Privacy Notice: Share Registration and Founders Portal
SECOND BEST BREWING COMPANY LIMITED
Last updated: 30 September 2026
Summary
Second Best Brewing Company Limited holds the information needed to register former BrewDog Equity for Punks investors, work out their Second Best shareholding, and maintain the company’s share register. We use it to verify your identity and allocation, run the Founders Portal, issue your shares and keep you informed.
Your portal record is only visible to you when signed in, and to a small number of authorised Second Best administrators. However, once shares are issued, the law requires your name, address and shareholding to be entered on our register of members, which some people have a legal right to inspect, and your name will appear in our filings at Companies House. Section 7 explains this.
The rest of this notice explains what we collect, why, who we share it with, how long we keep it and your rights.
1. Who we are
Second Best Brewing Company Limited (company number SC891552), with its registered office at c/o Turcan Connell, Princes Exchange, 1 Earl Grey Street, Edinburgh EH3 9EE (Second Best, we, us), is the controller of your personal data for the purposes described in this notice.
Where Second Best Lost and Found Limited handles a claim for shares that have not yet been transferred to you, it acts as a separate controller for that purpose and processes your data in line with this notice.
Contact: founders@secondbest.beer
We have appointed a data protection officer, who can be contacted at DPO@secondbest.beer for any question about this notice or how we use your personal data.
2. Scope of this notice
This notice covers personal data we collect and use in connection with:
- registering your interest in, and applying for, shares in Second Best;
- matching your registration against historic BrewDog Equity for Punks shareholder records;
- the Founders Portal, including your account and indicative allocation;
- issuing and transferring shares and maintaining our statutory registers; and
- communicating with you about your shareholding and the company.
It supplements our general website privacy policy at secondbest.beer/privacy. For personal data relating to the share programme and the Founders Portal, this notice applies. It does not cover our beer, bars or online shop.
3. The information we collect
Information you give us
- Identity and contact details: full legal name, date of birth, postal address, postcode, country and email address.
- Registration details: whether you registered as an Equity Punk or BrewDog employee, your acceptance of the share terms, and your privacy and marketing choices.
- Portal account details: your login credentials (passwords are stored securely in encrypted form and are never visible to us) and your portal reference.
- Supporting evidence you provide for a claim, such as a historic BrewDog investor number, investor statement, share certificate, confirmation email or your recollection of your holding.
- Correspondence with us, including queries and complaints.
Information we collect automatically
- IP address used when registering or signing in, device and browser information, and dates and times of access.
- Security and audit logs, including a record of administrative changes to portal records.
- Cookies and similar technologies on our websites, as explained in our website privacy policy at secondbest.beer/privacy.
Information we obtain from other sources
- BrewDog plc’s shareholder list, which is a public document, containing holder names (including joint holders) and the number of shares held. We use it solely to identify and verify former Equity for Punks investors and calculate their Second Best allocation.
- Information you submitted through our earlier register-interest form, such as your name and email address.
Information we create
- The results of matching your registration to historic records, including the records matched, how they were matched, your indicative allocation and any review status.
- Your shareholding once shares are issued.
4. How we use your information and our legal bases
We may only use your personal data where the law allows. The table below sets out what we do and the legal basis we rely on.
| What we do | Legal basis |
|---|---|
| What we doVerify your identity and combine duplicate registrations | Legal basisLegitimate interests: ensuring each person receives the correct allocation only once |
| What we doMatch your registration to historic Equity for Punks records and calculate your indicative allocation | Legal basisLegitimate interests: honouring former Equity for Punks investors in a fair and consistent way |
| What we doRun the Founders Portal and your account | Legal basisLegitimate interests; and taking steps at your request before you become a shareholder |
| What we doIssue shares to you, keep our register of members and make statutory filings | Legal basisLegal obligation under the Companies Act 2006 |
| What we doSend you service messages about your registration, allocation and shareholding | Legal basisLegitimate interests; and legal obligation where notices to shareholders are required |
| What we doHandle queries, reviews, corrections and complaints | Legal basisLegitimate interests |
| What we doKeep the portal secure and prevent fraud or duplicate claims | Legal basisLegitimate interests; and legal obligation where applicable |
| What we doComply with legal and regulatory requirements, take professional advice, and establish or defend legal claims | Legal basisLegal obligation; and legitimate interests |
| What we doSend you news and marketing about Second Best | Legal basisConsent, which you can withdraw at any time |
Legitimate interests. Where we rely on legitimate interests, we have considered your interests and rights and concluded that our use of your data is proportionate. Our interests include running the share programme fairly, accurately and securely, keeping shareholders informed and protecting the company from fraud and error. You can ask us for more information about this assessment.
If you do not provide information. Some information, such as your name and address, is needed for us to verify your allocation and to enter you on the register of members as the law requires. If you do not provide it, we may not be able to issue shares to you.
We do not use special category data (such as health or ethnicity) and do not ask for it.
5. How allocations are worked out
We match your registration against BrewDog plc’s shareholder list, which is a public document, to verify your entitlement and calculate your allocation. Final allotments are approved by the directors.
If you think your allocation is wrong, you can ask us to review it and provide any supporting information by emailing founders@secondbest.beer.
6. Who we share your information with
We do not sell your personal data. We share it only as follows:
- Service providers who host and operate the Founders Portal, send emails, store data and provide IT and security support. They act on our instructions under contracts that require them to protect your data.
- Second Best Lost and Found Limited, where it handles a claim for shares on your behalf.
- Professional advisers, including lawyers, accountants and any share registrar, under duties of confidentiality.
- Companies House, as required by law (see section 7).
- People entitled to inspect our register of members under the Companies Act 2006 (see section 7).
- Regulators, law enforcement, courts or other public authorities, where we are required or permitted by law.
- A buyer or successor of all or part of our business or shares, under appropriate confidentiality protections.
7. Our register of members and Companies House
Once shares are issued to you, the Companies Act 2006 requires us to enter your name, address, the date you became a member and the number of shares you hold on our register of members.
- Any shareholder can inspect the register free of charge, and any other person can inspect it or request a copy on payment of a fee, in each case only for a proper purpose. We must refuse requests that are not for a proper purpose, and may apply to court where appropriate.
- Our confirmation statement filed at Companies House includes shareholder information, which becomes part of the public record in accordance with the requirements then in force.
- We will not publish your email address, date of birth or portal details.
8. International transfers
Founders Portal data is stored in the United Kingdom. Some service providers used for our website, registration forms and emails may process data outside the UK. Where a service provider processes your data outside the UK, we make sure it is protected by a UK adequacy regulation or appropriate safeguards, such as the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. You can ask us for details.
9. How long we keep your information
| Information | How long we keep it |
|---|---|
| InformationRegister of members entries | How long we keep itWhile you are a shareholder and for 10 years after you stop being one, as required by law |
| InformationRegistration and matching records for shareholders | How long we keep itWhile you are a shareholder and for 6 years after, to deal with queries or claims |
| InformationRegistrations that do not result in shares | How long we keep it12 months after the share programme (including any Lost and Found claim period) closes, then deleted, unless needed for a query or claim |
| InformationCorrespondence and complaints | How long we keep it6 years after the matter closes |
| InformationPortal security and audit logs | How long we keep it12 months |
| InformationMarketing preferences | How long we keep itUntil you withdraw consent, plus a record of your withdrawal |
10. How we protect your information
We use appropriate technical and organisational measures to protect your data, including encryption, access controls limited to authorised administrators, secure password storage and logging of administrative changes. No system is completely secure, but we work to keep your data safe and will notify you and the Information Commissioner where the law requires.
11. Your rights
Under UK data protection law you have the right to:
- access a copy of your personal data;
- correct inaccurate or incomplete data;
- erase your data in certain circumstances;
- restrict how we use your data in certain circumstances;
- object to our use of your data where we rely on legitimate interests, and at any time to direct marketing;
- data portability in certain circumstances;
- withdraw consent at any time, where we rely on consent; and
- not be subject to decisions based solely on automated processing that significantly affect you, and to ask for human review.
Some rights are limited by our legal obligations. For example, we cannot delete information we are required to keep on our register of members.
To exercise any right, email our data protection officer at DPO@secondbest.beer. We will respond within one month, and may need to verify your identity first.
You also have the right to complain to the Information Commissioner’s Office (ico.org.uk (opens in a new tab), 0303 123 1113). We would appreciate the chance to deal with your concerns first.
12. Keeping your information up to date
Please tell us if your name, address or email address changes, so that our register of members and records stay accurate.
13. Age
The share programme and Founders Portal are intended for people aged 18 or over.
14. Changes to this notice
We may update this notice from time to time. We will post the updated version on the Founders Portal and tell you about any significant changes.
15. Contact us
Second Best Brewing Company Limited, c/o Turcan Connell, Princes Exchange, 1 Earl Grey Street, Edinburgh EH3 9EE
Email: founders@secondbest.beer
Data protection officer: DPO@secondbest.beer