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Stock Spirits Group Privacy Policy

We attach great importance to protecting and respecting privacy.

This Privacy Policy describes the way in which we handle personal data collected via the websites www.stock-polska.pl, www.stock-spa.it, www.stock.sk, www.stock.cz, www.stock.hr, www.stock.ba ("Websites").

In addition to the provisions of this Privacy Policy, the Code of Conduct, and the other documents referred to in this Policy apply.

Who are we and how to contact us?

We are a controller, within the meaning of Article 4 point 7 of GDPR, for personal data of Website users, including data of persons who apply for a job with Stock Group Companies using online forms.

You can contact us in any matters related with the use of your personal data, also when you wish to object to the processing of your personal data and exercise your rights in this respect. You can contact us by sending an email message to: gdpr@stockspirits.com

What do the terms used in this Policy mean?

Personal data

They mean data about living individuals identifiable on the basis of such data or on the basis of such data and other information held by the data controller (or data and information the controller can acquire).

They include information about Websites users, including persons applying for a job with Stock Group Companies using online forms.

Use of personal data

It means any operation carried out on personal data, including their collection from a given individual or obtaining them from other sources, as well as their recording, storage, modification, transfer and disclosure to other parties.

GDPR

It means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, 4.5.2016, pp. 1-88).

Stock

It means Stock Spirits Group PLC, Solar House, Mercury Park, Wooburn Green, Buckinghamshire, HP10 0HH, United Kingdom

Stock Group Companies,

They mean:

  • Stock Spirits (UK) Limited – Solar House, Mercury Park, Wooburn Green, Buckinghamshire HP10 0HH, UK
  • Stock Polska Sp. z o.o. with its registered office in Lublin, address: ul. Spółdzielcza 6, 20-402 Lublin
  • Stock Slovensko s.r.o. with its registered office in Bratislava, address: Galvaniho 7/A 821 04 Bratislava
  • Stock Plzeň – Božkov s.r.o. with its registered office in Plzeň – Božkov, address: Palírenská 641/2, 326 00, Plzeň – Božkov
  • Stock s.r.l. with its registered office in Milan, address: Via Tucidide, 56 bis - Torre 2, 20134 Milan
  • Stock BH d.o.o. with its registered office in Sarajevo, address: Džemala Bijedića 185/12, 71000 Sarajevo
  • Stock d.o.o. with its registered office in Zagreb, address: Josipa Lončara 3, 10090 Zagreb
  • Stock International s.r.o. with its registered office in Plzeň – Božkov, address: Palírenská 641/2, 326 00, Plzeň – Božkov

We, our, etc.

It means, depending on the context, Stock or Stock Group Companies

You, your

It means a living individual whose personal data is used by Stock or Stock Group Companies, namely a Website user, including a person applying for a job with Stock Group Companies using online forms.

How do we use your personal data?

We use your personal data in connection with maintaining the Websites for the purposes described below. Depending on the use made of data, either Stock or one of the Stock Group Companies will be the data controller – the party responsible for ensuring that data use is consistent with data protection laws.

Stock is the controller for personal data processed for the purposes of:

  • ensuring compliance with the legal restrictions on advertising and promotion of alcoholic beverages,  newsletter subscription,  optimising our website.
  • newsletter subscription,
  • optimising our website.

The local Stock Group Company is the controller for personal data processed for the purpose of:

  • responding to queries,
  • recruitment.

In addition, both Stock and Stock Group Companies – each within their own scope of responsibility – are controllers for personal data processed for the purpose of handling and resolving any requests, complaints and queries they receive in relation to the exercise of the rights granted to data subjects by GDPR.

Stock Group Companies are data controllers in the scope of the activity of the above mentioned relation to the following Websites:

www.stock-polska.pl

www.stock-spa.it

www.stock.sk

www.stock.cz

www.stock.hr

www.stock.ba

Ensuring compliance with legal restrictions on advertising and promotion of alcoholic beverages

We use personal data including information about the country of residence and date of birth provided by users to ensure that messages associated with advertising and promotion of alcoholic beverages are not addressed to minors. The legal basis under which we use your personal data for this purpose is our legal obligation (Article 6(1)(c) of GDPR) provided for by national laws which restrict advertising and promotion of alcoholic beverages.

Your data will be deleted as soon as the age verification has been successfully completed. The information about the successful passage of verification will be stored in the memory of your device via cookies no longer than until the end of the session browsing the Website (session cookies).

Responding to queries

We use your personal data including your email address, telephone number, and any data you choose to provide to us by filling out the query form, for the purpose of contacting you, responding to your query or taking other action in relation to your message. The legal basis under which we process your personal data for this purpose is our legitimate interest (Article 6(1)(f) of GDPR), which is to provide appropriate service to Website users, including customers.

However, if – when completing the query form – you decide to submit data we cannot use by invoking our legitimate interest, we will assume that by submitting the query, you agree for such data to be used for the above purpose. In such a case, the processing of your personal data will be based on your consent (Article 6(1)(a) of GDPR). You can withdraw your consent at any time without any consequences.

Your data will be stored for a period necessary to answer your query or to take other action in relation to your message, but for not longer than 1 year.

Newsletter subscription

We use your personal data including your name, surname and email address to send you a newsletter with updates about Stock Spirits Group PLC. We assume that by subscribing to the mailing list, you agree for your personal data to be used for this purpose. The legal basis for the processing of your personal data will be the performance of a contract (Article 6(1)(b) of GDPR).

Your data will be stored up to 2 years, but not longer than until you withdraw subscription.

Recruitment

We use your name, email address, telephone number, country of residence, information about your professional interests, and any other details you choose to share with us when enclosing your application documents (including your CV) or when completing the form. We use the above data to create a list of candidates for vacant jobs and to contact you in matters related to your recruitment process. The legal basis for the processing of your personal data for this purpose will vary depending on:

  • the legal basis for the employment you are seeking,
  • the scope of information you submit in the application documents and in the message form,
  • the provisions of the labour law effective in the individual countries.

Therefore, the legal basis under which we process your personal data for this purpose is our legal obligation (Article 6(1)(c) of GDPR), your consent (Article 6(1)(a) of GDPR) or legitimate interest (6(1)(f) of GDPR).

You can withdraw your consent at any time without any consequences. After withdrawing your consent, your data will not be used for recruitment.

Your data will be stored for 1 year from the date on which you submit your application using the online form.

Optimising our website and improving the comfort of using it

We use your personal data including your IP address, information about your operating system and browser and terminal equipment, as well as information about your activity on our Websites by recording and storing them in cookies. We use them to monitor how the website is used, customise its content, and improve the comfort of using it.

The legal basis for the processing of your personal data for this purpose is our legitimate interest (Article 6(1)(f) of GDPR), which is to optimise the operation of our Website through:

  • estimating our website traffic and identifying website use habits,
  • tailoring our website to user interests,
  • tailoring our website to users' terminal equipments
  • making search faster,
  • recognising returning users.

Your data will be stored for this purpose for 1 year.

You may block saving cookies on your device by changing your browser settings. However, this may limit the functionality of the website, preventing access to some of its sections. If you do not change your browser settings, our system will send cookies by default when you log on to our website.

You can remove cookies stored on your device by deleting the search history on your computer. You can also choose to browse our website “in private”, which will limit the range of data recorded by the computer.

Handling requests, complaints and queries related to the exercise of rights granted to data subjects

We use your personal data including your email address and any data you choose to provide to us in email for the purpose of handling and resolving your requests, complaints and queries related to the exercise of the your rights granted by GDPR, taking action in response to your request, complaint, or query, and communicating such actions to you.

The legal basis for the processing of your personal data for this purpose is our legal obligation arising under GDPR (Article 6(1)(c) of GDPR).

Your data will be stored for this purpose for 5 years from the date of request, complaint or query.

Who do we share your personal data with?

We share your personal data in the following cases:

  • when this is required by applicable laws, in particular at the request of the Public Prosecutor’s Office, the Police and other state authorities
  • when this is necessary in pursuit of our needs, in particular by:
    • law firms
    • other Stock Group Companies

In addition, your personal data may be shared with service providers - parties which process personal data at our request or on our behalf:

  • providers of ICT services, such as hosting, and supply or maintenance of computer systems and applications

Your personal data are shared with service providers under contracts whereby they are required to follow our instructions.

What rights do you have?

You have the right to:

  • request access to your personal data, confirmation that your personal data are used, copies of your personal data and information about the purposes of use, categories of personal data, categories of recipients to whom personal data has been or will be disclosed, the planned personal data retention period, and the source from which we have acquired the data (based on Article 15 of the GDPR).
  • request a copy of the personal data you have submitted to us and demand that it be provided to you or other party named by you in a commonly used, computer readable format – this applies to cases where we use your data on the basis of your consent or for the purpose of performing a contract (based on Article 20 of GDPR)
  • request that your data be rectified when incomplete or incorrect (based on Article 16 of GDPR)
  • request that all or some of your personal data be erased (based on Article 17 of GDPR) if:
    • you have withdrawn your consent, and we have no other legal basis for using the data,
    • Your personal data are no longer necessary in relation to the purposes for which they were collected or used,
    • You have filed an objection, and we have granted it,
    • Your personal information is used unlawfully
  • request restriction of the use of your personal data (pursuant to Article 18 of GDPR), i.e. demand that we stop using the data; however, this does not apply to the storage of your personal data where:
    • you contest the accuracy of your personal data; in such a case we will restrict use for a period needed to verify the accuracy of your data;
    • you contest the lawfulness of the use of your personal data by us;
    • we no longer need the data, but you need them to establish, exercise or defend legal claims;
    • you have objected to the use of your data – until we establish whether your objection is based on legitimate grounds.

You also have the right to:

  • object, on grounds related to your particular situation, against the use of your personal data on the basis of our legitimate interests. Following such an objection, we will consider whether – on account of your particular situation – the protection of your interests, rights and freedoms overrides the interests we pursue in using your personal data. If your objection proves to be justified and there is no other legal basis for the use of the data, we will erase them (pursuant to Article 21(1) of GDPR)
  • withdraw your consent to the use of your personal data at any time. Such withdrawal is without prejudice to the lawfulness of the use of the data on the basis of your consent prior to withdrawal (pursuant to Article 7 of GDPR)

If you have any questions, comments and requests regarding this Privacy Policy, wish to withdraw your consent or exercise your rights, please contact us You can contact us by sending an email to: gdpr@stockspirits.com

You are also entitled to file a complaint to the supervisory authority relevant for yours place of employment or residence.

How will you learn about a change to this Privacy Policy?

Any future changes to our Privacy Policy will be published on this website and, where appropriate, communicated to data subjects by electronic means, providing relevant information about intended changes and the date of their entry into force.