October 2025

1. Who we are

Beliv LLC, hereinafter “Beliv” or “we”, “us”, “our”, with address at 1511 Ave. Ponce de León, Ciudadela Suite 24, San Juan, 00923, Puerto Rico. For the purposes of UK data protection legislation, we are a data “controller”. 

You are likely to have followed a link here because you have entered one of our promotions (“Promotions”). This privacy policy explains our approach to collecting and using personal data (any information which relates to or identifies an individual) and about the people we interact with for the purpose of organising and managing our Promotions and any publicity surrounding those Promotions. 

It is important that you read this notice when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

2. Collection of information

When you enter and/or participate in one of our Promotions, we will initially collect your key contact information as part of the entry process and/or prize fulfilment process. This happens so we can fulfil contractual obligations to you – that is our legal basis for collecting that information. The type of information we may collect includes: –

• your name and address;
• your age;
• your phone number and e-mail address;
• your social media handle.

We may also ask you to provide other personal information such as your accessibility requirements to help us make appropriate arrangements for your attendance at a tattoo appointment (if relevant to the Promotion you are participating in) or attendance at any other ‘in person’ publicity activities you have agreed to participate in.  

We may also subsequently collect photographs and video recordings, provided to or taken by us when carrying out publicity activities connected to the Promotion.  We will always ask for your consent before collecting and using such data – that is our legal basis for collecting that information. 

Any information that we collect about you is stored electronically on our database. It may also be printed and stored in our filing system. Please note that the processing activities of third parties who we collaborate with for the purpose of our Promotions are not governed by this privacy policy and they may collect and use your information differently.

3. Use of information

We are committed to protecting and respecting your privacy and, subject to the below, will not pass your personal details to third parties without your permission. 

We may use information collected and processed in relation to our Promotions/or that we hold about you in the following ways:

• So that we can organise and manage our Promotions. This is a legitimate interest we pursue so we rely on Article 6(1)(f) under UK GDPR as the legal basis for this processing activity. 

• If your attendance at a tattoo appointment (if applicable) or any other ‘in person’ publicity activities is confirmed, so that we can confirm any access requirements. The lawful basis we rely on for processing this personal data is your consent under Article 6(1)(a) and Article 9(2)(a) UK GDPR as this type of information is classed as special category data.

• So that we can fulfil any prize that you have won as part of your participation in a Promotion. The legal basis for this processing is ‘contractual obligation’ so we rely on Article 6(1)(b) as our lawful basis under UK GDPR. 

• So that we can conduct publicity to promote the Promotion and Old Jamaica drinks. The lawful basis we rely on for processing this personal data is your consent under Article 6(1)(a) UK GDPR.

4. Sharing of information

We may disclose your personal information collected and processed in relation to our Promotions to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect our rights, property, or safety, and that of our members, or others.

We may share your personal information with the following third parties and for the following purposes:

• our marketing agency service provider(s), including SAMY ROAD, INC.; 
• Third party prize suppliers – any third parties who provide prizes for our Promotions;
• Prize fulfilment suppliers – any third parties who help us provide you with the prize e.g. delivery companies.
• Refresco Drinks UK Limited – who is the distributor for Old Jamaica Ginger Beer in the UK and who will arrange for the appropriate prize fulfilment suppliers to deliver your prize.

This may involve collecting personal data in or transferring personal data to countries outside the UK which have laws that do not provide the same level of data protection as UK law.

Whenever we transfer personal data internationally, we take steps to ensure that appropriate safeguards are in place to protect your information in accordance with applicable data protection laws. These safeguards may include contractual protections, such as standard contractual clauses, or reliance on adequacy decisions or other lawful transfer mechanisms.

5. Storage and security

We will only retain your personal information collected and processed in relation to our Promotions for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

6. Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the course of a Promotion and/or your relationship with us.

7. Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. The right to erasure is not absolute and only applies in certain circumstances. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information 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. 
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

• Withdraw consent. Where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, such as for publicity about or in connection with our Promotions, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Further guidance on your rights is available from the UK’s supervisory office for data protection, the Information Commissioner’s Office (https://.ico.org.uk/).  You have the right to complain to the Information Commissioner’s Office at https://ico.org.uk/concerns/ if you believe that your data has been processed unlawfully.

8. Access to information

You will not have to pay a fee to access your personal information (or to exercise any of the other rights set out in paragraph 8 above). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information 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.

10. Information relating to third parties

You should not provide us with any personal data relating to any other person, without first providing that person with a copy of this policy, informing them that they will be bound by this policy and obtaining their prior written consent to you submitting such information on their behalf.

11. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

12. Contact

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, withdraw your consent to such processing, or request that we transfer a copy of your personal information to another party, please email us at oldjamaicauk@gmail.com.

Questions, comments and requests regarding this privacy policy are also welcomed and should be sent to the address specified above.