INTRODUCTION

VAN SHA Spirits NL BV is committed to respecting the privacy of individuals, including its clients.

This Privacy Notice (“Notice“), any other documents referred to in it, sets out the basis on which we processes personal data, why we collect, store, use and share personal data, your rights in relation to your personal data.

For the purposes of applicable data protection law (in particular, the General Data Protection Regulation (EU) 2016/679 (the “GDPR“)), we are the “data controller” of your personal data.

PERSONAL DATA WE COLLECT

We may collect and process the following personal data:

INFORMATION YOU GIVE US:

If you complete a form on our website; complete a survey; enter into a contact with us to receive products and/or services; enquiring about or using our products and services

We may process your name and email address.

INFORMATION WE COLLECT ABOUT YOU

With regard to each of your visits to our site we may automatically collect the following information:

• Technical information, including the internet protocol (IP) address used to connect your computer to the Internet, login information, browser type, and version, time zone setting, browser plug-in types and versions, operating system and platform; and
• Information about your visit to our website such as the products and/or services you searched for and view, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

INFORMATION WE RECEIVE FROM OTHER SOURCES:

We may also receive information about you if you use any of the other websites we operate or the other services we provide.

Information about other people

If you provide information to us about any person other than yourself, such as your relatives, next of kin, your advisers or your suppliers, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.

HOW WE USE PERSONAL DATA?

When we ask you to supply us with personal data we will make it clear whether the personal data we are asking for must be supplied so that we can provide the products and services to you, or whether the supply of any personal data we ask for is optional.

Consent:  where you have given your express consent to receive marketing communications, we may use your personal data to:

• Send you newsletters, surveys, information about our awards and events, offers, and promotions, related to products and services offered by us which may be of interest to you;
• Developing, improving, and delivering marketing and advertising for products and services offered by us.

You have the right to withdraw your consent at any time by either contacting us using the contact information provided below.

Legitimate interests: where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests are:

• Providing you with newsletters, surveys, information about our awards and events, offers, and promotions, related to products and services offered by us which may be of interest to you;
• Communicating with you in relation to any issues, complaints, or disputes;
• Improving the quality of experience when you interact with our products and/or services, including testing the performance and customer experience of our website; or
• Performing analytics on sales/marketing data, determining the effectiveness of promotional campaigns.

You have the right to object to the processing of your personal data on the basis of legitimate interests as set out below, under the heading your rights.

Where required by law:  We may also process your personal data if required by law, including responding to requests by government or law enforcement authorities, or for the prevention of crime or fraud.

WITH WHOM DO WE SHARE PERSONAL DATA?

We may share your personal data with other VAN SHA business.

We take all reasonable steps to ensure that our staff protect your personal data and are aware of their information security obligations. We limit access to your personal data to those who have a genuine business need to know it.

We may also share your personal data with trusted third parties including:

• Legal and other professional advisers, consultants, and professional experts;
• Service providers contracted to us in connection with provision of the products and services such as providers of it services;
• Analytics and search engine providers that assist us in the improvement and optimisation of our website;
• If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; and/or
• If we, our business, or our assets are acquired by a third party, in which case personal data held by it about its users, suppliers, or customers will be one of the transferred assets.

We will ensure there is a contract in place with the categories of recipients listed above which include obligations in relation to the confidentiality, security, and lawful processing of any personal data shared with them.

We, or trusted third parties on our behalf, may contact you by email or post with information about products and services that might be of interest to you. Where necessary, at the time that you provide your personal data to us, you will be given the opportunity to indicate whether or not you are happy for us to use your personal data in order to tell you about such products or services.

You can unsubscribe from this at any time by clicking on the link provided in the relevant email, or by emailing us using the contact details provided below.

Where a third party recipients is located outside the European Economic Area, we will ensure that the transfer of personal data will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission where the data protection authority does not believe that the third country has adequate data protection laws.

We will share personal data if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and other agreements; or if we reasonably consider this necessary; or to protect the rights, property of others.

We will share personal data with law enforcement or other authorities if required by applicable law, for example for the purposes of crime prevention and fraud protection.

HOW LONG WILL WE KEEP PERSONAL DATA?

We will retain your personal data for as long as we believe it necessary or desirable to fulfil our business purposes or to comply with applicable law, audit requirements, regulatory requests or orders from competent courts.

Where there is a contract between us, we will retain your personal data for the duration of the contract, and for a period of 6 years following its termination or expiry, to ensure we are able to comply with any contractual, legal, audit and other regulatory requirements, or any orders from competent courts or authorities.

Where you have consented to marketing communications, you may change your preferences or unsubscribe from marketing communications at any time by clicking the unsubscribe link in an email from us.

Your personal information may be converted into statistical or aggregated data which cannot be used to re-identify you. It will then be used to produce statistical research and reports. This aggregated data may be shared and used in all the ways described in this privacy notice though it may also be used in other ways not described here.

WHERE DO WE STORE PERSONAL DATA AND HOW IS IT PROTECTED?

We take reasonable steps to protect your personal data from loss or destruction.

We also have procedures in place to deal with any suspected data security breach.  We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Where you have a username or password (or other identification information) which enables you to access certain services or parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our site; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

YOUR RIGHTS

Under the GDPR, you have various rights with respect to our use of your personal data:

RIGHT TO ACCESS

You have the right to request a copy of the personal data that we hold about you by contacting us at the email or postal address given below.  Please include with your request information that will enable us to verify your identity.  We will respond with 30 days of request.  Please note that there are exceptions to this right.  We may be unable to make all information available to you if, for example, making the information available to you would reveal personal data about another person, if we are legally prevented from disclosing such information or if your request is manifestly unfounded or excessive.

RIGHT TO RECTIFICATION

We aim to keep your personal data accurate and complete.  We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.

RIGHT TO ERASURE

You have the right to request the deletion of your personal data where, for example, the personal data are no longer necessary for the purposes for which they were collected, where you withdraw your consent to processing, where there is no overriding legitimate interest for us to continue to process your personal data, or your personal data has been unlawfully processed.  If you would like to request that your personal data is erased, please contact us using the contact details provided below.

RIGHT TO OBJECT

In certain circumstances, you have the right to object to the processing of your personal data where, for example, your personal data is being processed on the basis of legitimate interests and there is no overriding legitimate interest for us to continue to process your personal data, or if your data is being processed for direct marketing purposes.  If you would like to object to the pressing of your personal data, please contact us using the contact details provided below.

RIGHT TO RESTRICT PROCESSING

In certain circumstances, you have the right to request that we restrict the further processing of your personal data.  This right arises where, for example, you have contested the accuracy of the personal data we hold about you and we are verifying the information, you have objected to processing based on legitimate interests and we are considering whether there are any overriding legitimate interests, or the processing is unlawful and you elect that processing is restricted rather than deleted.  Please contact us using the contact details provided below.

RIGHT TO DATA PORTABILITY

In certain circumstances, you have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format.  This right arises where you have provided your personal data to us, the processing is based on consent or the performance of a contract, and processing is carried out by automated means. If you would like to request that your personal data is ported to you, please contact us using the contact details provided below.

Please note that there are exceptions to these rights, if, for example, we are under a legal obligation to continue to process your personal data. If we are unable to comply with your request due to an exception we will explain this to you in our response.

CONTACT

If you would like to contact us about this Notice, our use of your personal data, or about exercising any of your rights, please contact us by email at contact@vanshaspirits.com or by writing to us at: VAN SHA Spirits NL BV Fahrenheitstraat 273A (2^nd Floor), 2561DV Den Haag, The Netherlands

COMPLAINTS

If you believe that your data protection rights may have been breached, and we have been unable to resolve your concern, you may lodge a complaint the applicable supervisory authority or to seek a remedy through the courts.  Please visit https://autoriteitpersoonsgegevens.nl/en for more information on how to report a concern to the Autoriteit Persoonsgegevens.

CHANGES TO OUR NOTICE 

Any changes we may make to our Notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Notice.