COLLECTION AND USE OF PERSONAL DATA

 

 

1. WHAT INFORMATION DO WE COLLECT?

We obtain personal data about you when you decide to communicate it to us, for example, when you contact us by mail or register on our sites to benefit from certain services. In some cases, it is also possible that you have previously provided personal data to Spirits Media Group (for example, if you are a former employee).

When you decide to sign up or log in to Spirits Media Group sites through a third-party sign-in service that authenticates your identity and connects your social network credentials (such as LinkedIn, Google, or Twitter) to the site, we collect from the provider of the social network the data and contents necessary for the registration or connection that you have authorized, such as your name and email address. The other data we collect depends on the privacy settings that you set up with your social network provider, so we encourage you to review the privacy policy for that service.

By registering and/or providing personal data to Spirits Media Group, you also agree to the use of such personal data in accordance with this Online Privacy Statement. We do not use your personal data for any other purpose unless we obtain your consent for it, or if the law or professional standards permit or require it. For example, if you register with Spirits Media Group and provide data about your preferences, we will use them to personalize your experience.

If you sign up or sign in with a third-party SSO service, we will also be able to identify you as a single user on all devices you use, to personalize your usage experience on all Spirits Media Group sites you are visiting. If you have sent us your resume (CV) to apply online for a job offer within Spirits Media Group, we will use the personal data you have provided to study your application and/or offer you relevant job offers.

In some cases, when you sign up for certain services, we may temporarily keep your email address until we receive confirmation of the information you have provided to us by email (i.e., when we send an email to the address provided during your registration to confirm your subscription).

2. THE LEGAL BASIS APPLICABLE TO THE PROCESSING OF YOUR PERSONAL DATA

In general, Spirits Media Group collects only the personal data that is necessary to answer your requests. When we request additional optional data, you are informed when it is collected. The law in Europe allows us to process personal data, provided we have a legal basis for doing so. We are also required to tell you the nature of it.

Therefore, when we process your personal data, we will rely on one of the following legal bases:

• Execution of a contract: when the processing of your personal information is necessary to fulfill our obligations under a contract to which you are a party.
• Obligation imposed by law: when we are required to process your personal data to comply with a legal obligation, including archiving in order to comply with our tax obligations, or communication of information to a public body or to an enforcement authority.
• Legitimate Interests: We will treat your personal data if it is in our legitimate interest to do so, in order to best manage the business of our company in accordance with the law, and to the extent that this interest does not exceed your own interests.
• Your consent: In some cases, we will ask you for specific permission to process some of your personal information, and we will only process it for the purposes for which you consented. You may withdraw your consent at any time by contacting the Data Protection Officer at Spirits Media Group ([email protected]).

Examples of “legitimate interests” referred to above include:

• Providing information and/or services to visitors to our sites or information on employment opportunities;
• Preventing fraud or criminal activity and safeguarding our computer systems (IT);
• Customizing your online user experience and improving the performance, usability, and efficiency of Spirits Media Group’s online presence;
• Measuring the effectiveness of our marketing activities;
• Complying with our corporate social responsibility obligations;
• Exercising our fundamental rights within the European Union, in accordance with Articles 16 and 17 of the Charter of Fundamental Rights, including our freedom of enterprise and our right to property.

In some cases, and to the extent permitted by law, the personal data we collect may include special categories of data, such as information related to diversity (e.g., race, ethnic origin, religious beliefs, trade union membership), health data, or data relating to offenses.

3. AUTOMATIC COLLECTION OF PERSONAL DATA

In some cases, Spirits Media Group and its providers use cookies, web beacons, and other technologies to automatically collect certain types of data when you visit our sites online, and as part of emails we may exchange. Collecting this data allows us to personalize your online experience, improve the performance, usability, and efficiency of Spirits Media Group’s online presence, and measure the effectiveness of our marketing activities.

3.1 IP ADDRESSES

An IP address is an address assigned to your computer each time you access the Internet. This allows computers and servers to recognize and communicate with each other. We may collect the original IP addresses of our visitors for security and diagnostic purposes. We may also use this aggregated data to analyze trends and performance of our sites.

3.2 COOKIES

We may store cookies on your computer or connected device when you visit our sites online. This allows the site to remember your computer or device, and allows cookies to serve several purposes.

Some of our sites display an information banner that requires your consent to collect cookies. In case of refusal, we will not be able to track your connected computer or device for marketing purposes. However, certain cookies (such as “user input” cookies) are necessary for some functions and are not blocked by the banner. Your decision is saved in a cookie kept for 90 days.

You can revoke your choice at any time by deleting your browser’s cookies. Please note, however, that rejecting cookies may limit your use of certain features on our sites.

 

The cookies used on our sites include:

• Performance: Cookies to improve compatibility and loading speed.
• Security: Cookies to keep devices connected during visits to restricted areas.
• Preferences: Cookies to remember user preferences such as language.
• Analytics: Tools like Google Analytics to help us understand how visitors use our site.
• Feedback: Cookies for surveys or feedback collection to ensure visitors are not invited multiple times.
• Sharing on social networks: Cookies to facilitate sharing content on social networks.

3.3 GOOGLE ANALYTICS
Spirits Media Group uses Google Analytics. You can find more information about Google Analytics’ privacy practices at http://www.google.com/analytics/learn/privacy.html.

3.4 WEB BEACONS
Spirits Media Group may use web beacons to monitor website and email interaction. You may opt out of such data collection by disabling cookies.

3.5 GEOLOCATION TOOLS
Spirits Media Group may collect geolocation data from your computer or mobile device to provide location-based services or information.

4. WIDGETS AND SOCIAL NETWORK APPS
Spirits Media Group sites may include features for sharing through third-party social media platforms. These applications may collect data about your use of our sites, governed by the data protection policies of the social media providers.

5. CHILDREN

Spirits Media Group does not knowingly collect personal data from children under the age of 13.

SHARING AND TRANSFER OF PERSONAL DATA

1. TRANSFER WITHIN THE ENTITIES OF SPIRITS MEDIA GROUP

We may share your personal data with other entities within Spirits Media Group to fulfill legal obligations or for business purposes.

2. TRANSFER TO THIRD PARTIES
We do not share your personal data with unaffiliated third parties except when necessary for business purposes, or as required by law.

3. CONSENT

You may be asked to provide personal data to access certain services or communications. You can unsubscribe at any time by following instructions in communications.

4. YOUR RIGHTS

If Spirits Media Group processes your personal data, you have the right to request access, rectification, objection, deletion, restriction, and portability of your data. You can exercise these rights by contacting us at [email protected].

5. SECURITY AND INTEGRITY

We have implemented reasonable security procedures to protect your personal data from unauthorized access, loss, or misuse.

6. LINKS TO OTHER SITES

If you navigate between Spirits Media Group websites without logging out, you agree to the use of your personal data under this privacy policy.

7. AMENDMENT OF THIS DECLARATION

Spirits Media Group may periodically update this privacy policy. The last updated date will be noted on this page.

8. ISSUES RELATED TO THE POLICY AND ITS APPLICATION

For any questions, comments, or complaints about this privacy policy, please contact us at [email protected].