Privacy Policy

KYRÖ DISTILLERY COMPANY PRIVACY POLICY – privacy statement

EUROPEAN PARLIAMENT AND THE COUNCIL DIRECTIVE (EU) 2016/680

Registrar Rye Rye Oy / Kyrö Distillery Company (later “Kyrö”) Oltermannintie 6 61500 Isokyrö FINLAND * 2502509-5  office@kyrodistillery.com  Contact Jenni Soini, gdpr@kyrodistillery.com / +358 50 408 6575

Purpose of the processing of personal data

One of Kyrö Distillery Company's most important core values is trust and transparency. We want you to know that you can trust us and the processing of your personal information, and we openly disclose our privacy policy in this privacy statement. In Kyrö's privacy statement you will find information about our company and information about how we collect and use personal information about you and how you can exercise your privacy rights.

Kyrö's personal data registers consist of customers of Kyrö Distillery Company and its subsidiaries, Kyrö Distillery Home (hereinafter KDH) and Kyrö Distillery GmbH, such as distillery visitors, barrel owners, e-commerce customers, newsletter customers and newsletter subscribers, B-to-B subscribers customers and jobseekers. The purpose of the register is to manage and maintain customer relationships, provide information on operations, and other processing of personal data in accordance with the Personal Data Act for purposes related to Kyrö's operations. We use your valuable information to ensure quality communication, cf. Section 2 below.

1. WHAT PERSONAL INFORMATION DO WE COLLECT?

As a general rule, we receive information from the registrants when they contact our company, register as a member, participate in a survey, subscribe to a newsletter, make a purchase from an online store or restaurant through invoicing, and start a customer relationship or partnership.

The personal data registers collected by Kyrö mainly consist of the following categories:

1.1 Voluntarily given personal information

When you approach us, we will retain and store the necessary personal information about you that you have voluntarily provided to us, for example when using our website. Such information includes, for example, name, date of birth, telephone number, e-mail, or other contact information such as address.

In order to maintain the customer relationship and due to the agreement taking into effect, we also collect the following information: customer number, language of customer bulletins, customer role (barrel owner, e-commerce customer, distillery restaurant customer, partner representative), desired contact form (e-mail, phone, post). Information you provide to our company, such as direct marketing bans and consents, additional information, potential contacts for corporate customers Information about purchase transactions and information about the services purchased by the customer. (We do not use e-commerce history for customer profiling.) Photographic material of events.

If you do not provide us with the information, we need to handle customer relationships, we will not be able to enter into an agreement with you to ensure the comprehensive provision and realization of our services.

1.2 Automatically collected personal data, analytics and profiling

We do not use personal information or store data to profile our customers, nor do we use automated data processing directly to the information we receive from our customers.

The information used for analytics and marketing targeting is unidentified whenever possible. Unidentified information cannot be associated with a real person. Otherwise, we treat the information as personal insofar as the identifier contains customer targeting information, such as an IP address. We leverage Google Analytics to provide analytics related to the use of our site. The information sent to Google is anonymized. Learn more about Google Analytics data processing.

When you visit our distillery or restaurant, we have a surveillance camera system on our premises to ensure security. Surveillance camera recordings are used on a limited basis only to detect possible misuse.

1.3 Personal information obtained from third parties Kyrö Distillery Company, KDH and Kyrö Distillery GmbH may also collect, store and update personal data from the registers of the registrar providing address services.

1.4. Processing of sensitive data

We do not solicit or store sensitive personal information about you, such as information about your health, race, religion, political affiliation or sexual orientation.

2. HOW WE PROCESS YOUR PERSONAL INFORMATION

At Kyrö, we use your personal information for the following purposes:

2.1 To provide and perform our services to you

For us to serve you as well as possible, we need some of the personal information we mentioned above. Our newsletters are important to your customers, and we promise that the mail you receive from us will be related to your customer habits and the information will be relevant to you. If you have purchased any of our services, the retention of proper personal information guarantees that we will be able to serve you throughout your stay.

2.2 To improve our services to you

We are constantly looking for new ways to evolve and aim for something new. In this, our customers play a particularly important role. We collect feedback and engage in dialogue with our customers, and we collect personal information during the discussion. However, we remind you that, for example, in feedback surveys, personal data is not processed together with the answers, i.e. the answers cannot be identified with the respondents. At Rye Family, the address is not used for automatic location but for better targeting of marketing messages, and to ensure that consumers are informed about relevant events.

2.3 To inform you of matters concerning our companies

Our messages will keep you up to date in the world of rye. We do not spam or support your email. We also make sure the messages you receive are timely and get enough - not too often or too infrequently.

2.4 Personal information provided by e-mail or post

Let's be in touch! When you reach us by email or mail, we retain the personal information you provide to handle customer service situations to the highest possible standard. If you send us a job application and resume, we will retain your personal information during the recruitment process. We do not analyze recruitment data automatically.

2.4 To comply with our legal obligations

For contractual and accounting reasons, we may have a legal obligation to retain your personal information. In addition, if you request that we no longer contact you, we will ask you for permission to retain basic information so that we can honor your request.

3. LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

The collection and processing of data is based on the following legal bases: Contractual: to enable us to fulfill our obligations under the terms of the contracts (purchases, subscribers to the newsletter, Barrel Owners).

Our legitimate interest in providing quality service and information to you, and our legitimate interest in ensuring the efficiency and legality of our business (if these do not conflict with your rights).

Compliance with laws and obligations that apply to us Consent: when you have given your consent to the processing of personal data.

4. WHO DOES KYRÖ DISTILLERY SHARE YOUR PERSONAL INFORMATION with?

We only disclose essential personal information to external partners of our choice for customer relationship and marketing purposes. Each external partner has an agreement on the processing of personal data in accordance with the regulations and the processing is carried out in accordance with the Data Protection Regulation. External partners do not pass on personal information to their subcontractors.

For technical and data-related reasons, the data may be stored on servers of external service providers used by Kyrö, Kyrö Distillery GmbH and KDH. These third-party service providers may process the data, and this may also involve the processing of data outside the EU / EEA. Kyrö Distillery Company undertakes to primarily use the services of service providers operating in the EU / EEA area, and to ensure the commitment of the services it uses to the GDPR regulations with the relevant certificates. If we use a partner outside the EU / EEA, we will ensure that they are committed to complying with the Data Protection Regulation and will verify that the company is identified, for example, by the EU-U.S. Privacy Shield database.

5. 5. HOW DO WE take CARE of THE PROTECTION OF YOUR PERSONAL INFORMATION?

Our staff is trained in the privacy policy and the training is part of our company’s introduction program. Our staff has the necessary information and instructions to ensure the safe processing and storage of personal information.

The manual material is stored in locked rooms that can only be accessed by relevant persons. The use of digitally processed personal data is instructed, and access to the personal register is limited so that only those persons who have a need for it in the course of their work have access to and are entitled to use the information contained in the register. Access to the data requires a password and a username. The data is protected by a firewall, and all devices are protected by appropriate measures.

We continually ensure the secure processing of your personal information, but if we find a security breach, we will report the breach to the Data Protection Authority and the parties concerned within 72 hours.

6. TRANSFER OF DATA OUTSIDE THE EU AND THE EEA

For technical and data usage reasons, the data may be stored on servers of third-party service providers that we use. These third-party service providers may process the data, and this may also involve the processing of data outside the EU / EEA. We undertake to use primarily the services of service providers operating in the EU / EEA area, and to ensure the commitment of the services we use to the GDPR regulations with relevant certificates, such as identification with EU-U.S. Privacy Shield database.

7. HOW LONG DO WE STORE YOUR PERSONAL INFORMATION?

We maintain the information we collect as long as the retention of data is necessary on the basis of personal data set out in this Privacy Policy uses, unless the law requires or permits a longer storage period. We will then, within a reasonable time, delete all the above information in our possession.

8. YOUR PRIVACY RIGHTS

In all our operations, we undertake to treat appropriate personal data with care. Upon request and after verifying the identity of the inquirer, we undertake to provide all information we have recorded about the inquirer. You have access to all the information we hold about you, as well as all information about how your information is used by us at Kyrö and where it was obtained. You can request that your information be corrected and supplemented at any time. If you are logged in to Rye Family, you will be able to edit your customer information there. For other information, ask for it in person.

Upon receipt of the information necessary to verify your identity, we undertake to provide your information within one month.

You have the right to restrict the use of your data, as well as to withdraw your consent to the use of the data. You can also prohibit direct marketing, but if you prohibit this, you will not receive information from us regarding current news from Kyrö. To ensure that your injunction is enforced and to respect your request, we ask that you consent to the retention of the necessary information.

You have the right at any time to object to the processing of personal data concerning you based on your specific personal situation. In this case, Kyrö, as data controller, may no longer process personal data, unless he/she/they can show that there is a significant and justified reason for the processing that overrides the data subject's interests, rights and freedoms or is necessary to prepare, file or defend a legal claim. You have the right to request the transfer of your data from Kyro to another controller if the processing is based on a need or consent related to the agreement.

If you have any questions about privacy at Kyrö Distillery Company or Kyrö Distillery Home, please contact us and we will do our best to help you find a solution together. You can contact our privacy contact Jenni Soini, GDPR@kyrodistillery.com. If we can't find a solution together, you can contact the data protection authority.

10. UPDATING THE PRIVACY STATEMENT

In order to stay up to date of any changes in data protection law and legal, technical and business developments, we reserve the right to modify this Privacy Update as necessary. We will notify you by reasonable means if our privacy statement is substantially updated.

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More Information

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We value your privacy and handle data in accordance to EU GDPR regulations. Read more about GDPR here: https://gdpr.eu/tag/gdpr/