WHO WE ARE

The address of our website, hereinafter referred to only as “site”, is: https://www.vs-spirits.com/

OWNER OF THE DATA PROCESSING

VS Spirit srls

Via Navigliano 36 – 10020 San Sebastiano da Po

Contacted through the contact form on the site or by email info@vs-spirits.com .

WHAT PERSONAL DATA WE COLLECT AND WHY WE COLLECT IT

Among the Personal Data collected by vs-spirits.com, either independently or through third parties, are: Cookies; Usage Data; Geographic Location; First Name; Last Name; Date of Birth; Phone Number; VAT Number; Profession; Address; Province; Email; Zip Code; City; Tax Code.

Full details of each type of data collected are provided in the dedicated sections of this privacy policy or by means of specific informative texts displayed before the collection of the data itself.

Personal Data can be freely provided by the User or, in the case of Usage Data, automatically collected during the use of the site.

Unless otherwise specified, all data requested by the site are mandatory. If the User refuses to communicate them, it may be impossible for the site to provide the service. In cases where the site indicates some Data as optional, Users are free to refrain from communicating such data, without this having any consequence on the availability of the service or its operation.

Users who may have doubts as to which data is mandatory are encouraged to contact the Data Controller.

Any use of Cookies – or other tracking tools – by the site or the owners of third party services used, unless otherwise specified, is intended to provide the Service requested by the User, in addition to the other purposes described in this document.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through the site and warrants that he/she has the right to communicate or disseminate them, releasing the Owner from any liability towards third parties.

METHODS AND PLACE OF TREATMENT OF COLLECTED DATA

Processing methods

The Owner adopts appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.

The process is carried out through computer and/or telematic instruments, with organizational methods and logics strictly related to the indicated purposes. In addition to the Data Controller, in some cases, other subjects involved in the organization of the site (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller, may have access to the Data. The updated list of Data Processors can always be requested from the Data Controller.

Legal basis of the process

The Data Controller processes Personal Data relating to the User in the event that one of the following conditions exists:

– the User has given consent for one or more specific purposes; Note: in some jurisdictions, the Data Controller may be authorized to process Personal Data without the need for the User’s consent or another of the legal bases specified below, until the User objects (“opts-out”) to such processing. However, this does not apply where the processing of Personal Data is governed by European legislation on the protection of Personal Data;

– the processing is necessary for the performance of a contract with the User and/or the execution of pre-contractual measures;

– the processing is necessary for the performance of a legal obligation to which the Data Controller is subject;

– the processing is necessary for the performance of a task of public interest or for the exercise of public powers vested in the Data Controller;

– the processing is necessary for the pursuit of the legitimate interest of the Controller or of third parties.

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on law, provided for by a contract or necessary to conclude a contract.

Place

The Data are processed at the operational headquarters of the Data Controller and in any other place where the parties involved in the processing are located. For more information, please contact the Data Controller.

Your Personal Data may be transferred to a country other than the one in which you are located. You may refer to the section on details of the processing of Personal Data for further information on the location of processing. To obtain further information on the location of the processing, the User may refer to the section on details of the processing of Personal Data.

You have the right to obtain information about the legal basis for the transfer of Data outside the European Union or to an international organization under public international law or consisting of two or more countries, such as the UN, as well as the security measures taken by the Controller to protect the Data.

The User may verify whether one of the transfers just described takes place by examining the section of this document relating to details on the processing of Personal Data or request information from the Data Controller by contacting it at the contact details given at the beginning.

Storage Period

The Data are processed and stored for the time required by the purposes for which they were collected.

Therefore:

– Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the performance of such contract is completed.

– Personal Data collected for purposes related to the legitimate interest of the Controller will be retained until such interest is satisfied. You may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller.

When the processing is based on the User’s consent, the Controller may keep the Personal Data longer until such consent is revoked. In addition, the Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, at the end of this period, the right of access, cancellation, rectification and the right to Data portability can no longer be exercised.

PURPOSES OF THE DATA COLLECTED

The User’s Data are collected to enable the Data Controller to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), identify any malicious or fraudulent activities, as well as for the following purposes: Content commenting, Statistics, Displaying content from external platforms, Location-based interactions, Payment management, SPAM protection, Interaction with live chat platforms, Registration and authentication, Interaction with social networks and external platforms, Advertising and Contacting the User.

To obtain detailed information on the purposes of the processing and the Personal Data processed for each purpose, the User may refer to the section “Details on the processing of Personal Data”.

Comments

When visitors leave comments on the site, we collect the data shown in the comment form in addition to the visitor’s IP address and browser user agent string to facilitate spam detection.

An anonymized string created from your email address (otherwise known as a hash) can be provided to the Gravatar service to see if you are using it. The privacy policy of the Gravatar service is available here: https://automattic.com/privacy/. After your comment is approved, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images that include embedded location data (EXIF GPS). Website visitors can download and extract any location data from images on the website.

Contact Form

Cookie

If you leave a comment on our site, you can choose to save your name, email address and website in cookies. They are used for your convenience so that you don’t have to re-enter your information when you leave another comment. These cookies will last for one year.

If you visit the login page, a temporary cookie will be set to determine whether your browser accepts cookies. This cookie does not contain any personal information and is deleted when you close your browser.

When you log in, several cookies will be set to store your login information and screen display options. Login cookies last for two days and screen option cookies last for one year. If you select “Remember Me,” your login will persist for two weeks. If you log out of your account, your login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie does not include any personal data, but simply shows the ID of the article you just edited. It expires after 1 day.

The User, by filling out the contact form with their Data, consents to their use to respond to requests for information, quotes, or any other nature indicated by the header of the form.

Personal data processed: Zip code; city; tax code; last name; date of birth; email; address; name; phone number; VAT number; province.

Contact by phone

Users who have provided their telephone number may be contacted for commercial or promotional purposes related to the site, as well as to fulfill support requests.

Personal data processed: telephone number.

Mailing list or newsletter

By registering to the mailing list or newsletter, the User’s email address is automatically added to a list of contacts to whom email messages containing information, including commercial and promotional information, relating to the site may be sent. The User’s email address may also be added to this list as a result of registering with the site or after making a purchase.

Personal Data Processed: ZIP code; city; last name; Cookie; email; first name; phone number.

Content embedded from other websites

Articles on this site may include embedded content (e.g., videos, images, articles, etc.). Embedded content from other websites behaves in exactly the same way as if the visitor had visited the other website.

These websites may collect data about you, use cookies, integrate additional third-party tracking, and track your interaction with them, including tracking your interaction with embedded content if you have an account and are logged in to those websites.

Payment Management

The services of payment management allow the site to process payments by credit card, bank transfer or other instruments. The data used for payment are acquired directly from the manager of the payment service required without being in any way processed by vs-spirits.com .

Some of these services may also allow the scheduled sending of messages to the User, such as emails containing invoices or notifications regarding the payment.

PayPal (Paypal)

PayPal is a payment service provided by PayPal Inc., which allows the user to make online payments.

Personal Data processed: various types of Data as specified by the privacy policy of the service.

Interaction with social networks and external platforms

This type of service allows for interactions with social networks, or other external platforms, directly from the pages of the site.

Interactions and information acquired by the site are in any case subject to the privacy settings of the User relating to each social network.

This type of service may still collect traffic data for the pages where the service is installed, even when Users do not use it.

It is recommended to disconnect from the respective services to ensure that the data processed on the site is not linked back to the User’s profile.

Facebook Comments (Facebook, Inc.)

Facebook Comments is a service operated by Facebook, Inc. that allows the User to leave their own comments and share them within the Facebook platform.

Personal Data Processed: Cookies; Usage Data.

Place of processing: USA – Privacy Policy.

location-based interactions

Geolocation

The Site may collect, use and share Data related to the User’s geographic location in order to provide location-based services.

Most browsers and devices provide by default tools to deny geographic tracking. If the User has expressly authorized this possibility, the site may receive information on his or her actual geographic location.

Personal data processed: geographical location.

Protection from SPAM

This type of service analyzes site traffic, potentially containing Personal Data of Users, in order to filter it from parts of traffic, messages and content recognized as SPAM.

Google reCAPTCHA (Google Inc.)

Google reCAPTCHA is a SPAM protection service provided by Google Inc.

Use of the reCAPTCHA system is subject to Google’s privacy policy and terms of use.

Personal data processed: Cookies; Usage Data.

Place of processing: USA – Privacy Policy

Advertising

This type of services allow the use of User Data for commercial communication purposes in various forms of advertising, such as banners, also in relation to the User’s interests.

This does not mean that all Personal Data is used for this purpose. Data and conditions of use are indicated below.

Some of the services indicated below may use cookies to identify the User or use the technique of behavioral retargeting, i.e. displaying personalized advertisements based on the User’s interests and behavior, also detected outside the site. For further information, we suggest that you check the privacy policies of the respective services.

In addition to the possibilities of opt-out offered by the services below, the User may opt out of receiving cookies from a third party service by visiting the opt-out del Network Advertising Initiative page.

Google AdSense (Google Inc.)

Google AdSense is an advertising service provided by Google Inc. This service uses the Cookie “Doubleclick”, which tracks the use of the site and the behavior of the User in relation to advertisements, products and services offered.

The User can decide at any time not to use the Doubleclick Cookie by deactivating it: google.com/settings/ads/onweb/optout.

Personal data processed: Cookies; Usage Data.

Place of processing: USA – Privacy Policy – Opt Out.

Registration and authentication

With registration or authentication the User allows the Application to identify him/her and give him/her access to dedicated services.

Depending on what is indicated below, the registration and authentication services may be provided with the help of third parties. If this happens, this Application may access some Data stored by the third party service used for registration or identification.

Log In with PayPal (Paypal)

Log In with PayPal is a registration and authentication service provided by PayPal Inc. and connected to the PayPal network.

Personal Data processed: various types of Data as specified in the following paragraphs.

Place of treatment: See Paypal Privacy Policy..

Facebook Authentication (Facebook, Inc.)

Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and connected to the social network Facebook.

Personal Data processed: various types of Data as specified by the privacy policy of the service.

Place of processing: USA Privacy Policy.

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to track the behavior of the User.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google uses the Personal Data collected in order to track and examine the use of the site, compile reports and share them with other services developed by Google.

Google may use Personal Data to contextualize and personalize ads in its advertising network.

Personal Data processed: Cookies; Usage Data.

Place of processing: USA – Privacy Policy – Opt Out.

Google Tag Manager (Google Inc.)

Google Tag Manager is a statistics service provided by Google Inc.

Personal data processed: Cookies; Usage Data.

Place of processing: USA – – Privacy Policy

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of the site and interact with them.

If a service of this type is installed, it is possible that, even if Users do not use the service, it will collect traffic data relating to the pages where it is installed.

Google Fonts (Google Inc.)

Google Fonts is a service for displaying font styles operated by Google LLC or Google Ireland Limited, depending on where the site is used, which allows the site to integrate such content within its pages.

Personal Data processed: Usage Data; various types of Data as specified by the privacy policy of the service.

Place of processing: USA –  Privacy Policy.

MORE ABOUT PERSONAL DATA

Selling goods and services online

The Personal Data collected is used to provide services to the User or to sell products, including payment and delivery. The Personal Data collected to complete the payment may be that of the credit card, bank account used for the transfer or other payment instruments provided. The Payment Data collected by the Site depends on the payment system used.

USER RIGHTS

Users may exercise certain rights with reference to the Data processed by the Data Controller.

In particular, the User has the right to:

– revoke consent at any time. The User may revoke the consent to the processing of their Personal Data previously expressed.

– oppose the processing of their Data. The User may object to the processing of their Data when it is done on a legal basis other than consent. Further details on the right to object are set out in the section below.

– access to their Data. The User has the right to obtain information about the Data processed by the Data Controller, certain aspects of the processing and to receive a copy of the Data processed.

– verify and request rectification. The User may verify the correctness of its own Data and request its update or correction.

– obtain the limitation of the treatment. When certain conditions are met, the User may request the limitation of the processing of its Data. In this case, the Data Controller will not process the Data for any purpose other than its preservation.

– obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User may request the deletion of their Data by the Data Controller.

– receive their Data or have it transferred to another owner. The User has the right to receive his or her Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred without hindrance to another owner. This provision is applicable when the Data is processed by automated means and the processing is based on the User’s consent, a contract to which the User is a party or contractual measures related thereto.

 propose complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action.

Details of the right to object

When Personal Data are processed in the public interest, in the exercise of public powers vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users should note that if their Data were processed for direct marketing purposes, they may object to the processing without providing any reasons. To find out whether the Data Controller processes data for direct marketing purposes, Users may refer to the respective sections of this document.

How to exercise rights

In order to exercise the User’s rights, Users may address a request to the contact details of the Controller set out in this document. Requests are filed free of charge and processed by the Controller as soon as possible, in any case within one month.

COOKIE POLICY

The site makes use of Tracking Tools using Cookies commonly referred to as “technical” or other similar Tracking Tools to perform activities strictly necessary to ensure the operation or provision of the Service.

Third Party Tracking Tools

– SPAM Protection

Other activities that involve the use of Tracking Tools

Simple Interactions and Features

The Site uses Tracking Tools to enable simple interactions and activate features that allow Users to access certain resources on the Service and simplify communication with the Owner.

– Contacting the User

– Statistics

Improving the Experience

The site uses Tracking Tools to provide a personalized user experience, allowing for better management of personal settings and interaction with external networks and platforms.

– Content commentary

Measurement

The Site uses Tracking Tools to measure traffic and analyze User behavior with the goal of improving the Service.

– Statistics

Targeting and Advertising

The site uses Tracking Tools to provide customized commercial content based on User behavior and to manage, distribute and track advertisements.

– Interaction with social networks and external platforms

– Advertisement

How to manage preferences and give or revoke consent

There are several ways to manage preferences related to the Tracking Tools and to give or revoke consent where necessary:

Users can manage their preferences related to Tracking Tools directly through their devices’ settings – for example, they can prevent the use or storage of Tracking Tools.

In addition, whenever the use of Tracking Tools depends on consent, Users may give or revoke such consent by setting their preferences within the cookie policy or updating such preferences via the tracking settings widget, if any.

Thanks to special functions of the browser or device, it is also possible to remove previously saved Tracking Tools.

Other Tracking Tools stored in the browser’s local memory can be removed by deleting the browsing history.

With respect to third-party Tracking Tools, Users may manage preferences and revoke consent by visiting the relevant opt-out link (if available), using the tools described in the third party’s privacy policy or contacting the third party directly.

Locating Tracking Tools Settings

Users can, for example, find information on how to manage Cookies in some of the most popular browsers at the following addresses:

Users may also manage certain Mobile Tracking Tools by disabling them through the appropriate device settings, such as mobile advertising settings or tracking settings in general (Users may consult their device settings to find the relevant one).

ADDITIONAL INFORMATION ABOUT PROCESSING

Legal defense

The User’s Personal Data may be used by the Data Controller in legal proceedings or in the preparatory stages of any such proceedings to defend against abuse of the User’s use of the Site or related Services.

The User declares to be aware that the Data Controller may be obliged to disclose the Data by order of public authorities.

Specific information

At the request of the User, in addition to the information contained in this privacy policy, the site may provide the User with additional and contextual information regarding specific services, or the collection and processing of Personal Data.

System logs and maintenance

For operational and maintenance purposes, the site and any third party services used by it may collect system logs, i.e. files that record interactions and may also contain Personal Data, such as the User’s IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on the site and, if technically and legally feasible, by sending a notification to Users through one of the contact details in its possession. Therefore, please consult this page frequently, referring to the date of last modification indicated at the bottom.

If the changes affect processing whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.

DEFINITIONS AND LEGAL REFERENCES

Personal Data (or Data)

Personal data is any information that, directly or indirectly, even in conjunction with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data

This is information collected automatically through the site, including by third party applications integrated into the site, including: IP addresses or domain names of computers used by the user who connects with the site, URI (Uniform Resource Identifier), the time of the request, the method used to forward the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the response from the server (successful, error, etc.. ) the country of origin, the characteristics of the browser and the operating system used by the visitor, the various temporal connotations of the visit (e.g. the time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User’s IT environment.

User

The individual who uses the site which, unless otherwise specified, coincides with the Interested Party.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Manager)

The natural person, legal entity, public administration and any other entity that processes personal data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to the operation and use of the site. The Data Controller, unless otherwise specified, is the owner of vs-spirits.com .

vs-spirits.com (or website)

The hardware or software tool through which Users’ Personal Data are collected and processed.

Service

The Service provided by the Website as defined in the relevant terms (if any) on this site/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union in this document shall be deemed to extend to all current member states of the European Union and the European Economic Area.

Cookies

Cookies are Tracking Tools that consist of small pieces of data stored within the User’s browser.

Tracking Tool

Tracking Tool means any technology – e.g. cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that allows Users to be tracked, for example by collecting or storing information on the User’s device.

Legal references

This privacy policy is drafted on the basis of multiple legislative orders, including Articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy policy applies exclusively to vs-spirits.com .