Privacy Policy

Why and for whom?

At 46 Brands (“we”, “us”, “our”), we care about your personal privacy. This means that we respect and safeguard your privacy and your right to control and transparency regarding how your Personal Data is processed.

This Privacy Policy (“the Policy”) applies to all processing of Personal Data for which 46 Brands acts as the data controller. The Policy explains the purposes for which we process your Personal Data, the legal bases we rely on, and the measures we take to protect your Personal Data. We also provide information about how you can exercise your rights in relation to our processing of your Personal Data.

This Policy describes how we handle Personal Data when you communicate with us, use our services, or visit our website.

Definitions

“Processing” of Personal Data means any operation performed on Personal Data, such as storage, modification, reading, disclosure, or similar actions.

“Applicable Law” refers to the legislation applicable to the processing of Personal Data, including the General Data Protection Regulation (GDPR), supplementary national legislation, as well as case law, guidelines, and recommendations issued by a national or European supervisory authority.

“Personal Data” means any information relating to an identified or identifiable living individual.

“Data Controller” means the company or organization that determines the purposes and means of the processing of Personal Data and is therefore responsible for ensuring that Personal Data is processed in accordance with Applicable Law.

“Data Processor” means the company or organization that processes Personal Data on behalf of the Data Controller and may only process Personal Data in accordance with the Data Controller’s instructions and Applicable Law.

“Data Subject” means the living individual whose Personal Data is being processed.

“The Service” refers to the 46 Brands website, which provides information, marketing, and sales of wine and spirits.

46Brands responsibility for personal data

The information in this Policy covers the processing of personal data for which 46 Brands is the data controller, i.e. the processing for which we determine the purpose (why the processing is carried out) and the means (how, what personal data, for how long, etc.). The Policy does not describe how we process personal data in our role as a Data Processor – i.e. when we process personal data on behalf of our customers.

In order for you as a visitor to have a better experience with more relevant content and to receive our newsletter, we need to collect and process personal data in certain cases. This may include your email address and name so that we can send you our newsletter. It may also include so-called tracking pixels from, for example, Google or Facebook, or cookie files that are stored locally on your device so that we can present content that is relevant to you on subsequent visits.

Cookies

Personal Data relating to visitors to our website is processed in accordance with our Cookie Policy.

46 Brands uses cookies and similar tracking technologies in order to provide you with the best possible user experience. More information about how we use cookies can be found in our Cookie Policy

Processing Activities and Purposes

The primary purpose of the personal data processing we carry out is to provide, perform, and improve our services to you. There are several reasons why we may need to collect, manage, and store your data.

We primarily process personal data for the following purposes:

Contact and identification information to confirm your identity, verify your information, and communicate with you.
Information about your use of the service or product in order to improve your customer experience.
IP address to perform customer analysis and to ensure that content on our website is presented effectively for you and the device you are using.

How Do We Obtain Your Personal Data?

We collect your personal data in several different ways. We primarily obtain your personal data:

When you voluntarily provide your personal data to us.
Through social media platforms, for example Facebook.
Through third-party analytics technologies such as cookies.
Through our system logs.
Through information generated from data analysis.

Legal Basis

In order for us to process your personal data, we must have a legal basis for each processing activity. In our operations, we mainly process your personal data on the following basis:

Consent – 46 Brands processes your Personal Data after we have received your consent to the processing. Information about the processing is always provided when we request your consent.

If you would like additional information regarding the legal basis or bases under which we process your personal data, you always have the right to request a register extract. See the section “How to Exercise Your Rights” below.

Your Rights

You are in control of your Personal Data. We always strive to ensure that you can exercise your rights as efficiently and smoothly as possible.

Access

You always have the right to receive information about the personal data processing concerning you through a register extract. The extract will show, among other things, which personal data we store about you, the purposes of the processing, and the legal basis. We will only disclose such information once we have verified your identity.

Rectification

If you discover that the Personal Data we process about you is incorrect, please contact us and we will correct it.

Erasure

Would you like us to completely remove your data? You have the right to request the erasure of your Personal Data when it is no longer necessary for the purpose for which it was collected. If we are required to retain your data by law or under an agreement we have entered into with you, we will ensure that the data is only processed for the specific purpose required by law or the agreement. After that, the data will be deleted as soon as possible.

Objection

Do you disagree with our assessment that our legitimate interest in processing your Personal Data outweighs your interest in protecting your privacy? If so, we will review our balancing test to ensure it remains valid. Your objection will be considered when we perform a new assessment to determine whether we can continue to justify our processing of your Personal Data. If you object to direct marketing, we will remove your Personal Data immediately without further assessment.

Restriction of Processing

You may also request that we restrict the processing of your data:

While we handle a request from you regarding another one of your rights.
If, instead of requesting deletion, you want us to mark the data so it is not used for a specific purpose. For example, if you do not wish to receive marketing communications from us in the future, we still need to retain your name in order to know that we should not contact you.
In cases where we no longer need the data for the purpose for which it was collected, provided that you do not need the data to establish, exercise, or defend a legal claim.

Data Portability

We can provide you with the data that you have provided to us, or that we have received from you in connection with entering into an agreement with you. You will receive your data in a commonly used and machine-readable format that you can transfer to another data controller.

Withdrawal of Consent

If you have consented to one or more specific processing activities involving your Personal Data, you have the right to withdraw your consent at any time and request that we stop the processing immediately. Please note that withdrawing consent only applies to future processing and does not affect processing that has already taken place.

How to Exercise Your Rights

For questions, requests for access to the data we hold about you, or requests for deletion of your data, please contact us at:

info@46brands.com

and we will assist you.

Transfer of Personal Data

In order to operate our business, we rely on third parties who process Personal Data on our behalf, known as Data Processors. We always strive to process Personal Data within the EU/EEA, but some of our Data Processors are located outside the EU/EEA.

For example:

United States, to which we transfer Personal Data based on the European Commission’s Standard Contractual Clauses (SCCs) for international data transfers.

We have entered into Data Processing Agreements (DPAs) with all our Data Processors. These agreements regulate how the Data Processor may process Personal Data and the security measures required for such processing.

We may also be required to disclose your Personal Data to certain authorities in order to comply with legal obligations or official decisions.

Categories of Data Processors

Below are categories of recipients with whom we may share your data:

Marketing service providers, such as advertising agencies that create campaigns or providers that assist with sending communications by post or email.
Analytics and statistical systems used to perform customer analysis, contribute to industry statistics, and improve the customer experience.

Security

46 Brands has implemented appropriate technical and organizational measures to ensure that your Personal Data is processed securely and protected against loss, misuse, unauthorized access, or unlawful processing. If your Personal Data is shared with Data Processors, it will receive an equivalent level of protection.

Our Security Measures

Organizational Security Measures

Organizational measures are procedures and internal rules implemented within the organization, including:

Internal policies and guidelines
Login and password management

Technical Security Measures

Technical measures are implemented through technological solutions, including:

Encryption
Access logging
Data backups
Regular security monitoring
Two-factor authentication

If we do not keep our promises

If you feel that we are processing your Personal Data incorrectly, even after you have brought this to our attention, you always have the right to submit your complaint to the Swedish Data Protection Authority.

More information about our obligations and your rights can be found on the Swedish Data Protection Authority's website (https://www.imy.se/). You can also contact the authority at imy@imy.se.

Changes to this policy

We reserve the right to make changes to this Policy. In cases where the change affects our obligations or your rights, we will inform you of the changes in advance so that you have the opportunity to consider the updated policy.

Contact

Please contact us if you have any questions about your rights or if you have any other questions about how we process your personal data: info@46brands.com