PRIVACY POLICY
MARCH 23, 2023
CONTENTS
1. HOW DO WE MANAGE YOUR DATA?
- IF YOU ARE A DIGITAL VISITOR.
- IF YOU ARE OUR BUSINESS PARTNER
- IF YOU ARE A VISITOR TO OUR LOCATION
2 DISSEMINATION OF YOUR INFORMATION
- OUR PARTNERS
- THIRD PARTY RECIPIENTS
- SERVICE PROVIDERS
- BODIES OF GOVERNMENT OR LAW ENFORCEMENT
3 BEYOND THE EUROPEAN ECONOMIC AREA AND THE UK TRANSFERS (EEA)
1. HOW DO WE MANAGE YOUR DATA?
This section discusses the sources and types of personal data that we gather and handle, why we do so, and the legal basis for doing so.
This Privacy Statement applies to the following types of individuals:
• Section 1.1: Our Online Visitors
• Section 1.2 Our Business Partners (this section includes present and future clients, business partners, and suppliers, who are referred to collectively as Business Partners.
• Section 1.3 Visitors to our premises (If they are legal organizations, this includes their employees or representatives)
1.1. 1.1. IN THE EVENT THAT YOU ARE A DIGITAL VISITOR
A – Personal data sources
B – Personal data that we gather and handle
C – Why do we gather your personal information, and what are our legal grounds for doing so?
A. PERSONAL DATA SOURCES
We may obtain your personal data from the following sources:
- a. directly from you (for example, when you subscribe to any services offered on a website, mobile applications, events, interactive kiosks, or social media, including but not limited to email mailing lists, interactive services, posting material, or requesting additional goods or services);
- b. from your device or browser; and/or
- c. if you contact us, we may keep a record of that communication.
B. PERSONAL INFORMATION THAT WE MAY COLLECT AND USE
- a. name
- b. username
- c. address
- d. date of birth
- e. email address
- f. operating system
- g. browser type
- h. cookie data
- i. online marketing and tracking preferences
- j. IP address
- k. Location
- l. Details you provide to us while submitting material or seeking our services
- m. Answers you offer as part of our surveys, contests, games, and other interactive services; and/or n. Product orders, event invites issued, and tickets purchased
- o. Behavioural information from online, web, apps, email, and social media, provided you have given us permission.
C. WHY DO WE COLLECT YOUR PERSONAL INFORMATION AND WHAT ARE OUR LEGAL BASES FOR DOING SO?
We clarify the precise business interests we seek while processing your personal data in the table below, as well as the legal basis we depend on.
Personal data could be used to | WHAT ARE OUR LEGAL JUSTIFICATIONS FOR PROCESSING YOUR DATA? |
Provide you with our digital services | Application and Website Management
|
Account Administration | Create and maintain our relationship |
Understanding the market in which we operate is in our legitimate interest.
|
Management Communication
Management reporting Account Administration |
Discover our digital users’ surfing habits as well as the performance of our digital services. | Administration of Websites and Applications
Recognize the market in which we operate. |
Security | security, risk management, and crime prevention.
Management Communication |
Inform you about our products, services, and events that may be of interest to you through letter, phone, email, or other electronic means. | Publicize our products and services.
Management Communication Management reporting |
Discover how our products and services may be utilised.
|
Understanding the market in which we operate is in our legitimate interest.
Management Communication Management reporting |
Sharing information with advertising partners (such as Facebook, Instagram, Pinterest, LinkedIn, Tripadvisor, Snapchat, and TikTok). | Publicize our products and services.
Management Communication
|
Ad retargeting is the practice of sending you personalized and targeted advertisements on websites and social media based on your preferences, purchase history, and recorded behavior. | Management Communication
Publicize our products and services. Management reporting |
Wherever we use your email or other digital methods to transmit marketing information to you, we shall get your prior consent unless required by law.
If you do not want us to use your personal information for the aforementioned objectives, including direct marketing, please contact us at hello@goavodka.com.
When we use cookies or similar technology, we will get your prior consent where needed by law.
We never sell your personal information to a third party.
Our website may contain links to and from the websites of our partner networks, creative partners, and affiliates from time to time. If you click on a link to one of these websites, please be aware that they have their own privacy statements or policies. Please review their privacy notices or policies before submitting any personal information to these websites.
If you are unhappy with the way your personal data is treated as outlined in this Privacy Policy, please do not submit any information through this website or application.
1.2. IF YOU ARE A BUSINESS PARTNER OF OURS
This section addresses current and future clients, business partners, and suppliers, referred to together as Business Partners. The information we gather and handle about our clients is mostly commercial in nature. We may gather personal data on employees, directors, authorized signatories, and other people connected to our current or future Business Partners.
A – Personal data sources
B – Personal data that we gather and handle
C – Why do we gather your personal information, and what are our legal grounds for doing so?
A. PERSONAL DATA SOURCES
We may receive personal information about you from the following sources:
- a. directly from you,
- b. from a firm that employs you (if you are an employee of our Business Partner), and
- c. from our affiliates.
- d. at networking events we’ve organized, sponsored, or attended; and/or
- e. via publicly available sources (for example, your company website or social media sites).
B. PERSONAL INFORMATION THAT WE MAY COLLECT AND USE
We may collect the following types of personal data from our Business Partners’ employees, officials, authorized signatories, or other related individuals:
- a. Name
- b. Photograph (photography) – During our GOA Vodka events
- c. business address
- d. business email address
- e. business phone number
- f. business fax number
- g. work title or function
- h. business bank account data
- i. date of birth
- j. communication language
- k. initial point of interaction
- l. classification as a business partner (e.g., supplier, current or potential client); and/or
- m. GOA Vodka’s system use information, if suppliers or business partners have access to GOA Vodka systems.
C. WHY DO WE COLLECT YOUR PERSONAL INFORMATION AND WHAT ARE OUR LEGAL BASES FOR DOING SO?
We clarify the precise business interests we seek while processing your personal data in the table below, as well as the legal basis we depend on.
Personal data could be used to | WHAT ARE OUR LEGAL JUSTIFICATIONS FOR PROCESSING YOUR DATA? |
provide our products or services to you or receive your products or services
|
Our Contractual Responsibility (whether you act in your personal capacity or as a lone trader): Fulfill our contractual and legal duties in a timely and efficient manner.
Our Genuine Interest: Management Communication Fulfill our contractual and legal duties in a timely and efficient manner (if you are an incorporated entity) |
Create and maintain our relationship
|
Our Contractual Responsibilities (whether you act as a single trader or in your personal capacity):
Fulfill our contractual and legal duties in a timely and efficient manner.
Our legitimate interests are as follows: Management reporting Understand the market in which we operate Make or defend legal claims Fulfill our contractual and legal duties in a timely and efficient manner (if you are an incorporated entity) |
See how our products and services are or may be used. | Your consent or our reasonable interest *:
Recognize the market in which we operate. |
Discover our digital users’ surfing habits as well as the performance of our digital services. | Administration of Websites and Applications
Recognize the market in which we operate. |
Security
|
security, risk management, and crime prevention.
Management Communication |
Inform you about our products, services, and events that may be of interest to you through letter, phone, email, or other electronic means. | Publicize our products and services.
Management Communication |
Discover how our products and services may be utilised.
|
Understanding the market in which we operate is in our legitimate interest.
Management Communication |
Inform you about our products, services, and events that may be of interest to you through letter, phone, email, or other electronic means.
|
Publicize our products and services.
Management Communication |
Our communication and advertising campaign will leverage your picture (video or images) from events. | Publicize our products and services.
|
Checking your age at GOA Vodka events to verify compliance with alcohol consumption age limits | Compliance with legislation is in our legitimate interest.
|
* We will get your prior consent as needed by law.
If you object to us using your personal information for the aforementioned objectives, including direct marketing, please contact us at hello@goavodka.com.
Whenever we use your email to send you marketing information, we will get your prior consent as needed by law.
1.3. IF YOU COME TO OUR LOCATION
A – Personal data sources
B – Personal data that we gather and handle
C – Why do we gather your personal information, and what are our legal grounds for doing so?
A. PERSONAL DATA SOURCES
We may receive your personal information directly from you or from the records of our systems (If we add events the A B C needs to be copied from digital visitor above).
B. PERSONAL INFORMATION THAT WE MAY COLLECT AND USE
- a. Name
- b. Surname
- c. Date of Birth
- d. Email address
- d. Email address
- f. Company contact information
- g. Organization
- h. Role
- i. Visit time and date; and/or
- j. Image (for example, from CCTV cameras at our premises, where they are used)
C. WHY DO WE COLLECT YOUR PERSONAL INFORMATION AND WHAT ARE OUR LEGAL BASES FOR DOING SO?
In the table below, we explain what precise business objectives we pursue and what legal justifications we depend on when processing your personal data.
Personal data could be used for/to | WHAT ARE OUR LEGAL JUSTIFICATIONS FOR PROCESSING YOUR DATA? |
Security
|
Security, risk, and crime prevention management Fulfill our contractual and legal duties in a timely and efficient manner (if you are an incorporated entity)
|
Keep track of who comes into our building.
|
Management Communication
|
Inform you about our products, services, and events that may be of interest to you through letter, phone, email, or other electronic means. | Management Communication
Publicize our products and services.
|
Whenever we use your email to send you marketing information, we will get your prior consent as needed by law. If you object to us using your contact information for these purposes, please contact us at hello@goavodka.com.
2. DISSEMINATION OF YOUR INFORMATION
We never sell your personal information to a third party.
We utilize secure means to send personal information.
Data we collect may also be processed by employees working with or for us outside the EEA, or by one of our related organizations, suppliers, or service providers.
2.1 OUR PARTNERS
We may release your personal information to our affiliates, who may use it for the purposes outlined in this Privacy Policy. As a result, they will be joint data controllers of your information with us. Our affiliates, as data controllers, shall treat your data in accordance with the GDPR and other applicable data protection legislation.
2.2 RECIPIENTS FROM THIRD PARTIES
• When required by law and similar statutory disclosures, we may disclose your personal data with third parties who are controllers of your personal data.
• As part of a merger, sale, or asset transfer.
• Such third parties to whom we have secured your permission to release your Personal data.
2.3 SERVICE PROVIDERS INVOLVED FOR THE PURPOSE DESCRIBED IN THE ABOVE SECTIONS
Our service providers use your personal information for data analytics, marketing, and promoting our products and services to you. Our advertising and promotional agents and consultants, such as website hosting providers, carry out marketing campaigns or email mailings on our behalf, or assess or evaluate our data gathering process or customer service fulfillment. We shall make certain that any service provider we hire is obliged by data protection obligations, processes your personal data solely on our stated instructions, and does not use it for their own purposes.
2.4 BODIES IN CHARGE OF LAW ENFORCEMENT OR GOVERNMENT
We may disclose your personal information as permitted by law in order to investigate, prevent, or take action in connection with illegal activities, suspected fraud, infringement of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of our Terms and Conditions or other agreements, or as required by law.
3. BEYOND THE EUROPEAN ECONOMIC AREA AND THE UK TRANSFERS (EEA)
Whenever we transmit your personal data beyond the EEA and the UK (which includes EU member states as well as Iceland, Liechtenstein, and Norway), we will only do so using one of the following safeguards:
a. the transfer is to a non-EEA country that has received an adequacy decision from the EU Commission; b. the transfer is covered by a contractual agreement that covers the GDPR requirements relating to transfers to countries outside the EEA and the UK; c. the transfer is to an organization that has Binding Corporate Rules approved by an EU data protection authority; or d. the transfer is to an organization in the US that is certified under the EU-US Privacy Shield.
You may obtain a copy of any relevant document relating to transfers of your personal data beyond the EU and the UK by contacting us via hello@goavodka.com
4. YOUR DUTIES
You have the right to seek information from us about how we manage your personal data, to access copies of all personal data kept by us, and to request that your personal data be rectified, corrected, or deleted from our systems, as required by local legislation.
You can also request that we provide a copy of the personal data you gave to us, limit, restrict, or object to the processing of your data.
We do not make decisions primarily based on automated processing, including profiling.
If you give us permission to use your data, for example, so that we might use your electronic contact information to send you marketing emails, you can withdraw your permission at any time. Please keep in mind that even if you withdraw your consent, we can still use the consent you provided as the legal basis for processing your personal data prior to your withdrawal.
You have the right to object to our processing of your personal data if we have declared that we are acting in our legitimate business interests. We discussed our legitimate interests in the sections under ‘Why do we gather your personal data and what are our legal basis for doing so?’ above.
If you want to exercise any of your rights listed above, please contact us at hello@goavodka.com.
5. VARIATIONS
We reserve the right to change this Privacy Policy at any time by updating this page. Any changes to our processing will take effect within a reasonable time after the modified Privacy Policy is posted, giving you time to evaluate whether you agree with the changes.
6. CHILDREN
This website is solely intended for adults. We do not intentionally solicit information from children or individuals of legal drinking age, nor do we knowingly promote or otherwise target our websites, products, or services to minors or people of legal drinking age.
If we learn that a visitor to our websites is a child or is under the Legal Drinking Age in the nation or other area where he or she is situated at the time of registration and has registered without verified parental approval, we shall delete his or her personal data from our systems.
7. RETENTION TIME
We will only keep and Process your Personal Data for as long as it is required for the purposes for which it was collected in connection with your relationship with us, unless we have a legal right or obligation to retain the data for a longer period, or the data is required for the establishment, exercise, or defence of legal claims.
8. CONTACT INFORMATION
GOA Vodka, Ekkersrijt 4204, 5692 DE Son, The Netherlands shall be the data controller responsible for any personal data concerning you under the General Data Protection Regulation 2016/679 and any implementing laws (the “GDPR”). Whenever you visit our websites, the data controller is GOA Vodka, which is registered in the Netherlands under company number 84421657. Ekkersrijt 4204, 5692 DE Son, The Netherlands is our registered office. NL863205094B01 is our VAT number.
If you are a client or a potential customer of our EU firm, or an anyone associated to one of our present or future customers, GOA Vodka, which has contractual or business contacts with our customer, is the applicable data controller. If you engage with our EU business in any other capacity (for example, to deliver your services), GOA Vodka will be your data controller.
If you need to contact us, please send an email to hello@goavodka.com.
9. EXTRA INFORMATION
“We” or “us” refers to GOA Vodka, with its registered office at Ekkersrijt 4204, 5692 DE Son, The Netherlands, throughout this Privacy Policy and the related Terms and Conditions of Website Use and Cookie Policy.