Privacy Policy

Information on personal data protection
With the following information, Emporio Enologico Albese s.r.l. provides an overview of the processing of data and the rights of the Data subject in compliance with EU REG 679/2016 (GDPR) and Legislative Decree 196/2003 (Privacy Code).

1. HOLDER OF THE PROCESS

Who is responsible for processing the data and how can they be contacted?
The holder of the process is the following company, contactable as indicated below:

EMPORIO ENOLOGICO ALBESE s.r.l., in the person of the legal representative pro tempore, with registered office in Guarene (CN) Strada Porini 1/B - 12050 - VAT no. IT 01970770044 – Tel. +39 0173 35937 - Fax +39 0173 35562 - Email: ecommerce@emporioenologico.com

2. DATA SOURCES

Which sources and which data do we use?
We process the personal data that we obtain from the person who supplies it (the "Data subject") within the scope of our commercial activity.

We also process - where necessary to supply our services and/or products - personal data obtained from freely accessible public sources (e.g.: Chamber of Commerce, commercial registers and the registers of associations, the press and Internet), or received legitimately from third parties.

Important data includes personal information (e.g.: name, address or other contact details. date and place of birth, nationality), ID (e.g.: details of identity document), contact details (e.g.: e-mail, telephone number). It can also be data relating to an order (e.g.: job order, sales order or a bank transfer), data relating to the fulfilment of our contractual obligations, marketing and sales data and other data similar to the categories mentioned.

3. PURPOSE OF THE PROCESS

Why do we process your data (purpose of the process) and on what legal basis?
We process your personal data in compliance with the European General Data Protection Regulation (GDPR) and National Legislation for the following purposes:

1. Fulfilment of contractual obligations: The data will be processed to access the services supplied through registration, for needs preliminary to the stipulation of agreements, to implement them by means of operational and managerial processes, including the dispatch of e-mail (art. 6 par. 1b GDPR).
2. Compliance with legal provisions or in the public interest: The data will be processed for administrative and accounting requirements in the pursuit of legal obligations, particularly relating to taxation, including the dispatch of commercial invoices by e-mail; (art. 6 par. 1c and 1e GDPR).
3. In consideration of the assessment of interests: regardless of the actual fulfilment of the contract, for the purposes of the pursuit of legitimate interests on our part or that of third parties, such as, by way of non-limiting example:
   
   • Assessment of legal claims and defence in legal disputes;
   • Video surveillance for the defence of the right of the owner of premises to impede access by unauthorised persons;
   • Measures for the construction and security of sites (e.g.: control of access); following the balancing between the legitimate interest of the Holder or of the third party and the rights and freedom of the Data subject (art. 6 par. 1f GDPR).
4. For the purposes of marketing, but only after gaining consent. The data can be used by the Holder to pursue activities of marketing, commercial information and promotional activities, including the dispatch of newsletters and advertising material, also with messaging apps, after gaining specific consent, notwithstanding the right to withdraw such consent at any time. Withdrawal of consent will not affect the lawful nature of the processing of data carried out prior to such withdrawal. (art. 6 par. 1a GDPR).

4. ADDRESSEES OF DATA

Who receives and processes your data?
Within our structure, every employee appointed (e.g.: administration dept., production dept., purchases and sales dept., etc.) to process the data in order to fulfil our contractual and legal obligations will have access to it, to the extent strictly necessary.

With regard to the transferral of data to addressees outside of our structure, we may transmit it only in accordance with legal provisions to public bodies and public administrations, and to appointed data processors who process the data on behalf of the Holder, such as credit institutions, organisations specialising in the management of information systems and/or payment systems, parties that supply the goods and services offered by the Holder, parties that carry out transport or shipping activities and parties that the Holder engages to carry out promotional, advertising, marketing and communication activities, to professional and consulting firms, to parties responsible for keeping the accounts or auditing the financial statements of the company.

5. TRANSFERRAL OF DATA ABROAD

Will the data be transferred to another country or to an international organisation?
The transferral of data to organisations or to other countries outside of Italy or the European Union may take place when this is necessary to the conclusion or fulfilment of a contract or to fulfil legal obligations (e.g.: tax reporting obligations) or if specific consent has been granted. Information on the specific guarantee measures adopted in relation to the exportation of data can be requested from the Holder (article 13 par. 1f GDPR).

6. PROCESSING AND STORAGE OF DATA

How is your data processed and how long will it be stored for?
Your data will be processed in hardcopy and/or electronic, IT and optic format, in observance of the security measures pursuant to art. 32 of the GDPR and National Legislation, by specifically appointed persons who have been appropriately informed, in compliance with the provisions of art. 29 GDPR.

We will process the data in accordance with the principles of lawfulness, purpose limitation and minimisation, for the time necessary to fulfil contractual obligations. After the contractual relationship has been terminated, the data may be retained only for as long as is necessary to fulfil the storage obligations established by law, such as tax and anti-money laundering regulations (10 years). If we are holding the data solely for marketing purposes and/or for sending newsletters, it will be stored until the moment of withdrawal of the Data subject's consent, and for no longer than 12 months from the last direct interaction of the Data subject with the marketing communication received.

7. RIGHTS OF THE DATA SUBJECT

What are your rights?
The Data subject is entitled to ask the Holder for access to the data in compliance with art. 15 GDPR, correction and update of the data in compliance with art. 16 GDPR, the cancellation of the data in compliance with art. 17 GDPR (right to be forgotten), the limitation of the processing of data in compliance with art. 18 GDPR. The Data subject will also have the right to request the portability of the data pursuant to art. 20 GDPR; the Data subject may exercise the right to object to the processing of personal data pursuant to art. 21 par. 1 GDPR and the right to lodge a complaint with the Data Protection Supervisory Authority (art. 77 GDPR).

The Data subject may also withdraw consent to the processing of the personal data at any time. This is also valid for the withdrawal of the declarations of consent issued before the entry into force of the GDPR. In this case, withdrawal will be effective only for the future and will have no effect on the process prior to withdrawal.

8. OBLIGATION TO SUPPLY DATA

Are you obliged to supply your data?
The Data subject will be required to supply all the personal data required for the fulfilment of the contractual obligations, as well as the data that we will be required to collect to fulfil legal obligations. Without this data we will not be able to enter into or execute the contract.

9. AUTOMATED DECISION-MAKING - PROFILING PROCESSES

To what extent is there an automated decision-making or a data profiling process?
We do not use any automated decision-making process, including profiling, in accordance with article 22 GDPR in our customer relations. In the event that we should use such a procedure in individual cases, we will issue specific notification where required by law.

Information on the right to object in compliance with article 21 of the GDPR

A) Right to object to the processing of data for marketing purposes

In the case of consent to process personal data for marketing purposes, the Data subject will have the right to object to the processing of said data for purposes related to this type of marketing activity at any time.

In the case of objection to processing for the purposes of marketing, we will no longer process the data of the Data subject for this purpose.

B) Data subject's right to object

For reasons connected to the particular situation of the Data subject, the latter shall have the right to object at any time to the processing of personal data pursuant to article 6, par, letter e of the GDPR (data processing in the public interest) and article 6 par. 1 letter f of the GDPR (data processing on the basis of evaluation of interests).

In the event of opposition, we will no longer process the personal data of the Data subject, unless there are compulsory legitimate reasons for the process that exceed the interests of said Data subject, rights and freedom or the use for the exercise, investigation or defence of a right in court.

The opposition must not be presented in a specific form and must be addressed to the Holder of the Data Process indicated in the epigraph.

We inform you that, in such cases, we may no longer be able to proceed with the execution of the contract.