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Privacy

Privacy Policy

We attach great importance to protecting and respecting privacy.

This Privacy Policy describes the way in which we handle personal data collected via the website: Home (stage.keglevich.it) (“Website”) as well as personal data collected via email or other means of electronic communication. This Privacy Policy also describes how the Stock Spirits Group handles the information and data saved by the Websites and stored on your device (even if such information does not constitute personal data).

Who are we and how to contact us?

We are a controller, within the meaning of Article 4 point 7 of GDPR, for personal data of Website users, including data of persons who apply for a job with Stock Group Companies using online forms.

You can contact us in any matters related with the use of your personal data, also when you wish to object to the processing of your personal dataand exercise your rights in this respect. You can contact us by sending an email message to: gdpr@stockspirits.com

What do the terms used in this Policy mean?

Personal data

They mean data about living individuals identifiable on the basis ofsuch data or on the basis of such data and other information held by the data controller (or data and information the controller can acquire).

They include information about Websites users, including persons applying for a job with Stock Group Companies using online forms.

Use of personal data

It means any operation carried out on personal data, including their collection from a given individual or obtaining them from other sources, as well as their recording, storage, modification, transfer and disclosure to other parties.

GDPR

It means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, 4.5.2016, pp. 1-88).

Stock

It means Stock Spirits Group PLC, Solar House, Mercury Park, Wooburn Green, Buckinghamshire, HP10 0HH, United Kingdom

Stock Group Companies,

They mean:

We, our, etc.

It means, depending on the context,Stock or Stock Group Companies

You, your

It means a living individual whose personal data is used by Stock or Stock Group Companies, namely a Website user, including a person applying for a job with Stock Group Companies using online forms.

How do we use your personal data?

We use your personal data in connection with maintaining the Websites for the purposes described below. Depending on the use made of data, either Stock or one of the Stock Group Companies will be the data controller –the party responsible for ensuring that data use is consistent with data protection laws.

Stock is the controller for personal data processed for the purposes of:

In addition, both Stock and Stock Group Companies – each within their own scope of responsibility –are controllers for personal data processed for the purpose of handling and resolving any requests, complaints and queries they receive in relation to the exercise of the rights granted to data subjects by GDPR.

Stock Group Companies are data controllers in the scope of the activity of the above mentioned relation to the following Websites:

Ensuring compliance with legal restrictions on advertising and promotion of alcoholic beverages

We use personal data including information about the country of residence and date of birth provided by users to ensure that messages associated with advertising and promotion of alcoholic beverages are not addressed to minors. The legal basis under which we use your personal data for this purpose is our legal obligation (Article 6(1)(c) of GDPR) provided for by national laws which restrict advertising and promotion of alcoholic beverages.

Your data will be deletedas soon as the age verification has been successfully completed. The information about the successful passage of verification will be stored in the memory of your device via cookies until the end of the Website browsing session (session cookies). However,if you tick the “Remember me on this device” checkbox (by which you agree to having persistent cookies saved on your device), such information shall also be stored after the end of the browsing session. In such case, depending on the website browsed, such information may be stored even for up to 10 years. The cookies we use come from our websites, which means that no third parties have access to the information saved on your device.

Newsletter subscription

We use your personal data including your name, surname and email address to send you a newsletter with updates about Stock Spirits Group PLC. We assume that by subscribing to the mailing list, you agree for your personal data to be used for this purpose. The legal basis for the processing of your personal data will be the performance of a contract (Article 6(1)(b) of GDPR)

Your data will be stored up to2 years, but not longer than until you withdraw subscription.

Contests and events

You may find the detailed information on the processing of your personal data as part of the contests and events we organise on the website dedicated to the contest or event.

Monitoring the website traffic and ensuring correct operation of the Websites

We use your personal data including your IP address, information about your operating system and browser and terminal equipment, the content of the Websites you view (identified based on the URL), as well as other information about your activity on our Websites, including the information recorded and storedin cookies. We use such data and information to:

The legal basis for the processing of your personal data for this purpose is our legitimate interest (Article 6(1)(f) of GDPR), consisting in learning more about the needs, expectations and habits of Website users and ensuring effective communication via the Websites.

Your data will be stored for the above purposes for no longer than 1 year.However, this does not concern the identifiers and data stored in persistent cookies with longer lifespan (as described in more detail hereinbelow).

In connection with the monitoring of traffic on the Websites (also in connection with the use of Google Analytics tools), we use unique identifiers and other data stored in the memory of your device using persistent cookies. The cookies we use come both from our websites as well as from .google.com. Such cookies’ lifespan is no longer than 2 years. The identifiers and other data stored in the memory of your device may be accessed by Google Ireland Limited

Improving user Website experience

In connection with improving the user Website experience, also with preventing the recurring display of communications, we use certain information, including the identifiers, which does not constitute personal data. Such information may be stored in the memory of your device using cookies and it includes:

The cookies we use come from our websites, which means that no third parties have access to the information stored on your device

Ensuring Website use safety

In connection with ensuring Website use safety, we use certain information (includingthe identifiers of the browsing session) which constitute personal data. Such information is stored in the memory of your device using cookies. The legal basis for the use of such data is the legal obligation imposed on us under Article 6(1)(c) of the GDPR consisting in ensuring safety (also privacy and integrity) of the personal data sent as part of the users’ communication with the Website servers and, in cases going beyond the legal obligation imposed on us, our legitimate interest (Article 6(1)(f) of the GDPR) consisting in ensuring the safety of users’ communication with the Website servers. Your data shall be retained for the above purposes for a period corresponding to the lifespan of persistent cookies (as described in more detail hereinbelow).

As regards the session identifiers, we use them to ensure the safety of logging in to the Website contents, the access to which is restricted. For this purpose, we use session cookies from our websites, which means that no third parties have access to the information stored on your device

Handling requests, complaints and queries related to the exercise of rights granted to data subjects

We use your personal data including your email addressand any data you choose to provide to us in emailfor the purpose of handling and resolving your requests, complaints and queries related to the exercise of the your rights granted by GDPR, taking action in response to your request, complaint, or query, and communicating such actions to you.

The legal basis for the processing of your personal data for this purpose is our legal obligation arising under GDPR (Article 6(1)(c) of GDPR).

Your data will be stored for this purpose for 5 years from the date of request, complaint or query.

Who do we share your personal data with?

We share your personal data in the following cases:

In addition, your personal data may be shared with service providers – parties which process personal data at our request or on our behalf

Your personal data are shared with service providers under contracts whereby they are required to follow our instructions.

We transfer your personal data outside the European Economic Area, in particular to the United Kingdom. Your data may be sharedwith, among others, Stock Group Companieswhich have 6their seat in the United Kingdom.Such transfer always takes place in accordance with the applicable law. In the event that personal data are transferredto an entity located in a third country that does not ensure an adequate level of protection, we apply appropriate safeguards, including standard data protection clauses approved by the European Commission. You can obtain a copy of these safeguards by contacting us at the email address gdpr@stockspirits.com.

What rights do you have?

You have the right to:

You also have the right to:

If you have any questions, comments and requests regarding this Privacy Policy, wish to withdraw your consent or exercise your rights, please contact us. You can contact us by sending an email to: gdpr@stockspirits.com

You are also entitled to file a complaint to the supervisory authority relevant for yours place of employment or residence.

How can you manage cookies?

We save cookies on your device if you consent to it. This does not concern only the session and persistent cookies required to ensure the Website use safety and session cookies required for the purpose of age verification. You may grant your consent by clicking the “accept” button in the cookie banner displayed on our Websites. To remember your choice regarding the acceptance or rejection of cookies we will save an additional cookie on your device for no longer than 1 year.

With respect to the persistent cookies storing information about the successful passage of age verification (described above) you grant your consent by ticking the “Remember me on this device” checkbox during the age verification process.

By introducing a relevant change to the browser settings,you may delete the already saved cookies (e.g. together with the browser history and caches) or block the possibility of storing new cookies. Depending on the selected settings, you may block or delete all or some of the cookies. For example, you may block the storing of persistent cookies or cookies from other websites as well as delete cookies storedin particular time frames or during a given session. You may also choose to view our website in the “private” mode, which will restrict the range of the data registered by the computer.

You may find more information on the relevant browser provider’s website:

To find information relating to other browsers, visit the browser provider’s website.

To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.

How will you learn about a change to this Privacy Policy?

Any future changes to our Privacy Policy will be published on this website and, where appropriate, communicated to data subjects by electronic means, providing relevant information about intended changes and the date of their entry into force.