INFORMATION ON THE PROCESSING OF CUSTOMER PERSONAL DATA

With this personal data processing policy, pursuant to art. 13 of EU Regulation 2016/679 (the so-called "GDPR"), 3ND S.r.l., with registered office in Florence, Via del Tiratoio, 1, tax code and VAT number 06031960484 ("Vino.com"), as Data controller, would like to explain you the purposes of and methods for personal data use by Vino.com, what data are processed, what are your rights as concerned part and how they can be exercised.

This policy is only applicable to this website (hereinafter "Site"), therefore Vino.com can not be held responsible for other websites visited through hypertext links on the website.

By visiting this website, Users accept this policy, and are invited to read it before providing any personal information.

1. Data controller

Vino.com is the Data controller for personal data collected through the platform.

For some data processing operations, Vino.com avails itself of employees, agents or collaborators, who are responsible for processing data under Data controller's authority. Vino.com also makes use of the services of partner companies and professional studios providing accounting, administrative, legal, tax-related and financial consultancy and located all over Europe. These organisations are duly nominated to be responsible for data processing, pursuant to art. 28 of the GDPR.

The updated list with organisations and people responsible for data processing under the authority of the Data Controller, can be found at the Controller's offices.

The updated list with the responsibles and people in charge of data processing can be found at the Data Controller's offices.

2. Personal data categories

Vino.com will process your personal data collected upon contract termination and during the contractual relationship ("Data"). For instance, the Data Controller will acquire the following personal data:

1) personal data, such as name and last name, place and date of birth, residence address;
2) contact details, such as shipping address, telephone number and email address;
3) bank details (e.g. IBAN), if provided for a possible refund;
4) navigation data, such as IP address, time of access to the site and/or registration on the platform, possible sign up referrer, access methods to the server, numerical code with the status of the response given by the server (successful, error, etc.);
5) order data, such as average order value, type of ordered product, order frequency, order total over time and total number of orders placed.

The Data Controller will not acquire sensitive data through the website, or data belonging to special categories referred to in art. 9 of the GDPR or data related to criminal convictions or violations.

Vino.com will process your data exclusively for the purposes and within the limits indicated in the following paragraph.

3. Purpose and legal basis of data Processing

Vino.com will use your data for the following purposes:

a) for the execution of the contract
Data indicated in paragraph 2, nos. 1-4, will be processed by Vino.com to allow you to register on the website and use the services specifically connected to it. For instance, your data will be processed for order management, maintenance, technical assistance and service improvement purposes. Data will therefore be processed for the execution of the contract with the Data Controller.

Data provision is necessary to allow the establishment and management of the contractual relationship; should data not be provided, it will not be possible for us to execute the contract and provide you with the requested service.

b) for marketing purposes
Direct sales. With your consent, Vino.com may process your data to send you advertising material or commercial communications about possible offers or for market research. Such communications could be sent through automated systems (e.g. email, SMS, push notifications) and traditional systems (e.g. paper mail).

For this processing purpose, the Data mentioned in paragraph 2, nos. 1 and 2 will be used.

You can revoke your consent at any time, even if only for automated contact systems, by writing to assistenza@vino.com

Newsletter. Data indicated in paragraph 2, n. 2, provided upon newsletter subscription, will be used by Vino.com for the sole purpose of providing the requested newsletter service. Data will then be processed for the provision of the service requested to the Data Controller. You may at any time request to cancel your newsletter subscription by following the instructions indicated each time in any communication made for the purposes referred to in this point.

Soft spam. Data referred to in paragraph 2, n. 2, acquired in the context of Vino.com products sale through the platform, may be used to send commercial communications about products similar to those offered. This treatment does not require your express consent pursuant to art. 130 of the Legislative Decree from 30 June 2003, n. 196. You may, however, oppose to this treatment at any time by following the instructions indicated each time in any communication made for the purposes referred to in this point.

c) for profiling purposes
Vino.com may process your data to understand your order habits and preferences in relation to products and services offered through the platform, in order to offer you products and services in line with your profile.

For this purpose, Vino.com may process Data referred to in paragraph 2, nos. 1-2 and 5.

Vino.com will process these data on the basis of its legitimate interest in optimizing order procedures, by offering more functional and useful products and services for specific customer needs. Vino.com legitimate interest has been appropriately balanced with your interests and expectations while assessing the impact on data protection (available by clicking here), in that certain technical and legal measures have been envisaged to minimize the impact of the profiling carried out by Vino.com on your legal sphere.

We remind you that, pursuant to art. 21 of the GDPR, you can oppose this treatment at any time, for reasons connected to your personal situation, by writing to assistenza@vino.com

d) for the communication of your data to third parties for marketing purposes
If mentioned on the Site and with your specific consent, Vino.com may communicate your data to third parties which may process them to send you commercial communications also via SMS / MMS / VMS, push notifications and/or emails.

Recipients categories to whom Vino.com may communicate your data include subjects operating, for instance, in the commercial sectors indicated below:

- Clothing, fashion, accessories, shoes, optical, jewellery, clocks;
- Lenses and eye care products;
- Underwear, swimsuits and accessories;
- Tourism, Airports, flights, ticket discounts, conventions, travel, hotels, itineraries, restaurants, resorts, farm holidays, bus lines, bed & breakfast, hostels;
- Leather bags and suitcases;
- Event organization, weddings, parties, concerts;
- Children and early childhood, goods and services, toys, items and services for pregnant women and new mothers;
- Education, culture;
- Real estate ads, buying and selling, rentals, mortgages;
- House services, restoration, decoration, furniture, doors and windows, plate armour, anti-intrusion and strong-boxes, private guards and security;
- Personal services (investigations, meetings and socializing, get-togethers, health and wellness, herbalists and perfumeries, assisted hotel services, legal and accounting consultancy;
- Culture and training courses, specialization courses, masters, school remedial courses, assistance with university exams, cultural exchanges;
- Financial products, banking, social security, loans and debt consolidation, investments, home banking, investment platforms;
- Items for personal use: mattresses, armchairs, lifters and lifts, ergonomic bathtubs, various devices, including electronic ones;
- Business services (debt collection, commercial information, advertising and marketing, translation, interpreting, relocation);
- Search and selection of personnel, job offers, work experiences, internships;
- Prevention and safety devices;
- Food products, biological and zero-kilometers products
- Drinks and soft drinks, wines and spirits;
- Energy drinks and food supplements (healthy nutrition and fitness);
- Products for body care, hair stylist, make-up, nail-art, beauty centers and salons, treatments, chromotherapy, solarium, gym, spa treatments, sport items;
- Specialized medical services, dentists, teeth whitening, hair thickening, skin treatments and alike;
- Tattoos, piercings and microderma;
- Sanitizing products, monitoring of pollutants, filters and purifiers;
- Air conditioning and management of the living environment;
- Vegetable garden and gardening, floriculture and green thumb;
- Bricolage and DIY;
- Temporary depository, storage and alike;
- Pet services, food products, care, pet care, accommodation and treatments;
- electrical installations, antitheft, telephone, data, satellite, digital and alike;
- Entertainment and leisure, videogames, consoles, portable consoles and computer science;
- Multimedia entertainment;
- Subscription to paid channels, pay per view, pay TV, on demand, etc.;
- Thematic channels for children or by interest categories, multimedia content, CD, DVD, Bluray, Streaming and download;
- Thematic channels for music, hobbies, cooking, technical and cultural ones;
- Cinemas and theaters, cabaret and live shows, concerts, rehearsal, recording rooms, various equipment, post-production, editing and mixing;
- Sports, dedicated channels, specialized magazines, subscriptions, discounts, clothing, accessories, gyms, sports centers, events and competitions;
- Technology, computers, tablets, cameras, telephony, TV and HiFi;
- Appliances, home furniture, linens, artistic decoration;
- Interior design, furniture and interior design;
- Utilities and commodities: rates and energy and service providers;
- Data connection, ADSL, fiber, land line and satellite telephony, new connection technologies, internet providers, internet services, web design, social networks and internet-based services;
- Web page development, sites, applications for computers and mobile devices;
- Mobile network, telephone providers, rates and promotions, services and initiatives;
- Associations, groups, meet-ups, volunteering, social commitment;
- Press and electronic publishing, ebooks, daily newspapers, periodicals, comics, works of art and reproductions, collections and stamps;
- Home, car, person, travel insurance, special rates, discounts and offers;
- Driving schools, driver's license points recovery, car documents, special licenses, license renewal;
- Automotive, tuning, car documents, buying and selling, rental, spare parts, maintenance and car and motorcycle services;
- Meet-ups, competitions, sport events in the motors world;
- Cycling, equipment, events, services, spare parts and alike;
- Sea, lake and river: sailing products and services, fishing, tourism and leisure, water sports;
- Horoscopes, astrology, magic, cartomancy, tarot cards, sport scores predictions and betting;
- Contests and lotteries, price games and rewards programs.

The subjects or categories of subjects to whom Vino.com will communicate your personal data will process such data as independent data controllers according to the provisions of the respective privacy policies.

For this processing purpose, data referred to in paragraph 1, nos. 1 and 2 will be used.

Given consent can be revoked at any time by writing to assistenza@vino.com

4. Data retention period and duration of the treatments

Your Personal Data will be stored primarily on Oracle NetSuite and Google Cloud servers within the European Union.

Your data will be kept for the entire duration of the contractual relationship with Vino.com. Following contract termination, data will be kept for a period of 10 years, only to safeguard the rights of the Data Controller and fulfill legal obligations.

With reference to data processing for marketing purposes indicated in paragraph 2, lett. b), we inform you that the Data will be processed for the entire duration of the contract, unless you revoke your consent or exercise your right to oppose the treatment.

With reference to data processing for profiling purposes, we inform you that the Data will be processed for a maximum period of 12 months or for a different period that should be established by law or by regulations of the guarantor Authority, unless you oppose the treatment. After this period or in case of opposition, data will be stored, if necessary for other purposes, or will otherwise be permanently deleted.

With reference to data transfer to third parties for marketing purposes, we inform you that the data may be communicated until possible revocation of your consent.

5. Legal defense

Your data may be used for legal defense by Vino.com or during its preparatory phases.

6. Credit card details

Vino.com will not process your credit card details, which will be treated and/or stored directly by your bank circuit. Vino.com uses Braintree professional payment services, a PayPal Inc. society, that guarantees consumer the highest level of protection and confidentiality.

7. Cookies

Vino.com makes use of cookies to make User navigation easy and intuitive. More information on cookies is available by clicking here.

8. User rights

We kindly inform you that, following current regulations, you have the following rights:
- request and receive information as to whether Vino.com has your personal data and gain access to such data;
- request data transfer to another controller, for those data that are processed through automated systems;
- request and obtain modification and/or correction of your personal data if you believe they are inaccurate or incomplete;
- request and obtain cancellation - and/or limitation on processed data amount, in case there are data or information that are not necessary - or no longer necessary - for the aforementioned purposes, after retention period indicated in the last paragraph has passed.

Such requests may be sent to the Data Controller by writing to assistenza@vino.com or by registered mail to 3ND Srl, via del Tiratoio n. 1, 50124 - Florence (FI).

We also inform you that, pursuant to the laws in foce, you can send in any complaint regarding the processing of your personal data to the Guarantor for personal data protection.

9. Changes

Vino.com reserves the right to fully or partly change, or simply update the content of this Privacy Policy. Vino.com will inform you about these changes as soon as they are put in place.