Privacy Policy

Last updated: 19 January 2026

This Privacy Policy explains how Spirits Centurion (“we”, “us”, “our”) collects, uses, stores, and discloses personal data when you visit or make a purchase from www.spiritscenturion.com (the “Site”) or otherwise interact with our online shop for alcoholic beverages (collectively, the “Services”).

We sell products throughout the European Union. Protecting your personal data and complying with the GDPR is very important to us.

1. Data Controller

WA Invest & Trade kft.
1117 Budapest, Alíz utca I/B. ép. 3. em., Hungary
Phone: +36 20 4898 855
Email: support@spiritscenturion.com
Website: www.spiritscenturion.com

We are the data controller under the GDPR.

2. Legal Basis for Processing

We process personal data on the following legal bases:

  • Performance of a contract (Art. 6(1)(b) GDPR) – to fulfill orders, deliver products, provide services.

  • Legal obligations (Art. 6(1)(c) GDPR) – including alcohol and age-verification laws, tax and accounting requirements.

  • Legitimate interests (Art. 6(1)(f) GDPR) – for fraud prevention, security, analytics, and service improvement.

  • Consent (Art. 6(1)(a) GDPR) – for marketing communications, cookies, and SMS communications.

3. Personal Data We Collect

3.1 Data You Provide Directly

  • Name, billing and shipping address

  • Email address and phone number

  • Payment confirmation and transaction details

  • Account login credentials (username, password)

  • Customer service communications

  • Marketing preferences

  • Information submitted for publication (e.g., profile images, usernames, messages)

3.2 Age & Identity Verification (Alcohol Sales)

Due to EU alcohol laws, we verify your age and identity before allowing purchases. We may request:

  • Copy/photo of an official ID (passport, national ID, or driver’s license)

  • Date of birth and full name

Usage & Retention:

  • Used solely for age and identity verification

  • Access limited to authorized personnel or verified service providers

  • Copies deleted immediately after verification unless legal retention is required

Legal Basis: Art. 6(1)(c) + Art. 6(1)(f) GDPR

3.3 Automatically Collected Data

  • IP address

  • Device type, browser, operating system

  • Referring URLs

  • Pages viewed, visit duration, navigation paths

  • WooCommerce / WordPress session data

  • Cookies and similar tracking technologies

3.4 Data from Third Parties

We may receive data from:

  • Payment processors (Stripe, PayPal, etc.)

  • Shipping and fulfillment providers

  • Marketing or analytics partners (Google Analytics, Ads, Klaviyo, Twilio)

  • Social login providers (if applicable)

4. Cookies & Tracking

We use cookies to operate the Site, analyze traffic, personalize content, and enable shopping functionality:

  • WooCommerce / WordPress session cookies

  • Google Analytics & Ads (conversion tracking, remarketing)

  • Third-party service provider cookies

Consent: You must opt-in for analytics, ads, and tracking cookies. You can manage preferences via our cookie banner or browser settings.

Cookie Deletion / Blocking: Instructions for all major browsers are provided on the Site; disabling cookies may reduce Site functionality.

5. How We Use Your Personal Data

We use personal data for:

  • Order processing, payment, and delivery

  • Age and identity verification

  • Customer support

  • Transactional notifications (order confirmation, shipping updates)

  • Marketing communications (only with consent)

  • Fraud detection and prevention

  • Website improvements and analytics

  • Compliance with legal obligations

6. SMS Marketing & Abandoned Cart Notifications

6.1 SMS Marketing

We may collect and use your mobile phone number to send SMS communications if you have expressly opted in. This may include:

  • Promotional messages

  • Product updates

  • Order-related notifications

  • Abandoned cart reminders

Data processed:

  • Mobile phone number

  • Date and time of subscription

  • Technical information related to message delivery and interaction

  • Engagement data (e.g., delivered, opened, clicked)

Legal basis: Consent (Art. 6(1)(a) GDPR)
You may withdraw consent anytime by replying “STOP” or “UNSUBSCRIBE”, or by contacting support@spiritscenturion.com.

6.2 SMS Abandoned Cart Notifications

Our Site uses cookies or similar technologies to detect abandoned carts. If you opted-in to SMS messages, we may send reminders about incomplete purchases.

Data processed for abandoned cart notifications:

  • Products added to cart

  • Time and date cart was updated or abandoned

  • Technical session data (cookies, plugins)

  • Mobile phone number (with prior consent)

This information is used solely to send abandoned cart reminder messages.

6.3 Third-Party Service Providers (SMS)

We may use third-party providers to manage SMS messages (e.g., Klaviyo, Twilio). These providers:

  • Process data only on our behalf

  • Comply with GDPR (Art. 28)

  • Do not sell or share your data for their own purposes

6.4 SMS Data Retention

  • Your mobile number and SMS interaction data are retained only as long as you participate in the SMS program or until you withdraw consent

  • Upon opting out, your number is deleted unless legal retention obligations apply

7. Disclosure of Personal Data

We may share your data with:

  • Payment processors

  • Shipping and fulfillment providers

  • IT service providers and hosting partners

  • Analytics and marketing service providers

  • Legal or regulatory authorities when required

  • Group companies (subsidiaries, holding company) if necessary

Purpose: Only to fulfill Services, legal obligations, or protect our rights/users.

We do not sell personal data to third parties.

8. International Data Transfers

Data may be processed outside your country, including outside the EU.

  • Transfers rely on EU Standard Contractual Clauses (SCCs) or adequacy decisions

  • Published information on the Site may be globally accessible; we cannot control third-party use

9. Data Retention

We retain personal data only as long as necessary to:

  • Fulfill contracts

  • Comply with legal obligations

  • Prevent fraud

  • Resolve disputes

ID verification documents are deleted immediately after verification, unless legal retention is required.
WooCommerce order/payment data retained per local tax/accounting laws (usually 6–10 years).

10. Data Security

  • Encrypted transactions

  • Secure servers with restricted access

  • Regular backups and monitoring

  • Users responsible for their login credentials

Transmission over the internet is never fully secure.

11. Your Rights (GDPR)

You have the right to:

  • Access your data

  • Rectify inaccuracies

  • Request deletion

  • Restrict or object to processing

  • Data portability

  • Withdraw consent

  • Lodge a complaint with a supervisory authority

We may request proof of identity (e.g., ID copy) to validate requests. Contact: support@spiritscenturion.com

12. Third-Party Websites

We are not responsible for the privacy practices of external websites linked from our Site.

13. Updating Personal Data

You can request correction or update of your data at any time via support@spiritscenturion.com.

14. Changes to This Privacy Policy

We may update this Privacy Policy at any time. The current version is always on the Site.

15. Contact

WA Invest & Trade kft.
1117 Budapest, Alíz utca I/B. ép. 3. em., Hungary
Phone: +36 20 4898 855
Email: support@spiritscenturion.com

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