Privacy Policy

Since 25 May 2018, the provisions of the EU General Data Protection Regulation (hereinafter: GDPR) have applied throughout Europe. In the following, we would like to inform you about the processing of personal data carried out by Margolin Spirits Ltd (hereinafter, “Margolin Spirits”, “we”, “us” or “our”) about the processing of personal data in accordance with the GDPR. Please read our privacy policy carefully. If you have any questions or comments about this privacy policy, you can send them at any time to the email address given below.

The following privacy policy informs you about the nature and extent of the processing of so-called personal data by Margolin Spirits. Personal data is information that can be directly or indirectly attributed to you or can be attributed to you.

Data processing by Margolin Spirits

Data processing by Margolin Spirits can essentially be divided into two categories:

For the purpose of contract processing when purchasing in the shop, all data required for the execution of a contract is processed. If external service providers are also involved in the processing of the contract, e.g. logistics companies or payment service providers, your data will be passed on to them to the extent necessary in each case.

When you access the Margolin Spirits website, various information is exchanged between your device and our server. This may also include personal data. The information collected in this way is used, among other things, to optimise our website or to display advertising in the browser of your end device.

In accordance with the provisions of the GDPR, you have various rights that you can assert against us. These include the right to object to selected data processing, in particular data processing for advertising purposes.

If you have any questions about our privacy policy, you are welcome to contact our company data protection officer at any time. You will find the contact details below.

Name and contact details of the data controller

This privacy policy applies to data processing by

Margolin Spirits Ltd of Saint Martins Road, Rosslare Harbour, Wexford, Y35 C434. (“data controller”). You can contact us using hello@themargolin.com

Purposes of data processing, legal basis and legitimate interests of Margolin Spirits, as well as categories of recipients

This section explains the purposes of data processing, legal bases and legitimate interests pursued by us, as well as categories of recipients of your personal data.

Accessing our website

When you access our website, the browser used on your end device automatically sends information to the server of our website and temporarily stores it in a so-called log file. We have no influence on this. The following information is collected without your intervention and stored until it is automatically deleted:

the IP address of the requesting internet-capable device,
the date and time of access,
the name and URL of the file accessed,
the website from which the access was made (referrer URL),
the browser you use and, if applicable, the operating system of your internet-enabled computer as well as the name of your access provider.

The legal basis for the processing of the IP address is Article 6(1)(f) GDPR. Our legitimate interest follows from the purposes of data collection listed below. At this point, we would like to point out that we are not able to draw any direct conclusions about your identity from the collected data, nor will we do so.

The IP address of your terminal device and the other data listed above are used by us for the following purposes:

Ensuring a smooth connection setup,
Ensuring a comfortable use of our website,
evaluating system security and stability,

Provision to law enforcement agencies for prosecution in the event of cyberattacks or fraud.

The data is stored for a period of two months and then automatically deleted unless it is subject to a legal obligation to retain it. Furthermore, we use so-called cookies, analysis tools, targeting procedures and social media plug-ins for our website.

Conclusion, execution or termination of a contract

Data processing upon conclusion of a contract

The object of Margolin Spirits’s activities is the distance selling of goods and services, the retail trade within the scope of officially issued permits and the serial production of the goods to be offered. In this context, we process the data required for the conclusion, performance or termination of a contract with you. This includes:

First name, last name
Billing and delivery address(es)
E-mail address
Billing and payment data
Date of birth for age verification
Telephone number for queries, if applicable

The legal basis for this is Article 6(1)(b) of the GDPR, i.e. you provide us with the data on the basis of the contractual relationship between you and us. We are also obliged to process your e-mail address due to legal requirements to send an electronic order confirmation (Article 6(1)(c) GDPR). Insofar as we do not use your contact data for advertising purposes, we store the data collected for the purpose of processing the contract until the expiry of the statutory periods or possible contractual warranty and guarantee rights. After the expiry of this period, we retain the information of the contractual relationship required by commercial and tax law for the periods determined by law. For this period (regularly ten years from the conclusion of the contract), the data is processed again solely in the event of an audit by the tax authorities.

Furthermore, the following data processing is required to process the purchase contract:

We will pass on the necessary payment data to a payment service provider commissioned by us.

The addresses entered when completing an order or creating a customer account in the Margolin Spirits shop are forwarded to an external service provider for address suggestions and address verification. This serves the purpose of ensuring correct addresses for delivery in the course of contract fulfilment and to make the collection of addresses as convenient as possible for the user.

Furthermore, we pass on the necessary details of your order to a logistics company commissioned by us (An Post or DHL) for the purpose of processing the purchase contract. In order to ensure that the goods are delivered in accordance with your wishes, we transmit your e-mail address and, if applicable, your telephone number to the logistics company commissioned by us. The logistics company may contact you in advance of the delivery in order to coordinate details of the delivery with you. The data will be transmitted solely for this purpose and deleted after delivery has taken place.

Data processing for advertising purposes

The following statements refer to the processing of personal data for advertising purposes. The GDPR declares such data processing on the basis of Article 6(1)(f) to be conceivable in principle and a legitimate interest. The duration of data storage for advertising purposes does not follow any rigid principles and is based on the question of whether the storage is necessary for the advertising approach. At Margolin Spirits, we also follow the principle of deleting data for promotional use after 3 years without use.

Advertising purposes of Margolin Spirits

If you have concluded a contract with us, we will list you as an existing customer. In this case, we process your postal contact data outside of the existence of a specific consent in order to send you information about new products and services in this way. We process your e-mail address in order to send you information about our own similar products, unless you have given your specific consent.

Right of objection

You can object to data processing for advertising purposes at any time, free of charge, separately for the respective communication channel and with effect for the future. For this purpose, an e-mail or a postal letter to the contact details mentioned above is sufficient.

If you object, the contact address concerned will be blocked for further data processing for advertising purposes. We would like to point out that in exceptional cases, advertising material may still be sent temporarily after receipt of your objection. This is technically due to the necessary lead time for advertisements and does not mean that we will not implement your objection. Thank you for your understanding.

Newsletter dispatch

On our website we offer you the possibility to register for our newsletter. To ensure that no mistakes are made when entering the e-mail address, we use the so-called double opt-in procedure: After you have entered your e-mail address in the registration field, we will send you a confirmation link. Only when you click on this confirmation link will your e-mail address be included in our distribution list.

You can revoke your consent at any time with effect for the future. To do so, it is sufficient to unsubscribe from the newsletter via the link at the end of each newsletter sent or to send a short note by email to the email address given above.

Online presence and website optimisation

Cookies – general information

We use so-called cookies on our website. If these cookies are personal data, they are used on the basis of Article 6 (1) (f) GDPR. Our interest in optimising our website is to be regarded as legitimate in the sense of the aforementioned provision. Cookies are small files that are automatically created by your browser and stored on your end device (laptop, tablet, smartphone or similar) when you visit our site. Information is stored in the cookie that is related to the specific end device used. However, this does not mean that we gain direct knowledge of your identity. The use of cookies serves, on the one hand, to make the use of our offer more pleasant for you. For example, we use so-called session cookies to recognise that you have already visited individual pages of our website or that you have already logged into your customer account. These are automatically deleted when you leave our site or end your browser session. Furthermore, we also use temporary cookies for the purpose of user-friendliness, which are stored on your end device for a certain fixed period of time. If you visit our site again in order to use our services, it is automatically recognised that you have already been with us and which entries and settings you have made so that you do not have to enter them again.

If you have a customer account and are logged in or activate the “stay logged in” function, the information stored in cookies will be added to your account.

On the other hand, we use cookies to statistically record the use of our website and to evaluate it for the purpose of optimising our offer for you as well as to display information specially tailored to you. These cookies enable us to automatically recognise that you have already been to our website when you visit it again. These cookies are automatically deleted after a defined period of time. Most browsers accept cookies automatically. However, you can configure your browser in such a way that no cookies are stored on your computer or a message always appears before a new cookie is created. However, the complete deactivation of cookies may mean that you cannot use all the functions of our website. The storage period of the cookies depends on their purpose.

Google Analytics

For the purpose of demand-oriented design and continuous optimisation of our pages, we use Google Analytics, a web analysis service of Google LLC (“Google”), Amphitheatre Parkway, Mountain View, CA 94043, USA, on the basis of Article 6 (1) (f) GDPR. In this context, pseudonymised usage profiles are created and cookies are used. The information generated by the cookie about your use of this website, such as

Browser type/version,
operating system used,
Referrer URL (the previously visited page),
host name of the accessing computer (IP address),
time of the server request,

are transmitted to a Google server in the USA and stored there. The information is used to evaluate the use of the website, to compile reports on website activity and to provide other services associated with the use of the website and the Internet for the purposes of market research and the design of these Internet pages in line with requirements. This information may also be transferred to third parties if this is required by law or if third parties process this data on our behalf. Under no circumstances will your IP address be merged with other Google data. The IP addresses are anonymised so that an allocation is not possible (so-called IP masking).

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing this browser add-on. As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent the collection by Google Analytics by clicking on the following link:

Deactivate Google Analytics

An opt-out cookie will be set, which will prevent the future collection of your data when visiting this website. The opt-out cookie is only valid in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you must set the opt-out cookie again.

Further information on data protection in connection with Google Analytics can be found on the Google Analytics website.

Targeting methods

The targeting procedures listed below and used by us are carried out on the basis of Article 6(1)(f) of the GDPR. By means of the targeting measures used, we want to ensure that you are only shown advertising on your end devices that is oriented to your actual or presumed interests. It is in your interest as well as ours not to bother you with advertisements that are not of interest to you.

Use of Google AdWords

We use the Google AdWords service to advertise our website by displaying interest-relevant advertising. Google AdWords is a service operated by Google LLC (“Google”), 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA. Google AdWords allows advertisers to place advertisements in Google’s search engine results and in the Google advertising network. For this purpose, certain keywords are defined in advance by the advertiser. If a user retrieves a keyword-relevant search result in the Google search engine, the ads are filtered accordingly. Similarly, ads are placed on relevant websites in the Google advertising network by means of an automatic algorithm, taking into account the specified keywords.

If a data subject accesses the Margolin Spirits website via a Google AdWords ad, a conversion cookie will be stored by Google on the data subject’s system. Such a conversion cookie loses its validity after thirty days and is not used to identify the data subject but to check whether certain sub-pages of Margolin Spirits (e.g. the shopping basket) are called up within the period and thus to make the success of the advertising via AdWords measurable. The information collected by Google can be used statistically by Margolin Spirits. However, neither Margolin Spirits nor other advertising customers of Google AdWords are able to identify the persons concerned.

Google’s conversion cookie stores personal data, e.g. the websites you visit. Each time you visit Margolin Spirits, personal data, including the IP address of the internet connection used by the data subject, is therefore transmitted to Google in the USA and stored there. Google may pass this personal data on to third parties.

You can find more information and details on Google’s privacy policy.

Onsite targeting

Our website uses cookies to collect and analyse information in order to optimise advertising. This information includes, for example, details of which of our products you were interested in. The collection and evaluation is exclusively pseudonymous and does not enable us to identify you. In particular, the information is not combined with personal data about you. On the basis of this information, we can show you offers on our website that are specifically geared to your interests, as these result from your previous user behaviour. The cookie is automatically deleted after 30 days.

Option to object/opt out

You can prevent the targeting technologies described by making the appropriate cookie settings in your browser and deleting existing cookies on the end device via the settings of the Internet browser or with the help of other software. In addition, you have the option of deactivating preference-based advertising for various providers with the help of the preference manager available here. Personalised advertising by Google can be deactivated on this page.

Customer account

In order to provide you with the greatest possible convenience when shopping, your personal data will be permanently stored in a password-protected customer account. The creation of the customer account is voluntary and is based on your consent within the meaning of Article 6 (1) (a) GDPR. After setting up a customer account, no new data entry is required. In addition, you can view and change the data stored about you in your customer account at any time.

In addition to the data requested when placing an order, you must enter a password of your choice to set up a customer account. This password is used together with your e-mail address to access your customer account. Please treat your personal access data confidentially and in particular do not make them accessible to unauthorised third parties. We cannot accept any liability for misused passwords unless we are responsible for the misuse. Please note that you will automatically remain logged in after leaving our website, unless you actively log out. You have the option of having your customer account deleted at any time. To do so, please use the contact details mentioned above.

If you do not wish to create a customer account with Margolin Spirits, please use the option of ordering by telephone from Margolin Spirits.

Contact form and contact by e-mail

The online presence of Margolin Spirits offers you a contact form and contact by e-mail for easy contacting. If you contact Margolin Spirits by e-mail or via the contact form, your transmitted personal data will be stored automatically. Such personal data transmitted to Margolin Spirits on a voluntary basis will be stored for the purpose of processing or contacting you. This data will not be passed on to third parties.

Social Media

The data you enter on our social media pages, such as comments, videos, pictures, likes, public messages, etc. are published by the social media platform and are not used or processed by us for any other purpose at any time. We only reserve the right to delete content if this should be necessary. Where applicable, we share your content on our site if this is a function of the social media platform and communicate with you via the social media platform. The legal basis is our legitimate interest. The data processing is carried out in the interest of our public relations and communication.

If you wish to object to certain data processing over which we have an influence, please contact us. We will then examine your objection. If you send us a request on the social media platform, we may also refer you to other secure communication channels that guarantee confidentiality, depending on the response required. You always have the option of sending us confidential enquiries to our address stated in the imprint.

As already stated, where the social media platform provider gives us the opportunity, we take care to design our social media pages to be as data protection compliant as possible. With regard to statistics that the provider of the social media platform makes available to us, we can only influence these to a limited extent and cannot switch them off. However, we make sure that no additional optional statistics are made available to us.

Data processing by the operator of the social media platform

The operator of the social media platform uses web tracking methods. The web tracking can also take place regardless of whether you are logged in or registered with the social media platform. As already explained, we can unfortunately hardly influence the web tracking methods of the social media platform. We cannot, for example, switch this off.

Please be aware: It cannot be ruled out that the provider of the social media platform uses your profile and behavioural data, for example to evaluate your habits, personal relationships, preferences, etc. We have no influence on this. In this respect, we have no influence on the processing of your data by the provider of the social media platform.

Content Delivery Network

Our web site uses a so-called Content Delivery Network (CDN). A CDN is a network of powerful servers that cache content at various locations around the world. A CDN has two main tasks: to deliver content in the shortest possible time and to reduce the load on the web host by distributing traffic. CDNs transmit two types of content: Static and dynamic content. Static content is delivered to all website visitors in the same form, such as video content from streaming services or code frameworks (e.g. Javascript, jQuery). Dynamic content is first adapted to the user and only created at the moment of the request. This includes content that takes place via web applications, email or online shops and is personalised. In order to use the latter, information about the website visitor must first be transmitted to the CDN. The legal basis for the use of a CDN and the transmission of your data to it is our legitimate interest. The legitimate interest results from our need for a technically flawless and fast presentation of our web site and the relief of our IT infrastructure. You can object to the processing of your data on the basis of our legitimate interest at any time. To do so, please use the contact details provided.

Transfer to recipients outside the EU

With the exception of the processing described, we do not pass on your data to recipients based outside the European Union or the European Economic Area. The processing operations listed in the transfer of data to the servers of the providers of analysis and targeting technologies commissioned by us. These servers are located in the USA. The data transfer takes place in accordance with the principles of the GDPR and on the basis of so-called standard contractual clauses of the EU Commission.

Your rights

In addition to the right to revoke the consent you have given to us, you have the following further rights if the respective legal requirements are met:

Right to information about your personal data stored by us pursuant to Art. 15 GDPR; in particular, you may request information about the processing purposes, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the origin of your data if it has not been collected directly from you,

The right to have inaccurate data corrected or to have correct data completed in accordance with Art. 16 of the GDPR,

Right to have your data stored by us deleted in accordance with Art. 17 of the GDPR, insofar as no legal or contractual retention periods or other legal obligations or rights to further storage are to be observed,

The right to restrict the processing of your data pursuant to Article 18 of the GDPR, insofar as you dispute the accuracy of the data, the processing is unlawful but you object to its erasure; the controller no longer requires the data, but you need it to assert, exercise or defend legal claims or you have objected to the processing pursuant to Article 21 of the GDPR,

Right to data portability pursuant to Art. 20 GDPR, i.e. the right to have selected data stored by us about you transferred in a common, machine-readable format, or to request the transfer to another controller.

Right to complain to a supervisory authority: If you believe that the processing of your data violates data protection law or your data protection rights have otherwise been violated in some way, you can complain to the competent supervisory authority. This is the Irish Data Protection Commission, 21 Fitzwilliam Square South

Dublin 2, D02 RD28, Ireland.

Right of objection

Under the conditions of Art. 21 (1) GDPR, the processing of data may be objected to for reasons arising from the particular situation of the data subject.

The above general right to object applies to all processing purposes described in this privacy notice that are processed on the basis of Article 6(1)(f) GDPR. In contrast to the specific right to object to data processing for advertising purposes (see 3.3 above), under the GDPR we are only obliged to implement such a general right to object if you provide us with reasons of overriding importance for doing so (e.g. a possible risk to life or health). Furthermore, you have the option of contacting the data protection officer responsible for Margolin Spirits or the competent supervisory authority.

Data security measures

All data transmitted by you personally, including your payment data, are transmitted using the generally accepted and secure standard SSL (Secure Socket Layer). SSL is a secure and proven standard that is also used, for example, for online banking. You can recognise a secure SSL connection, among other things, by the appended s at the http (i.e. …) in the address bar of your browser or by the lock symbol in the upper or lower area of your browser.

We also use appropriate technical and organisational security measures to protect your personal data stored with us against manipulation, partial or complete loss and against unauthorised access by third parties. Our security measures are continuously improved in line with technological developments by us and by the service providers commissioned by us.

Changes to the privacy policy

We reserve the right to change the privacy policy from time to time in order to adapt it to changes in the law, changes in data processing or updated services. Changes that affect your contractual relationship with Margolin Spirits or for which your consent as a user is required will only be made with the consent of the user.

Customers, interested parties and users of Margolin Spirits are requested to inform themselves regularly about the current content of the privacy policy.