Introduction and legal basis
This Privacy Policy, which can be downloaded by the User for storage, is governed by EU Regulation (EU) 2016/679, regarding the Processing of Personal Data, in order to promote public awareness and understanding of the risks, rules, safeguards and rights in relation to the processing of personal data and to promote the awareness of Data Controllers and Processors regarding the obligations imposed on them by the EU Regulation.
Users are invited to periodically visit this section in order to be kept up-to-date on any regulatory changes.
Data Controller and Processor of Personal Data
The Data Controller is Prodes Italia S.r.l., VAT no. 09808810965, in the person of its director, with registered offices in Via Sansovino 6, 20133 Milan, Italy, info@bestwinestars.com – tel. +39 0236580208
General Risk Disclosure
The Data Controller, in the person specified above, informs users that, due to the particular nature of the medium used, there is a general risk of a breach of network security, a risk that may lie outside the scope of the security measures adopted pursuant to the regulations in force.
Therefore, users are advised to ensure that their browser has all the necessary requirements to guarantee online security of data transmission.
Object of collection and processing
With reference to data collected by cookies and for information on removal, we invite users to carefully examine our Cookie Policy, available in the dedicated section.
Purposes and methods of collection and processing
Personal data are collected to enable the main functions of the website, i.e. to allow users to register, to manage requests for information sent by users, to comply with applicable regulations and/or to respond to requests from public and administrative authorities, to carry out the activities necessary for the acquisitions, mergers, demergers or other transformations and for the execution of the aforementioned operations, to allow limited profiling of users’ preferences, characteristics, habits or consumption choices, in order to enable marketing activities focused on specific interests and needs of users, with the user’s prior consent.
Moreover, data are collected to allow www.bestwinestars.com to send out newsletters, subject to users’ consent by voluntarily subscription to the same through the “subscribe to newsletter” field, or by ticking the “subscribe also to newsletter” box on the registration form. www.bestwinestars.com also processes aggregate data for its own statistical purposes.
Legal basis
The basis for the processing of personal data is first and foremost contractual purposes. In this case the processing is mandatory, as it is necessary for the provision of the requested services.
Therefore, if users do not want their personal data to be used for such purposes, they should not use the services and the website.
Processing is also carried out on the basis of the legitimate interest of www.bestwinestars.com, its counterparties and partners in carrying out economic activities, within the scope and limits strictly necessary for the performance of the same, in line with users’ interests.
Finally, the legitimate interest in data processing is for profiling activities for the purpose of sending out marketing communications, based on users’ interests and needs.
In all these cases, data processing activities are not mandatory and users may object at any time, as indicated below, or by using the form available at www.bestwinestars.com.
Marketing Purposes, on the other hand, are optional.
However, failure to provide consent for these would make it impossible for www.bestwinestars.com and its partners to send users generic and/or personalised marketing communications and partner services/products.
Users may revoke their consent to the processing of personal data for Marketing Purposes at any time by sending the appropriate form, available for download at www.bestwinestars.com, to the info@bestwinestars.com.
Giving consent. Clear affirmative consent.
www.bestwinestars.com does not make use of automatic or predefined boxes to acquire consent from data subjects for the processing of personal data.
Users, in fact, as required by EU regulations, must express their consent in a clear, determined and conscious manner by clicking on the “I accept” button and only after having carefully read the text of the information notice.
This confirms consent to the processing and storage of personal data by the system.
Once users have consciously given their consent, by carrying out the procedure guided by the system, they assume the responsibility of having read the information provided, relieving the Controller of any liability.
Users must also give their consent to receive the newsletter to which they have voluntarily subscribed through the “subscribe to the newsletter” field, or by ticking the “subscribe also to the newsletter” box in the registration form.
To whom the data is disclosed
www.bestwinestars.com shares users’ personal data, for the purposes already mentioned, with:
producers (name, surname, delivery address);
suppliers of services instrumental to the operation of the website;
both appointed as External Data Processors;
the competent authorities for cooperation in investigations to ensure protection against unlawful or unauthorised use of the website, as well as to ensure compliance with Applicable Laws.
The data may also be communicated to parties delegated to carry out activities necessary to the purposes pursued by the website and disclosed exclusively within the scope of such purposes.
These are the company’s internal staff, assigned to carrying out the service offered by the website.
Users’ data may also be communicated to the following categories of third parties:
public authorities as part of the fulfilment of specific legal obligations;
administrative, judicial and tax authorities, in the cases and with the limitations provided for by law;
other entities controlled by and/or connected to the company, in the cases and with the limitations provided for by law;
service providers or consultants for requirements related to the management of the service.
In these cases, the data subject’s consent to the communication of personal data is not required.
Method of processing personal data
The User’s personal data are processed by electronic and non-electronic means for the period of time strictly necessary to achieve the purposes for which they were collected.
In the management of data, collected through www.bestwinestars.com, the most appropriate measures are taken in order to prevent loss, illegal or incorrect use of data as well as unauthorised access.
In addition, reasonable measures are taken to maintain the security of the personal data collected, including limiting the number of individuals who have material access to our databases and installing electronic security systems that protect against unauthorised access.
Modalities of data transfer
Users’ personal data may, during the course of our business, be transferred to third party companies both within and outside the European Union.
In this case, all appropriate measures will be taken to ensure that such transfer takes place in accordance with the provisions of Articles 45 and 46 of the Privacy Regulation.
Should users wish to receive further information regarding the guarantees in place and request a copy of them, they may write to us at info@bestwinestars.com.
Place of storage
Data provided by users will be collected and stored on the servers of ARUBA BUSINESS S.p.A.
In order to send out newsletters, Prodes Italia S.r.l. uses a system called SENDBLUE which allows the company to profile customers according to their language or country of origin, in order to create specific mailing lists for targeted communications.
Storage time of collected data
The data collected will be kept for the time necessary to carry out the activities and obligations for which they were collected. Subsequently, they will be archived, constituting the operator’s internal registry, or they will be deleted.
The internal registry may combine and classify users’ data by associating them with the recognition codes used for authentication.
User Rights
The data subjects’ rights are set out in Regulation (EU) 2016/678 and include the right to:
request confirmation of the existence of their personal data, among the data collected by the company;
know the origin, logic and purpose of their processing;
have the data updated, rectified and/or integrated;
request their cancellation and oblivion, transformation into anonymous form or blocking in the event of unlawful processing;
oppose their processing for legitimate reasons or in the case of use of the data for the mailing of advertising, commercial information, market research, direct sales, and interactive commercial communication;
request the transfer of their data to third parties, where possible and necessary.
Users may exercise these rights by directly contacting the Data Controller and the Data Processor, and request that they proceed with any of the aforementioned tasks, using the references included in this notice.
Alternatively, a special form for exercising rights is available for download on www.bestwinestars.com, which users may fill in and send to info@bestwinestars.com.
Reporting procedure
In the event of a breach of personal data protection regulations or an event leading to the loss of such data by the Data Controller, Regulation (EU) 2016/679 imposes the following procedure:
The obligation to report said occurrence by data subjects
If data subjects are aware that a breach of their personal data has occurred, they must urgently notify the Data Controller, using one or more of the contacts indicated in point sub 2) of this notice. The Data Controller must, within 72 hours, notify the breach to the Privacy Authority, together with the measures adopted to deal with the breach.
Reporting by the Data Controller
A Data Controller who becomes aware of the breach from other sources (DPO, Data Processor, Processing Managers) must notify the Privacy Authority within 72 hours, also indicating the measures to deal with the breach, as well as the data subject.
Complaints
Data subjects are also entitled to lodge a complaint with the Supervisory Authority. For more information regarding the procedure, please visit www.garanteprivacy.it.
Compensation for damage
A data subject who has suffered damage caused by the loss, unauthorised or unlawful disclosure or dissemination of his or her data is entitled to take appropriate action to obtain compensation.
Competent authority
Reports concerning the violation of personal data or damage suffered as a result of such a violation should be submitted to the competent authority www.garanteprivacy.it
Competent Court
In the event of disputes relating to the interpretation of this document, the competent court shall be, pursuant to Italian Legislative Decree 206/2005, the Consumer Court, i.e. the Court of Milan.