The Pure Essence Distillery Oy, a company incorporated and operatingunder the laws of Finland (hereinafter, the “Company”) recognizes theimportance of the privacy of those using its own websites, and is committed tosafeguarding your privacy. With this privacy policy (hereinafter the “PrivacyPolicy”) regarding the website pureessence.fi (hereinafter the “Site”) theCompany provides users with details of the data controller, of the personaldata collected through the Site, of the purposes of the processing of suchpersonal data, and of the means by which such processing is accomplished, ofany third parties involved in the processing, of any transfer abroad of suchdata, of the security measures adopted to protect the collected data, and ofthe manner in which the user may check the processing of those data regardinghim/her, and may exercise his/her rights under the EU regulation n. 2016/679(hereinafter “GDPR”).
When you use the Site, you agree to allow us to collect, use, and share yourinformation, as we describe in this Privacy Policy. If you do not agree, pleasedo not access or use the Site.

1. INFORMATION WE COLLECT
There are several ways we may obtain information about you, including through(A) information you provide to us directly; (B) information we automatically collect. This includes data that identifies you personally, whether directly(i.e., your name) or indirectly (i.e., information about your online use).
A) Information You Provide
the Company collects certain information from you when you directly provide itto us. This may include when you create an account with us, make a purchasethrough our Site, request information from us, sign up for newsletters or oure-mail list, enter into sweepstakes or other promotions, request customersupport, or otherwise communicate with or contact us directly. This informationmay include the following:
• Contact details including your name, address, email address, and telephone ormobile number;
• Login and account information, including username, password, and unique userID; and
• Billing and payment data, including credit card data; and
• Personal preferences, such as marketing preferences.
B) Information Automatically Collected
The Company collects the personal data of users visiting and consulting theSite, the so-called browsing data. The technological platform by means of whichthe Site is made available to the user, in fact automatically records certainbrowsing data – the transmission of which is implicit in the use of Internetcommunications protocols – such as, for example, the name of the Internetaccess provider, the source website, the pages visited, the date and durationof each visit, etc. Such information permits access to the Site and the use ofcertain services, and this information may be utilized in an anonymous andaggregated form for statistical purposes and in order to verify the correctfunctioning of the Site.
The Company does not collect such data in order to associate them with otherinformation about users, and subsequently to identify such users; nevertheless,the data in question, by their very nature, may permit the identification ofusers following processing and association with other information. Browsingdata may thus be used by the Company to ascertain whether any liability existsregarding computer crimes committed to the detriment of the Site, or by meansof the Site. Without prejudice to such event, the aforementioned browsing dataare only stored temporarily, in accordance with applicable law.
Whenever you visit or interact with the Site, the Company, as well asthird-party service providers, may use cookies, web beacons, pixel tags, logfiles, or other technologies to automatically or passively collect informationabout your online activity. For information about our use of cookies and othersimilar technologies through the Site, you can read our Cookie Policy.
Please note that the Company or our service providers may automatically collectthe following information about you:
• Computer or Device Information: We may automatically collect your InternetProtocol (“IP”) address or other unique identifier or information from thecomputer, mobile device, tablet or other device you use to access the Site,including, but not limited to, your browser type, device type, operatingsystem, software version, phone model, phone operating system, and the domainname from which you accessed the Site.
• Usage Information. We may collect information about how you use the Site,including: the date and time you visit the Site; what areas or pages of theSite you visit; the amount of time you spend visiting the Site; the number oftimes you return to the Site; other information about where you click on theSite; whether you open, forward, or click on links in emails we send; and anyother Site you may visit.
• Location Information. We collect general information about where traffic andpurchases on our site are coming from around the world. We use this informationat an aggregate level (meaning the information does not identify individualusers) to create reports to better understand how we engage with users.
• Service Providers. We may use service providers to support our Site. Some ofthese service providers may use technology such as cookies, web beacons, pixeltags, log files, Flash cookies, or HTML5 cookies to receive, collect, and storeinformation.
C. Combination of Information
We may combine the information we receive from and about you, includinginformation you provide to us, information we automatically collect through ourSites, information collected offline, information collected across othercomputers or devices that you may use, and information from third partysources.

2. INFORMATION USE
The Company may use the information we collect from and about you for a varietyof business purposes. These include to respond to your customer servicerequests, to improve customer experience and engagement, and to enhance orimprove our content, products, and services. We are committed to protecting andmaintaining the privacy of your information. Therefore, we will process yourdata only in accordance with applicable data protection law and this PrivacyPolicy.
Where necessary under applicable law, we will have a lawful basis to processyour data if:
-You have consented to such processing;
-We have a legitimate interest for processing your data – e.g., for dataanalytics purposes; fraud prevention; direct marketing; network and informationsystems security; enhancing or improving our content, products, and services;identifying usage trends; and determining the effectiveness of promotionalcampaigns; and/or
-We are legally obligated to process it.
We may use the information we collect from and about you to:
-Respond to your inquiries and contact you when necessary;
-Enhance your online experience, including as a way to recognize you andwelcome you to the Site;
-Review the usage and operations of our Site, develop new products or services,and conduct analysis to enhance or improve our content, products, and services;
-Provide you with customized content, targeted offers, and advertising on theSite, via email, text message or push notification, or across other websites orsocial media;
-Administer any orders that you have placed with us and process payments;
-Communicate with you about your purchase;
-Register and manage your account(s) with us;
-Contact you with information, newsletters, and promotional materials;
-Use your data in an aggregated non-specific format for analytical anddemographic purposes (this processing may involve profiling – for example tocreate audiences based on demographic or location-based information formarketing and customization purposes);
-Address problems with the Site or our business, and to protect the security orintegrity of the Site and our business; or
-For other purposes disclosed at the time you provide your information orotherwise with your consent.
Additionally, if you use the Site to connect with any third-party services(e.g., social media Site), you authorize us to use information from and aboutyou, on your behalf, to interact with these third-party services based on yourrequests.

3. INFORMATION SHARED
A) Information You Share
The Site offers many ways to find, enjoy, and share content. Your activity inconnection with the Site may include filling out surveys, reviewing and ratingproducts, inquiring about or purchasing products, participating in onlinecommunities, “liking” or “sharing” our content on your social media accounts orotherwise interacting with the Company. Any information you may disclose on ourSite, in blogs, on message boards, in chat rooms, or in other public areas ofthe Site or other third-party websites, applications, or services that the Sitemay link to, becomes public information. Please exercise caution whendisclosing personal information in these public areas.
B) Information We Share
We may share your personal information with:
-Affiliates: We may share your information with the Company affiliates andsubsidiaries for business, operational, promotional, and marketing purposes.
– Third parties. We may share your information with such as professionals,consultants and more generally third parties who cooperate with the Company forthe pursuit of the above purposes, or third parties who have been entrustedwith activities in outsourcing.
-Service Providers: We may share your information with service providers thatprovide business, professional or technical support functions for us, help usoperate our business and the Site, or administer activities on our behalf.
-Sweepstakes, Contests, and Promotions: If you choose to enter into one of oursweepstakes, contests, or other promotions (a “Promotion”) we may disclose yourinformation to third parties or the public in connection with administering thePromotion, as required by law, as otherwise permitted by the Promotion’sofficial rules, or otherwise in accordance with the terms of this PrivacyPolicy.
-Legal Obligations; Safety: We may access and disclose your information torespond to subpoenas, judicial processes, or government requests andinvestigations, or in connection with an investigation on matters related topublic safety, as permitted by law, or otherwise as required by law. We maydisclose your information to protect the security of our Site, servers, networksystems, and databases. We also may disclose your information as necessary, ifwe believe that there has been a violation of our Terms of Use, any other legaldocument or contract related to our services, or the rights of any third party.
-Sale or Transfer of Business or Assets: We may sell or purchase assets duringthe normal course of our business. If another entity acquires us or any of ourassets, information we have collected about you may be transferred to suchentity. In addition, if any bankruptcy or reorganization proceeding is broughtby or against us, such information may be considered an asset of ours and maybe sold or transferred to third parties. Should such a sale or transfer occur,we will use reasonable efforts to try to require that the transferee usepersonal information provided through this Site in a manner that is consistentwith this Privacy Policy.
-Aggregate or Anonymous Non-Personal Information: We may also share aggregate,anonymous, or de-identified non-personal information with third parties fortheir marketing or analytics uses.
-Other: We also may share your information as disclosed to you at the time ofcollection.

4. HOW LONG YOUR INFORMATION IS RETAINED
We will retain your individual personal data only as long as we need it for thepurpose for which we are processing it. For example, when you contact us with acomplaint, query, or other concern, we will retain your information for as longas needed to respond to your query. We may use data aggregated by GoogleAnalytics indefinitely without further notice to you.
We will periodically review the personal information we hold and delete itsecurely, or in some cases anonymize it, when there is no longer a legal,business, or consumer need for us to retain it. When we anonymize data, we mayretain such data indefinitely without further notice to you.

5. PROCESSING METHODS
The user’s personal data are processed by computer and telematic methods,mainly by electronic and automated means and, and, limited to particularoperations, by paper.
In accordance with the GDPR, specific security measures are observed to preventdata loss, unlawful or improper use, and unauthorized access.

6. YOUR RIGHTS
A) For EEA Residents
We respect your privacy rights and provide you with reasonable access andrights to the personal data (as defined in the GDPR) that you may have sharedwith us. If you live in the EEA, and wish to access, amend, delete, or transferany personal data we hold about you, you may contact us as set forth in the“Contact Us” section.
At any time, you may object to the processing of your Personal Data onlegitimate grounds, but we reserve the right to proceed with the processing ifotherwise permitted by applicable law. If you believe we have infringed uponyour right to privacy granted by applicable data protection laws, pleasecontact us to the following e-mail: privacy@pureessence.fi. You also have aright to lodge a complaint with data protection authorities.

B) For California Residents
California law permits residents of California to request certain details abouthow the Company shares their personal information with third parties oraffiliated companies for direct marketing purposes. If you are a Californiaresident and would like to make such a request, please contact us at: privacy@pureessence.You must put the statement “Your California Privacy Rights” in the subjectline. We are not responsible for notices that are not properly sent, or that donot have complete information.
California residents may also take advantage of the following rights:
-You may request, up to two times each year, that we disclose to you: (1) thecategories and specific pieces of personal information that we have collectedabout you; (2) the categories of sources from which we collect your personalinformation; (3) the business or commercial purpose for collecting yourpersonal information; (4) the categories of third parties with whom we haveshared your personal information; and (5) the business or commercial purposefor selling your personal information, if applicable.
-You may also request that we delete any personal information we have collectedfrom or about you. There are some reasons we will not be able to fully addressyour request, such as if we need to complete a transaction for you, to detectand protect against fraudulent and illegal activity, to exercise our rights, orto comply with a legal obligation.
We offer the following way for you to make such a request (“Data AccessRequest” and “Deletion Request”) free of charge:
-Send an e-mail to privacy@pureessence. You must put the statement “YourCalifornia Privacy Rights” in the subject field and include data access requestor deletion request. We are not responsible for requests that are not labeledor sent properly, or that do not have complete information.
In order for us to fulfill your Data Access Request or Deletion Request, wewill need to verify that you are who you say you are and that we indeed collector retain your personal information on our systems. For verification purposes,we will attempt to match information that you provide to us with information wealready have in our records. We will not be able to delete or provide you withaccess to your personal information unless we are able to verify your identity.We will respond to your request within 45 days of receiving your request, afterproper verification, unless we need additional time, in which case we will letyou know. We value your privacy and will not discriminate against you inresponse to you exercising your privacy rights.
An authorized agent may submit a request on your behalf, after submission ofproof of authorization in accordance with California law.
For purposes of compliance with the California Consumer Privacy Act, inaddition to the further details as described throughout this Privacy Policy, wemake the following disclosures:
-We collect the following categories of personal information:identifiers/contact information, commercial information, internet or otherelectronic network activity information, geolocation, visual and audio information,age, gender, and inferences drawn from the above.
-We disclose the following categories of information for a business purpose:identifiers/contact information, commercial information, internet or otherelectronic network activity information, geolocation, visual and audioinformation, and inferences drawn from the above.
C) Cookies; Tracking
Certain parts of our Site require cookies. You are free to adjust your deviceor Internet browser settings to limit certain tracking or to decline cookies. Pleaserefer to your device’s settings or your Internet browser’s “Help” section formore information on how to delete and/or disable your device or browser fromreceiving cookies or controlling your tracking preferences. Our system may notrespond to Do Not Track requests or headers from some or all Internet browsers.For more information about how we collect and use cookies, and how you cancontrol how we use certain cookies, see our Cookie Policy.

7. LINKS
The Sites may have links to third-party websites, which may have privacypolicies that differ from our own. We are not responsible for the practices ofsuch sites. By adhering to the proposals of the aforementioned third parties,the user may access multimedia pages belonging exclusively to these thirdparties, which, being outside the control of the Data Controller, are not inany way required to comply with the provisions of this Privacy Policy.
The Company therefore invite users to pay attention to adhering to the servicesoffered by third parties and to read the information notices provided by thethird party regarding the processing of personal data carried out by the same,in relation to which the Company cannot carry out any control, nor be heldresponsible.

8. DATA SECURITY
We have taken certain physical, administrative, and technical steps tosafeguard the information we collect from and about our visitors to the Site.While we make every effort to help ensure the integrity and security of ournetwork and systems, we cannot guarantee our security measures.

9. INTERNATIONAL TRANSFERS
Since the Company is working globally, Site covered by this policy attractusers from all over the world. The Company is based in Finland. Therefore, ifyou choose to give us personal information, we will process that information inthe European Union.
To ensure that we adequately protect your data, we only transfer your datasubject to suitable safeguards being in place. In particular, we transfer yourinformation outside the EEA through the use of standard contractual clauses andwe make sure that any such transfers are conducted in accordance withapplicable laws and using adequate and appropriate safeguards.

10. REVISIONS TO THIS PRIVACY POLICY
We reserve the right, at our sole discretion, to change, modify, add, remove,or otherwise revise portions of this Privacy Policy at any time. When we do, wewill post the change(s) on the Sites. Your continued use of the Sites followingthe posting of changes to these terms means you accept these changes.

11. DATA CONTROLLER
Data controller is The Pure Essence Distillery Oy, a Finnish limited liabilitycompany with registered office at Tehtaantie 3, 91800 Tyrnävä, Finland.

12. CONTACT
Data controller can be contacted at the following e-mail address: privacy@pureessence.

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