Privacy Policy

Introduction

Our consumers are at the heart of what we do. This Privacy and Cookie Notice applies to personal information collected by or on behalf of a company within Maison Ferrand. It sets out what we do with your personal information, how we keep it secure and explains the rights that you have in relation to your personal information.

Who we are

Right Spirits BV/Gusta Brands is a Dutch importing company and the official importer of Maison Ferrand, a French producer of fine spirits. Details on our companies can be found on:  www.rightspirits.com, www.gustabrands.nl and http://maisonferrand.com/en/our-spirits/

This website is operated by a member of Right Spirits BV registered in The Netherlands with company number 54930340 and registered address at Zekeringstraat 13B, 1014 BM Amsterdam).

All references to ‘our’, ‘us’, ‘we’, or ‘company’ within this notice are deemed to refer to Right Spirits/Gusta Brands and or Maison Ferrand, its subsidiaries, affiliates, and/or associates, as appropriate.

Are you of legal purchase age?

You must not provide us with your personal information if you are not of legal age to purchase alcohol in the jurisdiction in which you reside and (if different) in the jurisdiction in which you are accessing the website or app.

We do not intend to collect personal information from any individuals under the legal purchase age, or to market alcoholic beverages to anyone under the legal purchase age.

If we receive notice or believe that someone under the legal purchase age has provided us with personal information we will make every reasonable effort to remove such personal information from our records.

What types of personal information do we collect?

Personal information is information about an identifiable individual, as defined by applicable law. The personal information we collect includes, information you provide to us.

We have set out below more details regarding these types of personal information:

  • Information you provide to us: These types of personal information include:
    • contact details (such as your name, postal addresses, phone numbers and email addresses),
    • demographic information (such as your age or age range and gender),
    • information provided as part of online questionnaires (such as responses to any customer satisfaction surveys or market research),
    • competition entries/submissions, and
    • in certain cases your marketing preferences.
How/when do we collect personal information?
  • Information you provide to us: There are various situations in which you may voluntarily provide personal information to us.  These include when you:
    • enter a competition or take advantage of a promotion,
    • fill in an online questionnaire (such as a customer satisfaction survey),
    • contact us with an enquiry or ask us to provide you with information,
    • attend any of our promotional events,
    • forward an item to a friend, and/or
    • inform us of your marketing preferences.

We will indicate where any personal information we have requested is mandatory or optional. We will also explain the consequences should you decide not to provide information which we have indicated is mandatory. In some circumstances this may mean we are unable to provide you with a certain service or product.

Purposes for which your personal information is used

The different purposes for which we use your personal information are set out below:

  • Marketing Communications: We may use your personal information to communicate with you through channels such as post,  email and SMS about our products and services, and those of our subsidiaries, affiliates, and parent companies, and any of their related businesses. You have the right to opt-out at any time from receipt of further marketing communications as described in “Your Rights” section.

See the section on Cookies below for more details about online interest-based advertising. You have the right to opt-out at any time from the use of your personal information for online interest-based advertising.

  • Authentication and access control: We may use your personal information to authenticate your access to our websites or apps and to determine which content to provide you and/or whether you should be granted access to certain content (for example depending on your age or location). We may also use your personal information to verify your identity when responding to any requests to exercise your rights under applicable law.
  • Comply with legal obligations and protect against legal claims or liability: We may use your personal information to comply with our legal obligations, protect us against legal claims, or to detect, protect, or defend us and/or other third parties against error, negligence, breach of contract, theft, fraud, or other illegal or harmful activity, to comply with our audit and security requirements, or to audit compliance with our corporate policies, procedures, legal, or contractual obligations.
  • Customer service: We will use your personal information to provide specific services that you request from us, as well as to provide additional services that may be of interest. We will also use your personal information to maintain your accounts, and manage transactions such as credit card payments for any products that you order from us or our agents, or for the fulfilment of such transactions (e.g. delivery) or to answer any questions you may have. We may also use your personal information to notify you about changes to our services, our terms and conditions or this Privacy and Cookie Notice.
  • Technical maintenance: We use personal information for system administration purposes and to diagnose service or technology problems reported by our users or engineers, these types of problem may be associated with the IP addresses controlled by a specific web company or ISP.
Legal basis for the processing of personal information

We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case the legal basis will be one of the following:

  • Consent: For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by clicking on the “unsubscribe” link at the bottom of any marketing email we send you.
  • Our legitimate business interests: Where it is necessary for us to understand our customers, promote our services and operate effectively as a multinational beverages company, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights. For example we will rely on this legal basis when we conduct certain market analysis to understand our consumers  in sufficient detail so we can create new products and improve the profile of our brands.
  • Performance of a contract with you: This would also apply where we need to take steps prior to entering into a contract with you. For example, where you have purchased a product from us and we need to use your contact details and payment information in order to process your order and send the product to you.
  • Compliance with law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.
Information security

We take information security seriously and take precautions to keep your personal information secure. We have put in place appropriate  physical, technical, and organizational measures to safeguard the information we collect. However, we have no control over the privacy of any communication while it is in transit to us. We therefore recommend that you do not include confidential, proprietary, or sensitive information in any such communications.

Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at the contact details below.

In the unlikely event that we believe that the security of your personal information in our possession or control may have been compromised, we may seek to notify you of that development. If such a notification is appropriate, we will endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your email address, we may notify you by email.

You are reminded that, in accordance with the Conditions of Use for this website and/or app, you are responsible for maintaining the strict confidentiality of your account password, and you are responsible for any activity under your account and password. It is your sole responsibility to control the dissemination and use of your password, access to and use of your account, and to notify us when you wish to cancel your account. We will not be responsible or liable for any loss or damage arising from your failure to comply with this obligation.

Your rights

You have certain rights in relation to your personal information. These rights include:

  • the right to withdraw your consent to any processing of your personal information (where you had provided consent);
  • the right to object to the processing of your information for certain purposes;
  • the right to access your personal information, and the ability to erase, restrict or in certain cases receive a machine-readable copy of your personal information;
  • the right to ask us to rectify any information about you that you think is inaccurate; and
  • the right to  unsubscribe from any of our marketing communications at any time.

If you wish to exercise any of these rights you may contact us (using the contact details provided below). We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions.

How to make a complaint

You have the right to complain to a data protection authority if you think we have processed your personal information in a manner which is unlawful or infringes your rights.

However if you have such concerns we suggest that you initially contact us (using the contact details below in the “How to contact us” section ) so that we can investigate, and hopefully resolve, your concerns.

How long will we retain your personal information for?

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy and Cookie Notice unless a longer retention period is required or permitted by law.  After this period it will be deleted or in some cases anonymized.

For example, where you have made a purchase with us, we will keep a record of your purchase for the period necessary for invoicing, tax and warranty purposes. We may also keep a record of correspondence with you (for example if you have made a complaint) for as long as is appropriate to protect us in the event of a legal claim.

Where we have collected the personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent then we will delete your personal information. However, please note that where you unsubscribe from our marketing communications, we will keep a record of your contact details to ensure we do not send you further marketing communications in future.

Interfaces with Third-Party Websites and Services

Our websites and apps may contain links, references, and content from other websites and services outside of our control. Please be aware that we have no control over these websites and services and our Privacy and Cookie Notice does not apply to them.

We will not be liable to you for any issues arising in connection with their use of your information and we encourage you to read the Privacy and Cookie Notices and Conditions of Use of any linked, referenced, or interfacing websites and services you visit or use.

Cookies and similar technologies

Like many other websites and apps, we use cookies, scripts, pixel tags, e-tags, web beacons  and similar technologies (collectively referred to as “cookies”) to help us gather and store information about visitors to our websites and apps and certain third party websites with whom we have partnered. This section provides information about how we use cookies and how you can control them.

What is a cookie?

A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your device’s hard disk. A cookie will typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie, and a value, usually a randomly generated unique number.

Cookies are useful because they allow a website to recognize a user’s device. You can find more information about cookies at: www.allaboutcookies.org.

What types of cookies do we use?

We use two broad types of cookies:

  • First party cookies, served directly by us to your device when you visit our website.
  • Third party cookies, served by a third party on our behalf when you visit our website and certain third party websites with whom we have partnered.
What do we use cookies for?

The cookies we use can be divided into four broad categories:

1) Strictly Necessary cookies;
2) Performance cookies; and
3) Functionality cookies.

See below for more details regarding each of these categories of cookies.

1) Strictly Necessary Cookies

These cookies are essential to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies, services you have asked for, like shopping baskets or e-billing, cannot be provided.

Examples of Strictly Necessary Cookies we may use on this website include Content Management Cookies which are required by the site for the content management system to work and Template Preference Cookies which are necessary for mobile sites and enable the site to look and feel the way it is intended to.

2) Performance Cookies

These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and any error messages visitors receive from web pages. These cookies don’t collect information that directly identifies a visitor. Information collected by these cookies is often aggregated and therefore becomes anonymous. It is only used to improve how a website works.

We use Google Analytics to help analyze use of the site. This analytical tool uses cookies to collect standard internet log information and visitor behavior information which is then aggregated so that it does not identify any individuals. The information about your use of the website and your IP address is transmitted to Google and is used by us to evaluate visitors’ use of the website, compile statistical reports on website activity and create a profile of aggregated visitors based on demographics and interests. We also use a tool called Google Display Network Impression Reporting to help us understand which adverts we place on other websites in the Google Display Network are better at attracting visitors to our website. To opt out of being tracked by Google Analytics across all websites visit  http://tools.google.com/dlpage/gaoptout.

3) Functionality Cookies

These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.

We may place a cookie to remember your preferences (Preference Cookie) so that you do not need to re-enter your details (country/age and language preferences) on our gateway page. This is not suitable if you share your computer with someone else. This cookie does not collect your date of birth and expires automatically after 12 months.

We may also use Session Cookies, which are temporary cookies that remember user choices regarding the site, and preferences you have selected during the session. These cookies are deleted as soon as you leave the site.

How to manage cookies?

There are a number of ways to manage cookies.

If you are using a web browser (e.g. Google Chrome, Mozilla Firefox or Microsoft Edge), you have the ability to accept or decline cookies by modifying the settings in your browser. Please refer to your browser instructions or help screen to learn more about the functions which your browser provides to manage cookies. If you use different browsers and/or different devices you may need to ensure that each browser is adjusted to suit your cookie preferences. For instructions on how to manage cookies in your browser, please read the information available here: http://www.allaboutcookies.org/manage-cookies/. Please note that you may not be able to use all the interactive features of our site if all cookies are disabled.

If you are using a mobile app, the operating system of your mobile device (e.g. Apple iOS, Google Android or Microsoft Windows) provides privacy settings which let you manage how mobile apps use technologies similar to cookies to recognize your device and in certain cases make interest-based advertising available within mobile apps you use. Please refer to the instructions or help pages of your mobile operating system to learn more about the functions which it provides to manage these privacy settings.

You also have the ability to opt out of online interest-based advertising using the AdChoices icon as further described below.

How do I opt out of online interest- based advertising?

If you see any of our advertising with this logo on it –  you’re able to take control of whether you get these types of ads. This is the AdChoices icon provided by the European Interactive Digital Advertising Alliance (EDAA).

When you click through the Icon, you’ll get information about the companies that provide interest-based ads on the sites you visit. You’ll learn about how it works, how this type of advertising supports free content, and about other privacy choices.

If you don’t want this type of advertising, you can click through to the consumer choice page to opt out from the companies that participate in the Icon program.

For further information about how to manage or delete online interest-based advertising cookies in this way visit – http://www.youradchoices.com/

 How to contact us

We are committed to safeguarding your privacy. If you have any comments, queries, or complaints about our collection or use of personal information please contact us via:

Post: Right Spirits BV/Gusta Brands, Zekeringstraat 13B, 1014 BM Amsterdam, The Netherlands

Email: info@rightspirits.com

You may also contact your local data protection regulator in the event of any complaints. The details of the Autoriteit Persoonsgegevens are here: https://autoriteitpersoonsgegevens.nl/ and the details of your local regulators can be provided via the email address above.

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