications to you related to your account, investments, returns, exchanges or other transactions, to create, maintain and otherwise manage your account, and other features and functionalities related to your account and investment.

Compliance and Regulatory Requirements. We use your personal information to comply with legal and regulatory obligations, including verifying your identity, assessing investment suitability, conducting anti-money laundering checks, and maintaining records as required by financial services regulations.

Marketing and Advertising. We may use your personal information for marketing and promotional purposes, such as to send marketing, advertising and promotional communications by email, text message or postal mail, and to show you advertisements for our services. This may include using your personal information to better tailor the Services and advertising on our Site and other websites. If you are an EEA resident, the legal basis for these data processing activities is our legitimate interest in promoting our services, according to Art. 6 (1) (f) GDPR.

Security and Fraud Prevention. We use your personal information to detect, investigate or take action regarding possible fraudulent, illegal or malicious activity. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately. If you are an EEA resident, the legal basis for these data processing activities is our legitimate interest in keeping our website secure for you and other investors, according to Art. 6 (1) (f) GDPR.

Communicating with You and Service Improvement. We use your personal information to provide you with customer support and improve our Services. This is in our legitimate interests in order to be responsive to you, to provide effective services to you, and to maintain our business relationship with you according to Art. 6 (1) (f) GDPR.

Cookies

Like many websites, we use Cookies on our Site. We use Cookies to power and improve our Site and our Services (including to remember your actions and preferences), to run analytics and better understand user interaction with the Services (in our legitimate interests to administer, improve and optimize the Services). We may also permit third parties and services providers to use Cookies on our Site to better tailor the services and advertising on our Site and other websites.

Most browsers automatically accept Cookies by default, but you can choose to set your browser to remove or reject Cookies through your browser controls. Please keep in mind that removing or blocking Cookies can negatively impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available. Additionally, blocking Cookies may not completely prevent how we share information with third parties such as our advertising partners.

How We Disclose Personal Information

In certain circumstances, we may disclose your personal information to third parties for contract fulfilment purposes, legitimate purposes and other reasons subject to this Privacy Policy. Such circumstances may include:

• With vendors or other third parties who perform services on our behalf (e.g., IT management, payment processing via Stripe, data analytics, customer support, cloud storage, identity verification services, and regulatory compliance services)
• With business and marketing partners to provide services and advertise to you. Our business and marketing partners will use your information in accordance with their own privacy notices
• With professional advisers including lawyers, accountants, and auditors in connection with our business operations and regulatory compliance
• When you direct, request us or otherwise consent to our disclosure of certain information to third parties, with your consent
• With our affiliates or otherwise within our corporate group, in our legitimate interests to run a successful business
• In connection with a business transaction such as a merger or bankruptcy, to comply with any applicable legal obligations (including to respond to subpoenas, search warrants and similar requests), to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others

We disclose the following categories of personal information and sensitive personal information about users for the purposes set out above in “How we Collect and Use your Personal Information” and “How we Disclose Personal Information”:

Category:

• Identifiers such as basic contact details and certain account and investment information
• Commercial information such as investment application information and customer support information
• Financial information such as payment details and investment suitability assessments
• Internet or other similar network activity, such as Usage Data
• Geolocation data such as locations determined by an IP address or other technical measures

Categories of Recipients:

• Vendors and third parties who perform services on our behalf (such as Internet service providers, payment processors including Stripe, customer support partners, data analytics providers, and identity verification services)
• Business and marketing partners
• Professional advisers
• Regulatory authorities and law enforcement where required
• Affiliates

We do not use or disclose sensitive personal information without your consent or for the purposes of inferring characteristics about you.

User Generated Content

The Services may enable you to post reviews and other user-generated content. If you choose to submit user generated content to any public area of the Services, this content will be public and accessible by anyone.

We do not control who will have access to the information that you choose to make available to others, and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available, or for the accuracy, use or misuse of any information that you disclose or receive from third parties.

Third Party Websites and Links

Our Site may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.

Children’s Data

The Services are not intended to be used by children under the age of 18, and we do not knowingly collect any personal information about children under 18. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details set out below to request that it be deleted.

As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we “share” or “sell” (as those terms are defined in applicable law) personal information of individuals under 18 years of age.

Security and Retention of Your Information

Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” In addition, any information you send to us may not be secure while in transit. We recommend that you do not use insecure channels to communicate sensitive or confidential information to us.

How long we retain your personal information depends on different factors, such as whether we need the information to maintain your account, to provide the Services, comply with legal obligations (including financial services regulations that may require us to retain records for specified periods), resolve disputes or enforce other applicable contracts and policies.

Your Rights

Depending on where you live, you may have some or all of the rights listed below in relation to your personal information. However, these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law.

• Right to Access / Know: You may have a right to request access to personal information that we hold about you, including details relating to the ways in which we use and share your information
• Right to Delete: You may have a right to request that we delete personal information we maintain about you
• Right to Correct: You may have a right to request that we correct inaccurate personal information we maintain about you
• Right of Portability: You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions
• Right to Opt out of Sale or Sharing or Targeted Advertising: You may have a right to direct us not to “sell” or “share” your personal information or to opt out of the processing of your personal information for purposes considered to be “targeted advertising”, as defined in applicable privacy laws. Please note that if you visit our Site with the Global Privacy Control opt-out preference signal enabled, depending on where you are, we will automatically treat this as a request to opt-out of the “sale” or “sharing” of information for the device and browser that you use to visit the Site
• Restriction of Processing: You may have the right to ask us to stop or restrict our processing of personal information
• Withdrawal of Consent: Where we rely on consent to process your personal information, you may have the right to withdraw this consent
• Appeal: You may have a right to appeal our decision if we decline to process your request. You can do so by replying directly to our denial
• Managing Communication Preferences: We may send you promotional emails, and you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-promotional emails, such as those about your account, investments or transactions

You may exercise any of these rights where indicated on our Site or by contacting us using the contact details provided below.

We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address or account information, before providing a substantive response to the request. In accordance with applicable laws, you may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law.

Complaints

If you have complaints about how we process your personal information, please contact us using the contact details provided below. If you are not satisfied with our response to your complaint, depending on where you live you may have the right to appeal our decision by contacting us using the contact details set out below, or lodge your complaint with the Information Commissioner’s Office (ICO). For the EEA, you can find a list of the responsible data protection supervisory authorities here.

International Users

Please note that we may transfer, store and process your personal information outside the country you live in. Your personal information is also processed by staff and third party service providers and partners in these countries.

If we transfer your personal information out of Europe, we will rely on recognised transfer mechanisms like the European Commission’s Standard Contractual Clauses, or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined to provide an adequate level of protection.

Contact

Should you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, please contact us at info@inveruriedistillery.co.uk or contact us at Fetternear Stables, Kemnay, Inverurie AB51 5LY.

For the purpose of applicable data protection laws and if not explicitly stated otherwise, we are the data controller of your personal information.