Last updated: 31 July 2026

1. Who we are

This privacy policy explains how Second Best Brewing Company Limited trading as Second Best collects, uses and protects your personal data when you use our website, submit a verification form, make a claim in connection with the Second Best equity offer, complete an official registration form, or otherwise contact us.

Second Best Brewing Company Limited is the controller of your personal data for the purposes described in this policy.

If you have any questions about this privacy policy, or if you would like to exercise your rights, you can contact us at:

Email: hello@secondbest.beer

Address: Third Floor, 3 Hill Street, New Town, Edinburgh, EH2 3JP

This website is intended for adults, and we do not knowingly collect personal data relating to children.

2. The data we collect

We may collect and use the following personal data:

• first name and last name;
• email address;
• marketing consent preferences;
• legal name, date of birth and postal address;
• information you provide when you submit a claim, complete a verification form or complete an official registration form;
• records of communications with you;
• technical information about your device and use of our website, such as IP address, browser type, device information and website usage data;
• cookie and analytics information, where applicable.

We may also generate aggregated or anonymised information about how our website is used. Where that information does not identify you, it is not personal data.

3. How we collect your data

We collect personal data:

• directly from you, when you fill in our landing page, verification form or registration form, sign up for updates, submit a claim for the Second Best equity offer, contact us or otherwise communicate with us;
• automatically, through cookies and similar technologies when you use our website;
• from service providers who help us operate the website, forms, communications and registration process;
• in some cases, from publicly available sources or third parties where needed to verify information you have provided or to help us administer the equity offer.

Where we need certain information by law, or in order to process your claim or registration, and you do not provide it, we may not be able to progress your claim, registration or related request.

4. Why we use your data and our legal bases

We only use your personal data where we have a valid legal basis to do so.

To review and administer your claim

We use your data to receive, assess and manage claims in connection with the Second Best equity offer, communicate with you about your claim, and keep a record of the process.

Legal basis: our legitimate interests in administering the equity offer fairly and efficiently.

To complete registration steps and maintain records

If your claim progresses, we may use your legal name, date of birth, postal address and related information to complete official registration steps, maintain statutory records, and keep any shareholder-related records we are required to hold.

Legal basis: compliance with a legal obligation, and where relevant our legitimate interests in administering the offer and maintaining accurate records.

To send marketing communications

If you ask to receive news, updates or promotional emails from us, we will use your contact details to send them.

Legal basis: your consent or our legitimate interests, as applicable

You can ask us to stop sending marketing to you at any time.

To respond to enquiries and manage communications

If you contact us, we may use your data to respond to your enquiry, deal with complaints, and keep a record of our communications.

Legal basis: our legitimate interests in managing our relationship with you and handling enquiries properly.

To operate, secure and improve our website

We may use technical and usage data to administer the website, troubleshoot issues, maintain security, understand how visitors use the site, and improve performance and user experience.

Legal basis: our legitimate interests in running, protecting and improving our website.

Where cookies or similar technologies require consent under applicable law, we will rely on your consent for those technologies.

5. Marketing

You will only receive marketing emails from us where you have asked us to.

You can unsubscribe at any time by clicking the unsubscribe link in one of our emails or by contacting us at hello@secondbest.beer.

If you opt out of marketing, we may still send you service or administration messages where necessary in connection with your claim or registration for shares, or other dealings with us.

We will not share your personal data with third parties for their own direct marketing purposes unless we have your express consent.

6. Who we share your data with

We may share your personal data with trusted third-party service providers who help us operate our website and administer this process, including providers of:

• website hosting and related services;
• online forms and verification tools;
• email and communications platforms;
• analytics and website performance tools;
• professional advisory, legal or administrative services.

This may include providers such as Webflow, Typeform, Brevo and analytics providers where used.

We may also share your data:

• where required by law or regulation;
• with professional advisers;
• to establish, exercise or defend legal claims;
• in connection with a business sale, merger, transfer or restructuring.

We do not sell your personal data.

Where third-party service providers process personal data on our behalf, they are only permitted to use it for specified purposes, in accordance with our instructions, and must protect it in accordance with applicable data protection law.

7. International transfers

Some of our service providers may store or process personal data outside the UK.

Where this happens, we will make sure that your personal data is protected by appropriate safeguards in accordance with UK data protection law. This may include relying on:

• a country which has been recognised as providing an adequate level of protection for personal data; or
• approved transfer mechanisms such as the UK International Data Transfer Agreement or the UK Addendum to standard contractual clauses.

You can contact us if you would like more information about any international transfers or the safeguards we use.

8. Data security

We take appropriate technical and organisational measures to protect your personal data against accidental loss, unauthorised access, misuse, alteration or disclosure.

We limit access to personal data to those who have a genuine business need to know it. Anyone processing personal data on our behalf must do so only on our instructions and is subject to appropriate confidentiality and security obligations.

We also have procedures in place to deal with suspected personal data breaches and will notify you and/or the relevant regulator where we are legally required to do so.

9. How long we keep your data

We keep personal data only for as long as reasonably necessary for the purposes described in this policy, including to administer claims or complete registration for shares, maintain records, comply with legal and regulatory obligations, resolve complaints and deal with disputes or legal claims.

Where personal data is no longer needed, we will delete it or anonymise it.

10. Your rights

Under UK data protection law, you have the right in certain circumstances to:

• request access to the personal data we hold about you;
• request correction of inaccurate or incomplete data;
• request deletion of your personal data;
• object to processing where we rely on legitimate interests;
• ask us to restrict processing of your personal data;
• request transfer of your personal data to you or another provider, where applicable;
• withdraw your consent at any time where we rely on consent;
• object at any time to direct marketing;
• make a complaint

If you would like to exercise any of these rights, please contact us at hello@secondbest.beer.

We may need to ask for information to confirm your identity before dealing with your request.

11. Complaints

If you have any concerns about how we use your personal data, please contact us first and we will try to resolve them fairly and promptly.

You also have the right to make a complaint to the Information Commissioner’s Office (ICO), which is the UK regulator for data protection matters.

Further information about raising concerns with the ICO is available on the ICO website.

12. Cookies and analytics

Our website uses cookies and Google Analytics to track visits and understand how users interact with our site. This data is anonymous and aggregated — it does not identify you personally. You can opt out of Google Analytics tracking via Google’s opt-out tool: https://tools.google.com/dlpage/gaoptout

13. Third-party links

Our website may contain links to third-party websites. We are not responsible for those websites or their privacy practices. If you follow a link to another website, you should read that website’s privacy policy.

14. Changes to this policy

We may update this privacy policy from time to time. The latest version will always be available on our website.

It is important that the personal data we hold about you is accurate and up to date. Please let us know if your details change during your relationship with us.