1. Identity of the Data Controller

Levitate Vodka
Trade name: Levitate Vodka
Registered address: Dorspsstraat 61B, 2665BH, Bleiswijk.
Chamber of Commerce (KvK): 94142548
VAT number: NL005066638B31
Email: info@levitate-vodka.com

Levitate Vodka is the data controller within the meaning of the
General Data Protection Regulation (GDPR).

2. Scope of This Policy

This Privacy Policy applies to:

• Visitors of our website
• Consumers (B2C customers)
• Business customers (B2B customers)
• Users of our B2B portal
• Contact persons of business relations

3. Categories of Personal Data We Process

3.1 Consumers (B2C)

We may process the following personal data:

• First and last name
• Billing and shipping address
• Email address
• Phone number
• Date of birth or age verification information (18+ requirement)
• Order details
• Payment information (processed via payment provider)
• IP address
• Device and browser information
• Website usage data

3.2 Business Customers (B2B)

Company Information

• Company name
• Legal form
• Chamber of Commerce number
• VAT number
• Billing and shipping address
• Credit limit (if applicable)
• Customer-specific pricing structures or discounts
• Payment terms
• Invoice history

Contact Persons

• Name
• Business email address
• Business phone number
• Job title

3.3 Multiple Users Within One Organization

Business customers may create multiple user accounts within their organization.

Per individual user, we may process:

• Full name
• Business email address
• Role or authorization level
• Login credentials
• Account activity
• Order history
• Portal interactions

The business customer is responsible for informing its employees about this processing.

3.4 Credit Orders (B2B)

If a business customer orders on credit, we may additionally process:

• Invoice data
• Payment deadlines
• Outstanding balances
• Payment history
• Collection-related data (if applicable)

We may perform a credit assessment based on legitimate interest in order to manage financial risk.

4. Purposes of Processing

We process personal data for the following purposes:

• Processing and fulfilling orders
• Delivering alcoholic products
• Mandatory age verification (18+)
• Providing and managing access to the B2B portal
• Applying customer-specific pricing or discount structures
• Credit management and risk control
• Invoicing and accounting compliance
• Fraud prevention
• Customer service
• Website optimization and analytics
• System and platform security

Customer-specific pricing conditions are strictly confidential and tied to individual B2B accounts.

5. Legal Bases for Processing

We process personal data based on:

• Performance of a contract
• Legal obligation
• Legitimate interest
• Consent (where required by law)

6. Sharing Data With Third Parties

We share personal data only where necessary.

Payment Processing

Payments are processed via
Stripe

We do not store full payment card details.

Logistics

Orders are delivered via
DHL
or another designated logistics partner.

Hosting & Technical Infrastructure

We work with technical service providers and hosting partners that enable our webshop and B2B portal operations.

Data processing agreements are concluded with all data processors where required.

7. Analytics

We use PostHog for analysing website and platform usage. PostHog operates in cookieless mode: no cookies or local storage are placed on your device and no persistent user profile is created.

This may include:

• Page views
• Click behaviour
• Funnel analysis
• Error logging
• B2B portal usage

IP addresses are processed in anonymised form by PostHog. Data is stored on servers within the European Union (Frankfurt, Germany). No data is transferred to countries outside the EU/EEA.

The legal basis for this processing is our legitimate interest (Article 6(1)(f) GDPR) in optimising the website and ensuring its technical stability.

If marketing pixels or additional tracking are implemented in the future, this will be subject to consent where legally required.

8. Cookies

Our website may use:

• Essential (functional) cookies

Essential cookies are necessary for:

• Shopping cart functionality
• Login sessions
• Age verification
• Secure B2B authorization

If non-essential cookies are used, user consent will be requested beforehand.

9. Security Measures

We implement appropriate technical and organizational measures, including:

• Encrypted password storage
• Role-based access control
• Logging of administrative and user actions
• Restricted internal access to sensitive data
• Monitoring for unauthorized access
• Ability to suspend or deactivate accounts

10. Data Retention

We retain personal data:

• As long as necessary for contract performance
• As long as a B2B relationship remains active
• In accordance with Dutch tax retention laws (minimum 7 years)
• As required by applicable laws

After the retention period, data may be anonymized or deleted.

11. International Data Transfers

If personal data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards in accordance with the GDPR.

12. Data Breaches

In the event of a personal data breach, we act in accordance with applicable data breach notification laws.

Where required, incidents will be reported to the
Dutch Data Protection Authority
and affected individuals will be informed.

13. Data Subject Rights

Under applicable data protection law, you have the right to:

• Access your personal data
• Rectify inaccurate data
• Request deletion
• Restrict processing
• Object to processing
• Request data portability

Requests can be submitted via: [contact email].

14. Amendments

Levitate Vodka reserves the right to modify this Privacy Policy. The most recent version will always be available on our website.