Privacy Policy

With this privacy policy we are informing you what happens to your personal data when you visit our website. Personal data consist of all the information that refers to you as a person or through which you can be personally identified.

Our commitment to data privacy

Clandestino Spirits takes the protection of your personal data very seriously. We treat your personal data confidentially and observe the legal data privacy provisions as well as this privacy policy.

When you use our website, we collect various personal data. This privacy policy explains which personal details we collect, how, for what purpose and on what legal basis. It also explains what we use your personal data for and how long, and what your rights are.

The following office is responsible for data processing on our website:

Clandestino Spezialitäten GmbH

Imbisbühlstrasse 117, 8049 Zürich

Phone: +41 (0)79 199 09 97
E-Mail: Hola@clandestino-spirits.com

1. Which kind of personal data do we collect?

Some examples of the personal data we collect are general personal details (e.g. name, address, e-mail address, telephone number, date of birth, etc.).

When you obtain goods or services via our website, we may collect further personal data, e.g. customer data (orders, delivery address, customer account, etc.) or financial details (account numbers, credit information, etc.).

Finally, our website collects information in server log files that your Internet browser automatically sends to us. This includes the user agent (browser type and version, operating system), http header details (referrer URL, IP address of connected device), the time of the server request and the login status. These server log files are only merged with other data sources for fault analysis purposes.

2. When do we collect your personal data?

One way in which we obtain your personal data is when you send them to us. This is the case, for example, when you enter personal details into a contact form, or provide us with general personal data when you register on our website.

Other data are automatically collected by our IT systems when you visit our website. These are mainly technical data (e.g. Internet browser, operating system or time of page request) and data about the pages, products and services that you view on our website. These data are automatically captured when you access our website. The data we capture also include personal data with which you can be personally identified, such as your IP address.

3. For what purpose do we collect and process your personal data?

Certain personal details are collected in order to ensure that we can provide the website to you without errors.

Other personal data are used for analyzing your browsing behavior. These analyses help us to optimize our website but also serve to automatically display products that you may be interested in. When you place an order, we require your personal and purchase data to process the purchase and any after-sales warranties. We also use these data for our customer services and technical administration as well as advertising and marketing purposes.

We only collect, process and use personal data to the extent necessary for the establishment, substance or modification of the legal relationship.

We only collect, process and use personal data that are captured when you use our website (e.g. usage data, purchase history, purchase details, such as date of purchase, type, quantity and value of the purchased goods and services, shopping basket contents, payment methods used), if you gave us your consent to process your data when you registered on our website. Processing the data helps us to customize the website content to your requirements and preferences, to improve the product search function for you or to display advertising and products that may be of interest to you. We delete the personal data we collected if you revoke your consent; the legal retention periods remain unaffected by this.

If you have not registered on our website, we only collect, process and use data about your use of the website in anonymized form. In this case, the functions mentioned above are very limited, i.e. the potential website customizations, the search functions and the advertising and products displayed to you are not as well matched to your requirements and interests.

Registration on our website

You can register on our website in order to use additional functions. The details requested for registration are mandatory and must be provided in full, otherwise we will refuse your registration. We only use the personal data we collect for the purposes of the respective product or service for which you registered. We also use your e-mail address to inform you of important changes, to a product range for example, or technically necessary changes.

The personal data collected for the registration are stored for as long as you are registered on our website and then deleted; the legal retention periods remain unaffected by this.

Use of the contact form

When you send us, an enquiry using the contact form, we store your details from the contact form including the contact details you provide there in order to process the enquiry and in case there are any follow-up queries. We do not pass these data on without your consent.

The details you enter in the contact form remain on our systems until you request that they be deleted or until the reason for storing the data ceases to exist (e.g. once your enquiry has been processed). The legal retention periods remain unaffected by this.

4. On what legal basis do we collect and process your personal data?

The legal basis for collecting and processing your personal data depends on the respective purpose of the processing in each individual case. Potential legal bases include:

Safeguarding our legitimate interests, provided that your interests, basic rights and fundamental freedom are not unreasonably affected;

Concluding or fulfilling a contract; or
Your consent at the time your personal data are captured. You can revoke your consent at any time. An informal message by e-mail is sufficient. The legality of data processing already done remains unaffected by this.

5. To whom do we pass on your personal data?

We can share your personal data on to other branches and sister companies under Clandestino Spezialitäten GmbH’s umbrella. These companies may process and use your personal data in their own interests for the purposes stated in this privacy policy.

We can also pass on your personal data to third parties outside Clandestino Spirits (e.g. to the company entrusted with delivering the goods or the credit institution that processes the payment) if this is necessary for contract execution or in order to make use of the required technical or organizational services. These third parties are contractually obliged to process your personal data exclusively on our behalf and according to our instructions and to ensure the security of your personal data through appropriate technical and organizational measures. Your personal data are only sent to other countries if they have instituted privacy laws comparable to those in Switzerland or if suitable measures have been taken (Swiss-US Privacy Shield or contractual guarantees).

Finally, we may pass on your personal details to others if we are legally obliged to do so.

6. For how long do we store your personal data?

We store your personal data for as long as necessary for the purposes for which they were captured but no longer than we are permitted to by law.

We will delete your personal data when they are no longer needed, and at the latest at the end of the legally prescribed retention period.

7. How do we protect your personal data?

We have taken appropriate technical and organizational measures to prevent unauthorized or illegal access to your personal data. Because we cannot guarantee full data security for communication by e-mail, we recommend that you send confidential information through a secure means of transmission.

For security reasons and to protect transmissions of confidential information, e.g. your orders or queries, our website uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line in the browser changes from "http://" to "https://" and the lock icon on the address line. All the main payment methods (e.g. Visa/Mastercard, etc.) use only encrypted SSL or TLS connections for payments.

8. What are your rights?

Revoke your consent to the processing of your data

Certain data processing activities are only permitted with your consent. You can revoke any consent you have already given at any time. An informal e-mail is sufficient. The data processing already done remains unaffected by this revocation of consent.

Information, blocking, deletion

Within the scope of the applicable legal provisions, you have the right to be informed, free of charge and at any time, of the personal data that we store about you, their origin, any recipients and the purpose of data processing, and should you so wish, to have your personal data corrected, blocked or deleted. For this, or if you have any questions about data privacy, you may contact us at any time using the address provided at the top of this document.

Complaint to the regulatory authority

In the event of a breach of data privacy, you have the right to make a complaint to the Federal Data Protection Commissioner.

9. How can you subscribe to a newsletter?

If you wish to subscribe to one of the newsletters that we offer on our website, we need you to provide us with an e-mail address and other information that allows us to check that you are the owner of the e-mail address you provided and are in agreement with the newsletter subscription ("double opt-in" process). If you are a registered customer and wish to subscribe to a newsletter, you can give your consent for this at the time of registration or at a later time by making use of the subscription function on your customer profile.

The newsletters will provide you with regular recommendations and offers that may interest you. In order to be able to do this, we collect and process personal data about your browsing behavior on our website, your orders and whether you use our newsletter (e.g. whether you open the newsletter and which of the URL links you click). We evaluate these data for statistical purposes in order to adjust the contents of the newsletters to your interests.

We process the personal data you provide us with in the newsletter subscription form on the basis of your consent, which you can revoke at any point in the future. You can revoke it either by pressing the "Unsubscribe" link in the newsletter or by unsubscribing in your customer profile. We use the personal data that we collected about you to design the contents of the newsletter and to distribute it. We do not forward these data to third parties for their own (advertising) purposes.

We store the personal data that you provided us with for the purpose of the newsletter subscription until you unsubscribe from the newsletter.

10. How does the comment function work?

The comment function on our website stores not only your comment but also details of the time at which the comment was created, your e-mail address and, if you are not posting anonymously, the username you selected. We also record your IP address when you post a comment. Because we do not check comments before they are published on our website, we require these data in order to be able to take action against the author of a post in the event of a legal breach.

The comment and the associated personal data (e.g. IP address) are stored and remain on our website until the content of the comment is fully deleted, or until the comment has to be deleted for legal reasons (e.g. malicious comments).

As a user of our website, you can subscribe to the comments after you have registered. You will receive a confirmation e-mail to verify that you are the owner of the e-mail address provided and agree that you wish to receive the newsletter ("double opt-in" process). You can also unsubscribe from this function at any time by clicking a link in the information e-mails. The personal data that we collected when you registered are then deleted.

11. How do we use cookies?

We use cookies on our website. Cookies are small text files that are placed on your computer and stored in your browser. Cookies help us to make our website more user-friendly, effective and secure and do not cause any harm on your device.

Most of the cookies we use are "session cookies". They are automatically deleted when you leave the website. Other cookies remain on your system if you do not delete them. These cookies enable us to recognize your browser the next time you visit.

You can configure your browser to notify you when a cookie is set, only to allow cookies in an individual case, to accept cookies in certain cases or not at all, or to delete cookies automatically when the browser is closed. When cookies are deactivated, however, the functionality of our website may be limited.

Any cookies that are necessary for setting up the electronic communication process or to provide certain functions that you may want (e.g. shopping basket) are stored in accordance with Art. 6 para. 1 f of the GDPR. The website operator has a legitimate right to store cookies to ensure that it can provide its services optimally and without technical issues.

12. How do we use social media plug-ins?

Facebook plug-ins (Like & Share buttons)

Our website uses Facebook plug-ins supplied by Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA. You can recognize the Facebook plug-ins by the Facebook logo or the "Like button" on our website. You will find an overview of the Facebook plug-ins here https://developers.facebook.com/docs/plugins/.

When you visit our website, the plug-in sets up a direct connection between your browser and the Facebook server. Facebook is then notified that you have visited our website from your IP address. If you click the Facebook "Like" button while you are logged into your Facebook account, you can link the content of our pages to your Facebook profile. This enables Facebook to associate your visit to our website with your user account. Clandestino Spirits does not know what content is transmitted and how it is used by Facebook.

For more information please refer to the Facebook data privacy policy here https://www.facebook.com/policy.php.

If you do not want Facebook to be able to associate your visit to our website with your Facebook user account, please log out of Facebook.

Instagram plug-in

Our website uses Instagram plug-ins supplied by Instagram Inc., 1601 Willow Road, Menlo Park, California 94025, USA.

If you are logged into your Instagram account and click on the Instagram button, the content on our pages may be linked to your Instagram profile. This enables Instagram to associate your visit to our website with your user account. Clandestino Spirits does not know the content of the transmitted data and how they are used by Instagram. For more information please refer to the Instagram data privacy policy here https://instagram.com/about/legal/privacy/.

13. How do we use website analytics services?

Google Analytics

Our website uses functions of the web analytics service Google Analytics supplied by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Google Analytics uses cookies. These are text files that are stored on your computer and allow your use of our website to be analyzed. Google evaluates the use of our website in order to produce reports on website activity and to provide Clandestino Spirits with other services relating to website use and Internet use. The IP address transmitted by your browser for Google Analytics will not be associated with any other data held by Google.

The information about your use of our website obtained via the cookies is usually transmitted to a Google server in the USA and stored there. Google observes the data privacy provisions of the “Swiss-U.S. Privacy Shield” agreement and is registered with the US Department of Commerce for the “Swiss-U.S. Privacy Shield” (for information about the Swiss-U.S. Privacy Shield

visit https://www.privacyshield.gov/Swiss-US-Privacy-Shield-FAQs).

Our website uses the IP anonymization function. Google therefore truncates the IP address before transmitting it to the US. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and then truncated there.

You may stop cookies from being stored by selecting the appropriate settings in your browser, however, please note that you may not be able to use the full functionality of this website if you do so. You can also prevent Google from collecting and processing your data by downloading and installing the browser plug-in available

here: https://tools.google.com/dlpage/gaoptout?hl=en. In this case, an opt-out cookie is placed on your system which will prevent your data from being collected during future visits to this website.

Our website uses the Google Analytics “Demographics and Interests” function. This allows Google Analytics to gain insight into the age, gender and interests of the visitors to the website. These data originate from Google's interest-based advertising and from third-party visitor data. These data cannot be associated with a specific person. You can deactivate this function at any time by changing the advertising settings in your Google account or you can stop your data from being collected by Google Analytics altogether. For more information please refer to the Google data privacy policy here https://support.google.com/analytics/answer/6004245?hl=en.

Google Analytics Remarketing

Our website uses the functions of Google Analytics Remarketing together with the cross-device functions of Google AdWords and Google DoubleClick which are supplied by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

This allows the advertising target groups created by Google Analytics Remarketing to be linked to the cross-device functions of Google AdWords and Google DoubleClick. In this way, interest-based, personalized advertising tailored to you based on your previous usage and browsing behavior on one device (e.g. mobile phone) can be displayed on one of your other devices (e.g. tablet or PC).

If you have given Google the respective consent, Google links your web and app browser history to your Google account. In this way, the same personalized advertising can be displayed on every device from which you log into your Google account.

To assist this function, Google Analytics collects the google-authenticated IDs of the users who are temporarily linked to our Google Analytics data in order to define and create target groups for cross-device advertising.

You can stop cross-device remarketing permanently by deactivating personalized advertising in your Google account under

https://www.google.com/settings/ads/onweb/.

For more information please refer to the Google data privacy policy here https://www.google.com/policies/technologies/ads/.

Google AdWords and Google Conversion Tracking

Our website uses the online advertising program Google AdWords which is supplied by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

We use Google AdWords’ conversion tracking feature. When you click on a Google ad, a cookie is set for conversion tracking. The cookies are small text files that the Internet browser creates on your computer. These cookies expire after 30 days at the latest and are not used to identify you. If you visit our website and the cookie has not yet expired, Google and Clandestino Spirits can see that you clicked on the ad and were taken to our page.

Google tells us the total number of users who clicked our ad and were passed on to our website with a conversion tracking tag. However, we do not receive any information through which we could identify you.

You can prevent cookies from being stored by selecting the appropriate settings in your browser, however, please note that you may not be able to use the full functionality of this website if you do so. You can also stop the tracking by deactivating the Google conversion tracking cookie in your browser user settings.

For more information please refer to the Google data privacy policy here https://policies.google.com/privacy.

SAS CI Discover

Our website uses functions provided by SAS Customer Intelligence Studio 360 which is supplied by SAS Institute Inc., 100 SAS Campus Drive, Cary, NC 27513-2414, USA.

SAS complies with the data privacy provisions of the “Swiss-U.S. Privacy Shield” agreement and is registered for the “Swiss-U.S. Privacy Shield” with the US Department of Commerce

(https://www.privacyshield.gov/participant?id=a2zt0000000GnvOAAS&status=Active)

These functions depend on the use of a cookie. They enable us to store your web and app user history (browsing, orders, etc.) and, if you are logged into our website, for this data of your earlier usage to be collated and processed on our website. In this way, we can customize, and display adverts and offers that are personalized for you and based on your interests. On each device from which you log in with your account details, we can display the same personalized advertising and offers.

For more information please refer to the SAS data privacy policy here https://www.sas.com/en_us/legal/privacy.html.

Google reCAPTCHA

Our website uses Google reCAPTCHA which is supplied by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

reCAPTCHA checks if the data entered on our website (e.g. in a contact form) was entered by a person or an automated program. To do this, reCAPTCHA automatically observes the visitor’s behaviour as soon as the visitor accesses the website. For its analysis, reCAPTCHA evaluates various information (e.g. IP address, how long the visitor stays on the website or the user’s mouse movements). The data collected for analysis are passed on to Google.

The reCAPTCHA analyses run fully in the background. Visitors are not made aware that this analysis is taking place. For more information please refer to the Google data privacy policy here

https://policies.google.com/privacy and https://www.google.com/recaptcha/intro/android.html.

Facebook Pixel

Our website uses Facebook Pixel, a user action tracking function supplied by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA.

Facebook Pixel allows website users’ behavior to be tracked after they click on a Facebook ad and are referred to our website. This allows the effectiveness of Facebook advertising to be tracked for statistical and market research purposes and future advertising to be optimized.

The data collected are anonymous to Clandestino Spirits - we cannot draw any conclusions as to your identity. However, your data are stored by Facebook and processed in order to link them to your user profile and so that Facebook can use the data for its own advertising purposes as explained in the Facebook Data Policy. This enables Facebook to display ads on Facebook pages and outside of Facebook. The use of these data cannot be influenced by Clandestino Spirits.

You can choose to opt out of the remarketing function for good by deactivating the “custom audiences” remarketing function in the ad preferences section under

https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.

To do this, you must be logged into Facebook.

If you do not have a Facebook account, you can deactivate user-based Facebook advertising at the European Interactive Digital Advertising Alliance website by visiting

http://www.youronlinechoices.com/uk/your-ad-choices.

For more information please refer to the Facebook data privacy policy at https://www.facebook.com/about/privacy/.

14. What other tools do we use?

Google web fonts

In order to display our fonts in a standardized way, our website uses web fonts provided by Google. Your browser loads the required web fonts into your browser cache so that text and fonts are displayed correctly.

For this, your browser must make contact with the Google servers. This alerts Google to the fact that your IP address is connected to our website. If your browser does not support web fonts, a standard font on your computer will be used.

For more information about Google web fonts please visit

https://developers.google.com/fonts/faq and refer to the Google data privacy policy: https://www.google.com/policies/privacy/.

Google Maps

Our website uses the Google Maps service via an API. It is supplied by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.If you use the functions of Google Maps, Google stores your IP address and usually transfers it to a Google server in the USA. Clandestino Spirits has no influence on this data transfer.

For more information please refer to the Google data privacy policy here: https://policies.google.com/privacy.

15. Which payment services and processes are available?

Stripe

All the usual payment methods can be processed via the Stripe e-payment platform interface. Stripe is supplied by Stripe Payments Europe, Ltd. Stripe meets all the usual security standards, and in particular the Payment Card Industry Data Security Standard (PCI DSS).

You will find more information in the data privacy policy of Stripe Payments Europe, Ltd here https://stripe.com/de-ch/privacy