The following Privacy Policy is written by 1767 BEVERAGES Private Company, headquartered in Komninon 14 54631+30 231 026 7343 | Thessaloniki, Greece (hereinafter “1767”) as Data Controller of the personal data collected in our websites and Website for smartphones and tablets (hereinafter website and application are collectively referred to as “Application” and/or “Website”), provided directly by you or however received or generated by us as a result of us processing your registration to our Application.
1767 considers your privacy essential. We therefore ask you to read this information carefully in order to make a freely given, specific, informed and unambiguous choice when you are requested to give your personal data to log in to the websites or part of them and when your personal data are necessary to use services provided by the websites for example to purchase of products or services. In general, all the personal data (hereinafter “Personal Data” and/or “Data”) collected by 1767 through the websites or given by you when you use services provided by the websites (hereinafter “Services”) as fully described in the following section “C. Purposes of Personal Data Processing” of this Privacy Policy, will be processed lawfully and in a transparent manner in accordance with the principles stated in the current legislation on the protection of personal data, such as transparency, fairness, lawfulness, data minimisation, purpose limitation, accuracy, storage limitation, integrity and confidentiality.
This Privacy Policy is written on the basis of the transparency principle using a simple and not too legal language to increase the level of understanding of the statements given. This Privacy Policy is divided into sections (hereinafter collectively “Sections” and/or individually “Section”), each of them dealing a specific topic, so that you can immediately find what you are looking for and concentrate your attention on the topic of interest. The 1767 Website may contain links to other websites and/or smartphone Website. 1767 is not responsible for privacy practices or the content of such websites and/or smartphone Website.
Type of Personal Data Processed
Personal Data collected through the website are listed below.
Name, Last name, Contact Details and other Personal Data
When you create an account to log into the website 1767 may ask your personal information such as: name, last name, gender, contact details, month and year of birth, county or state and country of residence. In the same way, you may be asked to indicate other Data such as: shipping address, the choice of payment method and the age of the collector on the occasion of each purchase of goods and/or services; Data coming from your submission of texts, drawings or registration information, on the occasion of participation in competitions, promotions and initiatives of any kind. Further Personal Data may be collected during the management of each relationship through the website itself or may consist of those that you decide to provide to 1767 through the use of the website / Customer Service area of the website.
Some sections of the website can include free text fields in which it is possible to provide 1767 with information that may contain Personal Data. Being free fields, you may choose to communicate (even inadvertently) particular categories of Personal Data, such as those revealing political opinions, religious or philosophical beliefs, or union membership, as well as genetic data, biomedical data which can permit to uniquely identify a specific person, data related to health or sex life or sexual orientation.
1767 asks you not to disclose any of these types of data, unless you consider it strictly necessary to pursue the request you forward to us. Since the indication of such information is, as said, totally optional, if you choose to do so, 1767 could process such data only with your explicit consent and in compliance with the current legislation. 1767, therefore, underlines the importance of expressing your explicit consent to the processing of these particular categories of Personal Data in case you decide to share them with 1767.
Personal Data of Third Parties
As mentioned in the previous paragraph, by providing in the websites free text fields in which it is possible to forward any type of message, these could in fact contain Personal Data relating also to other people. In all cases in which you decide to share such Data, you will be considered a self-appointed Data Controller and, as such, you will have to assume all the relevant legal obligations and responsibilities. Therefore, in this regard, you undertake to hold 1767 harmless from any dispute, claim, request for compensation for damage from data treatment etc. that could reach 1767 from people whose Personal Data have been forwarded by you in violation of the applicable rules on the protection of Personal Data.
As, in such cases, 1767 does not collect this information directly from the data subjects (but indirectly from you), you guarantee that this specific treatment can be based on the consent of these data subjects or on another suitable lawful basis that legitimizes the processing of the information in question.
Navigation Data and Cookies
The computer systems and software used to run the websites acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected by 1767 to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow data subjects to be identified. This category of data includes the IP addresses or domain names of the computers used by the users connecting to the website, the addresses in URI (Uniform Resource Identifier) notation of the requested services, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (good result, error, etc.) and other parameters related to the operating system and the user’s computer.
These data are used for the sole purpose of obtaining anonymous statistical information on the use of the website, to check its correct functioning and to identify anomalies and/or abuses. Except in cases where the data are used to ascertain responsibility in the event of hypothetical computer crimes against the website or third parties, these data do not persist for more than seven days.
Information on the use of cookies is available in our Cookie Declaration that we invite you to read by clicking the following link Cookie Declaration
Personal Data Processing of Children below the Age of 16 Years
Children aged less than 16 years old or, in accordance with national local laws below the age set to directly collect the consent to the processing from children but in any case not less than 13 years old,– are not allowed to register on the websites to access the sections reserved for registered users.
Users who do not declare the age will be considered and treated as under 16 or, in accordance with the laws of the country declared at registration, as minors below the minimum age established to grant consent to the processing of data and therefore they not will be able to access the sections reserved for registered users of the websites.
Children under the age of 18 are not permitted to purchase goods or services from our Website.
Purposes of the Personal Data Processing
We will process your Personal Data for the following purposes:
allowing the execution of operations strictly connected and instrumental to the management of relationships with you, such as managing the response to queries received via the contact forms; enabling restricted sections of the websites; assisting you in case you lose the login/password data of your personal account on the websites; executing contracts for the sale of goods and/or services, managing and fulfilling orders via E-Commerce platforms; allowing you to consult the chronology of your purchases; ensuring the delivery of the purchased products and tracking your order status; allowing you to participate in games, initiatives, competitions and prize events (Services Provision);
allowing the correct execution of the contractual obligations we have assumed towards you and vice-versa (Contractual Obligations);
complying with laws, regulations and EU legislation or with provisions issued by authorities empowered by law and provisions issued by Supervisory and Control Bodies, as well as allowing tax and accounting compliance (Legal Compliance);
carrying out information activities about our products and/or services as well as promotional, commercial, marketing campaigns and market research through the use of automated systems without operator intervention (for example, e-mail), but also through traditional methods of contact, such as the postal service; performing customer satisfaction surveys (by sending questionnaires, conducting surveys or conducting surveys) (Marketing)
sending you, if you are using or have used a service on an Application or if you are buying or you have bought a product or a service through the website, direct marketing and promotional communication via e-mail about similar products or services (Soft Spam);
setting-up groups of users by processing the data provided by our users so that we don’t send generalized commercial and promotional communications to all users in an indistinct way. This enables us to segment users, creating groups based upon common features for example, on the country of origin, language, gender, previous purchases, etc. This allows us to send commercial communications – through the use of automated systems without the intervention of the operator (for example, e-mail), but also through traditional methods of contact, such as the postal service – that are the most relevant and least invasive possible, limiting as far as possible the circumstance that you receive messages not of your interest (Profiling).
Lawful Basis for Processing Personal Data, Mandatory/Discretionary Provision of Personal Data and Consequences in case of not providing
The lawful basis for processing the Personal Data, in accordance with the purposes set in the earlier Section of this Privacy Policy (“Purposes of the Data Processing”), is as follows. The provision of Personal Data and the related processing for the purposes related to Services Provision and Contractual Obligations, is strictly functional to the performance of the requested service and the correct execution of the contractual relationship with you and therefore they constitute a necessary condition for the establishment of the contractual relationship itself and the lawful basis of the processing. Consequently, failure to provide the Personal Data requested for this purpose, or the inaccuracy of the data provided, will make it impossible for 1767 to carry out the service and the contractual relationship and would legitimize 1767 to refuse to carry it out.
The provision of Personal Data, and the related processing for purposes related to Legal Compliance, is necessary for 1767 in order to comply with the related legal obligations. When you provide your Personal Data to 1767, we must process them in accordance with applicable laws which may include the storage and communication to the competent authorities for compliance with tax, customs or other obligations.
The provision of Personal Data, and the related processing of such data for the purposes related to the Marketing activity, is based on your explicit consent collected through a specific checkbox. You are not forced to provide such consent to 1767 and, if you do so, you are free to withdraw it at any time without suffering any consequence (other than not receiving marketing communications from 1767). You can withdraw your consent for this purpose by following the instructions contained in the “Data Subjects Rights” section of this Privacy Policy.
The provision of Personal Data, and the related processing, for the purposes related to the activity of Soft Spam is based on the legitimate interest of 1767 to send marketing communications via e-mail regarding products and services similar to those you have already used or purchased through the website. You can stop the receipt of these communications without suffering any consequence (other than that of not being able to receive further communications of this kind by 1767) using the link at the bottom of each of the e-mails received for that purpose.
The provision of Personal Data, and the related processing, for the purposes related to the Profiling activity is based on your explicit consent collected through a specific checkbox. You are not obliged to provide such consent to 1767 and, if you do so, you are free to revoke it at any time without suffering any consequence (other than not being able to benefit from the personalization of 1767’s commercial offers). You can withdraw your consent for this purpose by following the instructions provided in the “Data Subjects Rights ” section of this Privacy Policy.
Personal Data Sharing
The Personal Data will be made known to the 1767 staff in charge of the development and management of the websites that is authorized to process them for the purpose of achieving the aforementioned purposes and who are committed to confidentiality or otherwise have received an appropriate legal obligation to confidentiality.
Personal Data may be shared, used and transferred within the companies belonging to the 1767 for accounting and administrative purposes.
Personal Data will be made known to third parties, appointed as Data Processors, as they process Data on behalf of 1767 (for example, companies responsible for managing and processing sales orders, suppliers with whom it is necessary to interact for the Service Provision such as hosting providers, platform providers for sending e-mails or, again, suppliers who perform technical maintenance activities including the maintenance of network equipment and electronic communications networks, suppliers who develop interactive games and competitions, software developers for the payment systems, suppliers providing the technological platform and payment gateway for orders for products in the e-payments area, payment service providers for e-payments activities).
Personal Data may be shared with third parties with whom 1767 has ongoing contractual relationships concerning services functional to the performance of the activity (such as couriers for the delivery of products, audit firms, persons, companies or professional firms that provide assistance and advice on the subject, administrative, legal, tax, financial and credit recovery firms relating to the provision of the Services).
Finally, Personal Data will be communicated when requested to the competent taxation offices, or to other public bodies, according to the provisions of the laws in force.
Personal Data is not intended for publication or dissemination.
Personal Data Transfer
Given the international presence of 1767, some of your Personal Data may be shared with recipients, referred to in the previous paragraph, which could be found in countries outside the EU or the European Economic Area. 1767 ensures that the processing of your Personal Data by these parties will be in compliance with applicable law. Therefore, the transfers will be made with adequate guarantees, such as adequacy decisions, models of Standard Contractual Clauses approved by the European Commission or other guarantees considered adequate.
More information is available by writing to 1767 at the following address: info@1767.com
Personal Data Retention
The Personal Data processed for the purpose of Services Provision and Contractual Obligations will be retained by 1767 for the time strictly necessary for the execution of the requested service and for the correct execution of the contractual relationship with you. As this Personal Data is processed to provide you with the Services and allow the execution of the contractual relationship, 1767 may keep them for a longer period, in particular for what may be necessary in order to protect the interests of 1767 against possible claims arising from the Services Provision.
In any case, 1767 specifies that the retention time related to any orders and purchases you have made is equal to 24 months. 1767, moreover, specifies that it will keep your authentication credentials to the website Services up to 54 months from the date of the last login. At the end of this period the data will be made anonymous.
Your requests, and the data contained in them, collected through the Contacts/Customer Service area of the websites will be maintained for one year from the closure of the request in order to allow 1767 to handle any additional requests received after closure. At the end of this period the Data that permit the identification, even indirect, of a physical person (such as name, surname, e-mail) will be made anonymous and maintained, only in the form of aggregated data, for statistical purposes.
The Personal Data processed for the purposes of Legal Compliance will be retained by 1767 for the period envisaged by specific legal obligations or applicable legislation.
The Personal Data processed for the purposes of Marketing and Profiling will be retained by 1767 until the revocation of the consent you have given and renewed periodically. Once your consent is withdrawn, 1767 will no longer use your Personal Data for such purposes, but may retain them, particularly as may be necessary in order to protect 1767’s interests from possible liability based on such processing.
1767 informs you that, in order to respond to the principle of limitation of conservation, the data processed for the purposes of Marketing and Profiling will in any case be maintained for a maximum of 54 months from the date of the last login in accordance with the logic used for the retention of authentication credentials to the website Services referred to above.
The Personal Data processed for the purpose of Soft Spam will be kept by 1767 until you object to the process through the link found at the bottom of each of the Soft Spam e-mails sent.
Data Subject Rights
At any time you are entitled, as Data subject, to:
request access to your Personal Data, (and/or a copy of such Personal Data), as well as further information on the current treatment of them;
request the correction or updating of your Personal Data processed by 1767, where they are incomplete or out of date;
request the deletion of your Personal Data from the 1767 databases, where you deem the processing unnecessary or illegitimate;
request the limitation of the processing of your Personal Data by 1767, where you believe that your Personal Information is not correct, necessary or is unlawfully processed, or if you had opposed its processing;
exercise the right to data portability, i.e. to obtain a copy of the Personal Data supplied to 1767 that relates to you in a structured format, for common use and readable by an automatic device, or to request transmission to another Data Controller;
oppose the processing of your Personal Data, using a legal basis relating to your particular situation, which you believe should prevent 1767 from processing your Personal Data;
revoke your consent for the purposes of Marketing and Profiling and to oppose the processing for the purpose of Soft Spam. We remind you that the express consent for forwarding promotional communications referred to the Marketing and Profiling purposes extends not only to communications sent through the use of automated systems without the intervention of the operator (for example, e-mail), but also the traditional methods of contact, such as the postal service. It is always possible to withdraw consent to the treatment, even in a disjointed way, for example, deciding to receive such communications only through postal service and not through automated systems such as e-mail
Please note that the Personal Data you provided to 1767 may be changed at any time, through the “modify data” section of the websites or by writing to: info@1767.com. You may exercise the above rights by means of the methods indicated above.
We inform you that for the Marketing purposes you can revoke and terminate at any time the sending of this commercial information, by writing to the e-mail address indicated above or, in the case of communications received through IT tools, following the procedure indicated at the bottom of the communication (via the “Unsubscribe” button).
You can also stop receiving Soft Spam using the appropriate link at the bottom of each e-mail received (via the ” Unsubscribe ” button).
Consent for the purpose Profiling can be revoked by changing, at any time, the preferences of the user profile that can be created on the website or by writing to the e-mail address indicated above.
1767 also informs you that you always have the right to lodge a complaint with the competent Supervisory Authority (for example that of the State in which you have your habitual residence, in Italy the Guarantor for the Protection of Personal Data) if you believe that the processing of your data is contrary to the legislation in the field of personal data protection actually applicable.
Privacy Policy Amendments
This Privacy Policy version 1.0 is effective from 25 May 2018. 1767 reserves the right to modify or simply update its content, in part or completely, also due to changes in the applicable legislation. 1767 will be able to inform you of these changes as soon as they are introduced and they will be binding as soon as they are published on the website. 1767 invites you to visit this section regularly to get to know the most recent and updated version of the Privacy Policy in order to be always updated on the Personal Data collected and on the use that 1767 makes of them.
Contact Us
If there are any questions regarding this privacy policy you may contact us using the information below.
