VINITALY WINE CLUB PRIVACY POLICY AND COOKIE POLICY

This privacy policy describes the personal data collected or generated (processed) when you use vinitalyclub.com Vinitaly Wine Club’s website (“Site”) and VINO - Vinitaly Wine Club mobile application (“App”). It also explains how your personal data is used, shared and protected, what choices you have relating to your personal data and how you can contact us. We also remind you that our Privacy Policy applies in every case in which you enter our website and decide to browse it and use its services, regardless of the purchase of our products.

WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?

The data controller of the information collected through this website is DesignWine Srl ("Vinitaly Wine Club"), with registered office in Italy at Viale della Resistenza n.90, 47039, Savignano sul Rubicone (FC), business register number, tax code and VAT number IT03827840400 / GB105781913 (hereinafter "Vinitaly Wine Club"): Vinitaly Wine Club independently establishes the purposes and methods of data processing and the implementation of security procedures to guarantee the privacy, integrity and availability of such data.

WHAT PERSONAL DATA DO WE COLLECT AND WHEN?

We ask you for certain personal data to provide you with the products or services you request. For example, when you make purchases, contact our consumer services, request to receive communications, create an account, or use our Site or App. This personal data includes your:

  • contact details including name, email, telephone number and shipping, billing address;
  • login and account information, including screen name, password and unique user ID;
  • personal details including gender, hometown, date of birth and purchase history;
  • payment or credit card information;
  • images, photos;
  • personal preferences including your wish list as well as marketing and cookie preferences.

We collect additional personal data from you to enable particular features within our Site and App. This personal data includes your:

  • social network information, including credentials and any information from your public posts about Vinitaly Wine Club or your communications with us.

When interacting with our Site and App, certain data is automatically collected from your device or web browser. More information about these practices is included in the “Cookies and Pixel Tags” section of this privacy policy below. This data includes:

  • Cookies, IP addresses, referrer headers, data identifying your web browser and version, and web beacons and tags.

KIDS

We comply with local laws and do not allow children to register on our Site or App when they are under the legal age limit of the country in which they reside.

TOOLS TO MANAGE WHAT PERSONAL DATA WE COLLECT

When using our App and Site, we also provide in-time notice or obtain consent for certain practices. For example, we will obtain consent to use your location or send push notifications. We may obtain this consent through the App or Site or using the standard permissions available on your device.

In many cases, your web browser or mobile device platform will provide additional tools to allow you to control when your device collects or shares particular categories of personal data. For example, your mobile device or web browser may offer tools to allow you to manage cookie usage or location sharing.  We encourage you to familiarize yourself with and use the tools available on your devices.

WHY AND HOW DO WE USE YOUR PERSONAL DATA?

We use your personal data in the following ways:

To Provide the Features of the Site, App, and Services You Request
When you use our Sites and Apps, we will use your personal data to provide the requested product or service.  For example, if you make a purchase on Vinitalyclub.com, we will use the contact information you give us to communicate with you about the purchase, event or promotion. If you contact our consumer services, we will use information about you, such as delivery or payment information, or the product you have purchased to help you resolve a problem or question.

We can use the information on the purchased products to calculate further information on the purchase experience, such as the purchased grape varieties or the selected type of wine, so that all the calculated information can then be provided and represent one of the features of our Site.

In many cases, to use particular features within our Site and App you may need to provide Vinitaly Wine Club with additional data or additional consent to use particular data in a certain way. For example, to share content on social media, you may be required to provide your social media account credentials to sign in.

To Communicate Information about our Products, Services and for Other Promotional Purposes
When you consent, we will send you marketing communications and news concerning Vinitaly Wine Club’s products, services and other promotions. You can opt-out at any time after you have given your consent.

If you are an existing customer of Vinitaly Wine Club (for example, if you have placed an order with us), we may use the contact details you provided to send you marketing communications about similar Vinitaly Wine Club products or services where permitted by applicable law (unless you have opted-out). In other cases, we ask for your consent to send you marketing information. We may use the information that you provide to us as well as information from other Vinitaly Wine Club products or services - such as your use of Vinitaly Wine Club’s Site and App, your visits to or purchases made on Vinitalyclub.com - to personalize communications on products and services that may be interesting for you.

To Operate, Improve and Maintain our Business, Products and Services
We use the personal data you provide to us to operate our business. For example, when you make a purchase, we use that information for accounting, audits and other internal functions. We may use personal data about how you use our products and services to enhance your user experience and to help us diagnose technical and service problems and administer our Site and App.

To Protect Our or Others' Rights, Property or Safety
We may also use your personal data about how you use our Site and App to prevent or detect fraud, abuse, illegal use, violations of our Terms of Use, and to comply with court orders, governmental requests or applicable law.

For General Research and Analysis Purposes
We use data about how our visitors use our Site, App and services to understand customer behavior or preferences. For example, we may use information about how visitors to Vinitalyclub.com search for and find products to better understand the best ways to organize and present product offerings in our storefront.  

Other Purposes
We may also use your personal data in other ways and will provide specific notice at the time of collection and obtain your consent where necessary.

Legal Grounds
To process your personal data, we rely on certain legal grounds, depending on how you interact with our Site and App.

  • When you purchase Vinitaly Wine Club products from our Site and App, we need your personal data to fulfill our contract with you. For example, we need your payment and contact details to deliver your order.
  • When you use our App, we rely on your consent for processing and for certain limited purposes to fulfill our contract with you (for example, for in-App purchases). 
  • We also rely on other legal grounds, such as our legitimate interests as a business, to comply with a legal obligation, or to protect your vital interests.

SHARING OF YOUR PERSONAL DATA

Vinitaly Wine Club’s Sharing
Vinitaly Wine Club shares your personal data with:

  • Companies belonging to the Verona Fiere SpA group for the purposes and conditions described above.
  • Third party service providers processing personal data on Vinitaly Wine Club’s behalf, for example to process credit cards and payments, shipping and deliveries, host, manage and service our data, distribute emails, research and analysis, manage brand and product promotions as well as administering certain services and features. When using third party service providers we enter into agreements that require them to implement appropriate technical and organizational measures to protect your personal data. Currently the data supervisors charged with processing your personal data are the following:
  • Technical Partners (Vinitaly Wine Consulting and other technical partners that may be used by Vinitaly Wine Club from time to time) to processe the data required to manage and maintain the Vinitaly Wine Club servers and databases;
  • Ve Global UK Limited: various types of data as specified in the Privacy Policy of the service;
  • Shipping Partners (General Logistics Systems Italy SpA, BRT Spa, Sistema Italia 93 S.r.l. - MailBoxes Etc - other shippers that could be used for deliveries and withdrawals, such as: UPS Srl, Fercam SpA, I-Dika SpA, DHL SpA, TNT SpA) to process the data required to organize and carry out shipment, delivery and return of products purchased from Vinitaly Wine Club;
  • Payment partners (PayPal, Visa, Visa Electron, MasterCard, American Express, Wirecard, Satispay, Stripe and other payment partners that can be used by Vinitaly Wine Club from time to time) to process the data required to conclude the payments of products purchased from Vinitaly Wine Club.

PayPal
PayPal is a payment service provided by PayPal Inc., which allows users to make online payments using their PayPal credentials.
Personal Data collected: Various types of Data as specified in the Privacy Policy of the service. 

Wirecard
Wirecard is a payment service provided by Wirecard AG.
Personal Data collected: Various types of Data as specified in the Privacy Policy of the service.

Satispay
Satispay is a payment service provided by Satispay Limited, a company of the Satispay S.p.A. Group.
Personal Data collected: in order to carry out their duties, Satispay hold data in relation to personal details such as names, dates of birth, addresses, telephone numbers, email addresses, bank account details. For more informtion, please refer to Satispay’s Privacy Policy.

Stripe
Stripe is a payment service provided by Stripe Payments Europe, Ltd.
Personal Data collected: contact details (such as name, postal address, telephone number, email address), financial and transaction data (such as credit or debit card number, and bank account information), other personal data, such as date of birth, SSN or EIN and other various type of data as specified in the Privacy Policy of Stripe’s service.

  • Other third parties to the extent necessary to: (i) comply with a government request, a court order or applicable law; (ii) prevent illegal uses of our Sites and Apps or violations of our Site’s and the App’s Terms of Use and our policies; (iii) defend ourselves against third party claims; and (iv) assist in fraud prevention or investigation (e.g., counterfeiting).
  • to any other third party where you have provided your consent.

We may also transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation).

Your Sharing
When you use certain social features on our Sites or Apps, you can create a public profile that may include information such as your screen name, profile picture and hometown. You can also share content with your friends or the public, including information about your Vinitaly Wine Club activity. We encourage you to use the tools we provide for managing Vinitaly Wine Club’s social sharing to control what information you make available through Vinitaly Wine Club’s social features.

PROTECTION AND MANAGEMENT OF OUR PERSONAL DATA

Encryption & Security 
We use a variety of technical and organizational security measures, including encryption and authentication tools, to maintain the safety of your personal data.

International Transfers of your Personal Data
The personal data we collect (or process) in the context of our Site and App will be stored in Italy, in the USA and other countries. Some of the data recipients with whom Vinitaly Wine Club shares your personal data may be located in countries other than the country in which your personal data originally was collected. The laws in those countries may not provide the same level of data protection compared to the country in which you initially provided your data. Nevertheless, when we transfer your personal data to recipients in other countries, including the USA, we will protect that personal data as described in this privacy policy and in compliance with applicable law.

We take measures to comply with applicable legal requirements for the transfer of personal data to recipients in countries outside of the EEA or Switzerland that do not provide an adequate level of data protection. We use a variety of measures to ensure that your personal data transferred to these countries receives adequate protection in accordance with data protection rules; this includes signing the EU Standard Contractual Clauses, verifying the recipient has adopted Binding Corporate Rules or adheres to the EU-US and Swiss-US Privacy Shield Framework.

Retention of your Personal Data 
Your personal information will be retained for as long as is necessary to carry out the purposes set out in this privacy policy (unless a longer retention period is required by applicable law). In general, this means that we will keep your personal data for as long as you keep your Vinitaly Wine Club account. For personal data related to product purchases, we retain this longer to comply with legal obligations (such as tax and sales laws and for warranty purposes).

YOUR RIGHTS RELATING TO YOUR PERSONAL DATA

You have the right to request: (i) access to your personal data; (ii) an electronic copy of your personal data (portability); (iii) correction of your personal data if it is incomplete or inaccurate; or (iv) deletion or restriction of your personal data in certain circumstances provided by applicable law. These rights are not absolute. Where we have obtained your consent for the processing of your personal data, you have the right to withdraw your consent at any time.

You do, in any case, have the right to totally or partially oppose: lower-alpha processing of your personal data, for valid reasons, even if pertinent to the purpose of collection; the processing of your personal data for the purposes of advertisement or direct marketing mailings, or if used for the purposes of market surveys or commercial communications.
You may freely exercise your rights at any time by sending a written request to Vinitaly Wine Club – to the mailing address or to the e-mail address info@vinitalyclub.com - and we will reply promptly.
To ensure that your personal data is always exact, up to date, pertinent and complete, please advise us of any variations by writing to info@vinitalyclub.com.

Opting Out of Direct Marketing
If you have a Vinitaly Wine Club account, you can opt-out of receiving Vinitaly Wine Club’s marketing communications by modifying your preferences in the "view or change my profile" section of our Sites. You can also opt-out by modifying your email subscriptions by clicking on the unsubscribe link or following the opt-out instructions included in the message. Alternatively, you can contact us using the contact details in the “Contact Form” of your website or writing an email to: info@vinitalyclub.com.

COOKIES AND PIXEL TAGS

Vinitaly Wine Club collects information, which may include personal data, from your browser when you use our Site. We use a variety of methods, such as cookies and pixel tags to collect this information, which may include your (i) IP-address; (ii) unique cookie identifier, cookie information and information on whether your device has software to access certain features; (iii) unique device identifier and device type; (iv) domain, browser type and language, (v) operating system and system settings; (vi) country and time zone; (vii) previously visited websites; (viii) information about your interaction with our Site such as click behavior, purchases and indicated preferences; and (ix) access times and referring URLs.

Third parties may also collect information via Site through cookies, third party plug-ins and widgets. These third parties collect data directly from your web browser and the processing of this data is subject to their own privacy policies. 

We use cookies and pixel tags to track our customers’ usage of the Site and to understand our customers’ preferences (such as country and language choices). This enables us to provide services to our customers and improve their online experience. We also use cookies and pixel tags to obtain aggregate data about site traffic and site interaction, to identify trends and obtain statistics so that we can improve our Site. There are generally three categories of cookies used on our Site:

  • Functional: These cookies are required for basic site functionality and are therefore always enabled. These include cookies that allow you to be remembered as you explore our Site within a single session or, if you request, from session to session. They help make the shopping cart and checkout process possible as well as assist in security issues and conforming to regulations.
  • Performance: These cookies allow us to improve our Site’s functionality by tracking usage. In some cases, these cookies improve the speed with which we can process your request and allow us to remember site preferences you have selected. Refusing these cookies may result in poorly-tailored recommendations and slow site performance.
  • Social media and Advertising: Social media cookies offer the possibility to connect you to your social networks and share content from our Sites through social media. Advertising cookies (of third parties) collect information to help better tailor advertising to your interests, both within and beyond our Site. In some cases, these cookies involve the processing of your personal data. Refusing these cookies may result in seeing advertising that is not as relevant to you or you not being able to link effectively with Facebook, Twitter, or other social networks and/or not allowing you to share content on social media.

For a comprehensive and up-to-date summary of every third-party accessing your web browser, we recommend installing a web browser plugin built for this purpose.  You can also choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings on each browser and device that you use. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you may not have access to many features that make our Site and App more efficient and some of our services will not function properly.

VINITALY WINE CLUB'S APP

You can access all the services provided by Vinitaly WineClub through our mobile application Vinitaly Wine Club App. This information is applicable to the processing of your personal data collected via the website www.vinitalyclub.com and via the mobile application Vinitaly Wine Club App.
You can sign up for our mobile application by filling out the registration form and provide your name, your country of origin and defining your personal password. Alternatively you can sign up for our mobile application via your Facebook account or your Google Account +. In this case the service registration and authentication will be provided with the help of third party services Facebook and Google OAuth Authentication and Vinitaly Wine Club will access some of the personal data held by the third party service used for the registration.

Facebook Authentication
Facebook Authentication is a registration and authentication service provided by Facebook Inc. and is connected to the Facebook social network.
Personal Data collected: Various types of Data as specified in the Privacy Policy of the service.

Facebook permisisons asked by Vinitaly Wine Club
Vinitaly Wine Club may ask for some Facebook permissions allowing it to perform actions with the user's Facebook account and to retrieve information, including personal data, from it. For more information about the following permissions, refer to the Facebook permissions documentation and to Facebook privacy policy.

Google OAuth
Google OAuth is a registration and authentication service provided by Google Inc. and is connected to the Google network.
Personal Data collected: Various types of Data as specified in the Privacy Policy of the service.

CHANGES TO OUR PRIVACY POLICY

Applicable law and our practices change over time. If we decide to update our privacy policy, we will post the changes on our Site and App. If we materially change the way in which we process your personal data, we will provide you with prior notice, or where legally required, request your consent prior to implementing such changes. We strongly encourage you to read our privacy policy and keep yourself informed of our practices. This privacy policy was last modified in May 2018.

SECURITY MEASURES

We adopt security measures that are sufficient to reduce the risks of destruction or loss of data – even if accidental – to a minimum, to impede unauthorized access, illicit types of processing and processing that is not in accordance with the purposes of collection as indicated in our Privacy Policy.
However, Vinitaly Wine Club cannot guarantee its users that the security measures adopted to protect the site, data transmission and information on the site, limit or exclude any risk whatsoever of unauthorized access or dispersion of data via user devices: we advise you to ensure that your computer is equipped with appropriate software to protect data transmission on the network, both incoming and outgoing (such as up to date antivirus systems) and that your Internet service provider has also adopted adequate security measures to protect network data transmission (such as a firewall and antispamming filters).

QUESTIONS AND FEEDBACKS

We welcome questions, comments, and concerns about our privacy policy and privacy practices.
If you wish to provide feedback or if you have questions or concerns or wish to exercise your rights related to your personal data, please contact Consumer Services or our Data Protection Officer at our Privacy Office at:

Vinitaly Wine Club, via Roberto Ruffilli, n. 18/20 – 47030 San Mauro Pascoli (FC), Italy.

You may also send us an email at info@vinitalyclub.com. If you contact us with a privacy complaint it will be assessed with the aim of resolving the issue in a timely and effective manner. You also have the right to lodge a complaint with the relevant supervisory authority in the country in which you reside.