The purpose of this Privacy Policy is to inform you how and why UNISPIRITS SRL (“company”, “we”, “us” or “our”), avenue de Broqueville 7, 1150 Brussels, collects, stores, uses, shares, (“processes”) your information provided when you use our services. The policy will also help you understand your privacy rights and choices. We keep this policy under regular review, and may change it from time to time, so please check this page for any updates.
Last updated on 28/11/2023

Topics

• 1. What Personal Information do we collect?
• 2. How and why do we use tracking technologies?
• 3. For what purposes do we use your Personal Information and on which legal grounds?
• 4. What happens if you do not wish to provide your Personal Information?
• 5. To whom do we disclose Your Personal Information and why?
• 6. Is your Personal Information sent to recipients located in other countries and why?
• 7. How long do we keep your Personal Information?
• 8. How do we secure and store your Personal Information?
• 9. What are your rights regarding Personal Information?
• 10. How do we process children’s Personal Information?
• 11. Privacy policy of other websites
• 12. Changes to our privacy policy
• 13. How can you contact us or lodge a complaint to the relevant Supervisory Authority?

1. 1. What Personal Information do we collect?

We collect the following information which may be updated and vary depending on our activities:

We collect personal information that you voluntarily provide to us. The information we collect may include: Names, phone numbers, email addresses, mailing addresses, usernames, passwords, contact preferences.

We automatically collect certain information when you visit, use, or navigate the website, which may include, your device and usage information, such as your IP address, browser and device information, operating system, language preferences, referring URLs, device name, country, location information, about how and when you use our services. We may also use information about you which we may obtain from third parties such as Google or social media that you use. The information may consist of the pages you viewed, the time you viewed them, which beverage information or other content you accessed or provide, in what language, and what pages you looked at before viewing the current page.

2. 2. How and why do we use tracking technologies?

We use tracking technologies such as cookies, IP Addresses or Log files. Tracking technologies help us tailor our website to your personal needs.


• Like many businesses we use cookies to better understand how visitors use our website and the tools and services and improve their use and functionality. You can learn more about the cookies we use and how you can disable them in a our Cookies Policy
• An IP address is used to identify your device every time you log on to the Internet. We may keep track of Internet Protocol (IP) addresses to (among other things): (i) troubleshoot technical concerns, (ii) maintain website safety and security, (iii) restrict access to our Website to comply with applicable law or contractual restrictions, and, (iv) better understand how our website is used;
• We (or a third party on our behalf) may collect information in the form of log files that record activity on our Website and gather statistics about users' browsing habits. These entries are generated anonymously, and help us gather (among other things) (i) a user’s browser type and operating system, (ii) information about a user’s session (such as the URL they came from, the date and time they visited our Website, and which pages they've viewed on our Website and for how long), and, (iii) other similar navigational or click-stream information. We also use information captured in log files for our internal marketing and demographic studies, so we can constantly improve and customize the online services we provide you. Log files are used internally only, and are not associated with any particular user.
3. 3. For what purpose do we use your Personal Information and based on which legal grounds?

We collect information about you in order to:

• Respond to your request of service or for the performance of a contract:: When you register or sign-up on our site, your Personal Information is used to provide you with the relevant features and services you subscribe to, and to you the benefits and privileges that typically come along with your registration (e.g. receiving the communications you select at the time of registration, being invited to events, participating in a sweepstake, etc.);
• Send you transactional or administrative communications:(e.g. confirmation email when you sign up for, or unsubscribe from, a specific registration or activity), as well as certain service-related announcements (e.g., notices about updates to our privacy notices, discontinued features or programs on our Website, changes to our online services or technical support policies, or other related changes);
• Allow us to send you marketing information when you consent:
  - In addition to the purpose for which you submitted your Personal Information, you may also be given the option (through a check box or otherwise) to have your Personal Information used for an activity or service from the primary activity or service that you are requesting. For example, if you are signing up for a contest or other promotion, you may also be invited to sign up for newsletters or alerts from our Website hosting the promotion or from other websites. If you choose to receive these additional services, we will use your Personal Information to provide them to you.
  - When you use a QR Code or equivalent feature displayed on UNISPIRITS SRL products: we use your Personal Information to send you more information on the products where the QR code or equivalent feature is displayed or other products;
• Because it is also UNISPIRITS SRL legitimate interest to better serve you:
  - Subject to your consent when required, we may occasionally combine, update, or otherwise enhance the Personal Information collected through our Website with information we receive from outside records or third parties. For instance, we may combine purely demographic or survey information (e.g. age, gender, household information, and other interests, etc.) not linked to any Personal Information about you with Personal Information collected through our (such as during account registration). We may use the combined above-mentioned information and/or demographic information for our internal marketing and demographic studies and to constantly improve, personalize, and customize the products and services we provide you to better meet your needs. Some of the tools we use may involve automated individual decision-making subject to applicable law.
  - Feedback, questions, or comments through our “Contact Us” form and our “Tell Us” compliance reporting system: if you contact us via an online contact form, your Personal Information is used to respond to your inquiry or comment. We will ensure that your Personal Information remains accurate and up-to-date and avoid duplication in our informationbase, by verifying each of your interactions with us and/or one of our to ensure your Personal Information is still accurate or needs to be completed or updated with the additional information you will have provided.
  - We may conduct profiling based on monitoring your browsing activities on our Website to better understand your preferences and center of interests and adapt our marketing communications to your profile, unless you object in the conditions set forth in Section 9 of this Privacy Policy.

We take every reasonable step to ensure that the Personal Information we process is limited to the Personal Information reasonably necessary in connection with the purposes set out in this Policy.

4. 4. What happens if you do not wish to provide your Personal Information?

If you choose not to submit any Personal Information when requested, you may not be able to participate in certain activities and personalized features, other Website services and special services to you may be limited. For example, if you refuse to share your email address, you will not be able to receive our newsletters or otherwise register on our Website. However, to simply browse our website and learn more about UNISPIRITS SRL and our products, you do not need to give us any Personal Information. In any event, we will always inform you of the Personal Information that is necessary in order to benefit from a service.

5. 5. To whom do we disclose your Personal Information and why?

UNISPIRITS SRL may share for the purposes mentioned in Section 3 your Personal Information with its worldwide.

With third parties

UNISPIRITS SRL may also share your Personal Information with third parties, but only in the following circumstances:

• For marketing purposes if you gave us your consent.
• For support purposes: We may use service providers, agents or contractors to provide support for the internal operations of our Website and to assist us with administering them or the various functions, programs and promotions available on it. Any such third party shall at all times provide the same levels of security for your Personal Information as UNISPIRITS SRL and, where required, are bound by a legal agreement to keep your Personal Information private, secure and to process it only on the specific instructions of UNISPIRITS SRL ;
• For joint and co-sponsored programs and promotional purposes: When we run a joint or co-sponsored program or promotion on our Website with another company, organization, or other reputable third party; and, as part of this event, collect and process Personal Information, we may share your Personal Information with our partner or sponsor, subject to your consent when required. If your Personal Information is being collected by (or is shared with) a company other than UNISPIRITS SRL as part of such promotion, we will let you know this at the time your Personal Information is collected;
• For litigation and safety purposes: We may also disclose your Personal Information if we are required to do so by law, or if in our good faith judgment, such action is reasonably necessary to comply with legal processes, to respond to any claims, or to protect the safety or rights of UNISPIRITS SRL , its customers, or the public;
• In the event of a merger or acquisition of all or part of UNISPIRITS SRL by another company, or in the event that UNISPIRITS SRL were to sell or dispose of all or a part of the UNISPIRITS SRL business, the acquirer would have access to the information maintained by that UNISPIRITS SRL business, which could include Personal Information, subject to applicable law. Similarly, Personal Information may be transferred as part of a corporate reorganization, insolvency proceeding, or other similar event, if permitted by and done in accordance with applicable law
6. 6. Is your Personal Information sent to recipients located in other countries and why?

UNISPIRITS SRL is a global company and your Personal Information may be transferred across international borders. It may be transferred to countries that have a level of information protection laws than the one existing in the country from where you submitted your Personal Information. UNISPIRITS SRL takes the appropriate measures to maintain security of the Personal Information both during transit and at the receiving location by implementing contractual clauses.

7. 7. How long do we keep your Personal Information?

We will store the Personal Information that you sent us via our Website in our information bases as long as your account is active, for the duration of the contract with you or as needed to provide you the services you requested or to answer queries or resolve problems, provide improved and new services. We may also retain your Personal Information in accordance with our internal retention procedure as necessary to comply with our legal and regulatory obligations, resolve disputes and enforce our agreements. We may retain your Personal information for as long as it is necessary for the purpose(s) for which it was intended, unless applicable law requires a longer retention period.

8. 8. How do we secure and store your Personal Information?

UNISPIRITS SRL takes all reasonable necessary technical and organizational measures to protect the confidentiality and security of your Personal Information collected from this website and/or our applications, including sensitive Personal Information. These include but are not necessarily limited to: (i) storing your Personal Information in secure operating environments that are not available to the public and that are only accessible to authorized UNISPIRITS SRL employees, and our agents and contractors; and, (ii) verifying the identities of registered users before they can access the Personal Information we maintain about them.

9. 9. What are your rights regarding your Personal Information?
• You have the right not to provide us with your Personal Information. If you do not provide us with your Personal Information, we may not be able to respond to your request or provide you with marketing that we believe you would find valuable.
• If your Personal Information has been processed on the basis of your consent on said information, you can withdraw your consent at any time, without impact on lawfulness of processing based on consent before its withdrawal.
• You can request to access your Personal Information which we will provide you in electronic form. We may require you to prove your identity before providing you with the requested information.
• You can request to rectify your Personal Information if it is inaccurate, incomplete or out of date.
• You can request the erasure of your Personal Information (i) if your Personal Information is no longer necessary for the purpose of the information processing, (ii) you have withdrawn your consent on the information processing based exclusively on such consent, (iii) you objected to the information processing, (iv) the Personal Information processing is unlawful, (v) the Personal Information must be erased to comply with a legal obligation applicable to UNISPIRITS SRL .
• You can request the restriction of the processing (i) in the event the accuracy of your Personal Information is contested to allow UNISPIRITS SRL to check such accuracy, (ii) if you wish to restrict your Personal Information rather than deleting it despite the fact that the processing is unlawful, (iii) if you wish UNISPIRITS SRL to keep your Personal Information because you need it for your defense in the context of legal claims (iv) if you have objected to the processing but UNISPIRITS SRL conducts verification to check whether it has legitimate grounds for such processing which may override your own rights if the information processing is based on the legitimate interest of UNISPIRITS SRL .
• You can request the portability of the Personal Information you provided to us, if the Personal Information processing is based on your consent or the performance of a contract and is carried out by automated means (ie. excluding paper files).
• You have the right to object to the processing of your Personal Information by us, at any time, for direct marketing purpose or for marketing purpose based on profiling, unless we have compelling legitimate grounds for the processing which override your interests rights and freedoms.
10. 10. Marketing

We would like to send you information about products and services of ours that we think you might like via our newsletter. If you have agreed to receive marketing, you may always opt out at a later date. You have the right at any time to stop our company from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please click here.

11. 11. Exercising your rights

You can exercise any of the rights described in section 9 of this Privacy Policy and under information protection laws by contacting us as detailed in Section 16 below.

Save as described in this Privacy Policy or provided under information protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their excessive number or repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request.

Please note that we may require you to prove your identity before we can give to these rights.

12. 12. How we treat children's Personal Information?

Our website is not intended for anyone under 18 years of age. We do not knowingly collect personal information from anyone under 18 years of age. You must be at least eighteen years old to create an account and engage in activities and transactions on our website. If we are notified or learn that a Minor has submitted Personal Information to us through our Website, we will delete the account and take reasonable measures to promptly delete such data from our records.

13. 13. Privacy policy of other websites

This website contains links to other websites. Our privacy policy applies only to our website. If you click on a link to another website, you should read their privacy policy.

14. 14. Changes to our Privacy Policy

From time to time, it may be necessary for us to amend or update this Policy without prior notice to reflect changes in our information protection practices or in the applicable information protection laws.

15. 15. How can you contact us or the relevant Supervisory Authority?

If you have any queries, concerns or complaints regarding this Privacy Policy or if you wish to exercise one or more of the rights described in Section 9 of this Privacy Policy, please contact us.

UNISPIRITS SRL
Avenue de Broqueville 7, 1150 Brussels
or sending an email to: info@themysticgrove.com
You are informed that you can also lodge a complaint with the Supervisory Authority of the country where you are located if you have any concern about the conditions of processing of your Personal Information by UNISPIRITS SRL .