As an independent non-profit association, the Whisky Club Luxembourg A.s.b.l. (the “WCL”) aims to bringing you closer with all things whisky related. In order to send you these tailored updates and newsflashes and to invite you for events regarding matters of your particular interest (the Mailings), we process your personal data in electronic systems. Furthermore, as a member, we need to collect some data to manage the membership of our A.s.b.l. in accordance with the law and to provide you with the best possible service (the Member Management) In this Privacy Policy we set out what personal data we collect and use, for what purposes and to whom your personal data may be disclosed by us in the context of these Mailings and the Member Management. Further, this Privacy Policy includes important information regarding your rights with respect to the processing of your personal data. Therefore, we encourage you to read this Privacy Policy very carefully. From time to time, we may need to change this Privacy Policy. 1. Whose personal data do we collect? In the context of our Mailings, we collect your personal data because you are our member or other valued contact. In the context of the Member Management, we collect your personal data because you are a member.
2. How do we collect your personal data and why? We may collect information about you:
directly from you, such as the information you provided to us when you opted-in for our Mailings and provided your details for your membership application; and
from publicly available sources such as our Facebook page or the corporate website of the organization you are working for.
We have two legal bases for processing your personal data with respect to our Mailings : your consent or our legitimate interest if you are our member/subscriber to the Mailings. For the MemberManagement, the legal basis is that we need to have a membership list in accordance with the law. Our legitimate interest translates into our objective to communicate relevant developments and to invite our members and contacts (and their partners) to events. We also aim to only send relevant Mailings, to personalize our Mailings, and to keep our database up to date. Furthermore, we use the information provided by you to better understand the recipients of our Mailings and to improve our Mailings and service offering. Below we have schematically set out what personal data we collect about you and for what purposes. Personal data: Purposes:
name (initials)* to correctly address our Mailings
address (business and private) * to contact you
position or profession to correctly address you and to customize our Mailings
title(s) to correctly address you
email address* to contact you and send you the Mailings
telephone number, mobile telephone number or facsimile number to contact you
Birthday to check whether you are of legal drinking age
company or organization to contact you
name of your partner to invite your partner to our events (if appropriate)
(previous) mailings you have been sent by us to monitor the correctness of sent Mailings and the use of the correct contact details and to analyse our Mailings
dietary requirements to adapt the menu that we may offer during our events
we may also register when we are informed that you are deceased to keep the data we collect up-to-date and to ensure that you no longer receive undesired Mailings
opt-in/opt-out for marketing materials to correctly register and follow-up any opt-in or opt-out that you have indicated to us, in order to ensure our Mailings are customised to your expressed wishes and to ensure that you no longer receive undesired Mailings
opt-in/opt-out for other mailings to correctly register and follow-up any opt-in or opt-out that you have indicated to us, in order to ensure our Mailings are customised to your expressed wishes and to ensure that you no longer receive undesired Mailings
whether you have opened the Mailing and or clicked on any links included in the Mailing to analyse whether our Mailings are well-read and to improve our (future) Mailings
We are required to process the personal data marked with an asterisk (*) in order to be able to send you the Mailings and for our Member Management. Of course, you may refuse to give us certain of these personal data. Please keep in mind that this may result in us being unable to send you the Mailings or to correctly address you in these Mailings.
3. With whom do we share your personal data? In the context of the purposes as listed above, we may share your personal data with third parties, such as parties that help us organize or host our events and service providers that that help us organise our Mailings as well as hosting services. We will ensure that, where relevant, the necessary safeguards are implemented to ensure the protection of your personal data when disclosing your personal data to a third party. For example, we will enter into data processing agreements with relevant parties (providing for restrictions on the use of your personal data and obligations with respect to the protection and security of your personal data). . Personal Data may be transferred outside of the European Union (including to our service providers), in countries which are not subject to an adequacy decision of the European Commission and whose legislation does not ensure an adequate level of protection as regards the processing of personal data, including but not limited to the United States. In such case, it shall be ensured that adequate measures are taken to ensure adequate protection of your personal data in accordance with applicable data protection legislation. 4. How long do we store your personal data? We will store your personal data as listed above until the moment you have informed us that you no longer wish to receive our Mailings, we cease the sending of the relevant Mailings, or it appears that your email address is no longer in use (for example when we receive a filed delivery notification) or if you are no longer a member and do not wish to receive further marketing material. 5. What are your rights and how you can exercise them? Please note that you can always unsubscribe from our Mailings or change your preferences by clicking the subscribe or unsubscribe link at the bottom of every Mailing. You may also terminate your membership at any time. Further, you have the right to:
information about and access to your personal data;
rectify your personal data;
erasure of your personal data (‘right to be forgotten’);
restriction of processing of your personal data;
object to the processing of your personal data;
receive your personal data in a structured, commonly used and machine readable format and to (have) transmit(ted) your personal data to another organization.
To exercise your rights, please contact our Secretary. You will find his contact details at the bottom of this Privacy Policy. Finally, you have the right to lodge a complaint with the relevant Data Protection Authority, such as the Luxembourg National Commission for Data Protection.
Contact If you have any questions, comments or complaints in relation to this Privacy Policy or the processing of your personal data by us in the context of the Mailings, please feel free to contact your Secretary via jerome@whiskyclublux.com.