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Introduction Scotch & Soda respects the privacy of all visitors to its Website(s) and App(s) and is highly committed to maintaining the privacy of all such visitors. We will use your personal data to make sure that your orders will be handled as fast and easy as possible or that certain parts of the Website(s) or App(s) are more tailored to your interests. This statement describes how we deal with your personal data and online security.
This statement informs you about the following: 1. What data we collect 2. What we need your data for 3. How we may share your data 4. Legal grounds for processing your data 5. Your data is safe at Scotch & Soda (online security) 6. We do not keep your personal data longer than necessary 7. Where your data is processed 8. Cookies and Do Not Track 9. Online Advertising 10. Your privacy rights 11. Objection and complaints 12. Changes to our privacy statement 13. Minors providing personal data 14. Contact us
1. What data we collect Personal data are data that can be used to identify you as a person. We collect data in the following ways:
We only collect and further process your personal data for the purposes mentioned in the previous paragraph.
We will ask your consent before using your personal data for purposes other than those listed above, unless the further use of your data is compatible with the purpose for which the personal data were initially collected. We will inform you of, and, if necessary ask your consent for, any changes in the use of your personal data.
We may use your data for decisions based on automated decision-making, including profiling. For instance, we may use previous purchase data and or browsing data to suggest matching products to those previous purchases. By having your consent, we are able to do that both in advertising and on our Website(s) or the App(s).
3. How we may share your data We will not share (or sell) your personal data to third parties, except as disclosed in this privacy statement or with your consent. We may share your personal data with our third-party service providers, including, but not limited to:
These service providers are granted access to some or all of your personal data as necessary for the purposes described above and may use cookies (as defined below) or other automatic collection technology on our behalf. The service providers are contractually restricted by way of a data processing agreement in the way they may process your personal data.
We reserve the right to disclose your personal data to official authorities or third parties to the extent we reasonably believe that disclosure is required by law, or to protect your or others’ rights, property or safety.
Please note that the use of any feature made available to you on our Websites such as Facebook Connect, or the like feature (also connected to Facebook), may result in your personal data being collected or shared by us or by others. We cannot control how your data is collected, stored, used or shared by third-party sites or to whom it is disclosed. Please review the privacy policies and settings of your social networking sites to make sure you understand and agree with the data being shared.
If you do not want us to share your personal data with a social media site or application, you should not access such social media site or social media application. For example, you should not click a "like" button on a product detail page.
We may also share your personal data with applicable third parties in the event of a reorganisation, merger, sale, assignment or other disposition of all or a portion of our business, assets or shares.
4. Legal grounds for processing your data Consent By the following acts you give us your consent to process your personal data:
You have the right to revoke your consent at all times. When you revoke your consent, we will stop processing your personal data.
Necessary for the performance of an agreement When you place an order, you enter into a purchase agreement with us. In order to process and deliver your order, we need certain personal data, such as your name, e-mail, billing and shipment address.
Legitimate interests We may process your personal data for the purposes of our legitimate interests, except where such interests are overridden by your interests or fundamental rights and freedoms. For our legitimate business interests, we may process your personal data to:
5. Your data is safe at Scotch & Soda (online security) We appreciate the trust you place in us. Scotch & Soda is committed to protecting your personal data. We have implemented reasonable security measures, including Secure Socket Layer (SSL) encryption technology and other tools to protect all your personal data we may collect through our Website(s) or App(s). We use a variety of measures to ensure that your personal data is protected from unauthorized access, improper use or disclosure, unauthorized modification or alteration, unlawful destruction or accidental loss. However, the internet is an open system and Scotch & Soda cannot guarantee that the personal data you submit will not be intercepted by others. All our employees who have access to or are involved in the processing of personal data are bound by contractual confidentiality obligations and will respect the confidentiality of any such personal data. Our Website(s) and App(s) may include links to website(s) operated by third parties. Such third parties may collect personal data from visitors to their website(s). Scotch & Soda cannot guarantee the content or privacy practices of any such third party website(s) and does not accept responsibility for such website(s). We recommend you to read the privacy policies of third party website(s).
6. We do not keep your personal data longer than necessary Order information When you place an order for our products, we retain that information for a minimum period of six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes. Correspondence and enquiries When you make an enquiry or contact us by email or via our contact form, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 24 months thereafter, after which point we will delete your information. Mailing list We retain the information you used to sign up for our newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our newsletter service, whichever occurs first. In any other circumstances, we will retain your information for no longer than necessary, taking into account the following: - The purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under an agreement with you or to contact you in the future)
7. Where your data is processed Your data is processed within the European Union. In addition, we share a database with our Scotch & Soda affiliates in the United States. When personal data is shared with our US affiliates, we make sure that appropriate safeguards are in place to protect your data. More specifically, we will adhere to the standard contractual clauses of the EC or to the EU-US Privacy Shield Frameworks.
8. Cookies and Do Not Track We use the below cookies on our Website(s) that act as an identification card for your computer.
When you visit our Website(s), unique cookies are placed to distinguish your browser from all other browsers that visit our Website(s). By recognizing your browser, we can serve you better. You have the option to accept all cookies, or to reject marketing cookies. In addition, we may use Google Analytics to monitor activity on our Website(s). We have entered into a data processing agreement with Google (indirectly) to protect your personal data. To learn how Google Analytics collects and processes data, please visit: “How Google uses information from sites or apps that use our services” located at www.google.com/policies/privacy/partners.
9. Online Advertising Scotch & Soda may participate in interest-based advertising. As described above, we may automatically collect data regarding how you browse websites, use applications and shop in order to enhance your customer experience, improve our customer service, and provide you with communications and promotions from us or others. The objective of interest-based advertising is for Scotch & Soda or its advertising partners to show you ads that are more relevant to your interests. You can limit our and our partners’ ability to collect and use the last-mentioned data. To opt out of receiving interest-based advertising, click on any of the following links: - www.networkadvertising.org - www.aboutads.info To successfully opt out, you must have cookies enabled in your web browser. Please note that if you choose to opt out, you may continue to see ads on our Website(s) and receive communications from us, but such ads and communications will not be based on how you browse and shop. As described above, you can also prevent automatic collection of some data by disabling cookies on your web browser.
10. Your privacy rights Under applicable privacy laws (General Data Protection Regulation (GDPR)), you have, inter alia, the right to:
11. Objection and complaints If we have collected personal data from you on the basis of our legitimate interests, you can at all times object to the processing of your personal data by contacting us at consumercare@scotch-soda.com. We will in that case stop the processing, unless we have compelling legal grounds for the processing which override your interest to stop the processing. If you do not agree with our decision in relation to your personal data, you have the following options:
12. Changes to our statement Our Privacy Statement may change from time to time to reflect changes to our services or changes in the Applicable privacy laws. We will not reduce your rights under this Privacy Statement without your explicit consent. We will post any changes to our Privacy Statement on this page. We will notify you personally, for example through an email notification, of significant changes to our Privacy Statement.
13. Minors providing personal data Persons below the age of 18 may only provide personal data to Scotch & Soda if they have written consent from one of their parents or legal guardians who has read this privacy statement.
14. Contact us Scotch & Soda E-commerce B.V. is responsible for the processing of your personal data and acts as the controller. If you have any questions, feedback or want to know more about how your personal data is processed, or if you want to access, correct or remove your personal data, please contact us at consumercare@scotch-soda.com. You may write to us at: Scotch & Soda E-commerce B.V., Parellaan 76, 2132 WS, Hoofddorp, the Netherlands (department web store).