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Personal data processing policy

Personal data processing policy pursuant to Articles 13 and 14 of EU Regulation 2016/679 (“Regulation”).

TENUTA DI DONNAFUGATA S.r.l. Società Agricola (“Donnafugata”) provides information concerning personal data processing to users who visit Donnafugata’s websites https://www.donnafugata.it, https://visit.donnafugata.it, https://wineclub.donnafugata.it, https://winelovers.donnafugata.it and any other website under the domain name “donnafugata.it” (hereinafter collectively referred to as the “Website”) or fill in forms from the “Login to the Press & Trade Room” “Store Locator”, “Subscribe to our newsletter” and/or “Book your visit” sections of the Website (hereinafter collectively referred to as the “Forms”).

  1. Types of data collected

Browsing data

The computer systems and software procedures involved in the Website’s operation acquire, during their normal operation, some personal data, the transmission of which is implicit in the use of Internet communication protocols. This category includes the IP addresses or domain names of computers used by users to connect to the Website, the iMAC (Media Access Control) address, URI (Uniform Resource Identifier) form addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the reply given by the server (done, error, etc.) and other parameters concerning the user’s operating system and computer environment. Those data are used for the sole purpose of obtaining anonymous statistical information concerning use of the Website and checking that it is correctly operating. Data are deleted immediately after they have been processed. Those data may be used to ascertain responsibility in the case of hypothetical computer crimes to the detriment of the Website.

Data voluntarily supplied by natural and legal persons

After the voluntary supply of personal data by the user (by sending of electronic mail to the email addresses indicated in this Website, filling in the Forms and/or registering to the Website), Donnafugata shall process the sender’s personal data in order to reply to the requests made by the user and/or provide the requested services.

Within this context, Donnafugata processes the following data, provided that they are supplied by the user:

  • identification data;
  • contact data;
  • commercial information and data relating to individual tastes and preferences;
  • data of the interested party regarding food allergies and/or intolerances, as well as body temperature, for the purposes of accessing Donnafugata’s premises, also in order to attend guided tours of the winery with food and wine tastings and/or other winery events, upon request of the interested party.

Specific privacy notices will also be displayed on web pages dedicated to particular services provided by the website on request.

  1. Purpose and legal basis for processing personal data

Data provided by natural and legal persons and collected by Donnafugata will be processed for the following purposes:

  1. to check that services offered via the Website are correctly functioning (anonymous data processing);
  2. to obtain statistical information about use of the services and the Website, for example, most visited pages, number of visits per hour or day, geographic areas of origin, etc. (anonymous data processing);
  3. in the event that express consent has been given or when the data subject has already made purchases of products and/or services on the Website, for promotional and advertising purposes. In such cases, Donnafugata shall process personal data in order to send promotional offers and marketing messages related to Donnafugata’s products and services using both automated means, such as email, and conventional means such as postal mail or operator-assisted phone calls. It is clearly understood that the registration on the Website, any integrated services and/or subscription to the newsletter may be cancelled at any time at no cost to the user by following the instructions provided on the Site and/or at the bottom of each communication received by the user;
  4. in the event that express consent has been given, to communicate to third parties and/or disclose the customer’s identification and contact data in the context of business information, market and socio-economic research and publication on the Website and on Donnafugata’s other mediachannels;
  5. with regard to the “Store Locator” section, for the purpose of locating stores that resell Donnafugata’s products and/or services, by using contact data and information already published on public registers and directories. Non public data shall be processed upon the data subject’s express consent only;
  6. with regard to the “Book your visit” section, to allow access to Donnafugata’s winery and to protect the safety and health of visitors taking part in guided tours with tastings which may include wine and food, as well as for the purposes of preventing the spread of Coronavirus infection and any impact on public health and safety.

Failure to provide data in the “Login to the Press & Trade Room” “Store Locator”, “Subscribe to our newsletter” and/or “Book your visit” sections and/or the lack of express consent to data processing, where required, for the relating purposes mentioned above will impede correct performance of the services requested by the user.

The legal basis for processing any personal data provided for the aforementioned purposes is the performance of a service contract as requested by the data subject, the protection of a relevant public interest (preservation of public health), and/or the data subject’s express consent.

  1. Data processing methods

Any collected data shall be handled, stored and processed using electronic means and shall be saved on electronic media and/or on paper, databases and on any other suitable type of media. Specific security measures are taken to prevent data loss, unlawful or incorrect use of the data and unauthorised access to them.

The data will not be visible to other users of the Website and will not be disclosed; however, data may be communicated to companies, associations or professional firms appointed for managing the Website or appointed for dealing with the customers’ requests. The data collected with reference to the purposes of preventing the spreading of Coronavirus infection may be exclusively communicated to public entities for the fulfilment of all and any legal requirements. A list of third parties that may receive personal data is available on request to be sent by email to the following address [email protected].

In addition to the purposes specified in Point 2 above, data may be processed to fulfil obligations and/or exercise rights set forth by laws, regulations or EU legislation and in accordance with provisions set forth by supervisory authorities.

The personal data provided may be transferred out of the country to other countries located within the European Union. If required, transfer of the data subject’s personal data to countries located outside of the European Union will only be performed when adequate and appropriate safeguards have been provided pursuant to applicable legislation and in particular Articles 45 and 46 of the Regulation.

The Website uses cookies: for further information, please read our Cookie Policy at the following URL: https://www.iubenda.com/privacy-policy/86976359/cookie-policy

  1. Data retention period

Personal data collected and processed as a result of a user visiting the Website will be processed for the time needed to perform the services requested by the user.

Data processing will be carried out as long as the data subject does not exercise his right to withdraw, by sending written communication to the address [email protected] or following the procedure for cancelling registration on the Website (by following the instructions provided on the Website and/or at the bottom of each communication received by the user).

Data collected and processed in relation to services referred to in the Website will be in any event retained for a period of time not exceeding that required for the purposes for which they were collected and subsequently processed, also in order to fulfil contractual or legal obligations, specifically with regard to any existing emergency measures or regulations, to report activities performed, to guarantee Donnafugata’s right to protect itself from any liability potentially deriving from the data processing and until any possible action against Donnafugata is time-barred.

  1. Subjects to whom the data may be communicated

The data collected will not be disclosed but may be communicated both to subjects or entities entitled by the law and/or by regulations (including European Regulations) to access personal data and to internal staff or external collaborators of the Data Controller, as well as to companies, associations or professionals who provide services and carry out activities on behalf of the Data Controller as data processors for the fulfilment of legal obligations, as well as for any organizational and administrative purposes relating to the requested services. The names of the subjects who may become aware of the data as Data Controller are listed in an updated list available from Donnafugata (by making a request to the contact details indicated in point 6).

  1. Rights of the data subject

With regard to the data processing mentioned above, the data subject has the right, at any time, to exercise the rights set forth in the Regulation (Articles 15, 16, 17, 18, 19, 20 and 21), namely the right to: a) access his data; b) request the rectification, updating, integration, deletion, limitation or portability of said data; c) object to the processing of said data; d) withdraw consent to the processing of said data and e) lodge a complaint with the Personal Data Protection Authority, in accordance with the procedures and instructions published on the website www.garanteprivacy.it.

For any clarification on the data processing methods and for the exercise of the rights listed above, please write to the following e-mail address [email protected]. The Data Controller shall reply to the interested party within 30 days of receipt of the request, reserving the right to extend the deadline by a further three months in cases of particular difficulty, subject to reasoned communication to the interested party.

  1. Data controller – Data Protection Officer – Contact data

The data controller is: Tenuta di Donnafugata S.r.l. Società Agricola Via S.Lipari 18, Marsala TP, VAT No. 01155720814, Tel/Fax +39 0923 724201/+39 0923 724211.

Donnafugata has appointed Studio Cartwright Pescatore as Data Protection Officer, with the appointment of lawyer Francesca Zichittella, who can be contacted at the following e-mail address: [email protected].

 

Donnafugata reserves the right to update this policy information concerning the processing of personal data.

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