DOM SALVADOR WINES
PRIVACY POLICY
At VINHOS DOM SALVADOR, we understand that the use of your personal data requires your trust. We are subject to the highest standards of privacy and will only use your personal data for clearly identified purposes and in accordance with your data protection rights. The confidentiality and integrity of your personal data is one of our main concerns. This Privacy Policy establishes the way in which VINHOS DOM SALVADOR uses the personal data of its customers and potential customers.
1. COLLECTION AND PROCESSING OF USER DATA
The Personal Data collected and processed consists of information relating to the name, email, address, although other Personal Data may be collected, which may be necessary or convenient for the provision of services by VINHOS DOM SALVADOR.
After the collection of Personal Data, VINHOS DOM SALVADOR provides the User with detailed information about the nature of the data collected, purpose and treatment that will be carried out in relation to the Personal Data.
VINHOS DOM SALVADOR also collects and processes information about the characteristics of its hardware device and browser/software characteristics, as well as information about the pages visited by the User within the Site. This information may include your browser type, domain name, access times and the links through which the User accessed the Site (“Usability Information”). We use this information only to improve the quality of your visit to our Site.
Usability Information and Personal Data are referred to in this Privacy Policy as “User Data”. For the purposes of this Privacy Policy, a contractual relationship is understood to mean any and all contract established between VINHOS DOM SALVADOR and the entities that relate to it, regardless of the respective object.
2. SUBCONTRACTED ENTITIES
In the context of the processing of User Data, VINHOS DOM SALVADOR uses or may resort to third parties, which it subcontracts, to, on behalf of VINHOS DOM SALVADOR, and in accordance with the instructions given by it, process the Data of the User, in accordance with the law and this Privacy Policy.
These subcontracted entities may not transmit User Data to other entities, without VINHOS DOM SALVADOR having previously given written authorization to do so, and are also prevented from contracting other entities without the prior authorization of VINHOS DOM SALVADOR.
VINHOS DOM SALVADOR is committed to subcontracting only entities that offer maximum security in carrying out the appropriate technical and organizational measures, in order to guarantee the protection of the User's rights. All entities subcontracted by VINHOS DOM SALVADOR are bound to the latter through a written contract, which regulates, in particular, the object and duration of the processing, the nature and purpose of the processing, the type of personal data, the categories of data holders and the rights and obligations of the parties.
After the collection of personal data, VINHOS DOM SALVADOR provides the User with information about the categories of subcontracted entities that, in the specific case, may process data, on behalf of VINHOS DOM SALVADO
4. GENERAL PRINCIPLES APPLICABLE TO THE PROCESSING OF USER DATA
In terms of general principles relating to the processing of personal data, VINHOS DOM SALVADOR undertakes to ensure that the User Data, processed by it, are:
• Subject to fair and transparent treatment, in accordance with the law, in relation to the User;
• Collected for specific, objective and legitimate purposes, not being subsequently treated in a way contrary to these purposes;
• Appropriate, justified and limited to what is necessary for the purposes for which they are treated;
• Accurate and updated, whenever necessary, with all necessary measures being taken so that inaccurate data, taking into account the purposes for which they are processed, are erased or corrected without delay;
• Kept in a way that allows the identification of the User, only for the period necessary, for the purposes for which the data are processed;
• Treated in a way that guarantees their safety, including protection against their unauthorized or illegal treatment and against their loss, destruction or unforeseen damage, with appropriate technical or organizational measures being adopted;
• The data processing carried out by VIINHOS DOM SALVADOR is allowed and legal, when at least one of the following situations occurs:
– The User has, without any doubt, given his consent to the processing of User Data for one or more specific purposes;
– The processing is necessary for the execution of a contract to which the User is a party, or for pre-contractual procedures at the User's request;
– The treatment is necessary for the fulfillment of a legal obligation to which VINHOS DOM SALVADOR is subject;
– The processing is necessary for the defense of the fundamental interests of the User or another individual person;
– Processing is necessary for the purpose of legal interests pursued by VINHOS DOM SALVADOR or by third parties (except if the interests or fundamental rights and freedoms of the User that require the protection of personal data prevail).
VINHOS DOM SALVADOR undertakes to ensure that the processing of User Data is only carried out under the conditions listed above and in compliance with the aforementioned principles. When the processing of User Data is carried out by VINHOS DOM SALVADOR, based on the User's consent, the User has the right to withdraw his consent at any time. The withdrawal of consent, however, does not compromise the legality of the treatment carried out by VIINHOS DOM SALVADOR, based on the consent previously given by the User.
The period of time for which data is stored and preserved varies according to the purpose for which the information is processed. Effectively, there are legal requirements that oblige you to keep data for a minimum period of time. Thus, and whenever there is no specific legal obligation, the data will be stored and preserved, only for the minimum period necessary, for the purposes that motivated its collection or subsequent processing and, at the end of its term, they will be deleted.
5. USE AND PURPOSES OF PROCESSING USER DATA
In general terms, VINHOS DOM SALVADOR uses User Data for the following purposes:
• Management of contacts with the User; • Inform the User, upon request, of new products and services made available on the Site, special offers and campaigns, updated information on the activity of VINHOS DOM SALVADOR, and, in general, for the marketing purposes of VINHOS DOM SALVADOR, or through any means of communication, including electronic support or social media;
• Allow access to restricted areas of the Site;
• Ensuring that the Site meets the User's needs, through the development and publication of content as adapted as possible to the requests and type of User, improving the Site's search capabilities and functionalities and obtaining associated or statistical information regarding the User's typical profile (analysis of consumption profiles);
• Provision of services, and other services, such as newsletters, opinion surveys, or other information, or products requested by the User;
• Submission of Satisfaction Questionnaires;
• VINHOS DOM SALVADOR may combine Usability Information with anonymous demographic information for research purposes, and may use the result of this combination to provide more relevant content on the Site. In certain restricted areas of the Site, VINHOS DOM SALVADOR may combine Personal Data with Usability Information to provide the User with more personalized content.
The User Data collected by VINHOS DOM SALVADOR are not shared with third parties, without the User's consent, with the exception of the situations referred to in the paragraph below. However, in the event that the User contracts with VINHOS DOM SALVADOR services that are provided by other entities responsible for the processing of personal data, the User's Data may be consulted or accessed by these entities, insofar as this is necessary for the provision of said services and the User will be informed of this.
Under the applicable legal terms, VINHOS DOM SALVADOR may transmit or communicate User Data to other entities:
– In case such transmission or communication is necessary for the execution of the contract established between the User and WINES DOM SALVADOR;
– Or for pre-contractual measures, at the User's request, if necessary to fulfill a legal obligation, to which VINHOS DOM SALVADOR is subject, or if necessary to obtain the legitimate interests of VINHOS DOM SALVADOR or third party.
In the event of a transmission of User Data to third parties, reasonable efforts will be made for the transferee to use the User Data, properly transmitted with this Privacy Policy.
6. TECHNICAL, ORGANIZATION AND SAFETY MEASURES IMPLEMENTED
To ensure the security of User Data and maximum confidentiality, VIHOS DOM SALVADOR treats the information you have provided us in an absolutely confidential manner, in accordance with its internal security and confidentiality policies and procedures, which are periodically updated from according to the needs, as well as, with the terms and conditions foreseen by law.
Depending on the nature, scope, context and purposes of data processing, as well as the risks arising from the processing for the rights and freedoms of the User, VINHOS DOM SALVADOR undertakes to apply, both at the time of defining the means of processing, such as at the time of processing itself, the technical and organizational measures necessary and adequate for the protection of User Data and compliance with legal requirements.
It also undertakes to ensure that, by default, only data that are necessary for each specific purpose of the processing are processed and that these data are not made available without human intervention to an indeterminate number of people.
Communication between the user's device and WINES DOM SALVADOR is carried out through secure and communications channels that use the HTTPS protocol and the SSL security standard. Even so, in terms of general measures, VINHOS DOM SALVADOR adopts the following:
• Regular audits to identify the competence of the technical and organizational measures implemented;
• Raising awareness and training of personnel involved in data processing operations;
• Pseudonimization and encoding of personal data;
• Mechanisms capable of ensuring the confidentiality, availability and permanent resilience of information systems;
• Mechanisms that ensure the restoration of information systems and access to personal data quickly in the event of a physical or technical incident.
7. DATA TRANSFER OUTSIDE THE EUROPEAN UNION
The Site does not transfer your personal data to recipients located in countries outside the European Union.
8. USE OF COOKIES
When you visit our website, a small text file (Cookie) is created and saved on your computer's disk. Therefore, when browsing the Site, you are accepting the installation of this text file on your device. This file will allow you to access the Site more easily and quickly, as well as its customization, according to your preferences.
If you want to delete them or automatically set their blocking, in the “Help/Help” menu of your browser you will find how to make these settings. However, if you do not allow the use of cookies, there may be some features on the Site that you will not be able to use.
When browsing our Site, you are allowing the collection and storage of small text files, called cookies, which contain information and which are downloaded to the Users' computer or other devices through a server. These text files will allow for a more personalized and efficient browsing experience.
On each visit to the Website, your internet browser sends these cookies back to the Website, allowing the recognition and memorization of the Users' identity, as well as their usage preferences.
9. USERS' RIGHTS (DATA HOLDERS)
9.1. RIGHT TO INFORMATION
9.1.1. Information provided to the User by VINHOS DOM SALVADOR (when the data is collected directly from the User):
• The identity and contacts of VINHOS DOM SALVADOR and the person responsible for the processing;
• The contact details of the Data Protection Officer;
• The purposes of the processing for which the personal data are intended, as well as, if applicable, the legal reasons for the processing;
• If the processing of data is based on the legitimate interests of VINHOS DOM SALVADOR or of a third party, an indication of such interests;
• If applicable, the recipients or categories of recipients of the personal data;
• If applicable, an indication that the personal data will be transferred to a third country or an international organization, and the existence, or not, of an adequacy decision adopted by the Commission or reference to appropriate or adequate transfer guarantees;
• Period of retention of personal data;
• The right to request, from VINHOS DOM SALVADOR, permission/access to personal data, as well as its correction, elimination or limitation; • The right to object to the treatment;
• The right to data accessibility;
• If the processing of data is based on the User's consent, the right to withdraw it at any time, without compromising the legality of the processing carried out, based on the consent previously given; • The right to file a complaint with the CNPD or other supervisory authority;
• Indication of whether or not the communication of personal data constitutes a legal or contractual obligation, or a necessary requirement to enter into a contract, as well as whether the holder is obliged to provide personal data and the possible consequences of not providing such data;
• If applicable, the existence of automatic decisions, including the definition of profiles and information related to the basic concept, as well as the importance and expected consequences of such treatment for the data subject.
If the User's Data is not collected directly by VINHOS DOM SALVADOR, from the User, in addition to the information mentioned above, the User is also informed about the categories of personal data being processed and, thus, about the origin of the data and , eventually, if they are from publicly accessible sources.
If VINHOS DOM SALVADOR intends to further process the User's Data for a purpose other than that for which the data were collected, prior to such processing, VINHOS DOM SALVADOR will provide the User with information about that purpose and any other information of interest , as mentioned above.
9.2. Procedures and measures implemented to fulfill the right to information
The information referred to in 9.1. it is provided in writing (including by electronic means), by VINHOS DOM SALVADOR to the User, prior to the processing of personal data in question. Under the terms of the applicable law, VINHOS DOM SALVADOR is not obliged to provide the User with the information mentioned in 9.1, when and to the extent that the User is already aware of it. The information is provided by WINES DOM SALVADOR at no cost.
10. RIGHT OF ACCESS TO PERSONAL DATA
VINHOS DOM SALVADOR guarantees the means that allow the User to consult his/her Personal Data. The User has the right to obtain, from VINHOS DOM SALVADOR, confirmation that the personal data concerning him are or are not the object of processing and, if applicable, the right to access his personal data and the following information :
• The purposes of data processing;
• The categories of personal data in question;
• The recipients or categories of recipients to whom the personal data have been or will be disclosed, namely recipients established in third countries or belonging to international organizations; • The period of retention of personal data;
• Right to request, from VINHOS DOM SALVADOR, correction, elimination or limitation of the processing of personal data, or the right to prevent such processing;
• Right to file a complaint with the CNPD or other supervisory authority;
• If the data has not been collected from the User, the information available on the origin of that data;
• The existence of automated decisions, including the definition of profiles, and information regarding the underlying logic, as well as the importance and expected consequences of such processing for the data subject;
• Right to be informed about the appropriate safeguards associated with transferring data to third countries or international organizations.
Upon request, VINHOS DOM SALVADOR will provide the User, free of charge, with a copy of the User Data which is in the process of being processed. The provision of other copies requested by the User may incur administrative costs.
11. RIGHT TO CORRECT PERSONAL DATA
The User has the right to request, at any time, the rectification of his Personal Data and also the right to complete his personal data, including by means of an additional declaration.
In case of rectification of data, VIINHOS DOM SALVADOR communicates to each recipient, to whom the data has been transmitted, the respective rectification, unless such communication is considered impossible or implies a disproportionate effort for VIINHOS DOM SALVADOR.
12. RIGHT TO DELETE PERSONAL DATA ("RIGHT TO BE FORGOTTEN")
The User has the right to request, at any time, the rectification of their Personal Data. The User has the right to obtain, on the part of VINHOS DOM SALVADOR, the deletion of their data, when one of the following reasons applies:
• User Data is no longer necessary for the purpose for which it was collected or processed;
• The User withdraws the consent, on which the data processing is based, and there is no other legal basis for such processing;
• The User opposes the processing, under the right of opposition, and there are no prevailing legitimate interests that justify the processing;
• If User Data is illegally processed;
• If the User's Data have to be erased in order to comply with a legal obligation to which VINHOS DOM SALVADOR is subject;
• Under the applicable legal terms, VINHOS DOM SALVADOR is under no obligation to delete User Data, insofar as the processing proves necessary to comply with a legal obligation to which VINHOS DOM SALVADOR is subject or for the purposes of declaration, exercise or defense of a right of VINHOS DOM SALVADOR, in legal proceedings.
In the event of data deletion, VINHOS DOM SALVADOR communicates to each recipient/entity, to whom the data has been transmitted, the respective deletion, unless such communication proves to be impossible or implies a disproportionate effort for VINHOS DOM SALVADOR.
When VINHOS DOM SALVADOR has made the User's Data public and is obliged to erase them, under the right of such elimination, VINHOS DOM SALVADOR undertakes to ensure reasonable measures, including those of a technical nature, taking into account the available technology and the costs of its application, to inform those responsible for the effective processing of personal data that the User has asked them to delete the links to such personal data, as well as copies or reproductions thereof.
13. RIGHT TO LIMIT THE PROCESSING OF PERSONAL DATA
The User has the right to obtain, on the part of VINHOS DOM SALVADOR, the limitation of the processing of User Data, if one of the following situations applies (the limitation consists of inserting a mark in the personal data kept in order to limit its future treatment):
• If you dispute the accuracy of the personal data, for a period that allows VINHOS DOM SALVADOR to verify their accuracy;
• If the processing is illegal and the User opposes the deletion of the data, requesting, in return, the limitation of its use;
• If VINHOS DOM SALVADOR no longer needs the User's Data for processing purposes, but these data are required by the User for the purposes of declaration, exercise or defense of a right, in a legal proceeding;
• If the User has opposed the treatment, until it is verified that the legitimate reasons of VINHOS DOM SALVADOR prevail over those of the User.
When User Data are subject to limitation, they may only, with the exception of conservation, be processed with the User's consent or for the purposes of declaration, exercise or defense of a right, in legal proceedings, to defend the rights of another natural person or collective, or for reasons of public interest provided for by law.
The User who has obtained the limitation of the processing of his/her data, in the above-mentioned cases, will be informed by VINHOS DOM SALVADOR, before the limitation of the processing is cancelled. In case of limitation in the processing of data, VINHOS DOM SALVADOR will communicate to each recipient, to whom the data has been transmitted, the respective limitation, unless this communication proves to be impossible or implies a disproportionate effort for VINHOS DOM SALVADOR.
In case of limitation in the processing of data, VINHOS DOM SALVADOR will communicate to each recipient, to whom the data has been transmitted, the respective limitation, unless this communication proves to be impossible or implies a disproportionate effort for VINHOS DOM SALVADOR.
14. RIGHT TO PORTABILITY OF PERSONAL DATA
The User has the right to receive the personal data concerning him/her that he/she has provided to VINHOS DOM SALVADOR, in a structured format, commonly used and automatically read, and the right to transmit this data to another person responsible for the processing, if :
• The processing is based on consent or a contract to which the User is a party; and
• The treatment is carried out by automated means. The portability right does not include inferred data, nor derived data, ie, personal data generated by VINHOS DOM SALVADOR, as a consequence or result of the analysis of the data being processed.
The User has the right to have their personal data transmitted directly between those responsible for the processing, whenever this is technically possible.
15. RIGHT OF OPPOSITION TO TREATMENT
The User has the right to object, at any time, for reasons related to his particular situation, to the processing of personal data concerning him, based on the exercise of legitimate interests pursued by VINHOS DOM SALVADOR, or when the processing is carried out for purposes other than those for which personal data were collected, including profiling, or when personal data are processed for statistical purposes.
VINHOS DOM SALVADOR will complete the processing of User Data, unless it presents urgent and legitimate reasons for such processing, which prevail over the interests, rights and freedoms of the User, or for the purposes of declaration, exercise or defense of a right of VINHOS DOM SALVADOR, in a court case.
When User Data are processed for the purposes of direct marketing (marketing), the User has the right to object, at any time, to the processing of data concerning him for the purposes of said marketing, which includes the definition of profiles, insofar as it is related to direct marketing.
If the User opposes the processing of his/her data, for the purposes of direct marketing, VINHOS DOM SALVADOR will cease processing the data for this purpose.
The User also has the right not to be subject to any decision taken, exclusively based on automated processing, including the definition of profiles, that produce effects in its legal sphere or that affect it, significantly and in a similar way, unless the decision:
• It is necessary for the execution or execution of a contract between the User and WINES DOM SALVADOR;
• Is authorized by legislation to which VINHOS DOM SALVADOR is subject; or
• Is based on the User's explicit consent.
16. PROCEDURES FOR THE EXERCISE OF RIGHTS BY THE USER
The right of access, the right of rectification, the right of deletion, the right to limitation, the right to portability and the right to object may be exercised by the User, by contacting the Data Protection Officer of VINHOS DOM SALVADOR, through from info@alvarinhodomsalvador.com.
VINHOS DOM SALVADOR will respond in writing (including by electronic means) to the User's request, within a maximum period of one month from receipt of the request, except in cases of special complexity, in which this period may be extended to two months.
If the requests submitted by the User are manifestly unjustified or excessive, namely due to their repetitive nature, VINHOS DOM SALVADOR reserves the right to charge administrative costs or refuse to comply with the request.
17. PERSONAL DATA BREACHES
In case of data breach and to the extent that such breach is likely to imply a high risk to the rights and freedoms of the User, VINHOS DOM SALVADOR undertakes to communicate the breach of personal data to the User concerned, within a period of 72 hours from the knowledge of the incident.
Under legal terms, communication to the User is not required in the following cases:
• If VINHOS DOM SALVADOR has applied adequate protection measures, both technical and organizational, and these measures have been applied to the personal data affected, by the violation of personal data, especially measures that make the personal data incomprehensible to any unauthorized person to access such data, such as encryption;
• If VINHOS DOM SALVADOR has taken subsequent measures to ensure that the high risk to the User's rights and freedoms is no longer likely to materialise;
Or if communication to the User implies a disproportionate effort for VINHOS DOM SALVADOR. In this case, VINHOS DOM SALVADOR will make a public announcement or take a similar measure, through which the User will be informed. To exercise any of these rights, you can complete the attachment.
18. CHANGES TO THE PRIVACY POLICY
VINHOS DOM SALVADOR reserves the right to change this Privacy Policy at any time. In case of modification of the Privacy Policy, the date of the last modification, available at the bottom of this page, is also updated. If the change is substantial, a notice will be posted on the Site.
19. APPLICABLE LAW AND JURISDICTION
The Privacy Policy, as well as the collection, processing or transmission of User Data, are governed by the provisions of Regulation (EU) 2016/679, of the European Parliament and of the Council, of April 27, 2016 and by legislation and regulations applicable in Portugal, namely by Law 58/2019.
Any disputes arising from the validity, interpretation or execution of the Privacy Policy, or which are related to the collection, processing or transmission of User Data, must be submitted, exclusively, to the jurisdiction of the judicial courts of the district of Penafiel, without prejudice to mandatory legal norms applicable.