Privacy Policy

Introduction

1. At Companhia Espirituosa, S.A., we respect the privacy of those who use our products and services, including the websites and applications that we provide. In this document we refer to Companhia Espirituosa, S.A. as "Companhia Espirituosa, S.A.", "we" and "our"; and to you as "you", "you", "you" or "your".

2. This document, the "Privacy Policy", explains how we collect, process and store any personal data that belongs to you, i.e. information that allows us to identify you, such as your name, address, telephone number or email address. This information is referred to in this document as "personal information" or "personal data".

3. Information we collect, how we collect it and how we use it
3.1 Websites

a) Our websites can only be accessed by users who are of legal drinking age. Therefore, when you want to access our sites you must indicate whether you are of legal drinking age in your country. We collect this information only to allow you to access our sites. This information may be temporarily stored by the cookies we use so that on your next visit to our sites you do not have to repeat this process.

b) Our sites use cookies, web beacons, or unique device identifiers that allow us to identify your computer or device, including your browser, operating system and IP address, and track your use of our sites. We use this information to determine the number of users, to understand how users use the sites, and to identify the path you take within the sites in order to continually improve to enable us to provide you with an optimal experience.

c) For more information about the cookies and other technologies that we use, please see our cookie policy, available here.

3.2 Data of minors
We do not knowingly contact or collect information from individuals under the legal drinking age. If you become aware that we have inadvertently collected such information, please contact us so that we may obtain parental consent or remove the information.

Social Networking

We use social media to promote and advertise our products, as well as our Marketing actions. To improve the efficiency of investment in advertising on each platform, we employ cookies from these same social networks. These cookies allow us to make statistical evaluations of our users' behavior on our sites. It is important to note, however, that we cannot identify you based on the usage information from these cookies. Your relationship with social networks is governed by the terms and conditions of those networks. You can also find out how the different social networks protect your personal data in their respective privacy policies.

Will we share information with third parties?

1. Companhia Espirituosa, S.A. subcontracts third parties to process some of the personal data collected. The companies we contract are carefully chosen to ensure that they have procedures in place to comply with data protection legislation.

2. We list below the companies that are subcontracted by Companhia Espirituosa, S.A., as well as the data and the purposes for which the data is communicated to them.

a) Dascat Software, Ltd. (under the brand name 10.digital - www.10.digital) - this company publicizes our marketing and advertising campaigns and manages the hobbies that Companhia Espirituosa, S.A. conducts. Data processing by Dascat Software is safeguarded by the Data Treatment Agreement concluded between Companhia Espirituosa, S.A. and Dascat Software Lda. In this document are outlined the access to data, as well as procedures and best practices that aim to minimize the risk of improper access to your data, as well as information leaks. 

b) The Rocket Science Group (under the brand Mailchimp) - Company that provides the platform used to create, manage and send newsletters from Companhia Espirituosa, S.A. Privacy Policy.

c) Facebook Ireland Limited - Company that owns the social networks (Facebook.com and Instagram.com) used by the Companhia Espirituosa, S.A. for promotion and dissemination. Its relationship with Facebook is governed by the privacy policy of the platforms themselves (Facebook Privacy Policy, Instagram Privacy Policy).

d) Google Ireland Limited - A company which owns several products and a vast online advertising network used by Companhia Espirituosa, S.A. for promotion and publicity. Your relationship with Google is governed by Google's Privacy Policy.

e) Plivo US - Company that provides the service of sending sms for different Bartwist features, such as sending messages to users with QR code links. In this case, the sending of sms's is processed automatically and Plivo only receives the contact number of the person who will receive the text message and the content of the message. Data transmission to Plivo (such as phone number) is done through encrypted channels and following all best practices. You can read more about Plivo's privacy policy here.

f) Sendgrid Inc. - Company that provides the service of sending emails for different functionalities in Bartwist, such as registration confirmation, password recovery and other automatic email communications. The email communications processed by Sendgrid are automatic, and this subcontractor has access to the email addresses to which our system requires these emails to be sent, as well as the content of the email. The transmission of data to Sendgrid (such as the email address) is done through encrypted channels and following all best practices. You can read more about Sendgrid's privacy policy here.

3. Companhia Espirituosa, S.A. may change the list of subcontracted entities at any time.

4. We do not share your data with other companies, for the above purposes or for others.

How do we protect your personal information?

We implement the necessary security measures to ensure the confidentiality of the personal data we collect and process, and to prevent unauthorized disclosure, unauthorized access, loss or destruction of personal data. Please note, however, that no security or encryption method can guarantee complete protection of information against hacking or human error.

Your rights regarding your personal information

1. You may exercise your rights of access, rectification, deletion, limitation and/or portability by means of written communication, accompanied by a document proving your identity and/or the data to be rectified, if applicable, which should be sent to the e-mail address: info@bartwist.com.

2. Opposition to the data processing referred to herein which is communicated to Companhia Espirituosa, S.A. after the start of the same shall take effect only from the date of receipt of such communication and shall not affect the legitimacy of the processing carried out until then.

3. With regard to the exercise of the right to data portability, please note that under applicable law, this right is only applicable in relation to data collected on the basis of your consent.

How to contact us

If you have any questions or concerns about our privacy policy, please contact us at: info@bartwist.com or at the following address:Companhia Espirituosa, S.A. Quinta do Meiral | 3200-095 Lousã | Portugal

Complaints

1. We hope that you do not have any complaints about us or our services. However, if you are unhappy with our use of your personal information please contact us at info@bartwist.com

 

2. You may also lodge a complaint with the National Commission for Data Protection (CNPD) if you believe that the data processing we carry out is not in accordance with the applicable legislation.

Special Situations

1. To provide the service we may need to make personal and anonymous information available to third parties. This will only happen, however, in these specific circumstances:

a) with your express consent;

b) when in good faith we believe required by law;

c) when we believe in good faith that it is necessary to protect our rights or property;

d) when there is a transfer to any successor or purchaser in a merger, acquisition, liquidation, dissolution or sale of assets.

2. Your consent will not be required for disclosure in the situations referred to in (b) through (d); in any event, we will always seek to notify you to the extent permitted by law.

3. This Privacy Policy was last updated on June 6, 2022 but may change from time to time. If the Privacy Policy changes, we will post a notice on our sites. If the change affects registered users, we will send a notification via email, push notification or text.