I. PRIVACY POLICY AND DATA PROTECTION

In compliance with current legislation, Llonch Spirits (hereinafter also referred to as the “Website”) undertakes to adopt the necessary technical and organizational measures according to the level of security appropriate to the risk of the data collected.

Laws incorporated into this privacy policy

This privacy policy is adapted to current Spanish and European regulations on the protection of personal data on the internet. Specifically, it complies with the following regulations:

• 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 (GDPR).
• Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
• Royal Decree 1720/2007 of 21 December, approving the implementing regulations of Organic Law 15/1999 of 13 December on the Protection of Personal Data (RDLOPD).
• Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the controller of personal data

The controller of the personal data collected on Llonch Spirits is:
VALLESDIS, S.L.U., holder of Tax ID No. B58364829, and registered at:
, with the following registration details:
, whose representative is
Antonio Llonch (hereinafter, the “Data Controller”).
The contact details are as follows:

Address: Cervantes, 74 Local 3 A, 08201 Sabadell (Barcelona), Spain

Contact telephone: +34 670 098 427

Contact email: allonchandreu@gmail.com

Record of Personal Data

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Llonch Spirits through the forms available on its pages will be incorporated into and processed in our files for the purpose of facilitating, streamlining and fulfilling the commitments established between Llonch Spirits and the User, or maintaining the relationship established through the forms completed by the User, or responding to a request or inquiry.

Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained specifying, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User’s personal data shall be subject to the following principles set out in Article 5 of the GDPR and Article 4 et seq. of Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights:

• Principle of lawfulness, fairness and transparency: the User’s consent will be required at all times after fully transparent information has been provided regarding the purposes for which the personal data are collected.
• Principle of purpose limitation: personal data shall be collected for specified, explicit and legitimate purposes.
• Principle of data minimization: the personal data collected shall be only those strictly necessary in relation to the purposes for which they are processed.
• Principle of accuracy: personal data must be accurate and kept up to date at all times.
• Principle of storage limitation: personal data shall only be kept in a form which permits identification of the User for no longer than is necessary for the purposes of their processing.
• Principle of integrity and confidentiality: personal data shall be processed in such a way as to ensure their security and confidentiality.
• Principle of accountability: the Data Controller shall be responsible for ensuring compliance with the above principles.

Categories of personal data

The categories of data processed on Llonch Spirits are identifying data only. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Llonch Spirits undertakes to obtain the User’s express and verifiable consent for the processing of their personal data for one or more specific purposes.

The User shall have the right to withdraw consent at any time. It shall be as easy to withdraw consent as to give it. As a general rule, the withdrawal of consent shall not affect the use of the Website.

Whenever the User must or may provide their data through forms in order to make inquiries, request information, or for reasons related to the Website content, they will be informed if the completion of any of them is mandatory because such data are essential for the proper completion of the operation carried out.

Purposes of the processing for which personal data are intended

Personal data are collected and managed by Llonch Spirits for the purpose of facilitating, streamlining and fulfilling the commitments established between the Website and the User, or maintaining the relationship established through the forms completed by the latter, or responding to a request or inquiry.

Likewise, the data may be used for commercial purposes of personalization, operational and statistical purposes, and activities related to the corporate purpose of Llonch Spirits, as well as for data extraction, storage and marketing studies in order to adapt the Content offered to the User and improve the quality, operation and browsing experience of the Website.

At the time personal data are obtained, the User will be informed of the specific purpose or purposes of the processing for which the personal data are intended; that is, the use or uses that will be made of the information collected.

Retention periods for personal data

Personal data shall only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period:
,
or until the User requests their deletion.

At the time personal data are obtained, the User will be informed of the period during which the personal data will be retained or, where that is not possible, the criteria used to determine that period.

Recipients of personal data

The User’s personal data will be shared with the following recipients or categories of recipients:

In the event that the Data Controller intends to transfer personal data to a third country or international organization, the User will be informed, at the time the personal data are obtained, of the third country or international organization to which the personal data are intended to be transferred, as well as of the existence or absence of an adequacy decision by the Commission.

Personal data of minors

In compliance with Articles 8 of the GDPR and 7 of Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights, only persons over 14 years of age may lawfully give consent for the processing of their personal data by Llonch Spirits. If the person is under 14 years of age, the consent of the parents or guardians shall be required for processing, and such processing will only be considered lawful to the extent that they have authorized it.

Confidentiality and security of personal data

Llonch Spirits undertakes to adopt the necessary technical and organizational measures according to the level of security appropriate to the risk of the data collected, so as to guarantee the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized disclosure of or access to such data.

However, because Llonch Spirits cannot guarantee the invulnerability of the internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a personal data breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons.

Pursuant to Article 4 of the GDPR, a personal data breach shall mean a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Personal data shall be treated as confidential by the Data Controller, who undertakes to inform and ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom the information is made accessible.

Rights arising from the processing of personal data

The User has rights with regard to Llonch Spirits and may therefore exercise the following rights recognized in the GDPR and Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights against the Data Controller:

• Right of access: the User has the right to obtain confirmation as to whether or not Llonch Spirits is processing their personal data and, where that is the case, to obtain information about their specific personal data and the processing that Llonch Spirits has carried out or is carrying out, as well as, among other things, the information available regarding the origin of such data and the recipients of communications made or planned in respect of them.
• Right to rectification: the User has the right to have their personal data corrected if they are inaccurate or, taking into account the purposes of the processing, incomplete.
• Right to erasure (“the right to be forgotten”): the User has the right, provided that current legislation does not provide otherwise, to obtain the deletion of their personal data when those data are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent and there is no other legal basis for the processing; the User objects to the processing and there is no other legitimate ground for continuing it; the personal data have been unlawfully processed; the personal data must be erased in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a child under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of implementation, must take reasonable steps to inform controllers processing the personal data of the data subject’s request for the erasure of any links to, or copies or replications of, those personal data.
• Right to restriction of processing: the User has the right to restrict the processing of their personal data. The User has the right to obtain restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User requires them for legal claims; and when the User has objected to the processing.
• Right to data portability: where processing is carried out by automated means, the User shall have the right to receive from the Data Controller their personal data in a structured, commonly used and machine-readable format, and to transmit those data to another controller. Whenever technically feasible, the Data Controller shall transmit the data directly to that other controller.
• Right to object: the User has the right to object to the processing of their personal data or to request that such processing by Llonch Spirits cease.
• Right not to be subject to a decision based solely on automated processing, including profiling: the User has the right not to be subject to an individualized decision based solely on the automated processing of their personal data, including profiling, unless current legislation provides otherwise.

Accordingly, the User may exercise their rights by means of a written communication addressed to the Data Controller with the reference
“GDPR-www.llonchspirits.com”,
specifying:

• The User’s name and surname, and a copy of their ID document. In cases where representation is permitted, identification by the same means of the person representing the User, as well as the document proving such representation, will also be required. The photocopy of the ID document may be replaced by any other legally valid means of proving identity.
• The request with the specific reasons for the application or the information to which access is requested.
• An address for notification purposes.
• Date and signature of the applicant.
• Any document supporting the request being made.

This request and any other attached documents may be sent to the following address and/or email:

Postal address: Cervantes, 74 Local 3 A, 08201 Sabadell (Barcelona), Spain

Email: allonchandreu@gmail.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites other than Llonch Spirits, and which are therefore not operated by Llonch Spirits. The owners of such websites shall have their own data protection policies and shall, in each case, be responsible for their own files and privacy practices.

Complaints to the supervisory authority

If the User considers that there is a problem or infringement of the current regulations in the way their personal data are being processed, they shall have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the State in which they have their habitual residence, place of work or place of the alleged infringement. In the case of Spain, the supervisory authority is the Spanish Data Protection Agency (AEPD): https://www.aepd.es/

II. ACCEPTANCE OF AND CHANGES TO THIS PRIVACY POLICY

It is necessary for the User to have read and agreed with the conditions regarding the protection of personal data contained in this Privacy Policy, as well as to accept the processing of their personal data so that the Data Controller may proceed with such processing in the manner, within the periods and for the purposes indicated. Use of the Website shall imply acceptance of its Privacy Policy.

Llonch Spirits reserves the right to modify its Privacy Policy, in accordance with its own criteria, or as a result of a legislative, case law or doctrinal change issued by the Spanish Data Protection Agency. Changes or updates to this Privacy Policy shall not be explicitly notified to the User. Users are advised to consult this page periodically in order to be aware of the latest changes or updates.

This Privacy Policy was updated to comply with 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 (GDPR), and Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights.