Privacy Policy

PRIVACY STATEMENT eMpTy Specials BV

Date: 21/09/2023

We attach great importance to the responsible handling of (personal) data. We therefore process and secure your personal data carefully and in compliance with the provisions that legislation and regulations impose on this. This privacy statement provides information about the collection and processing of personal data.

It explains how we handle personal data. We make clear which personal data is collected and for what purposes it is used. We also explain how you can view, change or delete your data. We believe it is important that you are well informed about this and recommend that you read this document carefully. The most recent version can always be consulted on our websites.

1. Who is responsible for the processing of your data?

The eMpTy Specials BV group sells various services and products through various websites. 

Entrepreneur Name: eMpTy Specials BV - Trade name: The Wine BoxBelgium

Business address: H.-Geestmolenstraat 175, 9160 Lokeren

Phone number: +32471 08 61 62

Availability: Monday to Friday from 9:00 am to 5:00 pm

Email address: hello@thewinebox.wine

IBAN: BE22 7370 7159 6147<ON 1000.096.625>

VAT number: BE1000.096.625. 

We use several names to refer to our activities, including The Wine Box.

This privacy statement applies to all use that eMpTy Specials BV may make of personal data obtained by them from anyone who has had contact and/or visited our website(s).

2. Summary

We collect and process personal data for various purposes. The most important are: to be able to communicate with our customers, to be able to process their orders, to correctly handle warranty and service questions and to be able to show relevant advertisements and make offers.

The individuals whose personal data we process have certain rights with respect to their data. These rights are included in this statement.

We reserve the right to make changes to this privacy statement. It is recommended that you consult this privacy statement regularly so that you are aware of these changes.

3. What data do we process?

The following (categories of) personal data may be processed:

  1. address and/or contact details: such as name, residential, delivery and/or billing address and other contact details (such as email and telephone details) and social media accounts;
  2. identification data: gender, your date and place of birth, data about your IP address;
  3. order data and preferences: such as data relating to (previous) services/products purchased from us, the options and preferences chosen and the information exchanged in this regard (such as a customer ID, customer number, user name, login details and specified preferences and interests, customer cards, data relating to gift vouchers) and contacts with customer service;
  4. e-mail and telephone communications with us: such as e-mail correspondence, telephone conversations, and recordings of communications with us (in accordance with applicable law);
  5. data regarding your experiences, preferences and behaviour: such as data obtained from reviews, customer surveys, competitions or collected by placed cookies about your behaviour and preferences on our website(s) (such as a wish list, language settings, browser used and cookie preferences);
  6. financial data: such as data about the financial instruments you trade in, securities, (savings) accounts and/or mortgages. Income data, data relating to real estate and other financial data that are necessary for the provision of our services, which may also include a creditworthiness investigation, for example in the case of deferred payment;
  7. data to prevent fraud: such as sound recordings;
  8. information provided in job applications.

Our services are in principle not aimed at persons under the age of 18. If you are under the age of 18 and it appears from our statements that services are offered to you, then use of these is only permitted under the supervision and after permission from the person who has parental responsibility for that person under the age of 18.

4. On what grounds ("legal grounds") is the use of your data based?

We use personal data based on the following bases ("legal bases"):

  1. in order to perform the agreement, such as the agreement whereby you gain access to products or services ordered in the webshop or other products or services (which also includes data obtained in the pre-contractual phase);
  2. after your consent, for example in the context of marketing;
  3. to comply with legal obligations (such as those under the Agreement on the Advertising and Marketing of Alcoholic Beverages and tax obligations);
  4. if there is a legitimate interest for the processing, which may include the following "legitimate interests":
  5. our interest in maintaining a (commercial) relationship with our customers or members and our commercial interest in gaining more insight into our users, our customers and their wishes;
  6. our interest in conducting research and analyses and optimizing services;
  7. conducting proceedings;
  8. investigating the effectiveness of security measures.

5. What (for what purposes) do we use your data?

eMpTy Specials BV collects personal data to offer every Visitor a safe, optimal and personal user experience. The Data processing is essential for the proper functioning of our Website and the associated services. 

The processing is carried out exclusively for the following specific purposes:

– Customers:

Customer management: customer administration, order management, deliveries, invoicing, support, complaint monitoring and sending newsletters.


Personalized marketing and advertising: In that case, the Customer always has the right to unsubscribe from this.

– Visitors:

Answering information requests via the contact form on the Website:

Personalized marketing and advertising: If the Visitor has explicitly agreed to this. In that case, the Visitor is free to withdraw his consent at any time. Furthermore, the personal data of the Data Subject may also be used for the following purposes:

  • Dispute management.

  • Protection against fraud and infringement.
 

In addition, we use cookies to recognize (the IP address of) Visitors and to offer them a personalized user experience, to remember their technical choices and to detect and correct any errors on the Website. Please refer to our Cookie Policy for more information about how we use cookies. 

When visiting the Website, some data is collected for statistical purposes. Such data is necessary to optimize the use of our Website. This data is: probable place of consultation, hour and day of consultation, which pages were visited. In order to optimally protect your privacy, this data is always anonymized.

Under no circumstances do we collect sensitive personal data, such as data about your race, political opinions, health, religious or other beliefs, sexual orientation or the like.

The Data Subject always provides the personal data to OENANI himself and can thus exercise a certain control. If certain personal data are incomplete or apparently incorrect, OENANI reserves the right to temporarily or permanently postpone certain expected actions.

We also place and use cookies.

6. Are you obliged to provide the data?

You are required to provide certain data. If you do not want to provide us with that data, we cannot enter into the agreement with you and we cannot execute the agreement.

We also need certain data to comply with legal obligations, such as the Agreement on Advertising and Marketing of Alcoholic Beverages.

7. How long do we store personal data?

Your personal data will be stored for as long as necessary to pursue the purposes set out in Article 5. They will be deleted from the database when they are no longer necessary to pursue these purposes or if the Data Subject validly exercises the right to have the personal data deleted.

8. What rights do you have?

With regard to the processing of personal data, you have several rights. These rights are listed below:

  1. You may always ask us for an overview of the personal data that we have collected and request a copy of it - within the legal framework (right of access);
  2. If your personal data has been processed incorrectly and/or incompletely in our administration, you can request that we correct or supplement this data (right to correction);
  3. If you do not want us to have registered certain data, you can request that we delete this data (right to erasure or 'the right to be forgotten');
  4. You have the option to temporarily suspend the processing of personal data or to limit its use (right to restriction);
  5. Under certain circumstances you may object to the (further) processing of personal data (right to object);
  6. You can request us to transfer personal data to a third party (right to transfer);
  7. If we receive personal data about you from a third party and process that personal data, we will inform you - upon request - about the source from which this information was received.

Making a request as referred to under 3, 4 or 5 may result in the loss of the right to access purchased products or services, without the right to a refund.

A request does not have to be complied with if 1) we have a legitimate and/or compelling interest in doing so or 2) we can refuse to cooperate with that request on another legal basis.

Most of your personal data can be found in your own account. You can log in there and also change your data. For access to data that is not in your account, you can contact us directly.

Electronic commercial messages always include an unsubscribe button so that you can unsubscribe from receiving such messages.

9. Sharing personal data with third parties  

We will not sell or rent your personal information to third parties.

We may use third parties who are engaged to provide services on our behalf or for us, such as for the performance of the agreement or as described in this statement.

Parties with whom we collaborate and by whom personal data may be processed include the following:

  • government agencies;
  • staff;
  • payment companies, web shops and printing companies;
  • delivery partners;
  • suppliers;
  • support in the context of advertising and marketing campaigns, customer research and review partners;
  • product support;
  • other companies within our group;
  • IT service providers, such as for hosting and maintenance of the websites;
  • legal support;
  • other external service providers and advisors.

We may also, without your specific consent, provide your information in response to legitimate requests from authorities, on the basis of subpoenas or court orders, actions or to detect or prevent damage or fraud, theft or abuse, or actions to guarantee the security of our network and services. If there is reason to do so, we may ask you (or have you asked) to show proof of identity to prove that you are over 18 years of age.

We may also share your information with third parties in the event of a merger, demerger, acquisition or other change in which we are involved.

10. Processing outside the EEA

Personal data may be processed outside the European Union by the following third parties:

  • Google;
  • LinkedIn;
  • Twitter;
  • Instagram;
  • Facebook.

In the context of the use of Google Analytics, the following is noted. We have concluded a processor agreement with Google to make agreements about the handling of your data. Furthermore, we have not allowed Google to use the obtained Analytics information for other Google services. Finally, we have your IP addresses anonymized.

If your data is stored outside the EEA, we will ensure that this is done in a secure and lawful manner.

11. Security and data breaches

A data breach is – in short – any breach of the security of personal data, resulting in it being destroyed, lost, provided, transferred, stored or otherwise processed without authorisation.

A data breach can occur accidentally, for example by forwarding customer data to the wrong recipient, but it can also occur deliberately. In the latter case, one can think of personal data being stolen by a hacker or the copying of a database with personal data by an employee who leaves the company.

We have taken technical and organizational measures to prevent data leaks.

Measures taken include:

  • SSL/TLS connections for websites;
  • that only necessary persons have access to personal data, that access to the data is protected and that our security measures are regularly checked;
  • that persons who have access to data are aware of the importance we attach to the protection of personal data;
  • that persons who have access to data are bound by a confidentiality agreement.

However, it cannot be completely ruled out that at some point there will be a data leak. We are required to keep a record of all data leaks and can be held accountable by the Dutch Data Protection Authority. In addition, we are required to report a data leak to the Dutch Data Protection Authority within set deadlines, with reasons.

12. Contact

You can contact us in various ways. You can reach our customer service via chat, email, telephone or by writing to us. If you do so, we can view your Account Data, Usage Data and Financial Data, such as your customer number and the content of your question or complaint.

We will ask for your Account details to handle your question or complaint and may also contact you later for additional information. We can record our conversations/messages in a system together with your other data, so that we can help you as best as possible and can read back how we answered your questions earlier. This is also useful for you as a customer: if you contact us again later with a question about a previous problem, you do not have to explain the problem again.

After we have helped you with your question, we may contact you to ask whether you are satisfied with the way we have helped you.

When you call our customer service, these conversations are recorded for training purposes and to assess whether our employees are helping you well. These recordings are only used for these purposes. We also analyze Usage Data and Account Data regarding the contact with you so that we can improve our services. We have a legitimate interest in using your data for this purpose, namely improving our service provision so that we can serve you as well as possible.

It is also possible that we record (part of) the conversation between you and us when you place a new order or change an existing order. We have a legitimate interest in using your data for this purpose. We want to be able to prove what we have agreed with you. We will inform you about this before the recording starts.

We will also sometimes contact you to ask what you think of our services. We do this, for example, by e-mail or telephone. We will use the answers you give to improve our services. We can then contact you again later to discuss your answers. We have an interest in this use of your data because by improving our services, we can serve our customers better. If you no longer wish to be contacted, you can indicate this to our customer service.

If you communicate with us via social media (for example by sending a message, liking our post or by becoming a fan) we may receive and store personal data about you such as the content of your message, (user) name, your profile picture, your place of residence, your email address and your gender. We use the received data to respond to your message as best as possible and to gain better insight into the possible preferences of our customers. We have a legitimate interest in using the data received about you.

By gaining insight into our customers' preferences, we can tailor our products and services even better to the interests of our customers. This allows us to ensure that even more people can use our products and services. The privacy statement of the relevant social media channel applies to the use of social media. This privacy statement applies to the data stored by us.

13. Questions or complaints

Your requests and/or questions about the processing of personal data and/or this privacy statement can be addressed to the persons mentioned on the first page. We will strive to resolve your complaints as best as possible, within a reasonable period of time. We do everything we can to serve you as best as possible. If you are not satisfied with the handling of the complaint, you can contact the supervisory authority and, if desired, file a complaint.