Scotch Whisky International B.V. (SWI) attaches great importance to the protection of your privacy and the security of your personal data, in accordance with the General Data Protection Regulation (2016/679) (GDPR). This privacy policy describes how we handle and protect your personal data. It covers:
what personal data is and how we obtain it;
for what purposes and on what basis we process personal data;
how long we keep your personal data;
with whom we share your personal data;
how your personal data is protected;
the rights you have with regard to your personal data.
This privacy policy is intended for all persons whose personal data is processed by SWI, such as clients and prospects of SWI, persons who have registered for SWI newsletters and persons who apply for a job at SWI.
What is personal data?
Personal data is any information about an identified or identifiable natural person. We may, among other things, process the following personal data:
basic data, such as your first and last name, prefix and title;
contact details, such as your email address, postal address and telephone number;
personal data you provide when attending events or meetings, such as requirements regarding accessibility and diet;
personal data you provide when applying for a job, such as your name, date of birth, address, telephone number, nationality, marital status and any other data in your application;
any other personal data relating to you that you provide to us or that we may obtain in connection with the purposes and bases set out below.
You provide data, for example, when entering into an agreement with us, by giving us your business card or by applying for a job. We may also obtain your personal data from other sources, such as a business partner, counterparties, the Trade Register or public sources.
Purposes and legal bases
SWI may use your personal data for the following purposes:
to offer our whisky products;
to comply with our legal and regulatory obligations;
for marketing and business development, such as newsletters, invitations to our events and other communications that may be of interest to you;
to handle your job application or your registration for one of our events.
We process your personal data on one or more of the following legal bases:
the performance of an agreement;
compliance with a legal obligation;
a legitimate interest;
your consent.
Sharing personal data
In certain cases we may share your personal data with third parties, including but not limited to:
third parties such as regulators and other authorities, to comply with legal obligations;
external suppliers that process your personal data for the purposes in this privacy policy, such as ICT suppliers, suppliers of communication services and other suppliers to whom we outsource support services.
We share your personal data with these third parties only for the purposes and on the bases set out in this privacy policy.
Where a third party processes your personal data as a processor of SWI, SWI concludes a processing agreement with that party that meets the requirements of the GDPR. Third parties to whom we provide your personal data are themselves responsible for compliance with privacy legislation. SWI is neither responsible nor liable for the processing of your personal data by these third parties.
To provide our services, it may be necessary to transfer your personal data to a recipient in a country outside the European Economic Area. In that case, SWI ensures that the transfer complies with applicable laws and regulations.
How long we keep your data
We keep your personal data in accordance with the GDPR. Your personal data is processed until you inform SWI that you no longer wish to receive digital messages, or until SWI stops sending newsletters, white papers, event invitations or other digital mailings. Your personal data is deleted if:
your email address turns out to be no longer in use, for example when we receive error messages;
your personal data is processed on the basis of consent and you withdraw that consent;
the legitimate interest on which the processing is based lapses, for example when your company ceases to exist or when you have had no contact with SWI for a period of five years.
Your rights
At the bottom of every digital mailing from SWI you can change your preferences through the ‘unsubscribe’ link, so you can always withdraw your consent.
You also have the right to ask SWI for access to your personal data, and to have it corrected, supplemented, deleted, restricted or blocked. You can also request your personal data in a structured, commonly used and machine-readable format.
You can submit a request in writing to Scotch Whisky International B.V., Industriekade 18A, 2172 HV Sassenheim, the Netherlands, or by email to info@scotchwhiskyinvestments.com. Where we process your personal data on the basis of a legitimate interest, you have the right to object to that processing, in the same way. Finally, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).
The security of your personal data
SWI wants your personal data to be as secure as possible. We aim for a secure transfer of your personal data from your computer to our servers. SWI has taken appropriate technical and organisational measures to protect your personal data against loss or any form of unlawful processing.
Changes
SWI may amend this privacy policy from time to time. You can always consult the privacy policy on this website. We advise you to do so regularly, and in any case whenever you provide personal data to SWI.
Contact
If you have questions or comments about the processing of your personal data, please contact Scotch Whisky International B.V., Industriekade 18A, 2172 HV Sassenheim, the Netherlands, or email info@scotchwhiskyinvestments.com.