Privacy & Cookie Policy

Effective date: 9 March 2024
Last updated: 11 February 2026

At POSCOQ Vodka, we respect your privacy and are committed to protecting your Personal Data.

This Privacy & Cookie Policy explains what data we collect, how we use it, your rights, and how we safeguard your information.


Privacy Policy

1. Controller

The controller responsible for data processing is:

POSCOQ
KVK: 83174486
Maurits Escherlaan 16, Rhoon, The Netherlands
(“POSCOQ”, “POSCOQ Vodka”, “we”, “us”, or “our”)

For any questions or to exercise your rights, you can contact us at: info@poscoq.com.


2. Applicable Law

We process Personal Data in accordance with:

  • EU General Data Protection Regulation (GDPR)
  • Dutch GDPR Implementation Act (UAVG)
  • Dutch Telecommunications Act
  • Applicable EU ePrivacy rules

3. Definitions

Personal Data – Any information relating to an identified or identifiable natural person (e.g., name, IP address, device identifiers).

Processing – Any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion.


4. Legal Bases for Processing

We process Personal Data only when permitted under Article 6 GDPR, including where:

  • You have given consent
  • Processing is necessary for a contract
  • We must comply with a legal obligation
  • We have a legitimate interest that does not override your rights

5. Data We Collect

Technical Data (Website Access)

When you visit our website, our server automatically logs:

  • IP address
  • Date and time of access
  • Browser type and version
  • Pages accessed
  • Referrer URL
  • Session ID
  • Amount of data transferred
  • Request status

Legal basis: Legitimate interest (website security, stability, and optimization).

Contact Data

If you contact us via email, we may process:

  • Name
  • Email address
  • Any information you include in your message

Purpose: Responding to inquiries and communication.
Legal basis: Legitimate interest or consent.

We advise that you do not send sensitive personal data via email, as email may not always be fully secure.

Analytics & Usage Data

We analyze website traffic and behavior patterns to improve our services. These analyses are aggregated or anonymized where possible.

Tool used: Google Analytics.
Legal basis: Consent (for analytics cookies) and legitimate interest.

Content Management System

Our website is operated using WordPress. Content submitted through the site may be processed through this system.

Legal basis: Legitimate interest (website operation).


6. Marketing Communications

If you consent, we may send marketing communications by email. You may withdraw consent at any time via the unsubscribe link.

We may also send product information based on your previous purchases, where permitted by law. You can object at any time.


7. Social Media

We maintain social media profiles (e.g., Instagram). When you interact with our profiles, we may process:

  • Public profile data
  • Messages and comments
  • Engagement actions (likes, shares)

We and the social media platform may act as joint controllers for certain processing activities.

Legal basis: Legitimate interest and consent where applicable.


8. Advertising & Tracking Technologies

We use third-party tools and cookies to:

  • Measure advertising performance
  • Show relevant advertisements
  • Improve marketing effectiveness

These tools may process:

  • IP address
  • Browser and device data
  • Interaction data
  • Pixel or cookie IDs

Legal basis: Consent (where required) and legitimate interest.

We may not control how third-party providers further process data after transfer.


9. Data Sharing

Internal recipients

Authorized employees who need access to perform their duties.

External service providers

Including providers that assist with:

  • Website hosting
  • Analytics
  • Marketing
  • Communication tools

Authorities

If required by law or legal process.


10. International Transfers

Where data is transferred outside the European Economic Area, we ensure appropriate safeguards such as:

  • Standard Contractual Clauses
  • Adequacy decisions
  • Equivalent protection measures

11. Data Retention

We retain Personal Data only as long as necessary for the purposes described or to comply with legal obligations.

Statutory retention periods (e.g., tax or commercial law) may require storage for up to 7 years. After expiration, data is securely deleted.


12. Data Security

We implement appropriate technical and organizational security measures to protect Personal Data against:

  • Unauthorized access
  • Loss
  • Misuse
  • Alteration

Despite these measures, no internet transmission is completely secure. If a data breach occurs, we will notify affected individuals when legally required.


13. Your Rights

Under GDPR you have the right to:

  • Access your data
  • Rectify inaccuracies
  • Request erasure
  • Restrict processing
  • Object to processing
  • Data portability
  • Withdraw consent
  • Lodge a complaint

Supervisory authority (Netherlands):
Autoriteit Persoonsgegevens – https://autoriteitpersoonsgegevens.nl

We appreciate the opportunity to address concerns first.


14. What We Do Not Do

We do not:

  • Intentionally collect data from individuals under the legal drinking age
  • Sell Personal Data
  • Use automated decision-making or profiling with legal effects

If we become aware that we have collected data from underage users, it will be deleted without delay.


15. Policy Updates

We may update this Privacy Policy periodically. Changes take effect upon publication.


16. Contact

For any privacy-related questions, please contact us at info@poscoq.com.


Cookie Policy

1. What Are Cookies?

Cookies are small text files placed on your device when visiting websites. They enable functionality, analytics, and personalization.


2. Why We Use Cookies

We use cookies in compliance with:

  • EU ePrivacy Directive
  • Dutch Telecommunications Act
  • GDPR

Where required, we request your consent before placing non-essential cookies.


3. Types of Cookies We Use

Necessary Cookies

Required for website functionality and security.
Legal basis: Legitimate interest.

Analytics Cookies

Help us understand how visitors use our website.
Legal basis: Consent.

Marketing & Social Media Cookies

Used to deliver relevant ads and measure campaign effectiveness.
Legal basis: Consent.


4. Analytics (Google Analytics)

Google Analytics collects information such as:

  • Anonymized IP address
  • Pages visited
  • Time spent
  • Referring websites
  • Interaction patterns

Google states it does not combine your IP address with other Google data.

You can opt out using Google’s browser add-on: http://tools.google.com/dlpage/gaoptout?hl=en


5. Pixel Tags

We may use pixels or similar technologies to:

  • Track website interactions
  • Measure ad performance
  • Improve targeting

These may transmit event data to third-party providers. We and the provider may act as joint controllers for initial collection; the provider becomes controller for subsequent processing.


6. Managing Cookies

You can control cookies by:

  • Adjusting browser settings
  • Using our cookie consent banner
  • Deleting cookies manually

Disabling cookies may affect website functionality.


7. Advertising Opt-Out Tools

You can opt out of behavioral advertising through:

  • European Interactive Digital Advertising Alliance
  • Network Advertising Initiative
  • AdChoices platforms

8. Updates

We may revise this Cookie Policy periodically. Updates take effect when published.


9. Contact

For questions regarding cookies or data protection, contact us at info@poscoq.com.