Full policy

Owner and Data Controller

The Mindful Drinking Company Limited t/a AlcoholFree.com. Registered company address: 27 Unit E26 Enterprise Village Prince Albert Gardens, Grimsby, DN31 3AT. Company No: 11950570.

Owner contact email: info@alcoholfree.com

Types of Data collected

Among the types of Personal Data that AlcoholFree.com and related sub-sites collects, by itself or through third parties, there are: Usage Data; Tracker; email address; first name; last name; phone number; profession; county; state; country; ZIP/Postal code; gender; date of birth; city; physical address; company name; website; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); VAT Number; various types of Data; Tax ID; field of activity; User ID; number of employees; username; Data communicated while using the service; password; geographic position; profile picture; device information; workplace; payment info; purchase history; billing address; shipping address; language; answers to questions; name; marital status; social media accounts ; picture; prefix ; academic background; Twitter handle; house number; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using AlcoholFree.com and related sub-sites.
Unless specified otherwise, all Data requested by AlcoholFree.com and related sub-sites is mandatory and failure to provide this Data may make it impossible for AlcoholFree.com and related sub-sites to provide its services. In cases where AlcoholFree.com and related sub-sites specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by AlcoholFree.com and related sub-sites or by the owners of third-party services used by AlcoholFree.com and related sub-sites serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through AlcoholFree.com and related sub-sites and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of AlcoholFree.com and related sub-sites (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or enquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Displaying content from external platforms, Analytics, Contacting the User, Advertising, Commercial affiliation, Content commenting, Data transfer outside of the UK, Handling activities related to productivity, Handling payments, Interaction with external social networks and platforms, Location-based interactions, Managing contacts and sending messages, Managing data collection and online surveys, Managing support and contact requests, Registration and authentication, Registration and authentication provided directly by AlcoholFree.com and related sub-sites, Remarketing and behavioural targeting and SPAM protection.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• Advertising

  This type of service allows User Data to be utilised for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on AlcoholFree.com and related sub-sites, possibly based on User interests.
  This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
  Some of the services listed below may use Trackers to identify Users or they may use the behavioural retargeting technique, i.e. displaying ads tailored to the User’s interests and behaviour, including those detected outside AlcoholFree.com and related sub-sites. For more information, please check the privacy policies of the relevant services.
  Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

  Facebook Lookalike Audience (Facebook Ireland Ltd)

  Facebook Lookalike Audience is an advertising and behavioural targeting service provided by Facebook Ireland Ltd that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behaviour to Users who are already in a Custom Audience list on the base of their past use of AlcoholFree.com and related sub-sites or engagement with relevant content across the Facebook apps and services.
  On the base of these Data, personalised ads will be shown to Users suggested by Facebook Lookalike Audience.

  Users can opt out of Facebook's use of Trackers for ads personalisation by visiting this opt-out page.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy – Opt Out.

  JSDELIVR (jsdelivr.com)

  JSDELIVR is an advertising service provided by jsdelivr.com.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

• Analytics

  The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

  Google Analytics (Google LLC)

  Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilises the Data collected to track and examine the use of AlcoholFree.com and related sub-sites, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualise and personalise the ads of its own advertising network.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out.

  Google Analytics Advertising Reporting Features (Google LLC)

  Google Analytics on AlcoholFree.com and related sub-sites has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyse specific behaviour and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).

  Users can opt out of Google's use of cookies by visiting Google's Ads Settings.

  Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy – Opt Out.

• Commercial affiliation

  This type of service allows AlcoholFree.com and related sub-sites to display advertisements for third-party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics.
  Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with AlcoholFree.com and related sub-sites.
  For details of which data are collected, please refer to the privacy policy of each service.

  Amazon Affiliation

  Amazon Affiliation is a commercial affiliation service provided by Amazon.com Inc.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy; Luxembourg – Privacy Policy.

• Contacting the User

  Mailing list or newsletter (AlcoholFree.com and related sub-sites)

  By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning AlcoholFree.com and related sub-sites. Your email address might also be added to this list as a result of signing up to AlcoholFree.com and related sub-sites or after making a purchase.

  Personal Data processed: city; company name; country; county; date of birth; email address; first name; gender; last name; phone number; physical address; profession; state; Tracker; Usage Data; website; ZIP/Postal code.

  Contact form (AlcoholFree.com and related sub-sites)

  By filling in the contact form with their Data, the User authorises AlcoholFree.com and related sub-sites to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

  Personal Data processed: city; company name; country; county; date of birth; email address; field of activity; first name; gender; last name; number of employees; phone number; physical address; profession; state; Tax ID; User ID; various types of Data; VAT Number; website; ZIP/Postal code.

  Phone contact (AlcoholFree.com and related sub-sites)

  Users that provided their phone number might be contacted for commercial or promotional purposes related to AlcoholFree.com and related sub-sites, as well as for fulfilling support requests.

  Personal Data processed: phone number.

• Content commenting

  Content commenting services allow Users to make and publish their comments on the contents of AlcoholFree.com and related sub-sites.
  Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
  If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

  Comment system managed directly (AlcoholFree.com and related sub-sites)

  AlcoholFree.com and related sub-sites has its own internal content comment system.

  Personal Data processed: email address; first name; last name; phone number; Tracker; Usage Data; username; website.

  Facebook Comments (Facebook Ireland Ltd)

  Facebook Comments is a content commenting service provided by Facebook Ireland Ltd enabling the User to leave comments and share them on the Facebook platform.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy.

• Data transfer outside of the UK

  The Owner is allowed to transfer Personal Data collected within the UK to third countries only subject to specific legal requirements (so-called "restricted transfers"). Restricted transfers may take place according to the conditions specified below.

  Users can enquire with the Owner to learn which legal basis applies to which specific service.

  Data transfer abroad based on standard contractual clauses (UK) (AlcoholFree.com and related sub-sites)

  If this is the legal basis, the transfer of Personal Data from the UK to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.

  This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation, which are recognized as valid also under UK law. For further information, Users are requested to contact the Owner through the contact details provided in the present document.

  Personal Data processed: various types of Data.

  Data transfers according to a UK adequacy regulation (AlcoholFree.com and related sub-sites)

  If this is the legal basis, the transfer of Personal Data from the UK to third countries may take place according to a so called “adequacy regulation” of the UK Government.

  The UK Government adopts adequacy regulations for specific countries or territories whenever such countries or territories guarantee Personal Data protection standards comparable to those set forth by UK data protection legislation. Users can find an updated list of all adequacy regulations on the website of the Information Commissioner’s Office (ICO).

  Personal Data processed: various types of Data.

• Displaying content from external platforms

  This type of service allows you to view content hosted on external platforms directly from the pages of AlcoholFree.com and related sub-sites and interact with them.
  This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

  Google Fonts (Google LLC)

  Google Fonts is a typeface visualisation service provided by Google LLC that allows AlcoholFree.com and related sub-sites to incorporate content of this kind on its pages.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Font Awesome (Fonticons, Inc. )

  Font Awesome is a typeface visualisation service provided by Fonticons, Inc. that allows AlcoholFree.com and related sub-sites to incorporate content of this kind on its pages.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Google Maps widget (Google LLC)

  Google Maps is a maps visualisation service provided by Google LLC that allows AlcoholFree.com and related sub-sites to incorporate content of this kind on its pages.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Gravatar

  Gravatar is an image visualisation service provided by Automattic Inc. or by Aut O’Mattic A8C Ireland Ltd., depending on how the Owner manages the Data processing, that allows AlcoholFree.com and related sub-sites to incorporate content of this kind on its pages.
  Please note that if Gravatar images are used for comment forms, the commenter's email address or parts of it may be sent to Gravatar - even if the commenter has not signed up for that service.

  Personal Data processed: email address; Usage Data.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  YouTube video widget (Google LLC)

  YouTube is a video content visualisation service provided by Google LLC that allows AlcoholFree.com and related sub-sites to incorporate content of this kind on its pages.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

• Handling activities related to productivity

  This type of service helps the Owner to manage tasks, collaboration and, in general, activities related to productivity. In using this type of service, Data of Users will be processed and may be retained, depending on the purpose of the activity in question.
  These services may be integrated with a wide range of third-party services disclosed within this privacy policy to enable the Owner to import or export Data needed for the relative activity.

  Google Sheets (Google LLC)

  Google Sheets is an online spreadsheet and collaboration service provided by Google LLC.

  Personal Data processed: city; company name; country; Data communicated while using the service; date of birth; device information; email address; first name; gender; geographic position; last name; password; phone number; physical address; profession; profile picture; Tracker; Usage Data; username; VAT Number; workplace; ZIP/Postal code.

  Place of processing: United States – Privacy Policy.

• Handling payments

  Unless otherwise specified, AlcoholFree.com and related sub-sites processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. AlcoholFree.com and related sub-sites isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

  PayPal (PayPal Inc.)

  PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

  Personal Data processed: billing address; device information; email address; first name; last name; payment info; phone number; purchase history; Tracker; Usage Data; username; various types of Data as specified in the privacy policy of the service.

  Place of processing: See the PayPal privacy policy – Privacy Policy.

  GoCardless (GoCardless Limited)

  GoCardless is a payment service provided by GoCardless Limited.

  Personal Data processed: billing address; email address; first name; last name; payment info; phone number; shipping address; Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

• Interaction with external social networks and platforms

  This type of service allows interaction with social networks or other external platforms directly from the pages of AlcoholFree.com and related sub-sites.
  The interaction and information obtained through AlcoholFree.com and related sub-sites are always subject to the User’s privacy settings for each social network.
  This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
  It is recommended to log out from the respective services in order to make sure that the processed data on AlcoholFree.com and related sub-sites isn’t being connected back to the User’s profile.

  Facebook Like button and social widgets (Facebook Ireland Ltd)

  The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook Ireland Ltd

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy.

  LinkedIn button and social widgets (LinkedIn Corporation)

  The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  PayPal button and widgets (PayPal Inc.)

  The PayPal button and widgets are services allowing interaction with the PayPal platform provided by PayPal Inc.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: See the PayPal privacy policy – Privacy Policy.

  Twitter Tweet button and social widgets (Twitter, Inc.)

  The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Reddit button and widgets (reddit inc.)

  The reddit button and widgets are services allowing interaction with the reddit platform provided by reddit inc.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Pinterest “Pin it” button and social widgets (Pinterest, Inc.)

  The Pinterest “Pin it” button and social widgets are services allowing interaction with the Pinterest platform provided by Pinterest Inc.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

• Location-based interactions

  Geolocation (AlcoholFree.com and related sub-sites)

  AlcoholFree.com and related sub-sites may collect, use, and share User location Data in order to provide location-based services.
  Most browsers and devices provide tools to opt out from this feature by default. If explicit authorisation has been provided, the User’s location data may be tracked by AlcoholFree.com and related sub-sites.

  Personal Data processed: geographic position.

• Managing contacts and sending messages

  This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
  These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  Amazon Simple Email Service

  Amazon Simple Email Service is an email address management and message sending service provided by Amazon.com Inc.

  Personal Data processed: email address.

  Place of processing: United States – Privacy Policy; Luxembourg – Privacy Policy.

  ZOHO Campaigns (ZOHO Corporation B.V)

  ZOHO Campaigns is an email address management and message sending service provided by ZOHO Corporation B.V.

  Personal Data processed: city; company name; country; date of birth; email address; first name; gender; language; last name; phone number; physical address; state; Tracker; Usage Data; username.

  Place of processing: Netherlands – Privacy Policy.

• Managing data collection and online surveys

  This type of service allows AlcoholFree.com and related sub-sites to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
  The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.

  These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.

  Data provided via online forms, managed directly (AlcoholFree.com and related sub-sites)

  AlcoholFree.com and related sub-sites makes use of online forms that can be used to collect Data about Users.

  Personal Data processed: answers to questions; billing address; city; country; date of birth; gender; marital status; name; payment info; phone number; physical address; profession; social media accounts ; Tracker; workplace.

• Managing support and contact requests

  This type of service allows AlcoholFree.com and related sub-sites to manage support and contact requests received via email or by other means, such as the contact form.
  The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).

  ZOHO CRM Email (ZOHO Corporation B.V)

  ZOHO CRM Email is a support and contact request management service provided by ZOHO Corporation B.V.

  Personal Data processed: Data communicated while using the service; various types of Data as specified in the privacy policy of the service.

  Place of processing: Netherlands – Privacy Policy.

• Registration and authentication

  By registering or authenticating, Users allow AlcoholFree.com and related sub-sites to identify them and give them access to dedicated services.
  Depending on what is described below, third parties may provide registration and authentication services. In this case, AlcoholFree.com and related sub-sites will be able to access some Data, stored by these third-party services, for registration or identification purposes.
  Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

  WordPress.com Single Sign On (Automattic Inc.)

  WordPress.com Single Sign On is a registration and authentication service provided by Automattic Inc. and is connected to the WordPress.com network.

  Personal Data processed: Tracker; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

• Registration and authentication provided directly by AlcoholFree.com and related sub-sites

  By registering or authenticating, Users allow AlcoholFree.com and related sub-sites to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.

  Direct registration (AlcoholFree.com and related sub-sites)

  The User registers by filling out the registration form and providing the Personal Data directly to AlcoholFree.com and related sub-sites.

  Personal Data processed: academic background; billing address; city; company name; country; county; date of birth; email address; field of activity; first name; gender; house number; language; last name; number of employees; password; phone number; physical address; picture; prefix ; profession; profile picture; state; Tax ID; Tracker; Twitter handle; Usage Data; User ID; username; various types of Data; VAT Number; website; workplace; ZIP/Postal code.

• Remarketing and behavioural targeting

  This type of service allows AlcoholFree.com and related sub-sites and its partners to inform, optimise and serve advertising based on past use of AlcoholFree.com and related sub-sites by the User.
  This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioural targeting activity.
  Some services offer a remarketing option based on email address lists.
  In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

  Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

  Facebook Custom Audience (Facebook Ireland Ltd)

  Facebook Custom Audience is a remarketing and behavioural targeting service provided by Facebook Ireland Ltd that connects the activity of AlcoholFree.com and related sub-sites with the Facebook advertising network.

  Users can opt out of Facebook's use of Trackers for ads personalisation by visiting this opt-out page.

  Personal Data processed: email address; Tracker.

  Place of processing: Ireland – Privacy Policy – Opt Out.

  Facebook Remarketing (Facebook Ireland Ltd)

  Facebook Remarketing is a remarketing and behavioural targeting service provided by Facebook Ireland Ltd that connects the activity of AlcoholFree.com and related sub-sites with the Facebook advertising network.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy – Opt Out.

  Google Ads Remarketing (Google LLC)

  Google Ads Remarketing is a remarketing and behavioural targeting service provided by Google LLC that connects the activity of AlcoholFree.com and related sub-sites with the Google Ads advertising network and the DoubleClick Cookie.

  Users can opt out of Google's use of Trackers for ads personalisation by visiting Google's Ads Settings.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out.

• SPAM protection

  This type of service analyses the traffic of AlcoholFree.com and related sub-sites, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognised as SPAM.

  Google reCAPTCHA (Google LLC)

  Google reCAPTCHA is a SPAM protection service provided by Google LLC.
  The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

  Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Further information about the processing of Personal Data

• AlcoholFree.com Sub-Sites

  This policy refers to the usage of AlcoholFree.com and all related sub-sites which are connected to AlcoholFree.com and/or accessed by the use of your AlcoholFree.com account.

• Analysis and predictions based on the User’s Data (“profiling”)

  The Owner may use the Personal and Usage Data collected through AlcoholFree.com and related sub-sites to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
  User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
  The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

• Automated decision-making

  Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. AlcoholFree.com and related sub-sites may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. AlcoholFree.com and related sub-sites adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
  Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
  The rationale behind the automated decision making is:

  • to enable or otherwise improve the decision-making process;
  • to grant Users fair and unbiased treatment based on consistent and uniform criteria;
  • to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
  • to reduce the risk of User's failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within AlcoholFree.com and related sub-sites, Users can check the relevant sections in this document.

  Consequences of automated decision-making processes for Users and rights of Users subjected to it

  As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
  In particular, Users have the right to:

  • obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
  • challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
  • request and obtain from the Owner human intervention on such processing.

  To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.

• Equal protection of User Data

  AlcoholFree.com and related sub-sites shares User Data only with third parties carefully selected to ensure that they provide the same or equal protection of User Data as stated in this privacy policy and requested by applicable data protection laws. Further information on data processing and privacy practices by third parties can be found in their respective privacy policies.

• Preference Cookies

  Preference Cookies store the User preferences detected on AlcoholFree.com and related sub-sites in the local domain such as, for example, their timezone and region.

• Pseudonymous use

  When registering for AlcoholFree.com and related sub-sites, Users have the option to indicate a nickname or pseudonym. In this case, Users' Personal Data shall not be published or made publicly available. Any activity performed by Users on AlcoholFree.com and related sub-sites shall appear in connection with the indicated nickname or pseudonym. However, Users acknowledge and accept that their activity on AlcoholFree.com and related sub-sites, including content, information or any other material possibly uploaded or shared on a voluntary and intentional basis may directly or indirectly reveal their identity.

• Selling goods and services online

  The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
  The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by AlcoholFree.com and related sub-sites depends on the payment system used.

• sessionStorage

  sessionStorage allows AlcoholFree.com and related sub-sites to store and access data right in the User's browser. Data in sessionStorage is deleted automatically when the session ends (in other words, when the browser tab is closed).

• The Service is intended for adults

  Users declare themselves to be adult according to their applicable legislation. Minors may not use AlcoholFree.com and related sub-sites.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

AlcoholFree.com and related sub-sites uses Trackers. To learn more, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of AlcoholFree.com and related sub-sites or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, AlcoholFree.com and related sub-sites may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, AlcoholFree.com and related sub-sites and any third-party services may collect files that record interaction with AlcoholFree.com and related sub-sites (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

AlcoholFree.com and related sub-sites does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within AlcoholFree.com and related sub-sites and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.