Privacy Policy

Commercers Solutions GmbH, in its role as Data Controller, respects your right to privacy when you use our digital media (such as our websites, our mobile applications, our pages on the social network, any online forms to register to our events…) and communicate electronically with us.

The purpose of this Privacy Policy is to inform you how Commercers Solutions GmbH, Parchimer Str. 1, 19386 Lübz (“we,” or “our”) collect, store, use and process your Personal Data provided through any digital media operated by Commercers Solutions GmbH (“Digital Media”).

Topics 1. What Personal Data do we gather about you and how do we collect it?
2. How and why do we use tracking technologies?
3. For what purposes do we use your Personal Data and on which legal grounds?
4. What happens if you do not wish to provide your Personal Data?
5. To whom do we disclose Your Personal Data and why?
6. Is your Personal Data sent to recipients located in other countries and why?
7. How long do we keep your Personal Data?
8. How do we secure your Personal Data?
9. What are your rights regarding Personal Data?
10. How do we process children’s Personal Data?
11. How can you contact us or lodge a complaint to the relevant Supervisory Authority?
12. Changes to our Privacy Policy
13. Newsletter

1. What Personal Data do we gather about you and how do we collect it?

Personal Data is collected only for the purposes set out in Section 3 below and each time you participate in any of the features or services offered by our Digital Media.

The types and amount of information collected for the above-mentioned features and services may be updated and vary depending on the activities of Commercers Solutions GmbH.

Subject to applicable law requirements, we may use a variety of technologies that collect and provide information about how our Digital Media is accessed and used by you. We may also use demographic information about the users of our Digital Media, which we may obtain from third parties such as Google or social media that you use (“Usage Information”). Usage Information may consist of the pages you viewed, the time you viewed them, which beverage information or other content you accessed or provide, in what language, including demographic information about you (such as your age, gender and interest areas, where available) and what pages you looked at before viewing the current page, etc.

2. How and why do we use tracking technologies?

Commercers Solutions GmbH uses tracking technologies such as cookies, IP Addresses or Log files. Tracking technologies help us tailor our Digital Media to your personal needs.

  • We use cookies to better understand how visitors use our Digital Media and the tools and services offered, and improve their use and functionality. Subject to your consent where required by applicable law, our Digital Media use cookies and similar technologies (“cookies”). Cookies are small files that are placed on your device that serve a number of purposes like letting you navigate between pages efficiently, remembering your preferences, and generally improving your experience. The use of cookies on our Digital Media allows you to enjoy more seamless visits and more accurately measures your behavior on our Digital Media. You can learn more about the cookies we use and how you can disable cookies in the Commercers Solutions GmbH Cookie Policy.
  • An IP address is a number that is used by computers on the network to identify your computer every time you log on to the Internet. We may keep track of Internet Protocol (IP) addresses to (among other things): (i) troubleshoot technical concerns, (ii) maintain website safety and security, (iii) restrict access to our Digital Media to comply with applicable law or contractual restrictions, and, (iv) better understand how our Digital Media is used;
  • We (or a third party on our behalf) may collect information in the form of logs files that record activity on the Digital Media and gather statistics about users' browsing habits. These entries are generated anonymously, and help us gather (among other things) (i) a user’s browser type and operating system, (ii) information about a user’s session (such as the URL they came from, the date and time they visited our Digital Media, and which pages they've viewed on our Digital Media and for how long), and, (iii) other similar navigational or click-stream data. We also use information captured in log file for our internal marketing and demographic studies, so we can constantly improve and customize the online services we provide you. Log files are used internally only, and are not associated with any particular user.
  • We also use the “Web Custom Audiences” Pixel of the social media network Facebook, operated in Europe by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland(“Facebook”). The pixel are embedded in our website and connect your browser to the Facebook server. Facebook receives the information that our website has been accessed by your device and may thus relate your visit to our website with your Facebook user account, if you have one. This allows Facebook to monitor the effectiveness of its advertisements and to evaluate them for statistical and market research purposes, so that future advertising measures can be optimized. The data collected is anonymous to us and we have no information about the identity of the users and have no influence on the use of the data by Facebook. Further information about Facebook Pixel can be found in Facebook's privacy policy, which is available here: To object the use of Facebook Pixel on our websites/applications, use the Cookie Set Up Tool Facebook-Pixel-Funktionen deaktivieren.
  • Based on your consent, we use the "Snap Pixel" provided by Snap Inc, 2772 Donald Douglas Loop North, Santa Monica, CA 90405, USA to form so-called "Custom Audiences".our purpose here is to optimize our advertisements on Snap (social network), to measure the success of our Snap advertising campaigns and to play out more relevant advertising there.Snap is able to use the Snap Pixel to identify visitors to our website as a target group for the display of ads on the Snap social network.the Snap Pixel implemented on the website establishes a direct connection to the Snap servers when you visit the websites. Your visit and which pages you have accessed are transmitted to the Snap server, and individual information and parameters are transmitted that are necessary for optimizing advertisements, increasing relevance and measuring success, in particular information on events (so-called "conversion events") such as registrations, purchases or logins, etc. The data is transmitted as a hash and is therefore anonymized.
    You can find more information on the collection and use of data by Snap as well as your rights in this regard and options for protecting your privacy in Snap's privacy policy at

3. For what purpose do we use your Personal Data and based on which legal grounds?

We collect information about you to:

  • Respond to your request of service or for the performance of a contract
  • When you register or sign-up in our Digital Media (mobile app, websites, social media, etc.), your Personal Data is used to provide you with the relevant features and services you subscribe to, and to offer you the benefits and privileges that typically come along with your registration (e.g. receiving the communications you select at the time of registration, being invited to events, participating in a sweepstake, etc.);
  • When you purchase products on our websites: we use your Personal Data to manage your order and deliver your products. We can also implement technical solutions to detect fraudulent payment and secure the payment of your purchases on our websites.
  • Send you transactional or administrative communications
  • (e.g. confirmation email when you sign up for, or unsubscribe from, a specific registration or activity), as well as certain service-related announcements (e.g., notices about updates to our privacy notices, discontinued features or programs on our Digital Media, changes to our online services or technical support policies, or other related changes)
  • Allow us to send you marketing information when you consent:
  • In addition to the purpose for which you submitted your Personal Data, you may also be given the option (through a check box or otherwise) to have your Personal Data used for an activity or service different from the primary activity or service that you are requesting. For example, if you are signing up for a contest or other promotion, you may also be invited to sign up for newsletters or alerts from our Digital Media hosting the promotion or from other websites. If you choose to receive these additional services, we will use your Personal Data to provide them to you.
  • When you use the “Send to a friend” feature: this Personal Data is used only once to send the communication and is not further retained by us, as appropriate according to local law;
  • When you use a QR Code or equivalent feature displayed on Commercers Solutions GmbH products: we use your Personal Data to send you more information on the products where the QR code or equivalent feature is displayed or other products;
  • Because it is also Commercers Solutions GmbH legitimate interest to better serve you:
  • Subject to your consent when required, we may occasionally combine, update, or otherwise enhance the Personal Data collected through our Digital Media with data we receive from outside records or third parties. For instance, we may combine purely demographic or survey information (e.g. age, gender, household information, and other interests, etc.) not linked to any Personal Data about you with Personal Data collected through our offers (such as during account registration).
    We may use the combined above-mentioned information and/or demographic information for our internal marketing and demographic studies and to constantly improve, personalize, and customize the products and services we provide you to better meet your needs. Some of the tools we use may involve automated individual decision-making subject to applicable law.
  • We will ensure that your Personal Data remains accurate and up-to-date and avoid duplication in our database, by verifying each of your interactions with us and/or one of our affiliates to ensure your Personal Data is still accurate or needs to be completed or updated with the additional information you will have provided.
  • We may conduct profiling based on monitoring your browsing activities on our Digital Media to better understand your preferences and center of interests and adapt our marketing communications to your profile, unless you object in the conditions set forth in Section 9 of this Privacy Policy.

Commercers Solutions GmbH may process Personal Data involving automated decision making, including for the performance of a contract (e.g. avoid fraudulent payment) or subject to your explicit consent, to better serve your needs in accordance with your preferences.
Please note that the automated tools used are regularly checked to ensure that the Personal Data is processed fairly. Specific measures such as data minimization are implemented when creating profiles. You are invited to express your point of view through the right of access described above. You can also object the result of the automated decision by sending an email to the contact details in Section 11 below.

4. What happens if you do not wish to provide your Personal Data?

If you choose not to submit any Personal Data when requested, you may not be able to participate in certain activities and personalized features, other Digital Media services and special services offered to you may be limited. For example, if you refuse to share your email address, you will not be able to receive our newsletters or otherwise register on our Digital Media. However, to simply browse our Digital Media and learn more about Commercers Solutions GmbH and our products, you do not need to give us any Personal Data. In any event, we will always inform you of the Personal Data that is necessary in order to benefit from a service.

5. To whom do we disclose your Personal Data and why?

Commercers Solutions GmbH may also share your Personal Data with third parties, but only in the following circumstances:

  • For marketing purposes if you gave us your consent.
  • For support purposes: We may use service providers, agents or contractors to provide support for the internal operations of our Digital Media and to assist us with administering them or the various functions, programs and promotions available on it. Any such third party shall at all times provide the same levels of security for your Personal Data as Commercers Solutions GmbH and, where required, are bound by a legal agreement to keep your Personal Data private, secure and to process it only on the specific instructions of Commercers Solutions GmbH;
  • For joint and co-sponsored programs and promotional purposes: When we run a joint or co-sponsored program or promotion on our Digital Media with another company, organization, or other reputable third party; and, as part of this event, collect and process Personal Data, we may share your Personal Data with our partner or sponsor, subject to your consent when required. If your Personal Data is being collected by (or is shared with) a company other than Commercers Solutions GmbH as part of such promotion, we will let you know this at the time your Personal Data is collected;
  • For litigation and safety purposes: We may also disclose your Personal Data if we are required to do so by law, or if in our good faith judgment, such action is reasonably necessary to comply with legal processes, to respond to any claims, or to protect the safety or rights of Commercers Solutions GmbH, its customers, or the public;
  • In the event of a merger or acquisition of all or part of Commercers Solutions GmbH by another company, or in the event that Commercers Solutions GmbH were to sell or dispose of all or a part of the Commercers Solutions GmbH business, the acquirer would have access to the information maintained by that Commercers Solutions GmbH business, which could include Personal Data, subject to applicable law. Similarly, Personal Data may be transferred as part of a corporate reorganization, insolvency proceeding, or other similar event, if permitted by and done in accordance with applicable law

6. Is your Personal Data sent to recipients located in other countries and why?

Commercers Solutions GmbH is a global company and your Personal Data may be transferred across international borders. It may be transferred to countries that have a different level of data protection laws than the one existing in the country from where you submitted your Personal Data. Your Personal Data may also be transferred between different companies of the Commercers Solutions GmbH Group located in different countries. Commercers Solutions GmbH takes the appropriate measures to maintain security of the Personal Data both during transit and at the receiving location by implementing contractual clauses as set out by the European Commission, in accordance with applicable law.

7. How long do we keep your Personal Data?

We will store the Personal Data that you sent us via our Digital Media in our databases as long as your account is active, for the duration of the contract with you or as needed to provide you the services you requested or to answer queries or resolve problems, provide improved and new services. We may also retain your Personal Data in accordance with our internal retention procedure as necessary to comply with our legal and regulatory obligations, resolve disputes and enforce our agreements.
We may thus retain your Personal Data after you stop using Commercers Solutions GmbH services or our Digital Media according to the statute of limitations.

8. How do we secure your Personal Data?

Commercers Solutions GmbH takes all necessary technical and organizational measures to protect the confidentiality and security of your Personal Data collected from this website and/or our applications, including sensitive Personal Data. These efforts include but are not necessarily limited to: (i) storing your Personal Data in secure operating environments that are not available to the public and that are only accessible to authorized Commercers Solutions GmbH employees, and our agents and contractors; and, (ii) verifying the identities of registered users before they can access the Personal Data we maintain about them.

9. What are your rights regarding your Personal Data?

  • If your Personal Data has been processed on the basis of your consent, you can withdraw your consent at any time, without impact on lawfulness of processing based on consent before its withdrawal.
  • You can request to access your Personal Data
  • You can request to rectify your Personal Data if it is inaccurate, incomplete or out of date
  • You can request the erasure of your Personal Data (i) if your Personal Data is no longer necessary for the purpose of the data processing, (ii) you have withdrawn your consent on the data processing based exclusively on such consent, (iii) you objected to the data processing, (iv) the Personal Data processing is unlawful, (v) the Personal Data must be erased to comply with a legal obligation applicable to Commercers Solutions GmbH. Commercers Solutions GmbH will take reasonable steps to inform the other entities of the Commercers Solutions GmbH Group of such erasure.
  • You can request the restriction of the processing (i) in the event the accuracy of your Personal Data is contested to allow Commercers Solutions GmbH to check such accuracy, (ii) if you wish to restrict your Personal Data rather than deleting it despite the fact that the processing is unlawful, (iii) if you wish Commercers Solutions GmbH to keep your Personal Data because you need it for your defense in the context of legal claims (iv) if you have objected to the processing but Commercers Solutions GmbH conducts verification to check whether it has legitimate grounds for such processing which may override your own rights if the data processing is based on the legitimate interest of Commercers Solutions GmbH.
  • You can request the portability of the Personal Data you provided to us, if the Personal Data processing is based on your consent or the performance of a contract and is carried out by automated means (ie. excluding paper files).
  • You always have the option not to share any of your Personal Data with us. If you choose this option, you may be limited in the activities and features we can provide you.
  • You have the right to object to the processing of your Personal Data by us, at any time, for direct marketing purpose, for marketing purpose based on profiling, or if the data processing is based on the legitimate interest of Commercers Solutions GmbH (except if we can demonstrate compelling legal grounds for the processing).

10. How we treat children’s Personal Data?

Our Digital Media are not intended for children under the legal drinking age (“Minor”), so we do not knowingly collect personal data from Minors. You must be at least eighteen years old to create an account and engage in activities and transactions on our Digital Media. If we are notified or learn that a Minor has submitted Personal Data to us through our Digital Media, we will delete such Personal Data.

11. How can you contact us or the relevant Supervisory Authority?

If you have any questions, complaints, or comments regarding this Privacy Policy or our information collection practices, please contact us by writing to:
Commercers Solutions GmbH
Parchimer Str. 1
19386 Lübz
or sending an email to:

You are informed that you can also lodge a complaint with the Supervisory Authority of the country where you are located if you have any concern about the conditions of processing of your Personal Data by Commercers Solutions GmbH.

12. Changes to our Privacy Policy

We keep our Privacy Policy under regular review and we will place any updates on this web page.
This Privacy Policy was last updated in 2018.

13. Newsletter

On our website we provide the possibility to subscribe to the newsletter of STOCK SPIRITS GmbH & Co. KG, Winsbergring 12-22, 22525 Hamburg, the producer of the spirit “Sierra Tequila”. We use the double opt-in procedure. An e-mail is sent to the e-mail address you indicated and you have to complete the registration process by clicking on a confirmation link.
The personal data provided by you in this context will only be forwarded to STOCK SPIRITS GmbH & Co. KG enable the sending of the newsletter and will only be processed for this purpose. You can revoke your consent to Commercers Solutions GmbH at any time free of charge with effect for the future (for contact details see point 11.). If you unsubscribe from the newsletter, your personal data will be deleted if there are no mandatory retention periods.


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