Privacy Policy

Privacy Policy

Data update April 2023

This information, provided pursuant to articles 13 and 14 GDPR tells how the data of users, customers, candidates and suppliers - even during interaction with the site www.callmewine.com (the "Site", owned by Callmewine) are processed by Callmewine.

Data controller: Callmewine S.R.L., registered office in Via Natale Battaglia 8, 20127 Milan, CF/VAT number 07130650968 (hereinafter referred to as "Callmewine") which can be contacted at the following addresses: Via Natale Battaglia 8, 20127, Milan, Telephone: +39 02 81480430 (Monday-Friday 9.30-13.30 and 15.00-18.00), Mail info@callmewine.com

Callmewine has appointed a Data Protection Officer who can be contacted at the e-mail address privacy.dpo@callmewine.com.

Types of data processed, purposes and legal bases of the processing

Callmewine will process the personal data collected according to the methods and for the purposes described below:

Scope

Data

Data Subjects

Legal basis

Account Creation on the Site

Name, Surname, e-mail

Website users

Execution of the order (contract)

Ensure the proper functioning, management, maintenance and improvement of the Site

Ensure that data subjects browse safely and ascertain responsibility in the event of cyber-security breaches.

Obtain statistical analysis on the use of the Site with the possibility of analyzing the data also in aggregate form and to send promotional announcements in line with the wishes and interests of the user.

Allow purchases to be made through the Site

Plug-ins and interaction with social networks

The Site allows interaction with third-party sites and social networks (Google, Instagram, Facebook) through hyperlinks, sharing buttons, social plug-ins and other similar tools.

Navigation data:

- technical information, including IP address, information on the devices used by visitors to the Site, on the browser and operating systems, etc.

-information on navigation on the Site, including the URL of the pages visited and activities that are carried out on the page, dates and times of navigation, time spent on the Site, click streams.

Website users

Consent to cookies

Site users are always free to decide whether to provide their browsing data, for example by choosing to disable cookies through their browser settings. However, the refusal to provide information necessary for navigation purposes could make it impossible to carry out activities strictly connected with the navigation itself and, therefore, also the consultation and interaction with our Site, as well as with making purchases through the Site.

Consent of the interested parties expressed unequivocally when they click on a specific hyperlink, plug-in button or other similar tool.

Processing purchases through the Site

Name, surname, (company name and VAT number in the case of a company), e-mail address, telephone number, shipping and/or billing address

Customers

Execution of the order (contract)

Marketing Activities:

• sending newsletters and other communication material relating to products and/or services also of specific interest to Callmewine or companies of the Callmewine group

• market surveys also aimed at assessing the degree of user satisfaction

• sending e-mail messages relating to products similar to those purchased through the Site (so-called soft-spam)

e-mail address, telephone number and postal addresses, analysis of the preferences and consumption habits of the interested parties, through the detection of the type and frequency of purchases made by them.

Website users

Customers

the (optional) consent of the interested parties and, in the case of soft spam, the legitimate interest of Callmewine the interested party can always exercise the right to opt-out through the site

Creating a custom proposal

offer of products or services of specific interest through the creation of a customized shelf

data provided as part of registration, during a purchase or when browsing the site as well as relating to preferences and purchasing habits

Customers

the legitimate interest of the owner *

Execution of requests addressed to customer service

Data provided when contacting customer service

Customers

execution of a specific request

Search and selection of personnel - evaluation of spontaneous applications

personal data provided spontaneously by candidates by sending a curriculum vitae for the purpose of establishing an employment relationship or collaboration with Callmewine

Candidates for job positions in the company

execution of a spontaneous application request by the candidate

Execution of contracts for the supply of goods and services in favor of Callmewine

name, surname, date and place of birth, fiscal code, VAT number, residential/domicile address, telephone number, e-mail address and bank details

Suppliers

execution of a contract

*Legitimate interest: Callmewine informs that the legitimate interest is equally balanced with the interests of the customers following the outcome of the impact assessment (DPIA) conducted by the Data Controller, with particular reference to the processing of personal data for profiling purposes (letter E of the table) and that customers can exercise the right of opposition pursuant to art. 21 GDPR.

Processing personal data methods

The processing of the personal data of the interested parties will mainly be carried out with the aid of electronic or in any case automated means, according to the methods and with the instruments suitable for guaranteeing the security and confidentiality of the data in accordance with the GDPR. In particular, all the technical, IT, organizational, logistical and procedural security measures necessary to guarantee the minimum level of data protection required by law will be adopted, allowing access only to persons authorized to process data by Callmewine or its data processors appointed by Callmewine.

The processing of personal data does not involve fully automated decision-making processes and the security measures relating to the processing of data for the purposes referred to in letter E of the table have been adequately assessed through a specific impact assessment (DPIA) conducted by the Data Controller.

The information acquired and the methods of treatment will be pertinent and not excessive with respect to the type of services rendered. The data will also be managed and protected in environments whose access is under constant control. In particular:

• Navigation data is collected through the use of cookies. To learn more about how cookies work, how to activate and deactivate them, consult our cookie policy.

• Data for marketing purposes are processed by means of automated systems such as e-mail, sms, whatsapp or other instant messaging systems or by traditional methods (eg: paper mail or brochures).

• Plug-ins and interaction with social networks: by accessing one of the areas of the Site equipped with this type of tool, the Internet browser will connect the interested parties directly to the servers of the third-party sites in question, thus transferring their personal data to the managers of these sites.

Depending on the specific agreements in them with the managers of such third-party sites, Callmewine may act as independent data controller or joint data controller with regard to such data transfers. As regards the privacy protection methods and the processing of personal data collected by the managers of third-party sites with which the described interactions take place, please refer to the related sites.

• Data relating to payment methods. Callmewine will not process user or customer payment data in any way. In the case of payment using one of the types of payment card indicated on the Site, the data will be entered on a page that communicates via a secure encryption protocol with the payment service provider. Likewise, in case of payment via PayPal, the user will be directed to a page external to the Site.

Data Retention

• Personal account on the site: until the moment of cancellation of the account. Without prejudice to the possibility of extending the aforementioned retention period where this is necessary to fulfill a legal obligation to which Callmewine is subject or to protect a right of Callmewine before a competent authority.

• Data processed for the execution of contracts and making purchases: the maximum term of 10 (ten) years from the purchase itself, without prejudice to the possibility of extending the aforementioned retention period in the event that this is necessary to comply with a legal obligation to which Callmewine is subject or to protect Callmewine's right before a competent authority

• Marketing activities: until the consent is revoked and until the opt-out is exercised in the event of communications relating to products similar to those purchased by one's customers on the Site (soft-spam).

• Preferences and personalized shelf: for the entire duration of registration on the Site and without prejudice to the right of opposition by the interested party.

• Data provided when contacting customer service: Retention period: for the period strictly necessary to provide a reply to the requests of the interested parties.

• Data provided on the occasion of spontaneous applications: Retention period: for the period strictly necessary for the selection of candidates and up to 6 (six) months from collection or interview.

• Navigation data: These data are kept only for the time strictly necessary for the purposes for which they are collected.

Communication and dissemination of data

The personal data collected will be processed by the personnel appointed by Callmewine who need to know it according to their activity and/or by external subjects who perform services on behalf of Callmewine such as for example the management of the IT system, competent authorities and /o public bodies and supervisory and control bodies for the possible fulfillment of legal obligations, communication agencies and companies, other subjects who in any capacity collaborate - for the achievement of institutional purposes - with the Data Controller and who may act as managers of the treatment or independent owners.

The data relating to the interested parties will not be disclosed, except in anonymous and aggregated form, for statistical or research purposes.

Data transfer outside the EEA

Callmewine will not transfer the personal data of the interested parties to countries outside the European Economic Area ("EEA"), which includes, in addition to the member states of the European Union, Norway, Lichtenstein and Iceland.

In the event that this proves necessary to pursue the purposes of the treatments described in this Information, Callmewine guarantees that all possible transfers of data outside the EEA will take place in such a way as to guarantee the full protection of the rights and freedoms of the interested parties. Where, with regard to the recipient third country, no adequacy decisions have been issued by the European Commission, the data transfers will be carried out by adopting the guarantees provided for by articles 46 and following of the GDPR, including the standard contractual clauses approved by the European Commission.

Rights of the interested party

Pursuant to art. 13 of the GDPR, Callmewine the interested party has the right to:

• ask Callmewine for access to personal data concerning you, rectification, cancellation, limitation of treatment or to oppose their treatment

• revoke the consent at any time without prejudice to the lawfulness of the treatment based on the consent given before the revocation

• propose a complaint to the Guarantor for the protection of personal data at the following PEC address: protocol@pec.gpdp.it.

The above rights may be exercised by making an informal request to the Data Protection Officer at the email address privacy.dpo@callmewine.com.

Updates

Callmewine reserves the right to make changes to this information at any time, giving appropriate notice via the Site or by email.