Introduction

Mycroft Gin Ltd are committed to tackling alcohol fraud on a national level. We work to eliminate risk and aim to ensure We comply with all requirements and regulations and insist that our customers and suppliers perform due diligence checks on us in return.

As part of the Due Diligence requirement in the various excise regimes (Alcohol Wholesaler Registration Scheme. it is necessary for Mycroft Gin Ltd to carry out due diligence checks on existing and proposed customers, UK suppliers where applicable, and contractors. This is also important from anti-money laundering, anti-excise duty fraud and normal commercial perspectives.

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Purpose and Audience

The purpose of this policy is to set out our, Mycroft Gin Ltd, approach to due diligence. Alcohol duty fraud is a serious problem that harms not only the UK taxpayer but also legitimate businesses, communities and the wider economy. Without effective safeguards in place, there are considerable risks to all businesses along alcohol supply chains of becoming implicated in illicit trading. The due diligence condition requires that all excise registered businesses operating in the alcohol sector consider the risk of excise duty evasion as well as any commercial and other risks when they are trading. Doing so will help to drive illicit trading out of alcohol supply chains and reduce the risk to businesses of financial liabilities associated with goods on which duty has been evaded. This policy should be read by all members of staff, and especially by Directors, Buyers, Account Managers and Sales Teams.

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Statement of Policy

Mycroft Gin Ltd is committed to trading in full compliance with all relevant national, EU and international laws. We will:

• Objectively assess the risks of alcohol duty fraud within the supply chains in which we operate;

• Put in place reasonable and proportionate checks, in our day to day trading, to identify transactions that may lead to fraud

• or involve goods on which duty may have been evaded;

• Have procedures in place to take timely and effective mitigating action where a risk of fraud is identified; and

• Document the checks we intend to carry out and have governance in place to ensure that these are, and continue to be, carried out as intended or customer or other trading partner where we think there is a possibility that this could involve a fraudulent transaction.

• We will have close regard to “know your customer” requirements as set out in 2017 Money Laundering Regulations as amended from time to time.

• If we suspect fraud, HMRC will be notified

• All customers who do not pass the internal checks will be notified that their account will not be opened and customers with suspicious behaviour will be reported to HMRC in a timely manner.

• We will not inform you when or in what manner or to whom we report suspicious behaviour.

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Consequence of Non-Compliance

Failure to demonstrate due diligence may lead HMRC to conclude that a business is a risk to the revenue and not “fit and proper” for the purpose of excise legislation. This may lead to restrictions or conditions being imposed and, ultimately, to the withdrawal of authorizations, financial penalties, prosecutions and the seizure of stock.

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Processes

Mycroft Gin Ltd has adopted and documented processes that will:

• Check the identity of trading partners;

• Check the financial health of trading partners;

• Check the contract terms;

• Check the existence and provenance of goods that we buy and sell;

• Assess the credibility of the deal being contemplated

 

It is integral to those processes that in each case we will assess (having regard to said 2017 Regulations) how much information we need in order to justify the relationship or specific transaction. When we receive information, we will, as far as possible, cross-check it with independent sources.

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Privacy Policy

Your privacy is very important to us. At Mycroft Gin Ltd we have a few fundamental principles that we follow:

• We don’t ask you for personal information unless we truly need it.

• We don’t share your personal information with anyone except to comply with the law, develop our products, or protect our rights.

• We don’t store personal information on our servers unless required for the on-going operation of our site.

• Our policy is to respect your privacy regarding any information we may collect while operating our websites.

 

Consent

How do you get my consent?
When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we imply that you consent to our collecting it and using it for that specific reason only.

If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.

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How do I withdraw my consent?
If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at sales@mycroftgin.com

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Website Visitors

Like most website operators, Mycroft Gin Ltd collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Mycroft Gin Ltd’s purpose in collecting non-personally identifying information is to better understand how Mycroft Gin Ltd’s visitors use its website. From time to time, Mycroft Gin Ltd may release non-personally-identifying information in the aggregate, eg. by publishing a report on trends in the usage of its website.

 

Gathering of personally-identifying information

Certain visitors to the Mycroft Gin Ltd’s website choose to interact with us in ways that require us to gather personally-identifying information. The amount and type of information that Mycroft Gin Ltd gathers depend on the nature of the interaction. For example, we ask visitors who comment on our blog to provide a username and email address. Those who wish to receive Mycroft Gin Ltd updates via email, we collect their emails. In each case, Mycroft Gin Ltd collects such information only insofar as is necessary or appropriate to fulfill the purpose of the visitor’s interaction with Mycroft Gin Ltd. We do not disclose personally-identifying information other than as described below. And visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain website-related activities.

 

Third-party services

In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.

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However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.

For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.

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In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.

 

Aggregated statistics

Mycroft Gin Ltd may collect statistics about the behaviour of visitors to its websites. For instance, Mycroft Gin Ltd may monitor the most popular pages on the mycroftgin.com site or use spam screened by the service to help identify spam. Mycroft Gin Ltd may display this information publicly or provide it to others. However, Mycroft Gin Ltd does not disclose personally-identifying information other than as described below.

 

Protection of certain personally-identifying information

Mycroft Gin Ltd discloses potentially personally-identifying and personally-identifying information only to those of its employees, contractors and affiliated organizations that; (i) need to know that information in order to process it on Mycroft Gin Ltd’s behalf or to provide services available at Mycroft Gin Ltd’s websites, and (ii) that have agreed not to disclose it to others.

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Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using Mycroft Gin Ltd’s websites, you consent to the transfer of such information to them. Mycroft Gin Ltd will not rent or sell potentially personally-identifying and personally-identifying information to anyone. Other than to its employees, contractors and affiliated organizations, as described above, Mycroft Gin Ltd discloses potentially personally-identifying and personally-identifying information only in response to a subpoena, court order or other governmental request, or when Mycroft Gin  Ltd believes in good faith that disclosure is reasonably necessary to protect the property or rights of Mycroft Gin  Ltd, third parties or the public at large. If you are a registered user of a Mycroft Gin  Ltd website and have supplied your email address, Mycroft Gin  Ltd may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with Mycroft Gin  Ltd and our products. We primarily use our various product blogs to communicate this type of information, so we expect to keep this type of email to a minimum. If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users. Mycroft Gin Ltd takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information.

 

Cookies

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Mycroft Gin Ltd uses cookies to help Mycroft Gin  Ltd identify and track visitors, their usage of Mycroft Gin  Ltd website, and their website access preferences. Mycroft Gin Ltd visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Mycroft Gin Ltd’s websites, with the drawback that certain features of Mycroft Gin Ltd’s websites may not function properly without the aid of cookies.

 

Business transfers

If Mycroft Gin  Ltd, or substantially all of its assets were acquired, or in the unlikely event that Mycroft Gin Ltd goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Mycroft Gin Ltd may continue to use your personal information as set forth in this policy.

 

Privacy policy changes

Although most changes are likely to be minor, Mycroft Gin Ltd may change its Privacy Policy from time to time, and in Mycroft Gin Ltd’s sole discretion. Mycroft Gin Ltd encourages visitors to frequently check this page for any changes to its Privacy Policy. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change.

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Conditions on online ordering facility

Section 18.

(a) General

We have a self-declaration Challenge 25 policy of being over the age of 18 in the Terms and Conditions on the on-line ordering facility

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(b) The Protection of Children from Harm

We have put in place a sign on receipt/age verification process with our couriers whereby if recipients are unable to provide recognised ID the delivery must be terminated and returned to us.

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c) Challenge 25

The Challenge 25 age verification is to protect from selling alcohol to someone under age at the point of order/selection  It is Mycroft Gin's responsibility to ensure  that Mycroft Gin  does not sell age-restricted products online to people who are under age and Mycroft Gin  will take all reasonable steps to ensure that alcohol is not sold to anyone under 18.  We will display the Challenge 25 policy and this will rely on the purchaser confirming they are over the minimum age.  Delivery drivers will be instructed to ensure that age verification has taken place and that photo ID has been checked.

 

Questions and contact information

If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact us at sales@mycroftgin.com.

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