Cookies and Privacy

Last Updated: September 2025

Information About Us

This Privacy Policy (“Policy”) describes the personal information practices of Charles Wells Ltd (company number: 00106884), including in the UK, the trading names Wells & Co, and Brewpoint (known for the purposes of this policy collectively as “Charles Wells”, “we”, “us” or “our”) with respect to information we collect, use, and protect personal information about our customers and others who visit our pubs, websites, domains, mobile apps or similar, including any data you provide when you register with us, or in connection with any related services.

We are the controller (as defined in the UK GDPR) and are responsible for your personal data as controller to the extent explained in this Policy.

If you have any questions about this Policy, including any requests to exercise your legal rights, please contact us using the information set out in the contact details section at Paragraph 13.

Please note that many Charles Wells “Pub Partners” pubs/sites are owned and operated by Pub Partners, who are independent businessmen and women. This Policy does not apply to those Pub Partners, or to websites or mobile apps operated by them. Please refer to the privacy notices of such Pub Partners for information on their practices with respect to personal information.

Information We Collect

We may collect personal information about you when you visit one of our sites, use one of our websites (“Sites”), or use our web or mobile device applications (“Mobile Apps”) including those operated on our behalf by third parties. We refer to our Sites and Apps collectively as “Online Services”.

The types of personal information we collect may include:

Transaction information, such as product purchased, price, method of payment and payment details.

• Personal Information details such as name, postal address, email address, phone number, date of birth, age, gender, employment status, demographics and other contact information when you provide that information to us, such as if you register with our Online Services, enter a contest, competition, prize draw, or sweepstakes.

• Account information, such as username, password, and other identifiers or credentials used to access our Online Services or to acquire Charles Wells’ products and services.

• Technical Data could include your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and information about other technology on the devices you use to access this website

• Voice Recording, including digital recordings of your voice from telephone calls to us, which may be captured and analysed by our people and systems as well as transcripts generated from those voice recordings.

• Other personal information you choose to provide when you interact with Charles Wells.

We do not knowingly collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. We will not use the personal data that we do collect about you to make inferences about any of those special categories of personal data.

How We Collect Your Personal Data

The circumstances in which you provide personal information may include when you:

• purchase our products;
• register to use our Online Services;
• request to receive marketing or other communications; use our Wi‐Fi networks;
• submit information in relation to public health or governmental monitoring schemes;
• enter in one of our contests, competitions, prize draws, or sweepstakes; submit information when providing feedback; or
• use interactive features of our Online Services. Information Collected Through Automated Means

We may collect information from your computer system or mobile device through automated technologies when you visit our sites, call our offices, or use our Online Services or in‐pub/site technologies. These automated technologies may include cookies, local shared objects, and web beacons. Additional information regarding the use of cookies and other automated technologies is provided in this Policy below. The information we collect may include your Internet Protocol (IP) address; computer/mobile device operating system and browser type; type of mobile device; mobile device settings; the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device; device and component serial numbers; advertising identifier (e.g., IDFAs and IFAs) or similar identifier; the referring website or application; the linked sites, third‐party websites, applications or social media where you share Online Services content; and activity related to your use of our Online Services such as the pages you visit on our Sites or in our Mobile Apps.

If you call our offices, your voice may be recorded and stored. We may generate a text transcript of the words you speak when interacting with us. You will hear a warning to let you know that any information you provide on the call is being recorded and processed in this way for the purposes of training, quality monitoring, and / or operational purposes (for example evidence of transactions).The providers of third‐party apps, tools, widgets and plug‐ins on our Online Services, such as Facebook “Like” buttons, also may use automated means to collect information regarding your interactions with these features. This information is subject to the privacy policies or notices of these providers.

Location Information

Charles Wells Online Services and in‐pub/site technologies may collect precise information about the location of your mobile device or computer using geolocation and location presence awareness technologies such as GPS, Wi‐Fi, Bluetooth, or cell tower proximity. For most mobile devices and computer systems, you can withdraw your permission for Charles Wells to acquire this information on your location through your device or web browser settings. If you have questions about how to disable collection of precise location information, we recommend you contact your mobile device service provider, the device manufacturer, or your web browser provider. Please note that certain Online Services and in‐pub/site technologies may not function properly without precise location information. If you would like us to delete location information we may have collected that is specific to you, please contact us at the email or postal address listed below. Please note that we may be required by law to retain certain information. Some services within our pubs/sites are provided by third parties on our behalf and in those instances, contact should be directed to them. This will be declared by them at the point you register for their services.

We may use automated information for purposes such as to (i) personalise the visitor experience in our sites or on our Online Services, (ii) deliver content (including advertising) tailored to our users’ interests and the manner in which our users browse our Online Services or in‐pub/site technologies, and (iii) manage our business. We may also use this information to help diagnose technical and service problems; administer our Online Services,

Combined Information

We may combine personal information that we collect with information we receive from other sources, information about your prior transactions with Charles Wells and information that is automatically collected.

How We Use the Information We Collect

Charles Wells may use the personal information we collect to:

How We Share the Personal Information We Collect

Charles Wells does not sell or otherwise share personal information about you, except as described in this Policy. Charles Wells may share personal information within the Charles Wells Group. The Charles Wells Group includes Charles Wells Limited, and Charles Wells France, but may also extend to our Pub Partners. Members of the Charles Wells Group that receive this information from Charles Wells are not authorised to use or disclose the information except as provided in this Policy.

Charles Wells may share personal information with suppliers that provide services to Charles Wells, such as fulfilling orders, providing data processing and other information technology services, operating Online Services, administering promotions, contests, prize draws and sweepstakes, sending you marketing or other communications, conducting research and performing analytics, and personalising individual Charles Wells experiences. We do not authorise these vendors to use the personal information or to disclose it for any purpose other than to perform services on our behalf and where any processing is beyond our express authority then it will be necessary for such vendor to direct you to their own privacy policy.

Circumstances may arise where, whether for strategic or other business reasons, Charles Wells decides to sell or transfer all or a portion of our business. We may transfer or grant access to information we have collected and stored, including personal information, to the party or parties involved in the transaction as part of that transaction under suitable conditions of confidentiality.

Charles Wells reserves the right to use or disclose personal information as needed to satisfy any law, regulation or legal request, to protect the integrity of our Online Services and in‐pub/site technologies, to bring or defend against legal claims, to protect the rights, interests, safety and security of Charles Wells, Charles Wells employees or Pub Partners, or members of the public, or in connection with the investigation of fraud, illegal activity or violation of Charles Wells policy.

Your Choices

If you have opted‐in to marketing communications, you can subsequently elect not to receive marketing communications from Charles Wells or third parties appointed to deliver these on our behalf by following the opt‐out instructions in the marketing communications we send you or contacting us at the address or email address provided below. Please note that if you opt out of receiving marketing communications from us, we may still send communications to you concerning your transactions or enquiries, accounts with Charles Wells and any contests, competitions, prize draws, or sweepstakes in which you have enrolled.

Your Rights

Your rights under data protection laws in relation to your personal data are briefly summarised below, and you can exercise these rights by emailing us at privacy@wellsandco.com or by writing to us at the address details below.

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which we will tell you about, if applicable, after receiving your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
  • Request restriction of processing of your personal data. You can ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies

to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time if we are relying on your consent to process your personal data (such as direct marketing and cookies). This won’t affect any processing already carried out before you withdraw your consent or processing under other grounds. If you withdraw your consent, we may not be able to provide certain products or services to you.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to access your personal data and we try to respond to all requests within one month.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, we would appreciate the chance to deal with any concerns you may have before you approach the ICO so please contact us in the first instance.

Cookies and Similar Technologies

Charles Wells use cookies and other similar technologies to collect information for the purposes described in this Policy under “How We Use the Information We Collect.”

Cookies

A “cookie” is a text file that websites send to a visitor’s computer or other Internet‐ connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Like most websites, Charles Wells uses cookies for a variety of purposes in order to improve your online experience.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. These essential cookies are always enabled because our website won’t work properly without them. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e- billing services. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our website.

Statistics or Marketing cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Please note that third parties may also use cookies, over which we have no control. These third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies, performance cookies or targeting cookies:

To deactivate the use of third party advertising cookies, you may visit the relevant consumer page to manage the use of these types of cookies.

To opt out of being tracked by Google Analytics across all websites, visit https://support.google.com/analytics.

On most of our websites you can choose which cookies we can set by clicking on the button(s):

• Functional cookies    ALWAYS ACTIVE
  • Statistics cookies    OFF
  • Marketing cookies    OFF

You can also choose to “Deny” all cookies in the cookie banner.

However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

If you have any questions or concerns about our use of cookies, please send us an email at: privacy@wellsandco.com

We may associate personal information with a cookie file in those instances. We may collect personal information about our visitors’ online activities, overtime and across third‐ party websites, when using our Online services. Use the options in your web browser if you do not wish to receive a cookie or if you wish to set your browser to notify you when you receive a cookie. Click on the “Help” section of your browser to learn how to change your cookie preferences. You may also be able to install browser plug-ins or other software to prevent cookies from being placed. If you disable all cookies, you may not be able to take advantage of all the features of this Site.

Other Technologies

We may use other technologies, including web beacons and JavaScript, which sometimes work together with cookies and other means with our Sites and Mobile Apps to uniquely identify your device. These other technologies help enable features on our Sites and within our Mobile Apps. We may also use certain technologies to determine whether you have opened an e‐mail or clicked on a link contained in an e‐mail.

Links to Other Websites and Social Media

Our Online Services may offer links to third‐party websites that are not operated by Charles Wells. If you visit one of these linked websites, you should review the website’s privacy policy, terms and conditions, and other policies. We are not responsible for the policies and practices of third‐parties. Any information you submit to those third‐parties is subject to their privacy policyLinks to Other Websites and Social Media, terms and conditions, and other policies.

Information Security

Charles Wells is committed to taking appropriate measures designed to keep personal information secure. We have in place technical, administrative, and physical procedures designed to protect personal information from accidental, unlawful or unauthorised loss, access, disclosure, use, alteration, or destruction. While we take efforts to safeguard our information systems, no website, mobile application, computer system, or transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.

Retention of Personal Information

We retain personal information for the period of time necessary to fulfil the purposes outlined in this Policy and in accordance with Charles Wells records retention policies unless a longer retention period is required by law or necessary for our compliance with a legal obligation.

International Data Transfers

Charles Wells operates outside of the UK (but within the EEA) with business processes, management structures and technical systems that cross borders. From time to time we also use suppliers outside of the UK/EEA.

As such, we may share information about you within the Charles Wells Group and transfer it to those countries in the world where we do business (including in the EEA and other countries), in connection with the uses identified above and in accordance with this Policy and as permitted by the applicable laws. No such transfer will be made without appropriate safeguards in place to guarantee the security of personal data.

Changes to this Policy

We may change this Policy from time to time. If we change the Policy, we will post the revised version here and change the “Effective Date” listed at the top of this Policy. We encourage you to check here periodically for the most up‐to‐date version of our Policy.

How to Contact Us

If you wish to contact us concerning this Policy you can email privacy@wellsandco.com or write to us at

Privacy – Wells & Co. Compliance Team, Wells & Co
Brewpoint
Cut Throat Lane, Fairhill
Bedford
MK41 7FY