This policy sets out how we collect, handle, transfer, use and secure your data. We take your privacy very seriously and will treat information we receive from you in accordance with this policy. We will also treat your information in accordance with any relevant laws including, without limitation, the Spanish Data Protection and any requirements of social media platforms including without limitation Facebook, Google, Twitter, Youtube and Flickr (“Social Media Platforms”).
Personally Identifiable Information: the Site may request, collect and retain certain personally identifiable information such as name, address, phone number and e-mail address through various means, such as Site registration, competition entry, surveys, games, questions, comments and communications to the Site, and postings to chat and bulletin areas, if any. Information may also include your basic account information from Social Media Platforms, including, without limitation, your user ID, your date of birth, your profile picture and any comments you make on the Site, as well as any other information you supply to us when using the Site, including, without limitation, any information or materials submitted by you through the Site, whether names, personal information, photographs, films, stories, music, ideas, creative concepts, other materials, information or data of any kind and in any format and other content you post on and through the Site (“User Information”).
Non-Personally Identifiable Information: We may also collect certain non-personally identifiable information at the Site, (such as annual income, buying preferences, or age), also known as demographic or profile data.
We wish to keep this information as up to date as possible and you agree that you will remain responsible for keeping your information up to date by informing us of any changes to your information by contacting the site administrators at email@example.com or using the methods set out in any communications from us.
LEGAL DRINKING AGE
You must not provide us with your Personal Information, if you are not of legal drinking age to purchase alcohol beverage products in the jurisdiction in which you reside and, if different, in the jurisdiction from which you are accessing our website. If we become aware that someone under the legal drinking age has provided us with Personal Information, we will make every reasonable effort to remove such Personal Information from our files and any database.
INTERNET PROTOCOL (IP) ADDRESS
We may collect your IP address to help diagnose problems with our server, and to help administer the Site. An IP address is a number that is assigned to your computer when you use the Internet. This information does not contain any personally identifiable information about you. Your IP address is also used to help identify you during a particular session and to gather broad demographic data.
Malabusca and The Cutting Edge of Dreams Companies (either directly or via the third parties listed in Sharing) may use your personally identifiable information collected on or through the Site:
- To register you and allow you to access the Site;
- For advertising, direct marketing and promotional purposes for Malabusca and/or the The Cutting Edge of Dreams Companies where you have given consent, including in particular, to send you information about products we believe might of interest to you, newsletters, information about private tastings, limited edition releases, exclusive downloads and invitations to unique events, and to conduct prize draws and competitions;
- In the future promotional activities of Malabusca and/or the The Cutting Edge of Dreams Companies where you have given consent;
- To enable us to monitor, review and improve the products and services we offer;
- To provide you with information about updates and changes to this Site where you have given consent; and
- Any other purpose disclosed to you at the time of collecting your personal information.
If you do not want to receive this information, in the event it appears on the face of the site that this is envisaged, and your consent is obtained, you will always be given the opportunity to limit or stop this use at any time by following the instructions detailed in the communication you receive from us. We may use the information we gather along with information obtained from other sources, including but not limited to, information obtained from third parties.
If we wish to use information for any additional purpose we shall notify you of this and obtain your consent at the time that you provide that information prior to such use commencing.
With respect to non-personally identifiable information, we may use this data to improve the Site and for direct marketing and/or marketing and/or promotion and/or sales information, including to carry out our own demographic research analysis, for internal audit purposes and to monitor customer traffic patterns and usage of the Site to help us develop the design and layout of the Site. This information may also be used to evaluate what portions of the Site are more popular than others, determine where visitors came from, where visitors go, how long visitors stay on a particular page, or use of the Site in general. We will use your non-personally identifiable information in aggregate, anonymous form only, which means that the information will not contain any personally identifiable information about you or any other person.
We will not use your personal data for advertising, direct marketing and/or promotional purpose after we receive your notice of withdrawal or opting out of our system of communication.
Malabusca and The Cutting Edge of Dreams Companies may share your personally identifiable information with:
- The Cutting Edge of Dreams Companies and their associated companies, subsidiaries, agents and representatives, in accordance with the purposes set out in the Usage section;
- Our service providers, agencies and subcontractors, retained to perform functions on our behalf, or to provide services to us (such as event organising, warehousing and delivery; marketing and advertising; credit card and data processing; age verification; software development; website hosting and management; information technology and office services; legal, accounting, audit and other professional service providers related to our business); provided such service providers and subcontractors do not collect, use, or disclose the personal information for any purpose other than to perform such functions on our behalf, or to provide such services to us;
- Law enforcement, governmental or regulatory personnel and agencies when requested to do so or as required by law; and
- Third parties to whom you have provided your consent or who in our reasonable judgment, are providing or seeking the information as your authorized or appointed legal agent.
In order to make the Site more enjoyable for visitors, Malabusca constantly strives to learn how users use the Site. Information concerning your use of the Site and related services may be collected, used, retained and made available to one or more third parties, such as a data processor, fulfilment agency, or advertising agency, for advertising, direct marketing and promotional purposes.
Malabusca may transfer or assign information concerning your use of the Site, including, without limitation, personally identifiable information that you provide and other information concerning your use of the Site, to third parties, as a result of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization or liquidation of Malabusca.
You fully understand and unambiguously consent to the transfer of such personal data or information to, and the collection, retention, use and processing of such personal information in Spain and other countries or territories including, without limitation, those outside of the European Economic Area.
We will not transfer and/or share and/or provide your personally identifiable data unless your written consent is received (which is given by opting-in at Site registration for example).
THIRD PARTY WEBSITES
Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers or affiliates, to and from the websites of third parties and to and from links to social media platforms. If you follow a link to any of these websites or platform, please note that these websites and platforms should have their own privacy policies, which will govern their use of the information that you provide to them and that we do not accept any responsibility or liability for these policies (except where expressly set out in those policies). Please check these policies before you submit any personal data to these websites or social media platforms.
POSTING INFORMATION ON OR THROUGH THE SITE
You are solely responsible for the information and other content you post on or through the Site. See Terms and Conditions. You understand that personal and other information (e.g., user name, e-mail address, phone number) that you post on or through the Site (e.g. via functionality such as chat, bulletin boards, post cards or invitations), is generally accessible to and may be collected and used by others and may result in unsolicited messages or other contact from others. Users of any such functionality on the Site are encouraged to exercise caution when providing personal information.
We take security very seriously. Due to the open communication nature of the Internet however, we cannot guarantee that communications between you and us, and us and you, will be free from unauthorized access by third parties.
CONSENT TO PROCESSING IN SPAIN AND WORLDWIDE
By providing any personal data or information to the Site including, but not limited to, sensitive personal data (such as racial, ethnic, political, religious, trade union, physical or mental health, sexual or criminal record information), you fully understand and unambiguously consent to the transfer and/or process of such personal data or information to, and the collection, retention and processing of such personal information in Spain and other countries or territories including, without limitation, those outside of the European Economic Area by those parties mentioned in Sharing above.
YOUR ACCEPTANCE OF THIS POLICY
Site Administrators: firstname.lastname@example.org
Last Updated: January 2017