LAST UPDATED: JUNE 2021
In the course of its operations, Sir Edmond B.V. (hereafter: “Sir Edmond”) collects and processes personal data provided to it by its customers and other relations, as well as personal data obtained from visits to and the use of its website (https://www.siredmondgin.com/). Sir Edmond processes personal data with the utmost care and in accordance with the applicable regulations, in particular the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This privacy statement sets out the relevant grounds in this regard.
Categories of personal data
Personal data is collected directly by Sir Edmond from clients and other relations for the performance of its services and from visitors to its website to the extent necessary. It concerns the following categories of personal data.
Identification data provided to Sir Edmond by clients, relations and website visitors such as name, last name, position, gender, title, nationality, date of birth, postal address, location of residence, email address, phone number and/or financial data, including bank details and all other information disclosed by clients, relations and website visitors to Sir Edmond. Besides that, login data such as IP addresses and logs are automatically collected once visitors access the website. Furthermore, Sir Edmond indirectly collects data on the use of social networks and associated advertising identifiers from its social media partners.
Basis for personal data processing
For the collection and processing of personal data, Sir Edmond relies on the following grounds:
- Based on prior consent by its clients, other relations and website visitors (legal basis: Art. 6(1)(a) GDPR); and/or
- In order to perform its obligations under an agreement with clients and other relations or in order to take steps at the other party’s request prior to entering into an agreement (legal basis: Art. 6(1)(b) GDPR); and/or
- In order to comply with its legal obligations (legal basis: Art. 6(1)(c) GDPR); and/or
- In order to protect the legitimate interest pursued by Sir Edmond, such as to ensure the security and optimal function of the website and to detect and prevent frauds (legal basis: Art. 6(1)(f) GDPR).
Transfer of data
In principle, Sir Edmond does not make your personal data available to third parties. Sir Edmond only transfers personal data to third parties if this is necessary for the performance of an agreement entered into with you or if Sir Edmond is legally obliged to do so, for example in the context of the prevention or detection of criminal offences. If and insofar, for the performance of its activities, Sir Edmond uses the services of third parties (such as a website administrator) with which it shares or to which it transfers any of the personal data collected, Sir Edmond ensures it will have entered into a processing agreement with those parties in order to guarantee the protection of the personal data shared/transferred.
Data collected and processed by Sir Edmond based on one of the grounds for processing referred to above, may be transferred by Sir Edmond to countries outside the European Economic Area (EEA) in case the third country to which the data is transferred ensures an adequate level of protection of the data transferred. The European Commission has taken multiple adequacy decisions in this regard in which it decides that particular countries ensure such level of protection. In the absence of an adequacy decision, Sir Edmond shall only transfer your data in the event it has implemented appropriate safeguards to do so. For transfers of data to countries for which Sir Edmond has not implemented appropriate safeguards or for which it cannot otherwise ensure an adequate level of protection of your data similar to the GDPR, Sir Edmond shall not transfer your data without your prior explicit consent for the proposed transfer.
Cookies (Google Analytics)
You can manage or delete cookies in your web browser. You can only do so yourself since the cookies are stored on your personal device. Please consult the manual of your web browser for this. Deleting or disabling cookies could, however, negatively impact the functioning of Sir Edmond’s website.
On the website of Sir Edmond, a cookie is placed by Google as part of its “Analytics” services. Sir Edmond only uses analytical cookies. Sir Edmond uses the data obtained by means of Google Analytics to analyze its visitor’s surfing behavior in order to optimize the website’s functioning. Besides that, Google Analytics is used to analyze online advertisements such as Google AdWords. Google may provide the obtained data to third parties, if it is legally required to do so, or to the extent that third parties process the information on Google’s behalf. Sir Edmond has no influence in this regard. Sir Edmond has expressly disallowed Google to use the personal data obtained through Google Analytics for other products, services and employees of Google. Furthermore, Sir Edmond ensures that IP addresses are anonymized when processed by Google. Sir Edmond’s use of Google Analytics is done entirely in accordance with the GDPR.
Sir Edmond will not store personal data any longer than is necessary for the purposes for which the data is collected. Insofar as the law does not prescribe a different retention period, Sir Edmond applies a period of two years after the termination of the client relationship, agreement or the last contact, after which period the data is deleted.
You can always obtain access to your personal data that is collected and processed by Sir Edmond and/or have your personal data rectified or deleted, unless Sir Edmond is obliged to store the personal data for legal purposes. You may request Sir Edmond to send you a copy of your personal data. You also have the right to withdraw your consent for or to object to the processing of your personal data by Sir Edmond. Furthermore, you have the right to data portability. This means that you can request us to forward the personal data processed by Sir Edmond to you or to another organization, as specified by you, in a computer file.
These rights may be exercised at any time by sending an email to firstname.lastname@example.org. In order to respond to your request, Sir Edmond may need to ask you to provide proof of identity or additional information. Sir Edmond will endeavor to respond to your request as soon as possible.
In case Sir Edmond is unable to satisfy your queries, you could submit your complaints to the relevant national supervisory authority, which is the Dutch Data Protection Authority for the Netherlands.
Sir Edmond is committed to safeguarding your privacy. In this regard it has taken appropriate measures to combat its improper use, loss, unauthorized access, undesired publication and non-permitted amendment. Should you have the impression that your data is insufficiently secured or if there are any indications of its inappropriate use, please contact Sir Edmond.
Sir Edmond reserves the right to make amendments to this privacy statement. The most recent version can always be found on the website https://www.siredmondgin.com/.
In case of any questions or comments about Sir Edmond’s privacy statement or the collection and processing of personal data, please contact Sir Edmond, Postbus 37770, 1030 BJ Amsterdam telephone: +31 (0)20 2101100.