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PRIVACY POLICY

VOLANTE FREE SPIRITS

 

1. INTRODUCTION

Volante Free Spirits (hereinafter also referred to as the “Controller” or “we”) places particular importance on the protection of personal data of users visiting the website and using the online store operated under the domain volantespirits.com (hereinafter referred to as the “Website” or the “Store”).

This Privacy Policy is intended to provide comprehensive information regarding:

  • the principles of personal data processing,
  • the legal bases for data processing,
  • the methods of collecting and using personal data,
  • the periods for which personal data are stored,
  • the rights of individuals whose data are processed,
  • the rules governing the use of cookies and similar technologies.

This document has been prepared in accordance with:

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR), the Polish Act of 10 May 2018 on Personal Data Protection, regulations concerning electronic communications and privacy in the digital environment, other applicable provisions of European Union law and Polish law.

Personal data means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier (e.g. IP address), or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.

This Privacy Policy applies to all situations in which Volante Free Spirits acts as the controller of personal data, in particular in connection with:

  • operating the website,
  • operating the online store,
  • processing orders,
  • handling inquiries and correspondence,
  • conducting marketing activities,
  • sending newsletters,
  • performing analytical and statistical activities.

This Privacy Policy may be updated periodically due to changes in legal regulations, changes in the operation of the Website, or expansion of the services offered.

2. DATA CONTROLLER

The controller of personal data is:

Volante Free Spirits
Śliwkowa 4
62-002 Suchy Las, Poland
VAT ID (NIP): 7831609026
E-mail: shop@volantespirits.com

The Controller determines the purposes and means of personal data processing in accordance with Article 4(7) of the GDPR.

In matters concerning the processing of personal data, the exercise of data subject rights, or questions regarding this Privacy Policy, you may contact the Controller:

  • electronically: shop@volantespirits.com
  • in writing at the registered address indicated above

The Controller exercises due diligence to ensure the security of personal data and compliance of processing with applicable legal regulations.

3. WHAT PERSONAL DATA DO WE COLLECT?

The scope of processed data depends on how the Website and Store are used.

3.1 Data provided directly by the user

In connection with using the Website, we may process the following data:

a) When placing an order:

  • full name,
  • delivery address,
  • residential address (if different),
  • e-mail address,
  • phone number,
  • invoicing details (including company name and VAT ID if applicable),
  • information regarding ordered products.

b) When creating an account:

  • full name,
  • e-mail address,
  • password (stored in encrypted form),
  • order history.

c) When contacting us via form or e-mail:

  • full name (if provided),
  • e-mail address,
  • phone number (if provided),
  • message content.

d) When subscribing to the newsletter:

  • e-mail address,
  • optionally first name (if provided voluntarily).
3.2 Data collected automatically

When using the Website, the following data may be collected automatically:

  • IP address,
  • date and time of visit,
  • browser type,
  • device type,
  • operating system,
  • activity data within the Website,
  • data stored in cookies.

These data may be processed for technical, analytical, statistical, and marketing purposes.

3.3 Data of minors

The Website and Store are intended exclusively for adults. We do not knowingly process personal data of individuals under the age of 18. If we become aware that such data have been provided, they will be deleted without undue delay.

4. HOW DO WE COLLECT DATA?

Personal data are collected in the following ways:

4.1 Directly from the user

Data are provided voluntarily during:

  • placing an order,
  • creating an account,
  • subscribing to the newsletter,
  • sending an inquiry via the contact form,
  • contacting us via e-mail,
  • participating in promotional campaigns or contests (if organized).

Providing data is voluntary; however, in some cases it is necessary to conclude and perform a contract (e.g. processing an order).

4.2 Automatically via IT technologies

Data may be collected automatically through:

  • cookies,
  • server logs,
  • analytical tools,
  • marketing tools.

This information is used to:

  • ensure proper functioning of the Website,
  • analyze website traffic,
  • improve service quality,
  • personalize content and advertisements (where consent has been given).
4.3 From third parties

In certain cases, data may be obtained from payment processors, courier companies, or IT service providers, solely to the extent necessary for the performance of a contract.

5. PURPOSES AND LEGAL BASES FOR DATA PROCESSING

The Controller processes personal data only for specific, explicit, and legitimate purposes, in accordance with the principles set out in Articles 5 and 6 of the GDPR. Depending on the user’s relationship with the Controller, personal data may be processed for the following purposes:

5.1 Performance of a sales contract and order processing

In particular for the purposes of:

  • accepting and processing orders,
  • handling payments,
  • arranging delivery,
  • contacting the user regarding order fulfillment,
  • handling returns and complaints.

Legal basis:
Article 6(1)(b) GDPR – processing necessary for the performance of a contract or to take steps prior to entering into a contract. Providing personal data in this scope is a condition for concluding a contract. Failure to provide such data will make it impossible to process the order.

5.2 Compliance with legal obligations

In particular for the purposes of:

  • issuing and storing invoices,
  • maintaining accounting documentation,
  • fulfilling tax obligations,
  • providing information to authorized public authorities.

Legal basis:
Article 6(1)(c) GDPR – processing necessary for compliance with a legal obligation to which the Controller is subject.

5.3 Handling inquiries and communication

When contacting us via contact form, e-mail, or telephone, personal data are processed for the purpose of:

  • responding to inquiries,
  • conducting correspondence,
  • handling requests.

Legal basis:
Article 6(1)(f) GDPR – the Controller’s legitimate interest consisting of maintaining communication with users.

5.4 Marketing of our own products and services

Personal data may be processed for the purpose of:

  • sending newsletters,
  • sending commercial information,
  • informing users about promotions and new products,
  • conducting remarketing activities.

Legal bases:

Article 6(1)(a) GDPR – user consent (e.g. newsletter subscription),

Article 6(1)(f) GDPR – the Controller’s legitimate interest in marketing its own products, provisions concerning electronic communications – with respect to required marketing consents.

The user has the right to withdraw consent at any time or object to direct marketing.

5.5 Analytical and statistical purposes

Automatically collected data (e.g. IP address or website traffic data) may be processed in order to:

  • analyze the functioning of the Website,
  • improve the quality of services,
  • optimize the Website,
  • ensure the security of IT systems.

Legal basis:
Article 6(1)(f) GDPR – the Controller’s legitimate interest consisting of developing and securing the Website.

5.6 Establishment, exercise, or defense of legal claims

Personal data may be processed for the purpose of:

  • pursuing claims,
  • defending against claims,
  • conducting judicial or administrative proceedings.

Legal basis:
Article 6(1)(f) GDPR – the Controller’s legitimate interest.

5.7 Profiling

As part of marketing activities, personal data may be used for profiling, either automated or non-automated, in order to tailor marketing content to the user’s interests. Profiling does not produce legal effects concerning the user nor significantly affect their situation.

6. DATA SHARING

Personal data may be transferred to third parties only to the extent necessary for the purposes of processing and on the basis of appropriate data processing agreements, in accordance with Article 28 of the GDPR.

Data may be shared in particular with:

6.1 Entities supporting the Controller’s operations
  • hosting and IT service providers,
  • electronic payment system operators,
  • accounting firms and bookkeeping service providers,
  • courier companies and postal operators,
  • mailing system providers,
  • providers of analytical and marketing tools.

These entities process personal data solely in accordance with the Controller’s instructions and only to the extent necessary to perform the services entrusted to them.

6.2 Public authorities

Personal data may be disclosed to public authorities, courts, or other authorized entities when required under applicable law.

6.3 Transfers of data outside the EEA

If, in connection with the use of IT tools, personal data were to be transferred outside the European Economic Area (EEA) (for example to the United States), the Controller ensures the use of appropriate safeguards required by the GDPR, in particular:

  • Standard Contractual Clauses (SCC),
  • adequacy decisions issued by the European Commission,
  • other mechanisms provided for in Articles 44–49 of the GDPR.

The Controller does not sell users’ personal data.

7. HOW LONG DO WE RETAIN PERSONAL DATA?

Personal data are stored only for the period necessary to achieve the purposes of processing, taking into account applicable legal regulations. The retention period depends on the purpose of processing:

7.1 Data related to contract performance

Stored for the duration of the contract and after its termination for the period of limitation of claims under civil law (generally 6 years).

7.2 Accounting and tax data

Stored for the period required by tax and accounting regulations (generally 5 years from the end of the relevant tax year).

7.3 Data processed on the basis of consent

Stored until consent is withdrawn.

7.4 Data processed on the basis of legitimate interest

Stored until an effective objection is raised or the purpose of processing ceases to exist.

7.5 Analytical and technical data

Stored for the period necessary to achieve statistical purposes and ensure the security of IT systems. After the above retention periods expire, personal data are deleted or anonymized in a way that prevents identification of the individual.

8. YOUR RIGHTS

In accordance with Regulation (EU) 2016/679 (GDPR), every person whose personal data are processed has specific rights. Within the scope provided by law, you have the following rights:

8.1 Right of access to data

You have the right to obtain confirmation as to whether we process your personal data and, if so, to access those data and information regarding their processing.

8.2 Right to rectification

You have the right to request the immediate correction of inaccurate personal data or to complete incomplete data.

8.3 Right to erasure (“right to be forgotten”)

You have the right to request the deletion of personal data if:

  • the data are no longer necessary for the purposes for which they were collected,
  • you withdraw the consent on which the processing is based,
  • you successfully object to the processing,
  • the data have been processed unlawfully.

This right may be limited if processing is necessary to comply with a legal obligation or to establish, pursue, or defend legal claims.

8.4 Right to restriction of processing

You have the right to request restriction of processing in cases specified in Article 18 of the GDPR.

8.5 Right to data portability

For data processed on the basis of consent or contract and in an automated manner, you have the right to receive the data in a structured, commonly used format and to transfer them to another controller.

8.6 Right to object

You have the right to object to processing based on the Controller’s legitimate interest. If data are processed for direct marketing purposes, the objection is effective without the need to provide justification.

8.7 Right to withdraw consent

Where processing is based on consent, you have the right to withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.

8.8 Right to lodge a complaint

You have the right to lodge a complaint with the President of the Personal Data Protection Office (UODO) if you believe that the processing of personal data violates legal provisions. To exercise your rights, you may contact the Controller at: shop@volantespirits.com The Controller may request confirmation of identity in order to protect personal data against unauthorized access.

9. COOKIES AND SIMILAR TECHNOLOGIES

The Website uses cookies and other similar technologies (such as tracking pixels and web beacons).

9.1 What are cookies?

Cookies are small text files stored on a user’s device (computer, smartphone, or tablet) while using the Website.

9.2 Purposes of using cookies

Cookies may be used for the following purposes:

  • ensuring the proper functioning of the Website,
  • maintaining user sessions,
  • remembering user preferences,
  • conducting statistical analyses,
  • optimizing the performance of the Website,
  • conducting marketing and remarketing activities (after obtaining user consent).
9.3 Types of cookies used

a) Essential cookies

These are necessary for the proper functioning of the Website and do not require user consent.

b) Functional cookies

These allow the Website to remember selected settings and user preferences.

c) Analytical cookies

These allow us to analyze how users interact with the Website in order to improve it.

d) Marketing cookies

These are used to display advertising content tailored to the user’s interests.

9.4 Legal basis for the use of cookies

Essential cookies – Article 6(1)(f) GDPR (legitimate interest).

Analytical and marketing cookies – Article 6(1)(a) GDPR (user consent).

Consent may be expressed via a consent management tool (cookie banner) and may be withdrawn at any time.

9.5 Managing cookies

Users may:

  • change cookie settings in their browser,
  • delete stored cookies,
  • withdraw consent via the cookie banner settings.

Limiting the use of cookies may affect the functionality of the Website.

10. DATA SECURITY

The Controller applies appropriate technical and organizational measures to ensure a level of security appropriate to the risk to the rights and freedoms of individuals. In particular, the following measures are applied:

  • encryption of data transmission (SSL),
  • protection of IT systems,
  • restricted access to data only for authorized persons,
  • access management procedures,
  • regular system updates.

The Controller undertakes measures to protect data against:

  • unauthorized access,
  • loss,
  • destruction,
  • unauthorized modification.

11. EXTERNAL LINKS

The Website may contain links to other websites, including social media platforms or business partners. The Controller is not responsible for the data processing policies of those websites. Users are encouraged to review the privacy policy of each external website they visit.

12. CHANGES TO THE PRIVACY POLICY

The Controller reserves the right to make changes to this Privacy Policy, in particular in the event of:

  • changes in legal regulations,
  • changes in the operation of the Website,
  • expansion of the services offered,
  • implementation of new technological tools.

The current version of the Privacy Policy will always be published on the Website. In the event of significant changes, users may be informed via a notice on the Website or electronically (where applicable). This version of the Privacy Policy is effective as of:

2 March 2026