Privacy statement

PRIVACY POLICY OF INSPIRITS PREMIUM DRINKS B.V.
This is the privacy policy of Inspirits Premium Drinks B.V. (‘IPD’). This privacy policy provides information about the data we process of our users and customers who visit the IPD website, take part in consumer campaigns, etc. We consider it important to ensure that our services are transparent, personal and reliable. We are therefore continuously looking for ways to improve our services where necessary and to align them as much as possible with your personal wishes and requirements. When doing so IPD handles your data carefully and makes sure that any processing of your data complies with the applicable legislation and regulations.
This privacy policy may be amended from time to time if new developments give cause to do so. You can always find the most up-to-date privacy policy on www.Inspirits.com. IPD recommends that you consult this privacy policy regularly so that you are aware of any changes. The privacy policy always states the date on which the last change was made.
This privacy policy was last changed on 30 April 2018.

WHEN IS THIS PRIVACY POLICY APPLICABLE?

This privacy policy applies to all data which IPD collects and processes from users and customers of IPD and the website in connection with products and services that it offers. This includes data which is collected offline via, for example, customer service, and data which is collected online by marketing campaigns, as well as advertising cookies on our website, our ‘branded’ pages, on third-party platforms and our mobile applications. On the IPD website you will find a number of links to other websites. Although these websites have been carefully selected, we are not responsible for processing your personal data via these websites. This privacy policy is not applicable to the use of these websites.
This privacy statement is part of the user terms and conditions and our general terms and conditions of delivery.

WHO IS RESPONSIBLE FOR YOUR DATA?

Inspirits Premium Drinks B.V., established at Zijlstraat 56, 3111 PS Schiedam or another specified address, is the party responsible for processing personal data as described in this privacy policy. In accordance with the provisions of the Personal Data Protection Act [Wet bescherming persoonsgegevens] and, as of 25 May 2018, the General Data Protection Regulation [Algemene Verordening Gegevensbescherming], IPD has registered its procedures for processing personal data with the Dutch Data Protection Authority [Autoriteit Persoonsgegevens] (‘AP’) in The Hague. This involved indicating which data IPD processes, for which purposes and to which people and/or bodies the data is issued. Please refer to the public register of the Dutch Data Protection Authority .

YOUR PERMISSION
By using our site(s), or by issuing personal data to IPD in some other way (online or offline), you explicitly agree to IPD collecting, using and sharing your personal data in accordance with this Privacy Statement. If you do not agree to your personal data being used in this way, we explicitly advise you not to use this and other IPD sites and to refrain from issuing information to IPD any other way.
IPD will only collect, use or share your personal data with due regard for the applicable legislation and regulations. Usually we will ask your permission to do so, but sometimes there will be other grounds which justify the processing of your personal data. We will always ask your explicit permission before processing specific categories of personal data (relating to health and other sensitive information). You are not obliged to grant this permission but, if you decide not to do so, this may result in restrictions on your participation in certain activities.


PRIVACY POLICY TABLE OF CONTENTS
– Explanation of the structure of this privacy policy
– Asking a question or submitting a complaint
– Participating in a special campaign
– Camera security
– Product recall
– IPD website
– Electronic newsletter, information and offers
– Do we use cookies?
– Which third parties have access to your data?
– How do we protect your data?
– Questions and requests for inspection, correction and deletion.

EXPLANATION OF THE STRUCTURE OF THIS PRIVACY POLICY
In this privacy policy we describe for each service which of your personal data IPD processes in order to supply you with a specific service and what this exactly means.

Under 18
Our services are not accessible to young people under the age of 18.
We therefore request that you do not issue any data to us if you are younger than 18.

Which data do we process?

Whenever you leave information with one of our employees, on the website, via a contact form, or in some other way, IPD processes the contact details you have submitted such as your name, age, address, place of residence and/or in order to register and/or confirm your participation, to determine whether you fulfil the terms and conditions and so that any requested data/products can be sent to you.

We also process different types of information, such as information which you have issued yourself (first name and surname, address, age, email address, etc.), information which IPD automatically collects if you use (one of) our site(s) (type of browser, IP address, any hyperlinks you have clicked, etc), information which we collect from other sources (commercially available sources such as public databases, information from third parties, etc.).

Why do we process this data?
We may use your personal data to improve our products and your experiences on the IPD sites. We do this by evaluating the use of the IPD sites, products and services, by analysing the effectiveness of our advertisements, competitions and promotions, by personalising your website experience, but also in order to evaluate statistics on website activities (anonymously and combined with statistics from other users), such as the time you visited the website, whether you had visited the website in the past and via which site you access to our website, to make the IPD sites more user-friendly and to align them more effectively with your interests and requirements, to help you improve your future activities and experiences on our sites, by collecting information about the device that you use to view the IPD sites, such as your IP address or the type of Internet browser or operating system that you use and by linking this to your personal data, to protect IPD against possible fraudulent transactions or to identify these, to monitor compliance with our terms and conditions and to manage our business and so that we can contact you in connection with your comments/questions about products and services which you have ordered from us. We may also contact you regarding products and services which may be important for you, on the condition that you have given us permission to do so, or you have already purchased a product or service from us in the past, the communication is relevant for, or related to, that previous purchase and takes place within the deadline set by applicable legislation. IPD may also link your data to some additional information we have received from you. We may also share your details with trusted third parties (for example advertisers, advertising agencies, advertising networks, etc.) so that we can make you personalised offers. These third parties may place their own cookies on your device in order to help us advertise specifically in a way that links up with your personal interests. They will only collect this data insofar as you have given your permission for the placement of cookies for marketing and advertising purposes.

How long do we keep your data for this purpose?
We keep your data only for as long as is necessary. How long that is depends on our relationship. If you are a returning client or supplier, we will store the data for at least the duration of our cooperation. If you have only entered into an agreement with us once, your data will be deleted within 4 weeks after it has become clear that contact between us is no longer required. You can always ask us how long the retention period is in your specific case.

DO YOU WANT TO ASK A QUESTION OR SUBMIT A COMPLAINT?

If you submit a complaint, or if you contact IPD by telephone, email, via social media, online chat service or by post, or ask a question, we may ask you for your contact details so that we can process your question or complaint. We use this personal data only for this purpose and your personal data will only be accessible to those people at IPD who are involved in processing your question or complaint.

Which data do we process in such instances?

In order to be able to register your question or complaint we make a note of it in our customer service database. Any personal data which is exchanged during the conversation will also be included in this note. We may also ask you for your contact details, such as your age, name, address, place of residence, telephone number and/or email address.

How long do we keep your data for this purpose?
We do not keep questions, complaints and your contact details for any longer than 2 years, unless the nature of the question or complaint forces us to retain them for longer. We keep the content of the conversation – and (any) personal data which you have issued during the conversation – for no longer than 4 weeks after the conversation has taken place, unless the nature of the question and/or complaint forces us to keep the conversation for longer.

PARTICIPATION IN A SPECIAL CAMPAIGN
IPD regularly organises special campaigns which you can take part in, such as savings schemes, competitions or promotional games of chance. In some cases we will ask you to fill in a registration form from a folder, advert or website so that you can take part.

Which data do we process in such instances?
Whenever you participate in a special campaign, IPD processes the contact details you have submitted such as your name, age, address, place of residence and/or in order to register and/or confirm your participation, to determine whether you fulfil the terms and conditions of the promotional campaign and so that any prizes and benefits you are eligible for can be sent to you. Depending on the type of special campaign, we also process information about your participation, such as your scores, submissions or savings balance.

How long do we keep your data for this purpose?
We keep registrations and information on your participation until after the campaign so that we can share out prizes and answer questions about the campaign. We will communicate the length of the retention period for each campaign individually.

CAMERA SECURITY
Our stores are equipped with cameras to protect our employees, customers and property. These cameras are placed in clearly visible locations and, when entering one of our stores, your attention will be drawn to the presence of CCTV.

How long do we keep video images from our entrance?
We do not keep any video images which we register with our security cameras for longer than 14 days, unless there are good reasons to keep images for longer (for example if they are important for a police investigation). After that we will delete these images.

PRODUCT RECALL

In the unfortunate event of something going wrong with a product we have sold and we want to recall this product, we may not only publish press releases on our websites and in national newspapers, but also contact you directly in the interests of your welfare if, of course, we already have your contact details.

IPD WEBSITE (general)
Whenever you visit the IPD website we process a number of your details (such as your age (because you have to be at least 18), your IP address and your usage of any online services) in order to provide the various functions of these online services and manage them from a technical perspective. Some of this data is also analysed and segmented in order to personalise the website and communication.

What does this imply?
First and foremost we need this data in order to provide the various functions on the IPD website. The data in question enables our website administrators to manage the IPD website, for example in order to solve technical malfunctions or improve accessibility. To help you find information on our websites quickly and easily we also use (functional) cookies.

Which data do we process in such instances?

We process data such as the IP address of your computer, smartphone, smartwatch or tablet, the unique identifiers of cookies placed on these devices, the web pages visited, the Internet browser you use to surf the Internet, the length of a visit/session, sites visited previously/thereafter, your usage of the web or app pages (such as product interactions, searches, promotion), and transaction data.

How long do we keep your data for this purpose?

We do not keep this data for this purpose for any longer than is necessary.

Which details do we process for this purpose?
Apart from your age we do not process any personal details, and only data on the products which you have marked as favourites.

How long do we keep details for this purpose?
In principle, we keep these details for two years after your last contact with us, such as the date of your last purchase or the last time you used our (mobile) applications, unless the law prescribes a longer or shorter retention period, or if this is necessary in connection with legal proceedings.

What does this imply?
First and foremost we need this data in order to provide the various functions on the IPD website. The data in question enables our website administrators to manage the IPD website, for example in order to solve technical malfunctions or improve accessibility. To help you find information on our websites quickly and easily we also use (functional) cookies.

Which data do we process in such instances?
We process data such as the IP address of your computer, smartphone, smartwatch or tablet, the unique identifiers of cookies placed on these devices, the web pages visited, the Internet browser you use to surf the Internet, the length of a visit/session, sites visited previously/thereafter, your usage of the web or app pages, etc.

ELECTRONIC NEWSLETTER, INFORMATION AND OFFERS
On the IPD website you can register to receive our electronic newsletter containing our offers and general information. You can deregister whenever you want. All direct marketing communication that we send you (such as our newsletters) is accompanied by information and the tools you need to deregister.

IF YOU COMMUNICATE WITH US VIA SOCIAL MEDIA
-Sharing the IPD website via social media
If you opt to share the IPD website via social media, such as YouTube, Facebook and/or Twitter, your personal data (such as your name and the fact that you are interested in our products and services) will also be visible to all visitors of your personal social media pages. The use of such social media websites is subject to the terms and conditions (including the privacy policy) of the social media websites in question. The general terms and conditions of IPD and this privacy policy do not apply to the use of these social media websites.

-Our social media pages
We are active on various social media platforms, such as Twitter, YouTube and Facebook. If you communicate with us via our social media pages (for example if you place a comment, upload media, send a personal message or become one of our fans by clicking the ‘Like’ button) we may receive personal information about you (such as your (user) name, your profile photo, your place of residence, your email address and your gender). How we handle your data is described in the IPD Facebook Privacy Statement which should be regarded as a supplement to (i) this privacy policy and (ii) the terms and conditions of use and other statements by Facebook. IPD recommends that you read the terms and conditions of use and other statements by Facebook carefully. They may deviate from IPD’s privacy policy.


WHICH THIRD PARTIES HAVE ACCESS TO YOUR DATA?
IPD engages third parties (such as printing companies and email and postal companies) when providing its services and conducting other business activities. Insofar as these third parties handle your data when carrying out the corresponding services and business activities, they will do so in the capacity of processor for IPD and IPD will have put in place the required technical and organisational measures to ensure that your data is processed exclusively for the above purposes. IPD also engages parties such as Google to analyse your data and carry out its direct marketing and targeted advertisement campaigns.

Personal data is issued to supervisory bodies, tax authorities and investigatory authorities only if IPD is obliged to do so by law. Within this framework we may also forward your personal data to recipients in countries outside the European Economic Area. In such instances IPD will take suitable measures which are reasonably necessary to ensure that your data is optimally protected.


HOW DO WE PROTECT YOUR DATA?
IPD handles your personal data with the utmost care. We have taken various technical and organisational measures to protect your personal data against loss or unlawful use. We demand of third parties that handle or process your personal data on our behalf to do the same. Access to your personal data is limited in order to prevent unlawful access, change or misuse and is only permitted for our employees and advisers and only insofar as it is necessary for them to have access to this data.

QUESTIONS AND REQUESTS FOR INSPECTION, CORRECTION AND DELETION
You can ask, at any time, to inspect the data which IPD can collect about you and have it amended or deleted by sending a request to:
IPD, Consumer Service Department [afdeling Consumentenservice]
Zijlstraat 56
3111 PS Schiedam