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Privacy Policy

The security and privacy of your information is of paramount importance to us at *Heritage Wine Vault*, a fine wine distributor specializing in providing premium wines from renowned vineyards around the world. Through this Privacy Policy, we are committed to protecting your privacy and ensuring that your personal information is handled with the utmost care and responsibility.

The following notice is designed to make you aware of the aspects of the processing of your personal data and your rights regarding such processing under:

Act No. 133 of 08.07.2011 on the protection of personal data, published on 14.10.2011 in the Official Gazette No. 170-175 art. 492, amended by Parliament Act No. 155 of 15.07.2022, published on 05.08.2022 in the Official Gazette No. 246-250, in force from 05.09.2022.

1. General information  

We, *Heritage Wine Vault* (hereinafter the ”Company”) represent the controller in accordance with the General Data Protection Regulation (hereinafter – ”GDPR”).

2. Purpose of processing and categories of data processed  

In this regard, the purposes for which personal data are processed by the Company are as follows:

  • providing fine wine distribution services;
  • promoting exclusive wine collections;
  • offering wine-related events, tastings, and experiences;
  • customer loyalty and engagement programs.

In order to fulfil the purposes of the distribution and promotion field, the Company processes personal data in the following operations:

  • the drafting of documents required for sales contracts with our customers, at all stages;
  • the drafting of the documents necessary for the preparation of the materials required for the promotion of our wines and the provision of distribution services, at all stages;
  • regular transmission of information and commercial offers via newsletter/e-mail/promotional material;
  • maintaining internal databases;
  • accurately identifying customers when they want a service to be provided;
  • providing information on Company events;
  • participating in surveys on the Company’s offerings and services in relation to customer satisfaction;
  • soliciting and using information on wine preferences and other relevant data from various sources.

The following categories of data are processed within the Company:

  • Surname, first name, domicile/residence, series and number of identity document, IDNP, nationality, date of birth, e-mail address, phone and/or mobile phone numbers, fax number (where applicable), data resulting from business ownership documents (including history and extracts from relevant state authorities);
  • Customer contact with the Company, such as registration on the website, a forwarded email or letter, or other records of contact with the Company;
  • Customer account information, such as account numbers or other information related to the customer’s account or that is included in the business relationship management contract with each customer;
  • Legitimate Access Information – The Company will collect passwords, indices and similar security information used for authentication and access to accounts and services (for online accounts opened by each customer on the Company’s website);
  • Customer preferences for particular wines, products, and services when customers let the Company know what they are, or when the Company assumes what they are, based on how customers use the Company’s products and services; in this way the Company will be able to prioritise what the customer is interested in;
  • Marketing preferences;
  • See the Cookies section for details on what the Company collects using cookies;
  • Browsing history. If permission is given, the Company collects categories of websites that website guests have browsed from their mobile phone, device or PC, e.g. news. However, the Company will not hold a history of the websites that Company web page guests browse, this is limited to a short period of time to enable the connection to be made. The Company uses this interest information to send personalized marketing offers or display advertisements. Visitors can opt-out of advertisements under the Cookies section on the Company’s website or, in the case of marketing, through unsubscribing by accessing the first newsletter received.
  • Information that the Company obtains from other sources, such as public or private authorities, fraud prevention agencies, and other data providers. This includes demographic data, interest data, and browsing behavior.
  • For the loyalty program consisting of offering benefits, discounts, rebates to reward loyalty;
  • Answers to invitations and confirmations of participation in events.

The personal data we process is primarily identification, transactional, financial, demographic, location or other personal data that we collect directly from you or from other sources when you become our customer or use our products or services.

Sensitive personal data reveals your racial and ethnic origin, political opinions, religious and philosophical beliefs, genetic data, biometric data, health data, or data about your life or sexual orientation.

*THE COMPANY DOES NOT INTENTIONALLY COLLECT SENSITIVE PERSONAL DATA FROM YOU FOR STORAGE.*

3. Legal basis of the processing 

The legal basis for collecting and processing your data for each of the purposes mentioned above is:

  • Contracts for the provision of wine distribution services as well as contracts with third parties to which you are a party or your request prior to entering into a contract.
  • Legitimate business interests of the Company, e.g. preventing fraud, maintaining the security of our services, direct marketing and improving services. Whenever we rely on this legal basis to process your data, we assess our business interests to ensure that they do not override your rights. In addition, in some cases you have the right to object to such processing. The legitimate interest of the Company to enable us to exercise our statutory rights in our favour, to take legal action against any unlawful or damaging activity against the Company.
  • Compliance with a mandatory legal requirement, for example, accounting and tax requirements, which are subject to strict internal policies (such as storage periods), procedures, and the right to restrict the use of our own data, which controls the scope of our services to be provided.
  • In addition, to the extent you have agreed, this constitutes your consent. The processing of personal data on the basis of consent is an additional purpose to the processing of personal data for the performance of the contract to which you are a party and does not determine the provision of services.
  • The processing is necessary for the performance of a task which is of public interest.

We will collect your personal data when, for example:

  • You use any of our services;
  • You register for a particular service;
  • You subscribe to our newsletter or other services;
  • You contact us through various channels, or request information about a service;
  • You visit or browse our website;
  • You have given permission to other companies, such as our business partners or associates, as well as third-party suppliers or contractors of ours, to exchange information with us for the purpose of providing services to you;
  • When personal data is public; or
  • You are the customer/beneficiary of a wine purchase activity we provide.

We also collect information from certain companies where appropriate and to the extent that we have legal grounds to do so. These include fraud prevention agencies, trade directories, verification/control agencies, billing agencies, and contracted service providers.

We use cookies (small text files stored in your browser) and other techniques such as web beacons (small, transparent image files used to track your movements around our site). For further details on this and how to opt-out of these, please see the Cookies section of our website.

4. Categories of recipients to whom personal data collected may be disclosed

In order to achieve the purposes set out above, we use the following categories of product and service providers/processors:

  • providers (wine producers and distributors) directly/indirectly involved in the provision of wine distribution services;
  • state authorities (including tax authorities);
  • accountants, auditors, legal experts, lawyers or other such external advisors of the Company or to third parties providing products and services to the Company (providers of security services, IT systems, financial consultants);
  • Company suppliers directly/indirectly involved in the marketing and promotion process.

5. Storage period

Your personal data will be kept by the Company for a period not exceeding the period necessary to achieve the purposes described above and/or for any other period required by virtue of the legal obligations applicable to the Company, using the following criteria for determining this period:

  • When you purchase wine through the Company, we keep your personal data for the duration of our contractual relationship;
  • When you participate in a promotional offer, we keep your personal data for the duration of the promotional offer;
  • If you contact us for the provision of a service, we keep your personal data for the time necessary to process your enquiry, but no longer than 10 (ten) years from the last correspondence sent, for tax purposes;
  • If you have registered on our website, we keep your personal data until you request that we delete it or after a period of inactivity (no active interaction with us). In this regard, we note that the data processed for this purpose will be deleted 5 (five) years after the last interaction;
  • If you have given your consent for marketing, we keep your personal data until you unsubscribe or request that we delete it or after a period of inactivity (without an active interaction with our brands) defined in accordance with the regulations and guidelines. In this regard, we note that data stored in our databases for the purpose of direct marketing communications is deleted from the records of these databases 10 (ten) years after your last interaction with us;
  • If cookies are stored on your computer, we keep them for as long as necessary for them to achieve their purposes (e.g. for the duration of a session for shopping cart cookies or session ID cookies) and for a period defined in accordance with the regulations and guidelines, we mention that the data processed through cookies used to provide online behavioural advertising, to personalise our services.

6. Your rights

The Regulation confers certain rights on individuals in relation to the processing of their personal data.

You have the right to:

  • Access your data: you can request a copy of your personal data held by the Company.
  • Rectification: if any of your personal data is incorrect, you can request that it be corrected.
  • Erasure: you can request that we delete your personal data under certain conditions.
  • Restriction of processing: you can ask us to restrict the processing of your personal data under certain conditions.
  • Object to processing: you can object to the processing of your personal data under certain conditions.

If you wish to exercise any of these rights, please contact us at contact@heritagewinevault.com.