For the purposes of the applicable legislation on data protection, in particular under Article 4, paragraph 7 of the RGPD, the company responsible for the processing of personal data is World Wild Wines *************, Address ***********, Codigo Postal**********, www.worldwildwines.com.
Delete – we will permanently delete your personal data as soon as the retention period ends or when we receive a valid request from you to do so and provided that there are no legitimate interests justifying the retention of your personal data.
Personal data – any information relating to a natural person which can identify him directly or which makes him identifiable, directly or indirectly, in particular by reference to an identifier.
Clients – customers and others to whom World Wild Wines supplies goods in the course of its business.
Personnel – includes dependent employees as well as interns involved directly in World Wild Wines’ business.
General Data Protection Regulation (GDPR) – a European Union legal instrument aimed at harmonising European data protection laws. It had an effective date of application on 25 May 2018 and any references to it should be interpreted accordingly to include any legislation amending it, giving effect to it or aiming to implement it.
Site Users – any person who accesses the World Wild Wines website, available at www.worldwildwines.com.
WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?
World Wild Wines collects different types of personal data depending on the different purposes, as explained below. In any case, we stress that we do not knowingly collect personal information from persons under the age of 18. If we discover that we have unintentionally collected personal information from children under the age of 18, we will take steps to delete the information as soon as possible, unless we are required by applicable law to retain it.
CUSTOMER DATA: We only collect the data necessary for the preparation, fulfilment and performance of any contract entered into between you and World Wild Wines, and to respond to any subsequent claims relating to it. We usually only need to have your contact details (such as name, telephone number, email address, address and postcode) to enable us to ensure that our relationship runs smoothly. We also hold information relating to your online engagement, which we use to ensure that the marketing communications we address to you are relevant and timely, as per consent you have given. We may also hold information that you, directly or through someone in your company, have chosen to share with us (evaluation of our services and products, allergies, physical and health conditions and dietary restrictions). If for any reason we require any additional personal data, you will be informed.
SUPPLIER DATA: We only collect the data necessary for the preparation, fulfilment and performance of any contract entered into between the Supplier and World Wild Wines, as well as to respond to and manage any complaints related thereto. We will collect contact person details, including those of your company, such as names, telephone numbers and email addresses. We will also collect bank details so that we can pay you.
Please note that the above list of categories of personal data that we may collect is not exhaustive.
DO I HAVE AN OBLIGATION TO PROVIDE MY DATA?
In the scope of our business relationship, you will have to provide the personal data necessary to establish and create that relationship and to comply with the pre-contractual and contractual obligations and diligences derived from it, as well as those which we are legally obliged to collect. Without this data, we will generally have to refuse the conclusion or the execution of the contract or we will not be able to maintain the contract and will have to terminate it.
If you do not provide us with the necessary information and documentation, we will not be able to establish or continue the business or employment relationship you want, or follow up on your requests to us.
HOW DO WE COLLECT YOUR PERSONAL DATA?
We may collect personal data in several ways:
Personal data we receive directly from you if you contact us proactively, usually by phone or email; and/or if we contact you by phone or email or through business development activities more generally.
There are a number of ways you can share your information with us. It all depends on what suits you. These might include:
– Entering your details on the World Wild Wines Site, via the form as part of the registration process; or
– Enter a competition via a social media channel, such as Facebook or Twitter, Instagram, Pinterest or other;
– Subscribe to our newsletter or any of our events;
– Through the chat feature on the website;
Personal data we receive from other sources, typically through commercial due diligence or other market information, including lists of participants in relevant events. We also receive personal data from other sources, for example if you “like” our Facebook page or “follow” us on Instagram, we will receive personal information from those sites.
We collect your data automatically via cookies, in accordance with your browser’s cookie settings. If you are also an Applicant or Customer of World Wild Wines, we may use data from your use of our Sites to improve other aspects of our communications with you or the services we provide to you.
Why do we process your data (purpose of processing) and on what legal basis?
Supply of products and services:
World Wild Wines may use your Personal Data where necessary to perform the contract entered into between you and World Wild Wines, and to identify you. We may also use your Personal Data to prevent and investigate possible misuse of it.
We may, from time to time, send you information that we consider to be of interest to you. In particular, we may use your data for the purposes listed below, where appropriate, namely:
– allow us to develop commercial or marketing actions, namely to promote actions to publicize new features or new products and services;
– send you data on reports, promotions, offers, events and contact establishment;
– provide you with information about certain discounts and offers to which you are entitled due to your relationship with World Wild Wines;
– allow us to send you newsletters, which may contain information regarding promotional campaigns, information on events, discounts, promotions and offers, invitations, reminders regarding your reservations, actions to publicise new features, new products or services and to send you information on participation in contests and sweepstakes, in accordance with the thematic preferences you have indicated to us, by email;
– provide you with information about personalized and exclusive offers for products and services identified based on your personal preferences and behaviors, as well as from your use of products, services and browsing on the websites;
When you have provided us with your electronic contact details in the context of the sale of a product or service, we may use them for the purpose of marketing our own or similar products and services. However, you may, free of charge, if you do not agree with our marketing approach, refuse to send such communications either at the time of collection or by opting out of each message. For sending any other type of electronic communication, we will ask for your express prior consent. We need your consent for some aspects of these activities that are not covered by our legitimate interests (in particular, the collection of data through cookies and the provision of direct marketing to you through digital channels).
– To store (and update as necessary) your information in our database, so that we can contact you in relation to the contracts you wish to enter into/agree to with us;
– To offer services to you or to obtain support and services from you;
– To comply with certain legal obligations;
– To help us target appropriate marketing campaigns, and World Wild Wines may adopt automated decisions, including profiling;
– In rare circumstances, to assist us in asserting, exercising or defending a right and
– To defend the vital interests of the data subject.
We may also use your personal data if we consider it necessary to do so in order to defend our legitimate interests.
Development of products and services
World Wild Wines may use your personal data for the development of its products and services. However, we will predominantly use aggregated data and statistical information for such purposes. World Wild Wines keeps track of the pages our customers visit within the website to determine which services/products are most requested.
In this case, information is collected regarding the computer or device (including mobile devices) you use to access it, namely your IP address, the website through which you accessed ours, your browser type and language, operating system, cookies, the country from which you are accessing referring and exit pages, URL, platform type, the number of clicks made, domain names, landing pages, pages visited and the order in which you visited them, the time spent on a particular page, the date and time you accessed our website, access errors and other similar information your browser sends us.
World Wild Wines may use your personal data to communicate with you, in particular to send you news related to our products or services, or to assist you in customer support aspects, in particular to respond to and handle user requests through customer service channels, as well as monitoring the quality of our service.
In this case your full name, email address and telephone number are collected.
Subscribing to the World Wild Wines Newsletter may involve the use of personal data in order to carry out personalised advertising of our products and services available to the user via e-mail, push notifications through any other electronic means or from third parties.
You can unsubscribe from the Newsletter at any time by following the information we provide in each communication.
World Wild Wines may use data that has been identified based on your personal and behavioural preferences, which we collect from your interactions with us, whether through the Site, app, helpline, as well as from product usage, to send you personalised offers.
In this case, the following personal data will be collected: gender and preferences for services or products.
The processing of data for the purpose of profiling and market research is also based on the legitimate interest of World Wild Wines. To this end, World Wild Wines has considered the interests and rights of the data subjects, and the measures taken by the controller to fulfil its general obligations in terms of proportionality and transparency, and has concluded that:
(a) the impact on the fundamental rights and freedoms and guarantees of individuals is low;
b) such treatment can be reasonably foreseen by the person concerned;
c) the processing of data for the above purposes does not give rise to exclusion, discrimination, defamation or situations that endanger the reputation of the data subject and/or the bargaining power.
If you consider that said processing may generate some kind of emotional repercussion, you may exercise the right of access and/or opposition, as well as voluntarily exclude yourself without the need for justification.
We inform you that you can limit this purpose by exercising the right to object by writing an e-mail to any of the contacts listed under “Contacts”.
Improving the service available to the user
Your Personal Data related to your purchases in our online shop (www.worldwildwines.pt), tastes and preferences may be used for the purposes of analysis, user profiling, market research, quality surveys and improving our customer interaction.
We process the aforementioned personal data in accordance with the provisions of the RGDP and other legislation applicable in this field, the processing being based, in the main, on pre-contractual diligence and contract enforcement, the fulfilment of a legal obligation or for the satisfaction of legitimate interests pursued by World Wild Wines or protection of vital interest of the data subject.
In other words, we use and process your personal data for the management and performance of contracts or other steps requested by the data subject (Art. 6.1 paragraph b) RGDP); in the framework of a legitimate interest (Art. 6.1 paragraph f) RGDP); based on your consent (Art. 6.1 paragraph a) RGDP) and by legal imperative or in the public interest (Art. 6.1 paragraph c) and e) RGDP).
WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
Where appropriate and in accordance with local laws and requirements, we may share your personal data in various ways and for various reasons with the following categories of persons:
– In the course of an investigation, complaint or procedure, to the Tax Authorities, Audit Authorities, the Administration, Public Bodies, the Court, Foreigners and Border Services (“SEF”) and Security Forces, who are responsible for the matter and, internally, to the areas or departments of World Wild Wines that collaborate in the collection of information and communication of the facts to the competent authority;
– Third party service providers who perform functions on our behalf (including external consultants, business partners and professional advisors such as lawyers, auditors and accountants, recruitment firms, technical support functions and IT consultants who perform testing and development work on our company’s technology systems);
– Third party providers of outsourced computer and document storage services, where we have an appropriate handling agreement (or similar protections) in place;
– Marketing technology platforms and providers;
– In the event of the acquisition or disposal of businesses or assets, we may share your personal data with the potential acquirers of those businesses or assets
– In the case of payments the credit entities and the other payment service providers, as well as the technology service providers related to payment services to whom the data is transmitted to effect the transaction, and who may be obliged by the legislation of the State where they operate, or by agreements concluded by it, to facilitate information on transactions to the authorities or official bodies of other countries, located both within and outside the European Union, in the framework of the fight against the financing of terrorism, serious forms of organised crime and prevention of money laundering.
Our website and application provides you, in certain circumstances, with social plugins from various social networks. If you decide to interact with a social network such as Facebook, Twitter, Google + (e.g. through account registration), your activity on our website or in our app will also be available to the respective social network. If you are connected to one of these social networks during your visit to our website or app or are interacting through one of the aforementioned social plugins, the social network may include this information to your profile on said social network, in accordance with its privacy settings. If you wish to avoid this type of data transfer, please log out of your social network account before entering our website or application or change your privacy settings whenever possible. We advise you to read the privacy policies of the social networks you use to get detailed information about the collection and transfer of personal information, know your rights and which privacy settings appropriate to your profile you should select.
HOW DO WE SAFEGUARD YOUR PERSONAL DATA?
We are committed to taking all reasonable and appropriate measures to protect the personal information we hold from misuse, accidental or unlawful alteration, loss and unauthorised disclosure or access. To this end World Wild Wines uses security systems, rules and other procedures to ensure the protection of your personal data, as well as to prevent unauthorised access to data, misuse, disclosure, loss or destruction.
If you suspect misuse, loss or unauthorised access to your personal information, please inform us immediately.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We only keep your personal data for as long as is necessary to achieve the purpose for which we collected it, to respond to your needs, your requests to us, or to comply with our contractual and legal obligations.
To determine the period for which we store your data, we use the criteria mentioned below. If several criteria apply simultaneously, we will retain your personal data under the criterion that entails the retention of your personal data for the longest period of time.
a) When you purchase products and services, we will retain your personal data for the duration of our business relationship, including any claims that may arise, as well as and for the period of ten 10 years after the termination of such relationship, without prejudice to compliance with legal obligations of the controller;
b) When you contact us to ask questions, request information and clarifications, we will retain your personal data for the period of time necessary to resolve your question/provide you with the requested information and/or clarifications;
c) When you create a customer account, i.e. when you register on our website, we will retain your data until you ask us to delete it or after a period of inactivity of two 2 years;
d) Where you have consented to us sending you direct marketing, we will retain your personal data for as long as the purpose for which it was collected remains unchanged or until you unsubscribe or ask us to delete it;
f) With respect to data collected in the recruitment process, for a maximum period of five  years after the closure of the recruitment process;
h) The period of time provided by applicable law;
i) Until the specific purpose applicable to certain data ceases to exist.
We may also retain some of your personal data to the extent necessary to comply with our legal obligations and to administer or enforce our rights, including through recourse to judicial or administrative remedies.
In any of the aforementioned situations, if judicial or administrative proceedings are pending, the data will still be kept for the duration of the proceedings and up to six months after the final decision has been handed down.
After the above retention periods, personal data will be deleted and/or erased in an absolutely secure manner.
HOW CAN YOU ACCESS, CHANGE OR REMOVE THE PERSONAL DATA YOU HAVE PROVIDED US WITH?
One of the main aims of the GDPR is to protect and clarify the rights of EU citizens and people in the EU with regard to data privacy. This means that you have a number of rights in relation to your data, even if you have given it to us yourself. These are described in more detail below.
We will endeavour to deal with your request without undue delay and, in any event, within one month (subject to any extensions permitted by law). Please note that we may keep a record of your communications to help us resolve any issues raised by you.
Right to object: this right allows you to object to our processing of your personal data on grounds relating to your particular situation where your personal data is processed for one of the following reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or to exercise official authority; (iii) to send you direct marketing materials, including profiling; and (iv) scientific, historical, research or statistical purposes.
If you exercise your right to object, we will stop the processing of the data to which you object, unless:
– we can demonstrate that we have compelling legitimate grounds for the processing which override your interests; or
– we are processing your data for the establishment, exercise or defence of a right.
Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (e.g. for marketing purposes), you may withdraw this consent at any time and we will no longer carry out the specific activity to which you previously consented, unless we consider there is an alternative reason to justify our continued processing of your data for this purpose, in which case we will inform you of this condition.
Data Subject Access Requests: You may ask us at any time to confirm the information we have about you, as well as request additional information about the purposes of the processing, the period for which we keep your data, the existence of automated decisions, the recipients to whom the data is disclosed, among other information provided for in Article 15 of the GDPR. We may ask you to verify your identity and further information about your request. If we grant you access to information we hold about you, we will not charge you for such access unless your request is “manifestly unfounded or excessive”. If you ask us for additional copies of this information, we may charge you a reasonable administration fee, where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, you will always be informed of the reasons for doing so.
Right to forget/delete: In certain circumstances, you have the right to request that we delete your personal data. Normally, the exercise of this right must meet one of the following criteria:
– the data is no longer necessary for the purpose for which we originally collected and/or processed it;
– where you have withdrawn your consent for us to process your data and there is no other valid reason for us to continue processing it;
– if you object to the processing and there are no overriding legitimate interests to justify it:
– the data has been unlawfully processed (i.e. in a way that does not comply with the GDPR); or
– it is necessary for the data to be deleted in order to comply with our legal obligations as a controller.
This right, however, does not apply, and therefore World Wild Wines may continue to lawfully process your data where necessary:
– to exercise the right of freedom of expression and information;
– to comply with legal obligations or to perform a task in the public interest or the exercise of official authority;
– for public health reasons in the interest of the public;
– for archival, research or statistical purposes; or
– for the exercise or defence of a right.
When complying with a valid request for data erasure, we will take all reasonable practical steps to erase the data.
Right to restrict processing: In certain circumstances, you have the right to restrict our processing of your personal data. This means that we may only continue to store your data and may not carry out any further processing activities with it until: (i) one of the circumstances listed below is resolved; (ii) we have obtained your consent; or (iii) further processing is necessary for the establishment, exercise or defence of a right, the protection of the rights of another person or reasons of important public interest of the EU or a Member State.
The circumstances in which you are entitled to request that the restriction of the processing of your personal data are:
– in the event that you dispute the accuracy of the personal data we process about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
– in the event that you object to the processing of your personal data for our legitimate interests. In this situation, you can ask for the data to be restricted while we verify our grounds for processing your personal data;
– if our processing of your data is unlawful, but you would prefer us to restrict our processing of your data rather than erasing it; and
– if we no longer need to process your personal data, but need the data for the establishment, exercise or defence of a right.
If we have shared your personal data with third parties, they will be notified about the restricted processing, unless this is impossible or would involve a disproportionate effort. We will, of course, notify you before lifting any restriction on the processing of your personal data.
Right of rectification: You have the right to request that we rectify any inaccurate or incomplete personal data we hold about you. Where we have shared such personal data with third parties, they will be notified about the rectification, unless this is impossible or involves a disproportionate effort. Where appropriate, we will also disclose to you to which third parties we disclosed the inaccurate or incomplete personal data. Where we believe it is reasonable not to comply with your request, we will explain the reasons for our decision. It is important that the personal information we hold about you is accurate and up to date. Please let us know if there are any changes to your personal information during the period we hold your data.
Right to data portability: If you so wish, you have the right to transfer your personal data between controllers. In effect, this means that you can transfer your data from your World Wild Wines account to another online platform. To enable you to do this, we will provide you with your data in a commonly used password-protected machine-readable format so that you can transfer the data to another online platform. Alternatively, we may transfer the data directly for you. This right to data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or to fulfil a contract.
Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority, which in Portugal is the National Commission for Data Protection and whose contact details are:
National Commission for Data Protection
Address: Av, D. Carlos I, 134 – 1º, 1200-651 Lisboa
If you wish to exercise any of these rights or withdraw your consent to the processing of your personal data (if consent is our legal basis for processing your personal data), please contact us. Please note that we may keep a record of your communications to help us resolve any issues raised by you.
How can you contact us
World Wild Wines
An alternative, you can email us at: firstname.lastname@example.org
Contact details for the World Wild Wines DATA PROTECTION OFFICER:
World Wild Wines
Data Protection Officer
HOW DO WE STORE AND TRANSFER YOUR DATA INTERNATIONALLY?
Data transmission to other countries (countries outside the European Union) only occurs if this is necessary for the execution of orders or requests from you (e.g. payment orders or product shipments), if required by law or if you have given us express permission to do so. If it is necessary to use service providers from third countries, these are obliged to comply with the written instructions in this regard by signing an agreement with the EU standard contractual clauses for compliance with the level of data protection applicable in the EU. You will receive detailed information from us separately, where defined by law. We want to ensure that your data is stored and transferred in a secure manner. We will therefore only transfer data outside the European Economic Area or EEA (i.e. the Member States of the European Union together with Norway, Iceland and Liechtenstein) where this complies with data protection legislation and the means of transfer provide adequate safeguards in relation to your data, for example:
– by a data transfer contract, which incorporates the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to controllers and processors in jurisdictions lacking adequate data protection laws; or
– by adhering to the EU-US Privacy Shield framework for the transfer of personal data from entities in the EU to entities in the United States of America or any equivalent agreement relating to other jurisdictions; or
– by transferring your data to a country where the European Commission has recorded a finding of adequate protection in relation to the data protection levels of that country through its legislation; or
– if you have consented to the transfer of data.
To ensure that your personal data receives an adequate level of protection, we have applied appropriate procedures with the third parties with whom we share your personal data to ensure that your personal information is handled by those third parties in a manner that is consistent with and complies with data protection law.
Warranties and caveats
The user guarantees that the personal data communicated to World Wild Wines are correct and accurate and undertakes to notify any changes or modifications thereto and assumes sole responsibility for losses and damages caused by erroneous, inaccurate or incomplete communication of the data. The user is expressly warned that by disclosing personal data on public means of World Wild Wines such as Facebook, Google+, Twitter and Instagram, this information may be seen and used by third parties. World Wild Wines does not read any personal communications posted on its clients’ own websites.
RECOMMENDED BROWSERS TO VIEW THE PAGE CORRECTLY
The World Wild Wines website is optimised for viewing with Google Chrome, Safari, Mozilla Firefox, Microsoft Internet Explorer and Microsoft Edge web browsers.
What is a cookie?
If you want to check or change the type of cookies you accept, you can do so in your browser settings.
– Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in on each page, but do not collect any information from your computer; or
– Persistent cookies: these are stored as a file on your computer and remain when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies from Google Analytics, Facebook and Mailchimp.
– Strictly necessary cookies: These are essential to enable you to use the website effectively, they cannot be disabled. Without these cookies, the services available to you on the site cannot be provided. These cookies do not collect information about you that can be used for marketing.
– Performance Cookies: These cookies allow us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
– Functionality cookies: these allow our site to remember the choices you make (such as your username, language or region you are in) and provide enhanced functionality. For example, we may provide you with relevant news or updates on our website. These cookies may also be used to remember changes you make to text size, font, and other parts of the web pages that you can customise. They may also be used to provide services you have requested, such as viewing a video. The information these cookies collect is usually anonymised.
– Personalisation cookies: These cookies are persistent (for as long as you are registered with us) and mean that when you log in or return to the site you may see ads similar to those you have previously browsed.
Under the terms of Law No. 41/2004 of 18 August, the storage of information and the possibility of accessing information stored in a user’s terminal equipment (namely through cookies) are only carried out by World Wild Wines if the user has given his prior and express consent to the installation of cookies on his equipment, and we therefore ask you, prior to using the websites, to accept the present Privacy and Cookies Policy.
You can see this information for the main Internet browsers at the following addresses:
♦ Chrome: at https://support.google.com/chrome/answer/95647?hl=pt
♦ Explorer: at https://support.microsoft.com/pt-pt/help/278835/how-to-delete-cookie-files-in-internet-explorer
♦ Firefox: at https://support.mozilla.org/pt-PT/kb/ativar-e-desativar-cookies-que-os-websites-utiliza
♦ Safari: at https://support.apple.com/kb/ph5042?locale=pt_PT
Finally, if you wish to have greater control over the installation of cookies, you can install programs or add-ons to your browser, known as “do not track” tools, that will allow you to choose which cookies you wish to allow.
DECLARE, EXERCISE OR DEFEND RIGHTS
We may sometimes need to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in relation to the exercise or defence of rights. Article 9(2)(f) of the GDPR allows such processing where it is “necessary for the establishment, exercise or defence of legal claims or when courts are acting in their judicial role.”
This may arise, for example, in cases where we need to obtain legal advice in relation to legal proceedings or if we are required by law to retain or disclose certain information as part of a legal process.
AMENDMENTS TO THE DOCUMENT