pursuant to EU Regulation 679/2016 (“GDPR”)

Holder of the treatment

The processing of personal data is carried out by Tenuta Polvaro Sas di De Zan Caterina & C. (hereinafter the “Company”), Via Polvaro, 35 30020 Annone Veneto (Ve), Tax code and VAT number 00393840277, and registration at Business Register of Venice n° 129520, which acts as the Data Controller of personal data.

Data collection

The categories of personal data that the Company collects and processes while browsing or purchasing on www.tenutapolvaro.com are as follows:

1. personal data necessary to complete and execute the purchase on www.tenutapolvaro.com such as name and surname, e-mail address, shipping address, billing address, telephone and payment details;
2. e-mail address when the user signs up for the newsletter service;
3. personal data provided to Customer Service for the assistance requested;
4. subject to the user’s consent, personal data is collected and used for commercial communications;
5. to register for the Wine Club, the Company collects the user’s name and surname, e-mail address, password and date of birth. In the event of registration, the Company collects information on the user’s access to the reserved area of ​​the site. With the express consent of the user, by analyzing personal data, the Company can process information regarding interests and preferences with respect to the products and services offered, in order to present proposals and offers in line with the user’s tastes;

information on the navigation of www.tenutapolvaro.com, such as the pages visited and the interaction with the single page; information saved on the Company’s servers.

Use of personal data

The Company collects and processes the personal data of users for the following purposes:

1. to conclude and execute the purchase contract for the products offered on www.tenutapolvaro.com. When the user concludes the purchase, we ask for the personal data necessary for the execution of the contract, such as payment, anti-fraud checks if he chooses to pay by credit card, billing, product shipping and any management of the made.
2. registration on the website and use of the services offered to registered users. Registration on the website is possible by entering some personal information, necessary to guarantee the performance of the services offered to registered users.
3. provision of the services offered on www.tenutapolvaro.com. To this end, the Company needs to collect, in relation to each service and its characteristics, the personal data necessary for the performance of the specific service requested by the user.
4. management of requests to Customer Service, which uses the personal data provided by the user to satisfy their requests for information and requests for assistance.
5. statistical analysis and surveys. The Company uses some information on the use of the website by users, navigation methods and use of the related services, to carry out statistical analyzes and surveys in order to improve the offer and services.
6. sending commercial communications following the purchase of a product, so-called soft spam. Following the purchase of a product on the website, the Company will send to the e-mail address that the user provided at the conclusion of the order, communications containing commercial proposals on similar products and services.
7. subject to the user’s express consent, the Company may use the contact details that the user has provided for commercial communications on products and services, in order to update the user on news, exclusive products, offers and promotions. Furthermore, always with prior consent, it may use the user’s contacts in carrying out market research and surveys for the detection of satisfaction in order to improve services and the relationship with users.
8. only with the user’s consent, the Company will be able to customize the experience of the user registered on www.tenutapolvaro.com, proposing advances and offers in line with the tastes expressed and sending personalized commercial communications according to the interests shown. The personalization will be carried out by analyzing previous purchases and other information described in the previous paragraph “Data Collection”’. 

If the user wishes to authorize the activities referred to in points g) and h) and subsequently does not wish to receive further communications from the Company or wishes to limit the ways in which he is contacted, he can at any time interrupt these communications by simply clicking on the appropriate ‘unsubscribe’ link at the bottom of each communication, or can always contact the Company through the Customer Service. However, the user may receive further communications from the Company even after submitting the unsubscribe request, as some deliveries may have already been planned, and the systems may take some time to execute the request.

In relation to all the activities indicated above, users’ personal data will be processed mainly through IT and electronic tools; the instruments used by the Company guarantee high safety standards, in full compliance with current legislation on the subject.

The Wine Club

On the occasion of the creation of the Wine Club account, the Company offers the possibility to use the following services:

Account details – user data management

Orders – progress of the shipment and verification of the user’s order history

Payment methods – collection of the user’s credit card data to quickly complete purchases

Addresses – management of user addresses to quickly complete purchases

With the express consent of the user, the Company may use the contact details for commercial communications on products and services, in order to update the user on news, exclusive products, and for conducting opinion polls and market research, in order to detect the degree of satisfaction and improve the services offered.

Only with the prior consent of the user, the Company will be able to customize the experience based on interests and the contents of commercial communications and offers that it will see when browsing www.tenutapolvaro.com as a registered user. This activity makes it easier for the user to find products and services that are more popular and in line with his interests and at the same time allows for the improvement of the dedicated offer. Personalization is made possible by the analysis of the user’s data held by the Company, described in the previous paragraph “Data Collection”. In particular, the information on purchases made in the past and those concerning the sections of the website visited most often or the services that the user uses more frequently help the Company to understand which products and services the user is most interested in.

Legal basis of the processing

The Company processes personal data only in the presence of one of the legal conditions provided for by current legislation, and specifically:

1.  for the conclusion and execution of a contract. In this case, the Company takes care to use only the minimum information necessary for the execution of the same. This basis legitimizes the processing of personal data that takes place in the following activities:
   • conclusion and execution of a purchase contract for the products offered on www.tenutapolvaro.com;
   • registration on the website and use of the services reserved for registered users;
   • provision of the services offered on www.tenutapolvaro.com;
   • management of user requests by our Customer Service.
2. The provision of the user’s personal data for these activities is a contractual obligation. The user is free to communicate his data to the Company or not, but in the absence of the requested data, the Company will not be able to conclude or execute the contract and requests. This means that the user will not be able to purchase the products and will not be able to use the services of the Company and that the Company will not be able to manage the user’s requests.
3. to follow up on a legal obligation. In the event of the conclusion of a contract for the purchase of goods on www.tenutapolvaro.com, the processing of the user’s data will take place to give effect to the legal obligations to which the Company is subject. The user is free to decide whether to conclude a contract and whether or not to communicate his data to the Company, but if he does so, his data will be necessary and will be processed to fulfill the aforementioned legal obligations to which the Company is bound.
4. for the legitimate interest of the Company. Some of the user’s personal data in the event of purchasing products on www.tenutapolvaro.com by credit card, may be processed to carry out anti-fraud activities: the Company has a legitimate interest in carrying out this activity to prevent and pursue any fraudulent activity.
5. based on the user’s consent. The Company will carry out the following treatments only if the user has given his express consent:
   
   • carrying out marketing activities and opinion polls and market research;
   • analysis of browsing and consumption habits in the context of the use of the Wine Club profile, in order to personalize the experience on the website;

Providing consent for such activities is optional. The user is free to provide his consent or not, but in the absence of the same it will not be possible for the Company to carry out marketing activities, opinion polls and market research, and analysis of habits.

Who will process the data?

The user’s personal data will be processed by the Company’s internal staff who are specifically trained and authorized to process them and will also be transmitted to third parties that the Company uses to provide its services on www.tenutapolvaro.com; these subjects have been adequately selected and offer a suitable guarantee of compliance with the rules on the processing of personal data. These subjects have been designated as data processors and carry out their activities according to the instructions given by the Company and under its control.

The third parties in question belong to the following categories: site manager, banking operators, internet providers, companies specialized in IT and telematic services, couriers, agencies that carry out marketing activities, companies specialized in market research and data processing.

User data may be transmitted to the police forces and to the judicial and administrative authorities, in accordance with the law, for the detection and prosecution of crimes, the prevention and protection from threats to public security, to allow the Company to ascertain, exercise or defend a right in court, as well as for other reasons related to the protection of the rights and freedoms of others.

Transfer of data outside the EU

Some of the third parties listed in the previous paragraph ‘Who will process the data?’ may be based in countries outside the European Union which nevertheless offer an adequate level of data protection, as established by specific decisions of the European Commission.

The transfer of the user’s personal data to countries that do not belong to the European Union and that do not ensure adequate levels of protection will be carried out only after the conclusion between the Company and said subjects of specific agreements, containing safeguard clauses and appropriate guarantees for protection. of the user’s personal data, the so-called ‘standard contractual clauses’, also approved by the European Commission, or if the transfer is necessary for the conclusion and execution of a contract between the user and the Company (for the purchase of offered on the website, for registration on the website or the use of services on the website) or for the management of requests.

Duration of data retention

The Company retains the user’s personal data for a limited period of time, which varies according to the type of activity that involves the processing of personal data. After this period, the user’s data will be permanently deleted or in any case made irreversibly anonymous.

The user’s personal data are stored in compliance with the terms and criteria specified below:

1. data collected to conclude and execute contracts for the purchase of goods on www.tenutapolvaro.com: up to the conclusion of the administrative and accounting formalities. The billing data will be kept for 10 years from the billing date;
2. registered user data: the data will be kept until the user requests the cancellation of his Wine Club account;
3. payment data: up to the certification of the payment and the conclusion of the related administrative and accounting formalities resulting from the expiry of the right of withdrawal and the terms applied for contesting the payment;
4. data collected in the context of the use of services offered on www.tenutapolvaro.com: these data are kept until the termination of the service or the request to unsubscribe from the service by the user;
5. data related to user requests to our Customer Service: the data useful to assist the user will be kept until the fulfillment of his request;
6. data used for commercial communication towards users who purchase products on www.tenutapolvaro.com (soft spam): these data are kept until the termination of the service or the exercise of opposition by unsubscribing from the service by the user;
7. data provided for commercial communications activities, opinion polls and market research: up to the unsubscription from the service or following a request by the user to interrupt the activity and in any case within two years from the last interaction of any kind of ‘user with the Company;
8. data used to personalize the Site and to show customized commercial offers: as long as the user does not revoke the consent given for this activity or requests its termination, and in any case within 2 years from the last interaction of any kind of the user with the Company;

In any case, for technical reasons, the termination of the processing and the consequent definitive cancellation or irreversible anonymization of the related personal data will be final within thirty days from the terms indicated above.

User Rights

At any time, the user can exercise his rights with reference to the specific processing of his personal data by the Company. Below is their general description and how to exercise them.

1. Access and modify data: the user has the right to access his personal data and to request that it be corrected, modified or integrated with other information. If desired, the Company will provide a copy of its data in its possession.
2. Withdraw consent: the user can revoke at any time a consent he has given for the processing of his personal data in relation to any activity for marketing purposes. Upon receipt of the request, the Company will promptly cease the processing of the user’s personal data based on this consent, while different treatments or based on other assumptions will continue to be carried out in full compliance with the provisions in force.
3. Oppose the processing of your data: the user has the right to object at any time to the processing of his personal data carried out on the basis of legitimate interest by the Company, explaining the reasons that justify his request; before accepting it, the Company will have to evaluate the reasons for the request.
4. Delete the data: in the cases provided for by current legislation, the user can request the deletion of personal data. Once the request has been received and examined, if legitimate, the Company will promptly cease the processing and delete the personal data.
5. Request that the processing of personal data be temporarily limited: in this case, the Company will continue to store the user’s personal data but will not process them, unless otherwise requested and the exceptions provided for by law. The user can obtain the limitation of the processing when he contest the accuracy of his personal data, when the processing is unlawful but opposes the cancellation of his data, when your data no longer serves the Company but needs it to exercise its right in court and when you oppose the processing, in the period in which the Company evaluates the reasons for your request.
6. Request data or transfer them to a person other than the Company (right to data portability). The user can request to receive his data processed by the Company on the basis of his consent or on the basis of a contract with the user in a standard format. If desired, where technically possible, the Company may, upon request, transfer the data directly to a third party indicated by the user.

To ensure that user data is not violated or illegitimately used by third parties, before accepting a request to exercise one of the rights indicated, the Company may ask for some information to be sure of the user’s identity.

Security measures

The Company protects the user’s personal data with specific technical and organizational security measures, aimed at preventing personal data from being used illegitimately or fraudulently. In particular, the Company uses security measures that guarantee: the pseudonymisation or encryption of data; the confidentiality, integrity, availability of data as well as the resilience of the systems and services that process them; the ability to restore data in the event of a data breach. Furthermore, the Company undertakes to test, verify and regularly evaluate the effectiveness of technical and organizational measures in order to guarantee continuous improvement in the safety of treatments.

Complaints

If the user believes that the processing of his personal data has been carried out illegally, he can lodge a complaint with one of the competent supervisory authorities for compliance with the rules on the protection of personal data.

In Italy, the complaint can be presented to the Guarantor for the Protection of Personal Data.

More information on the methods of presentation are available on the website of the Guarantor, at the address http://www.garanteprivacy.it.

Changes to this policy

The constant evolution of the services offered by the Company may lead to changes in the characteristics of the processing of the user’s personal data described so far. Consequently, this privacy statement may undergo changes and additions over time, which may also be necessary in relation to new regulatory interventions on the protection of personal data.

We therefore invite the user to periodically check the contents: where possible, we will try to promptly inform the user about the changes made and their consequences.

The updated version of the privacy policy, in any case, will be published on this page, indicating the date of its last update.

Legislative references and useful links

The processing of the user’s personal data is carried out by the Company in full compliance with the regulations on the subject provided for by Regulation (EU) 2016/679 General Data Protection Regulation, the rules on the processing of Italian personal data and the provisions of the Authority of Italian control (http://www.garanteprivacy.it) and, where applicable, of the competent foreign control authorities.

Last Update: 2 September 2021