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​​​MY DATA PROTECTION

PRIVACY POLICY 2018-05-20

Handling of personal data within MACKMYRA SVENSK WHISKY AB and its subsidiaries.

CONTENTS
1. INTRODUCTION

2. WHAT IS PERSONAL DATA?

3. WHAT PERSONAL DATA DO WE PROCESS ABOUT YOU AND WHY?

3.1 WHEN YOU HAVE REGISTERED PERSONAL DATA WITH MACKMYRA IN CONNECTION WITH
BOUGHT PRODUCTS OR EXPERIENCES, SIGNED UP FOR COMPETITIONS WE ORGANISE
ALTERNATIVELY, CONTACT THE MACKMYRA CUSTOMER SERVICE CENTRE.

3.2 WHEN YOU REGISTER PERSONAL DATA WITH MACKMYRA IN CONNECTION WITH
REGISTRATION IN THE MACKMYRA CASK WEB

3.3 WHEN YOU HAVE REGISTERED PERSONAL DATA WITH MACKMYRA FOR SUBSCRIPTION TO ANY OF
OUR NEWSLETTERS

3.4 WHEN, AS A REPRESENTATIVE OF A COMPANY THAT IS A SUPPLIER OR
MACKMYRA RETAILERS PROVIDE US WITH YOUR PERSONAL DATA.

3.5 WHEN YOU ARE A SHAREHOLDER IN MACKMYRA.

3.6 WHEN WE HAVE A LEGAL OBLIGATION TO PROCESS YOUR PERSONAL DATA.

4. HOW LONG WE KEEP YOUR PERSONAL DATA?

5. TO WHOM WE DISCLOSE YOUR PERSONAL DATA?

6. HOW WE PROTECT YOUR PERSONAL DATA?

7. ABOUT COOKIES

8. HOW TO OPPOSE ELECTRONIC DIRECT MARKETING.

9. YOUR RIGHT TO REGISTER EXTRACTS, CORRECTION OF INCORRECT DATA, ETC.

10. CONTACT DETAILS.

11. UPDATES TO THE MACKMYRA PRIVACY POLICY.

1. INTRODUCTION

When you provide your personal data to MACKMYRA SVENSK WHISKY AB or any of its
subsidiaries ("Mackmyra"), you should feel safe. Your privacy is important to us. We are therefore
committed to ensuring that the personal data collected about you is stored and processed in a secure and
securely, and in accordance with the provisions of the Swedish privacy legislation
and data protection reform (GDPR) that will enter into force in the EU in May 2018. This information text
explains how Mackmyra handles your personal data and what rights you have. We therefore ask you
to read the information below carefully. If you have any questions about how your
personal data is processed, you are welcome to contact us. Our contact details can be found at the end of
this information text.

2. WHAT IS PERSONAL DATA?
Personal data is any information that can be directly or indirectly linked to you, such as names, pictures,
social security number, email address, IP address or purchase history.

3. WHAT PERSONAL DATA DO WE PROCESS ABOUT YOU AND WHY?
In this section, we explain how your personal data is used in order for us to fulfil
agreements, maintain effective co-operation with partners, and provide you with
information and offers, which we have based on your previous purchases or on a previous
actively expressed interest in our products, experiences or newsletters, think you are interested in.

3.1 WHEN YOU HAVE REGISTERED PERSONAL DATA WITH MACKMYRA IN CONNECTION WITH
BOUGHT PRODUCTS OR EXPERIENCES, SIGNED UP FOR COMPETITIONS WE ORGANISE
ALTERNATIVELY, CONTACT THE MACKMYRA CUSTOMER SERVICE CENTRE.

- We store the personal data necessary for the purpose of administering and delivering
what you have purchased in accordance with our terms of purchase, or shown interest in, and to provide you
information and offers we think you might be interested in.

- Necessary personal data can be for example: name, social security number, e-mail address,
postal address, telephone number, details of your purchase history.

- We store your personal data in fulfilment of the contract until the product or
the experience you bought has been delivered or until the contract between us has ended or until the
the competition you entered has ended. After that, we save a selection of necessary personal data with
based on a balance of interests when we have a legitimate interest in using your data for statistical purposes
and to market our products and services, secure payment and prevent
frauds. You can choose at any time via the Mackmyra website to change your preferences for,
or unsubscribe from further marketing communications from Mackmyra.

- We will keep your personal data for up to 12 months after the current support for saving it
under the above paragraph no longer applies, including as a basis for any complaints. Your
purchase history is kept for up to 7 years for our legitimate interest to analyse trends over time.

3.2 WHEN YOU REGISTER PERSONAL DATA WITH MACKMYRA IN CONNECTION WITH
REGISTRATION IN THE MACKMYRA CASK WEB

- We save the personal data that is necessary for the purpose of administering and delivering
the services we offer via the fatweb and to provide you with information and offers we believe
that you are interested in.

- Necessary personal data can be for example:  Name, e-mail address, postal address,
telephone number and your password to the cask web.

- We save your personal data based on a balance of interests when we (and you) have a legitimate
interest in facilitating the booking of barrel tastings, barrel owner activities, bottling and more, and to
use your data for statistics and to market our products and services. You
can at any time via Mackmyra's website choose to change your preferences for, or completely
unsubscribe from, further marketing mailings from Mackmyra. months after last use) or have another active engagement with us (e.g. barrel owner,
barrel friend or newsletter recipient). To ensure traceability, we save data about our
communication with you for 12 months. Your purchase history is stored for up to 7 years for our legitimate interest in analysing trends over time.

3.3 WHEN YOU HAVE REGISTERED PERSONAL DATA WITH MACKMYRA FOR SUBSCRIPTION OF
ANY OF OUR NEWSLETTERS

- We store the personal data necessary for the purpose of administering and delivering
our newsletters and to be able to provide you with information and offers we think you are interested in.

- Necessary personal data may include, for example: name, e-mail address, telephone number, postal address.

- We store your personal data based on a balance of interests when we have a legitimate interest
to use your data for statistical purposes and to market our products and services. You are
can at any time via the Mackmyra website choose to change your preferences for, or completely
unsubscribe from further marketing communications from Mackmyra.

- We will keep your personal data until you actively unsubscribe from all marketing from
Mackmyra. To ensure traceability, we keep data about our communications with you for up to 12
months after you have chosen to unsubscribe from all marketing.

3.4 WHEN, AS A REPRESENTATIVE OF A COMPANY THAT IS A SUPPLIER OR
MACKMYRA RETAILERS PROVIDE US WITH YOUR PERSONAL DATA.

- In some cases, we store your contact details in order to maintain an effective and efficient
cooperation and to be able to provide the company you represent with information and
offers we think the company is interested in.

- Necessary personal data may include, for example: name, e-mail address, telephone number.

- We store your personal data based on a balance of interests when we have a legitimate interest
to use your data to maintain an effective and efficient co-operation with
the company you represent.

We will retain your personal data for up to 12 months after the relevant retention period under
the above paragraph no longer applies, including as a basis for any complaints.

3.5 WHEN YOU ARE A MACKMYRA SHAREHOLDER
Mackmyra's share register is administered by Euroclear, an external party. For information on how your
personal data is processed in connection with general meetings, please see:
https://www.euroclear.com/dam/ESw/Legal/Integritetspolicy-bolagsstammor-svenska.pdf.

Mackmyra may, on the basis of a balance of interests, when we have a legitimate interest
use your personal data to market our products and services. You can at any time
preferably via Mackmyra's website, choose to change your preferences for, or completely unsubscribe from
from, further marketing mailings from Mackmyra.

- We store the personal data that is necessary for the purpose of providing you with information and
offers we think you might be interested in.

- Necessary personal data may include, for example: name, e-mail address, postal address and age.

- We will keep your personal data for up to 12 months after you are no longer a Mackmyra shareholder.

3.6 WHEN WE HAVE A LEGAL OBLIGATION TO PROCESS YOUR PERSONAL DATA
In addition to what is described in the paragraphs above, in some cases we process your personal data when we are
required by law, for example because of our accounting obligations. When we process your personal data
because we are legally obliged to do so, we do so on the basis of a legal obligation.

4. HOW LONG WE KEEP YOUR PERSONAL DATA?
Your personal data will only be stored for as long as necessary to fulfil the purposes, or as long as
as we are required to store them by law. After that, your data will be deleted or de-identified in a
secure way, so that they can no longer be linked to you.

5. TO WHOM WE DISCLOSE YOUR PERSONAL DATA?
Mackmyra will never sell your data to a third party. However, we may disclose your
personal data if it is necessary to administer and deliver what you have purchased in
in accordance with our terms and conditions of purchase, for example, for those who choose to become a Mackmyra cask owner.

Recipients who process personal data on behalf of Mackmyra always enter into a so-called
data processing agreement with us in order for us to ensure that your data is processed
in a correct and safe way.

If you buy barrels stored at one of our satellite warehouses, the respective partner at that
locality behind the satellite warehouse will provide you with current local offers and
information.

6. HOW WE PROTECT YOUR PERSONAL DATA?
Your privacy is important to us, which is why we put security at the centre of our work. We take measures to
protect your data in accordance with the General Data Protection Regulation and established guidelines for
information security. This means that we have data protection procedures and rules in place, such as sending
your data securely and ensures that staff only have access to the data they
need to carry out their work. We also log events in our IT systems and archive data
without searchability when your personal data must be stored for a longer period (e.g. according to the Accounting Act).

7. ABOUT COOKIES
Nhen you visit our website, we may also collect information and data about you by
use so-called cookies. 

 8. HOW TO OPPOSE ELECTRONIC DIRECT MARKETING
Mackmyra Swedish Whisky may use your email address or mobile phone number
for direct marketing purposes. If you do not want us to use your email address or your
mobile phone number for direct marketing, you can always follow the link at the bottom
in any email or SMS received from Mackmyra to unsubscribe from further
direct marketing. You can also use the following link: change your
communication settings...se

9. YOUR RIGHT TO REGISTER EXTRACTS, CORRECTION OF INCORRECT DATA, ETC.
You have the right to be informed about the personal data we hold about you. In addition, you have the right to
you can, under the conditions laid down by law, request the correction of inaccurate data, the limitation of data
or erasure of your personal data. You also have the right to object to the processing that
is based on a balance of interests. As regards the treatment based on a
contractual relationship between us, you have the right to request that the data be transferred to another
data controller (data portability). You can always contact us for help or
information on your rights as set out in the contact details below. You also have the right to submit a
complaints to the Data Protection Authority.

10. CONTACT DETAILS
Mackmyra Svensk Whisky AB  (org. nr. 556567-4610) is the data controller for the processing of
your personal data. If you wish to take action under point 9 above, please contact us in writing
personally signed request sent to:

Mackmyra Svensk Whisky AB
Att: Dataskyddsombud
Kolonnvägen 2
802 67 GÄVLE

In the letter, please provide your name, address, e-mail, telephone number and social security number
in addition to your case. Please also attach a copy of your identity document. A reply will be sent to your
registered address.

If you have general questions about our processing of personal data, please contact us via
E-post: Dataskyddsombud@mackmyra.se.

11. UPDATES TO THE MACKMYRA PRIVACY POLICY
This information was last updated on 18 May 2018. We reserve the right to modify
our privacy policy at any time. The current privacy policy will be available at
Mackmyras website.