We are committed to protecting your privacy and your rights! We make every effort to be GDPR compliant.
This Privacy Notice explains in detail the types of personal data we collect about you when you interact with us. It also explains the way we collect it and how we store and handle that data, and keep it safe.
We know that there’s a lot of information here but we want you to be fully informed about your rights, and how we use your data.
We hope the following sections answer any questions you have but if not, please do get in touch with us.
It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.
Who We Are
Whisky.lu is a website owned by The Luxembourgish Cask Selection, a company registered in Germany.
For simplicity throughout this notice, “this Website”, “we”, “us” means the ownership of The Luxembourgish Cask Selection and its brands, including Whisky.lu.
Explaining the Legal Bases We Rely On and Operate Under
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you place an order with us and purchase an item for home delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier.
If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity affecting us to law enforcement.
In specific situations, we require your data in order to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will use your purchase history to send you or make available personalized offers.
We also may use your data for our own research, e.g. combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services.
We will also use your email address details to send you marketing information by email, telling you about products and services that we think might interest you.
What Sort of Personal Data We Collect
We collect information so that we can provide the best possible experience when you buy our products or utilize our services. Much of what you likely consider personal data is collected directly from you, such as:
- If you have a web account with us: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password
- Details of your interactions with us through email, online or over the phone. For example, we collect your name and email when you request assistance from our customer support team. We also collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, gift list and wish list choices, voucher redemptions, brands you show interest in, web pages you visit and how and when you contact us
- Details when you complete contact forms or request newsletters or other information from us (for example your name or email)
- Copies of documents you provide to prove your age or identity where the law requires this. (including your passport and driver’s license). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality
- Details of your shopping preferences. For example, which of our online shops you prefer to visit and where you redeem your vouchers
- Details of your visits to our websites and which site you came from to ours
- Personal details which help us to recommend items of interest. We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us. Of course, it’s always your choice whether you share such details with us
- Payment card information. We do not store this on our servers, it is passed in a secure manner onto the payment gateways that we use
- Your comments and product reviews
- To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered
- Cookies and similar technologies on our websites allow us to track your browsing behavior, links clicked, items purchased, your device type, and to collect various data, including analytics, about how you use and interact with our products or services. This allows us to provide you with more relevant product offerings, a better experience on our sites and mobile applications, and to collect, analyze and improve the performance of our Services. We may also collect your location (IP address) so that we can personalize our offerings. For additional information, and to learn how to manage the technologies we utilize, please visit our Cookies Policy
- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback
- Data about usage of our products and services is automatically collected when you use and interact with our products or services, including metadata, log files, cookie/device IDs and location information. This information includes specific data about your interactions with the features, content and links (including those of third-parties, such as social media plugins) contained within the Services, Internet Protocol (IP) address, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data, information about devices accessing the products or services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and error data, and some of this data collected might be capable of and be used to approximate your location.
- Supplemented Data may be received about you from other sources, including publicly available databases or third parties from whom we have legally and lawfully acquired data, in which case we may combine this data with information we already have about you so that we can update, expand and analyze the accuracy of our records, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
When We Collect Your Personal Data
We collect and store your personal information in order to provide you with the services or products that you buy from us. Using the below data collection mechanisms, we collect and keep the following personal information from you:
- Online order forms – your name, billing and shipping addresses, country, phone, and email address, orders and receipts and details of your shopping preferences. We use this information so we can send you your order or provide you with our services. We also use it for our own sales research and reporting. For your security, we’ll also keep an encrypted record of your login password.
- User registration forms – your name, username, and password. We use this information so we can authenticate you and log you in our system
- Newsletter registration forms – your name, email address, IP address, and sometimes country. We use this information so we can occasionally send you emails and notifications
- Comments forms – your name and email address and any details of your interactions with us you decide to share when you contact us. We use this information so we can publish your comments on our website and occasionally send you emails and notifications
- Contact forms – your name and email address and any details of your interactions with us you decide to share when you contact us. We use this information in order to reply to your questions and occasionally send you emails and notifications
- Analytics and traffic log solutions – we use Google analytics and they collect information like IP address, device information, cookies, visit duration and tracking, mouse and swipe actions, etc. We do not use, collect, nor keep this information
- Security tools and plugins – IP address, device information. We use this information to prevent unauthorized access, hacker attacks, and other security breaches. We periodically delete all this information and we do not store it for more than 4 months.
- Social Media – your social media username, if you interact with us through those channels. We use this to help us respond to your comments, questions or feedback.
- Direct communication with you – sometimes we may need you to verify your identity before we can fulfill your order. In those cases, we may ask you for copies of documents to prove your age or identity (including your passport and driver’s license). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
Other times when we collect your data:
- When you visit any of our websites, and use your account to buy products and services, or redeem vouchers online.
- When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).
- When you create an account with us.
- When you engage with us on social media.
- When you sign up as an Affiliate
- When you contact us by any means with queries, complaints etc.
- When you ask us to email you information about a product or service.
- When you enter prize draws or competitions.
- When you book any kind of appointment with us or book to attend an event, for example a class, with us
- When you choose to complete any surveys we send you.
- When you comment on or review our products and services.
- When you fill in any forms. For example, when you use our contact forms
- When you’ve given a third party permission to share with us the information they hold about you.
How and Why We Use Your Personal Data
We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you. We then use this to offer you promotions, products and services that are most likely to interest you. The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
You can always change the way we store your data or delete your data stored with us, just remember that if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for. For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.
We strongly believe in both minimizing the data we collect and limiting its use and purpose to only that (1) for which we have been given permission, (2) as necessary to deliver the products and services you purchase or interact with, or (3) as we might be required or permitted for legal compliance or other lawful purposes.
Here’s how we’ll use your personal data and why:
- To process any orders that you make by using our websites. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations. For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, guarantees and so on.
- To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
- To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest. For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent logins from unexpected locations.
- To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
- With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, and telephone our customer info centers about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
- To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
- To display the most interesting content to you on our websites or apps, we’ll use data we hold about your favorite products, services and so on. We do so on the basis of your consent to receive notifications and / or for our website to place cookies or similar technology on your device. For example, we might display a list of items you’ve recently looked at, or offer you recommendations based on your purchase history and any other data you’ve shared with us.
- To administer any prize draws or competitions which you enter, based on your consent given at the time of entering.
- To improve and optimize the operation and performance of our products and services
- To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests. For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having.
- To collect aggregate statistics about use of our products and services
- To understand and analyze how you use our products and services and what products and services are most relevant to you.
- To comply with our contractual or legal obligations to share data with law enforcement. For example, when a court order is submitted to share data with law enforcement agencies or a court of law.
- To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
Of course, you are free to opt out of receiving these requests from us at any time by updating your preferences in your online account
- To build a rich picture of who you are and what you like, and to inform our business decisions, we’ll combine data captured from across our websites, third parties and data from publicly-available domains and lists as we have described in the section What Sort of Personal Data do we collect? We’ll do this on the basis of our legitimate business interest. For example, by combining this data, this will help us personalise your experience and decide which content to share with you. We also use anonymised data from customer purchase histories to identify trends in different areas of the country. This may then guide which products we display in particular stores.
- To process your booking/appointment requests where applicable
- For website analytics. We use multiple web analytics tools provided by service partners such as Google Analytics, to collect information about how you interact with our website or mobile applications, including what pages you visit, what site you visited prior to visiting our website, how much time you spend on each page, what operating system and web browser you use and network and IP information. We use the information provided by these tools to improve our offerings. These tools place persistent cookies in your browser to identify you as a unique user the next time you visit our website. Each cookie cannot be used by anyone other than the service provider (ex: Google for Google Analytics). The information collected from the cookie may be transmitted to and stored by these service partners on servers in a country other than the country in which you reside. Though information collected does not include personal data such as name, address, billing information, etc., the information collected is used and shared by these service providers in accordance with their individual privacy policies. You can control the technologies we use by managing your settings through our Cookies Policy or the ‘cookie banners” that may be presented (depending on URL of website visited) when you first visit our webpages, or by utilizing settings in your browser or third-party tools, such as Disconnect, Ghostery and others.
Sometimes, we’ll need to share your details with a third party who is providing a service (such as delivery couriers). We do so to maintain our agreement with you. Without sharing your personal data with them, we’d be unable to fulfil your request.
We may share your personal data with affiliated companies within our corporate family, with third parties with which we have partnered to allow you to integrate their services into our own Services, and with trusted third party service providers as necessary for them to perform services on our behalf, such as:
- Processing credit card payments
- Serving advertisements
- Conducting contests or surveys
- Performing analysis of our Services and customers demographics
- Communicating with you, such as by way email or survey delivery
- Customer relationship management.
We only share your personal data as necessary for any third party to provide the services as requested or as needed on our behalf. These third parties (and any subcontractors) are subject to strict data processing terms and conditions and are prohibited from utilizing, sharing or retaining your personal data for any purpose other than as they have been specifically contracted for (or without your consent).
And of course we use your personal data to communicate with you. We may contact you directly or through a third party service provider regarding products or services you have signed up or purchased from us, such as necessary to deliver transactional or service related communications. We may also contact you with offers for additional services we think you’ll find valuable if you give us consent, or where allowed based upon legitimate interests. You don’t need to provide consent as a condition to purchase our goods or services (with some exceptions but these will be clearly marked and explained where applicable).
Who We Share Your Personal Data With
We sometimes share your personal data with trusted third parties. Or we use tools and plugins, provided by 3rd parties, who have access to your personal data. For example we may use Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. See our Cookies Notice for details.
Companies and plugins that we use include Google (Analytics and AdWords mostly), MailPoet, Mailchimp, Facebook, Twitter, Pinterest, Instagram, Yahoo, Bing, YouTube, etc. This means that these tools and plugins have access to some of your personal data (e.g. ip addresses, device information, access information, cookies, visit duration and tracking, mouse and swipe actions). While we make every effort to ensure we use these tools and plugins in a GDPR compliant way, it is ultimately these tools and plugins owners responsibility for the correct handling of the personal data they collect thru our website
Here’s the policy we apply to and request from those organizations to keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in our contract with them.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Although we share this information with them, we explicitly do not store any of your analytics or traffic information.
How Long We Keep Your Personal Data
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. At the end of that retention period, your data will either be deleted completely or anonymized, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Some examples of customer data retention periods:
Orders and Accounts
When you place an order or create an account with us, we’ll keep the personal data you give us for five years so we can comply with our legal and contractual obligations as well as for accounting and tax purposes.
If your order included a warranty, the associated personal data will be kept until the end of the warranty period.
Newsletter, comments, and contact forms
We store your newsletter, comments, and contact form related info for about 5 years, which is the period of time when we redesign our site, and that is when we delete that old information.
How We Protect Your Personal Data
We know how much data security matters to you. With this in mind, we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our websites and apps using ‘https’ technology. All your sensitive information (e.g. your passwords if you had chosen to create an account with us) is stored securely and encrypted. All our communication with you through our website are done over a secure and encrypted 256 bit or higher SSL connection.
Access to your personal data is password-protected, and sensitive data such as payment card information) is securely sent over to the payment gateways that we use. We do not collect and keep your credit card, PayPal or other payment information, that is processed by the payment gateways we use.
We regularly monitor our systems for possible vulnerabilities and attacks, and we carry out testing periodically to identify ways to further strengthen security.
Where Your Personal Data May Be Processed
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA). The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.
We operate in several countries across several continents, so it is likely that your personal data might be transferred to a third-party data processors in countries that are outside the EEA such as Australia or the USA. For example, this might be required in order to fulfil your order, process your payment details or provide support services.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish to receive more information about this, please contact us.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
What Are Your Rights Over Your Personal Data
We will always get your clear consent before we collect your data. We do not collect any data from children, if you are under 18 years of age, you are not authorized to use this website.
We will not send you any unsolicited email unless you have given us your clear consent that you would like to receive emails from us. You have the option to opt-out of receiving any emails from us at any time. To do so, simply let us know.
You have the right to:
- Request access to the personal data we hold about you, free of charge in most cases.
- Request correction of your personal data when incorrect, out of date or incomplete.
- Withdraw consent for us to contact you
- Request to be forgotten
- Request we stop using your personal data for direct marketing (either through specific channels, or all channels)
- Request that we stop any consent-based processing of your personal data after you withdraw that consent.
- Know if and when data breaches of your personal data occur
You can contact us to request to exercise these rights at any time as follows:
To Access your personal data
We let our users access their data, and take it with them anywhere else, if they want to. Please download and complete this data request form if you wish to gain access to the personal data that we hold about you as an individual. You can then email the form to us. This form provides everything you need to know about sending in a request.
To correct your personal data
To ask for your information that you shared with us to be amended, please update your online account or contact us and we will do it for you. If we choose not to action your request we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We will then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorized a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
The right to know about data breaches
We always inform all our users of any data breaches within 24 hours after we discover that they had occurred. These users include all groups of people from whom we collect and have contact info — regular website users, customers, contact form entries, and even commenters. So far we have had zero data breaches.
The right to be forgotten
We provide our users with the ‘right to be forgotten’. You can delete your personal data stored in our system at any time. To do so, please fill out the following form and email it to us. In some cases we are required by law to retain your data, for example your order information for accounting and tax purposes, etc.
To easily access, view, update, delete or port your personal data (where available), or to update your subscription preferences, please sign into your Account and visit “Account Settings.” In some cases, that functionality may not be available under your Account. In those cases, simply contact us with your request and we will execute it for you. If you are unable for any reason to access your Account Settings or our Privacy Center, you may also contact us by one of the methods described in the “Contact Us” section below.
How Can You Stop the Use of Your Personal Data for Direct Marketing
There are several ways you can stop direct marketing communications from us:
- Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
- If you have an account, log in into your account, visit the ‘My Account’ area and change your preferences.
- Contact us and describe your request, we will be happy to handle it personally for you
Age and Usage Restrictions
Our products and services are available for purchase only for those over the age of 18. Our Services are not targeted to, intended to be consumed by or designed to entice individuals under the age of 18. If you know of or have reason to believe anyone under the age of 18 has provided us with any personal data, please contact us.
We don’t use profiling in any of our services. We provide the same service to every one of legal age and stature. We do not store nor are interested in any information on health, race, sexual orientation, religion, political beliefs, and anything else that is not directly related to the services we provide.
Additional Notes for Non-EU Users
This Privacy Notice is available in English and sometimes other languages across our websites. In case of any dispute about its meaning, the English version will take precedence.
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes. Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes. This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your personal data on servers in other countries.
We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.
We’ll ensure that any third parties process your personal data only in accordance with their legitimate interests. These third parties may be subject to different laws from those which apply in your country of residence. Please note that we do not take active steps to ensure that any overseas recipient of your personal data complies with the laws which apply in your country.
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it. If you have any questions that haven’t been covered, please contact us and we will be pleased to help you
We will respond to all requests, inquiries or concerns within twenty (20) days.