Privacy Policy

Privacy Policy

1. General

This policy explains how DrinkBuy ApS, Ryesgade 118, 2100 Copenhagen Ø, CVR No. 45343278 (hereinafter referred to as “DrinkBuy”, “we”, “us”, “our”) collects and processes your personal data.
The policy covers, among other things, the personal data you provide to us when you create a user account in the DrinkBuy app (hereinafter referred to as the “App”) or when you contact us directly.
DrinkBuy is the data controller for the processing of your personal data. You may contact us regarding your personal data via our email at info@drinkbuy.dk.
The policy is always available under your profile in the App as well as on www.DrinkBuy.dk.

2. Processing

2.1. User in the App
When you create a user in the App, we automatically process information about you and your use of the App.

2.1.1. Information
To create a user in the App, you are required to provide certain personal data. This may be entered manually into the registration form or, where available, retrieved partially or fully from your Facebook profile or another social media profile, should you choose to create your account using a social media login. The data collected during user registration includes your name, date of birth, email address, and phone number. If the data is retrieved from a social media profile, your user ID and profile picture from that platform will also be collected and stored for use in the App. If you choose to register without using a social media profile, we will, at a minimum, collect your phone number in order to create a unique account linked to it 

In addition, DrinkBuy can collect information about:
• Your activities and behavior within the App, including your use of available products and services.
• Your device (device-specific information), such as hardware model, operating system version, device ID in tokenized format, and unique device identifiers.
• Your current physical location, including data about devices, nearby Wi-Fi access points, and mobile towers.
Your physical location is determined using various technologies, including IP address, GPS, other sensors, and NFC technology for location-based data collection.
In addition to data received directly from you, your data may be supplemented with data from third parties, including our external partners.
When you make purchases in the App, you will be asked to enter your payment card information in order to complete the transaction. These card details are exchanged directly between you and FLATPAY ApS, which acts as our payment service provider. DrinkBuy therefore has no access to or insight into your unprocessed payment or card information.

2.1.2. Purpose
Your personal data is processed for the purpose of granting you access to the App and its services and managing your user profile and user rights.
We also use information about you to continuously place you into a purchasing profile group. This allows us to tailor the offers and benefits you receive via the App to better suit your preferences.
In certain cases, your personal data is processed to ensure compliance with the App’s terms of use. This includes investigation of potential breaches of DrinkBuy’s terms and conditions as well as the prevention, management, or investigation of security or technical issues related to the App and its usage. DrinkBuy works continuously to improve the user experience by optimizing our app, products, and services. Therefore, your personal data may be used for customer satisfaction surveys, market research, and similar purposes. For statistical purposes, your data is processed in anonymized form to develop and improve our services, product offerings, campaigns, and promotions. The anonymized data is also used to create market analyses, which we share with our partners. These analyses are fully anonymized and cannot be traced back to you as an individual.

2.1.3. Legal Basis
The processing of your personal data is carried out in accordance with the General Data Protection Regulation (EU) 2016/679 and the Danish Data Protection Act no. 502. We only process the data necessary to deliver the App and its services, including its content. This processing is based on Article 6(1)(b) of the GDPR (performance of a contract) and Article 6(1)(f) (legitimate interests), in order to fulfil your request to use the service. Your personal data may also be processed where our legitimate interests override yours. This may include handling your inquiries, preventing and investigating security and technical issues, business development, enforcing terms, and conducting market research and customer satisfaction analyses. In certain cases, the processing of your personal data is necessary for compliance with a legal obligation under Article 6(1)(c) of the GDPR.

2.2.1. Information
When using the App, the following personal data may be processed: your phone number and, if provided in the App, your name, date of birth, and email. In addition, data may be processed regarding:
• Your purchases and other transaction data.
• Your use of the App, including redemption of discounts and special offers.
• Communication with us via the chat function.
• Information used for billing your purchases.
Information about your use of the App may also be used in anonymized form for statistical purposes. This is done to develop and improve our services, product offerings, campaigns, and promotions. The anonymized data may also be used to create and share market analyses with our partners. It is emphasized that the data shared cannot be traced back to you as an individual.

2.2.2. Purpose
Your data is processed to administer your access to and use of the App. This includes granting you access to the App’s benefits and communicating with you regarding your use of the App. The data is also used to invoice your purchases, compile statistics, and deliver tailored marketing. We process your personal data when there is an appropriate and legitimate interest in operating, maintaining, and developing our business or establishing and maintaining customer relationships. When processing is based on our legitimate interests, we always assess these against your right to privacy. For example, we offer you an easy way to opt out of marketing communications and, where possible, use pseudonymized or anonymized data. You have the right to object to the processing of your data when such processing is based on legitimate interests. However, DrinkBuy may reject an objection if the processing is necessary for the establishment, exercise, or defence of legal claims in accordance with applicable law.

2.2.3. Legal Basis
The legal basis for processing your data is our agreement with you to deliver the App’s content, cf. Article 6(1)(b) of the GDPR. Data about your purchases and your use of benefits is also processed based on our legitimate interest in providing you with a personalized experience. This includes, among other things, continuously granting you access to relevant benefits and discounts, cf. Article 6(1)(f) of the GDPR.

2.3. Marketing
When you consent to receive marketing communications, we process the necessary personal data in order to send you relevant marketing materials. You can read more about this in our Terms of Marketing available at www.drinkbuy.dk.

2.3.1. Information
In connection with marketing, we process your contact details and information regarding your user and purchasing behavior to tailor marketing content to your interests. This may include your name, date of birth, email address, phone number, and data regarding your use of the App. It also includes information about newsletters you open and click on, gamification features you engage with, competitions you participate in, and similar activities.

2.3.2. Purpose
The purpose of the processing is to send you marketing communications in accordance with our Terms of Marketing and to deliver tailored marketing and profiling. This ensures that our marketing efforts are more accurately aligned with your needs and interests.

2.3.3. Legal Basis
Processing is carried out solely based on your prior consent to receive marketing communications. The legal basis for this processing is Article 6(1)(a) of the General Data Protection Regulation (consent). By accepting to receive marketing communications, you thereby give your explicit consent to such processing. You may withdraw your consent at any time by contacting DrinkBuy via email or through the contact form in the App.

2.4. Visits to DrinkBuy.dk
When you visit our website, we automatically collect and process information about you and your use of the site. In addition to this privacy policy, our Cookie Policy also applies, which you can find at www.drinkbuy.dk.

2.4.1. Information
We may process information regarding your behavior on the website, including the elements you click on, the type of browser you use, the search terms you enter, your IP address, your network location, and information about your device, such as your computer, tablet, or similar equipment.

2.4.2. Purpose
The purpose of the processing is to optimize your user experience on DrinkBuy.dk, generate useful and accurate statistics, and use the collected information to execute personalized marketing campaigns on the website and via our partners, provided you have given consent to the use of statistics and marketing cookies.

2.4.3. Legal Basis
The processing of information collected through the website is carried out on the basis of Article 6(1)(a) of the General Data Protection Regulation where personalized marketing is concerned and you have provided consent for such use. In other cases, the data is processed pursuant to Article 6(1)(f), based on our legitimate interest in improving the website. Processing based on a balancing of interests is only undertaken where your interests, rights, and freedoms do not override our legitimate interest in the processing. If your interests prevail, the processing will only take place if you have provided your consent.

2.5. Communication
When you contact us via any platform, we process the necessary personal data to handle your inquiry.

2.5.1. Information
In connection with your inquiry, we process your contact details as well as other relevant information necessary to respond to your request. This may include information related to your profile in the app, such as payment details, usage history, or similar. It may also include prior correspondence with you, including feedback, complaints, comments, and other related data.
Furthermore, we will process any new information that you may share with us during the course of the communication or that may arise as part of any continued correspondence.

2.5.2. Purpose
The purpose of processing your personal data during correspondence is to respond to your inquiries, handle complaints, correct errors in the app, or similar purposes. Any data already held about you may be updated or supplemented with relevant information that arises from the correspondence.

2.5.3. Legal Basis
The legal basis for the processing of your personal data in connection with correspondence is our legitimate interest in handling your inquiry and ensuring the quality of the service we provide to you, in accordance with Article 6(1)(f) of the General Data Protection Regulation (GDPR).

2.6. Visits to DrinkBuy’s Social Media Profiles
When you visit DrinkBuy’s profiles on social media, such as Facebook, Instagram, and similar platforms, we may process information about you.

2. 6.1. Information
   When visiting and interacting with our profiles on social media, we may process the information you have made available through your settings on the social media platforms, information about your reactions to our posts, sharing of our posts, and comments on our posts.

2.6.2. Purpose
The purpose of processing your information is to market DrinkBuy on social media, including responding to your inquiries, managing your participation in competitions held on our social media platforms, and contacting you if you win. When social media platforms use your personal data in connection with DrinkBuy’s profiles for their own purposes, such as improving their advertising systems, they will process your information in accordance with their privacy policies.

2.6.3. Legal Basis
The legal basis for processing your personal data is our legitimate interest in marketing DrinkBuy through our presence on social media and interacting with customers on the platforms they already use, pursuant to Article 6, Section 1, Letter f of the General Data Protection Regulation.

3. Data Processors

Your personal data may be shared with DrinkBuy’s partners (data processors), who process the data on behalf of DrinkBuy. This may, for example, include tasks such as sending newsletters, holding competitions, managing your user profile and rights, processing transactions, preventing and correcting errors in the app, and similar purposes. To ensure we always offer the best products and services, we continuously monitor the market for new and improved solutions. Therefore, we reserve the right to change, replace, or add data processors. Your personal data will only be shared with data processors that are relevant to the specific processing.

4. Recipients

4.1 Sharing of Personal Data with Third Parties

We only share your personal data internally within DrinkBuy if it is necessary to fulfil the purposes of this privacy policy. We do not share your personal data with third parties outside of DrinkBuy’s organization unless one of the following conditions applies: If a third party, such as bars, nightclubs, theatres, stadiums, or other venues handling your order, requires access to your information to deliver DrinkBuy’s services or for other legitimate reasons, we will share your information with the relevant third party. For example, we may share your phone number with a third party preparing your order if it is necessary to ask whether you accept a substitute product, inform you that an item is missing from your order, or clarify special requests.

4.2 Personal Data to Service Providers and Group Companies

We may also share your personal data with our group companies or authorized service providers who help deliver our services (e.g., data storage, accounting, analysis, marketing, or fraud prevention), as well as with payment processing services to process your payments to us.
When third parties process data on behalf of DrinkBuy, we have implemented appropriate contractual and organizational measures to ensure that your data is processed solely in accordance with the purposes of this privacy policy and applicable law. This is done based on our instructions and with appropriate confidentiality obligations and security measures. If third parties, such as our partners who prepare and/or deliver your order, need access to your personal data to provide our services, we will share the necessary information with them. Depending on the partner’s role, this may include your name, delivery address, purchase-related data (such as order number, delivery time, ordered products, comments, and feedback). If a third party processes data for its own purposes, such as complying with legal obligations, the third party will be responsible for processing that data. We may also share your phone number and name with our partners preparing your order if it is necessary, for example, to clarify whether you accept a substitute product, inform you about missing items from the order, or clarify special requests.

4.3 Transfer of Personal Data in the Event of Merger, Acquisition, or Sale

In the event that DrinkBuy is involved in a merger, business acquisition, or asset sale, your personal data may be transferred to the third party involved in this process. We will continue to ensure the confidentiality of your information and inform the affected users if their personal data is transferred or subject to a new privacy policy. If we have received your explicit consent, we may share your personal data with third parties outside of DrinkBuy. You may withdraw your consent at any time without charge by contacting us.

5. Your Rights

Right to Access:
You always have the right to request information about what personal data we have registered about you, the purpose of the processing, the types of data being processed, any recipients of the data, and the source of the data. You also have the right to obtain a copy of the personal data we process about you. If you wish to receive a copy of your personal data, please send a written request to info@DrinkBuy.com.

Right to Rectification:
You have the right to have incorrect information about you corrected. If you discover errors in the information we have registered about you, please contact us so that we can correct them.

Right to Erasure:
Under certain circumstances, you have the right to have all or some of your personal data erased before the regular deletion deadline. If the processing of your information is still necessary, such as for compliance with our legal obligations, we are not required to delete it.

Right to Restriction of Processing:
In certain cases, you have the right to restrict the processing of your personal data to storage only, for example, if you believe that the data we are processing about you is incorrect.

Right to Data Portability:
In certain cases, you have the right to obtain the information you have provided to us in a structured, commonly used, and machine-readable format and have it transferred to another data controller.

Right to Object:
You have the right to object to our processing of your personal data, including in relation to marketing and profiling that we perform to tailor our marketing to you. This processing is based on your consent and/or our legitimate interests.

Right Not to Be Subject to Automated Decision-Making:
You have the right not to be subject to decisions based solely on automated processing, including profiling.

Right to Lodge a Complaint:
If you believe that your personal data is not being processed correctly, you can contact us via our support function in the app or by writing to info@drinkbuy.dk. If we do not resolve the issue satisfactorily, you may lodge a complaint with the relevant authority, the Danish Data Protection Agency (Datatilsynet). You can find information about the agency at www.datatilsynet.dk.

6. Retention and Deletion

Your personal data will be deleted when it is no longer necessary for the purpose for which it was collected, processed, and stored, and when we are not legally obligated to retain it.

Unless we are legally required to store it for a longer period, the data will be stored until:

• It is no longer necessary to provide you access to our app, e.g., if you delete your user profile in the app.
• It is no longer necessary to manage your user profile in the app.
• It is no longer necessary to send you marketing based on your consent, e.g., if you withdraw your consent or your consent has not been used in 1 year.

Personal data used for statistical purposes will be anonymized and deleted no later than 5 years after its collection.

7. Security

At DrinkBuy, we prioritize security. Therefore, we have implemented appropriate technical and organizational security measures to protect your information from accidental or unlawful deletion, loss, alteration, or deterioration, as well as from being accessed by unauthorized parties or misused.

Only selected employees, who have been instructed in the proper handling of personal data, have access to your data. The information is processed in a secure environment, and all data transfers between your device and DrinkBuy are encrypted via SSL.

Operators processing data on behalf of DrinkBuy are always subject to instructions and a data processing agreement. They are obligated to comply with applicable laws, DrinkBuy’s security standards, and various provisions on data protection.

8. Data Controller

DrinkBuy ApS, Ryesgade 118, 2100 Copenhagen Ø, CVR: 45343278, is the data controller for the personal data collected by DrinkBuy. If you have any questions, wish to exercise one or more of your rights, or have other inquiries, you can contact us via email at info@DrinkBuy.dk or through the chat function in the app.

9. Changes to the Policy

The Privacy Policy is updated regularly. The latest version is always the one available at www.DrinkBuy.dk.

Last revised on April 22, 2025.