PRIVACY POLICY

We, TRUE SPIRITS, take our responsibility in the processing of your personal data very seriously. We process your personal data exclusively in compliance with the statutory provisions, in particular the EU General Data Protection Regulation ("GDPR"), the Data Protection Act ("DSG") and the Telecommunications Act ("TKG").

This data protection information is intended for the customers of our online platform www.true-spirits.com.

 

  • What categories of personal data do we process?

Personal data is any information relating to an identified or identifiable natural person.

We process your personal data, which is necessary for the execution of our legal relationship (for the consideration of our online platform www.true-spirits.com) with you and the legal obligations that apply to us. This means the data that you provide to us, e.g. when registering for our online platform, logging in or otherwise contacting us. This includes master, contact, contract, billing, revenue, bank, and communications data. If you upload media content (such as images) that contains personal data as part of our online platform, we will also process it.

In addition, we process data that is automatically collected from you (server log files). This includes the internet protocol ("IP") used to connect your computer to the internet – the address, date and time of the request, which data file is requested (name and URL), what amount of data is transferred to you, a notification whether the transfer request was successful, the recognition data of the browser and operating system used, and the website from which the access was made. This information is technically necessary to show you our content and to ensure stability and security (legal basis - legitimate interest iSd Article 6 Para.1 § f GDPR).

 

  • For what purposes data processing occurs and on what legal requirements are they based?

We process your data on the basis of a contract concluded/to be concluded between you and us (Article 6 Para. 1 § b GDPR), specifically for the use of our online platform. When using our online platform, we analyse your usage behaviour in order to deliver content that is suitable for you.

Based on your consent (Article 6 Para. 1 § a GDPR), we process your data, where necessary, for the use of cookies and tracking tools (see point 6 for details), for the electronic delivery of information on our services as well as information to deal with and respond to your request, when contacted by you.

Due to our legitimate interest (Article 6 Para. 1 § f GDPR), we process your data for the purpose of operation, security and optimisation of our online platform and our website, to prevent fraud, to assert, exercise and defend legal claims, to respond to your enquiries and for the purpose of sending information about our services and invitations to our events.

Furthermore, data is processed in order to fulfil legal obligations or official orders to which we are subject (Article 6 Para. 1 § c GDPR).

 

  • What are the consequences of not processing your data?

You are not legally or contractually obliged to provide us with any data. Without your data, we are not able to fulfil the purposes for which we legally process your data (see point 2.).

 

  • How long do we process your data?

In principle, we only store your personal data for as long as it is required to be used for the purposes for which it is processed (see point 2.).

After reaching its purpose, it is checked whether the data is still needed or whether the deletion or anonymisation is precluded by a statutory retention period. Where this is the case, data will be processed to a limited extent for the duration of the retention period. Aside from this, data can also be required and processed for the defence and assertion of legal claims within the statutory or contractual warranty period or damages period.

If data processing is based on your consent (see point 2.), we process the data for the duration of its validity.

 

  • Disclosure of data

Where this may be necessary for the aforementioned purposes and where there is a legal basis, data will be passed on to third party recipients.

For the operation, administration and maintenance of our online platform and website, external companies typical for our business activities are commissioned, who provide services in electronic data processing and information technology. In doing so, they can access the data mentioned above in Point 1. These include:

Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, and Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland, for the purposes of web analysis, access statistics, payment processing via Angular TS Add, and for data management and hosting purposes.

Facebook Inc., 1601 p. California Ave, Palo Alto, CA 94304, USA ("Facebook"), for login via Firebase Authentication.

Zoho Corporation GmbH. Trinkausstr. 7 40213 Düsseldorf, Germany for the purpose of analysing user activity.

For the provision of other contractual and legal obligations, we pass on data to typical service providers such as banks. In addition, data transfers may be made to authorities, courts, tax advisors and legal representatives where required on occasion.

For sending invitations as well as for carrying out marketing measures, we may pass on data to advertising agencies commissioned by us in individual cases.

In individual cases, recipients of your personal data may be located outside your country. The level of data protection in other countries may not be the same as in Austria. However, we only transfer your personal data to other countries for which the EU Commission has decided that it has an adequate level of data protection or where we take measures to ensure that all recipients have an adequate level of data protection, for which we conclude standard contractual clauses (2010/87/EC and/or 2004/915/EC).

 

  • Cookies, Web Analysis/ Web Tracking
  • Cookies

We use cookies to make your use of the website as easy, effective and secure as possible. Cookies are text files that are stored on the user's computer when you visit a website. Cookies are then sent back to the web server from which they originate each time they are visited. They serve to make our offer more user-friendly and effective overall. Cookies are used to recognise the user and their settings, to measure the frequency of page views, for general navigation and to perform tracking.

During the use of our website, you may also receive cookies from third parties (within the scope of the web analysis used) on your computer (so-called "third-party cookies"). We assume no liability for damages caused to you by the use of your data by third parties.

The following types of cookies are used when using the website (a list of all cookies used can be found here: Cookie list.

Transient cookies: these are automatically deleted when you close the browser. This type of cookie includes in particular "session cookies". These store a so-called session ID, which can be used to assign various requests from your browser to a common session. This allows your computer to be recognised when you return to our website. Session cookies are deleted when you log out or close the browser.

Persistent cookies: persistent cookies are used to recognise your browser the next time you visit. The storage duration of persistent cookies may vary. However, you can delete persistent cookies at any time (see below).

In general, you can set your browser so that you are informed about the setting of cookies and allow cookies only in individual cases, exclude the acceptance of cookies for certain cases or in general, and enable the automatic deletion of cookies when the browser is closed. You can also prevent the setting of cookies by changing your browser settings (use your browser's help function), but this may limit the functionality of the website.

When setting cookies that affect your privacy, your consent will be obtained beforehand. This is done by continuing to browse the website for information about the type and purposes of the cookies used via the cookie banner. The use of cookies, which are indispensable for the proper functioning of the website or for activities that you expressly request, does not require explicit consent.

 

  • Web analysis

This website uses Google Analytics, a web analytics service provided by Google. Google Analytics uses goal-oriented cookies. We use Google Analytics to analyse and regularly improve the use of our website and services.

The information generated by the cookie on your use of the website is usually transmitted to a Google server in the USA and stored there.

This website uses Google Analytics with the "_anonymizeIp()" extension. As a result, IP addresses are processed in a truncated manner, which can be used to exclude personal data. Insofar as the data collected about you is subject to a personal reference, this is immediately excluded and the personal data is deleted immediately. For more information on IP anonymisation, see https://support.google.com/analytics/answer/2763052?hl=de.

On behalf of us, Google will use the information mentioned to evaluate your use of the website, to compile reports on website activity and to provide us with other services related to the use of the website and the internet. The IP address transmitted by your browser within the scope of Google Analytics will not be merged with other data from Google.

You can prevent the storage of cookies using the settings of your browser software or prevent the processing by Google of the data generated by the cookie and related to your use of the website by pressing the following link and downloading and installing the browser plug-in available there: https://tools.google.com/dlpage/gaoptout?hl=de

You can also prevent the collection of and transfer to Google of the data generated by the cookie and related to your use of the website (incl. your IP address) along with the processing of this data by Google by activating the "Do Not Track" option in your browser or by objecting to the collection here (opt-out link).

When the opt-out is exercised, a cookie is set for exclusion. If all cookies on your computer are deleted, this opt-out cookie will also be deleted; therefore, if you wish to continue to object to anonymised data collection by means of web tracking, you must set the opt-out cookie again.

This website also uses Google Analytics for a cross-device analysis of visitor flows, which is carried out via a user ID. You can disable the cross-device analysis of your usage in your customer account under "My Data", "Personal Data".

 

  • Facebook Pixel

This website uses Facebook Pixel, a web analytics service of Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland ("Facebook"). We have signed a data processing contract with Facebook. The data is partially sent to the USA or Ireland. The transfer of the data to the USA or Ireland is based on standard contractual clauses and the GDPR. When accessing our website, a connection to the Facebook servers is established via software and data is sent to servers located either in the USA or in Ireland. Facebook Pixel also uses cookies to store information about the website user and to analyse the use of the website by the website user. According to Facebook, Facebook will use the collected data to evaluate the use of the website, to compile reports on the website activities and to provide further services related to the use of the website and the internet. Facebook may also transfer this information to third parties if required to do so by law or if third parties process this data on behalf of Facebook. Detailed information on how Facebook handles user data can be found in Facebook's privacy policy https://www.facebook.com/privacy/explanation.

Disable Facebook Pixel

You can only prevent Facebook Pixel from capturing your user data on this website by clicking on the following link. An opt-out cookie is set that prevents the collection of your data on future visits to this site: Disable Facebook Pixel.

 

  • Consent, right of revocation

Where data processing is based on your consent, you may revoke it at any time, e.g. by email to This email address is being protected from spambots. You need JavaScript enabled to view it.. In such a case, the data previously stored about you will be deleted or anonymised and subsequently reused only for statistical purposes without personal reference. By revoking your consent, the legality of the data processing carried out on the basis of the consent until the revocation shall not be affected.

 

  • What other rights do you have?

Under certain legal conditions, you have the right to information about the personal data concerning you (Article 15 GDPR), the right to rectification of personal data concerning you (Article 16 GDPR), the right to deletion (Article 17 GDPR), the right to restrict data processing (Article 18 GDPR) and the right to data transfer (Article 20 GDPR).

In particular, you have the right to object at any time to the processing of personal data concerning you where the processing is necessary for the performance of a task which is in the public interest or in the exercise of official authority (Article 6 Para. 1 § e GDPR) or if the processing takes place in order to safeguard our legitimate interests (Article 6 Para. 1 § f GDPR), unless the processing is carried out on compelling legitimate grounds that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims. If your data is processed in order to conduct direct marketing, you are in any case entitled to object.

You can find the legal regulations concerning these rights of affected persons here:

http://eur-lex.europa.eu/legal-content/DE/ALL/?uri=CELEX%3A32016R0679

Furthermore, you have the right to complain to the Austrian Data Protection Authority (Barichgasse 40-42, 1030 Vienna, email: This email address is being protected from spambots. You need JavaScript enabled to view it.).

Insofar as changes to your personal data occur, we ask for appropriate notification.

 

  • Contact

If you have any further questions, would otherwise like to contact us or wish to exercise your rights of data (see point 8), please contact us under the contact details mentioned above, e.g. This email address is being protected from spambots. You need JavaScript enabled to view it..

 

  • Data Protection

The protection of your personal data is carried out by appropriate organisational and technical measures. These precautions concern, in particular, protection against unauthorised, unlawful or even accidental access, processing, loss, use and manipulation.

Notwithstanding efforts to comply with an always reasonable level of due diligence requirements, it cannot be ruled out that information may be viewed or used by other persons. Therefore, we recommend that you do not send us confidential or sensitive data by unencrypted email.

 

  • Change of data protection information

New legal requirements, business decisions or technical developments may require changes in our data protection information. The data protection declaration will thereby be adjusted accordingly. The latest version can always be found on our website.

 

  • Disclaimer

Please note that we do not assume any liability for the disclosure of information due to errors not generated by us in data transmission and/or unauthorised access by third parties (e.g. hacker attack on email accounts, telephones, interception of fax).