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Confidentiality declaration
We take the protection of our customers' data very seriously and this of course also applies to the personal information of our prospects and clients. Below you will find a description of how your data will be processed and the your rights in accordance with the ‘data privacy regulations’.
Valid from may 25, 2018.
Important contact information in order to communicate with us as the responsible authority:
WINE CITY
350 avenue du Prado
13008 MARSEILLE
0556347544
remi.serie@patriwine.fr
Data categories :
We handle the following categories of your personal data:
- Patriwine and Wine City mailing registration,
- Subscriptions,
- Purchasing data,
- Email and postal advertising preferences,
- Product interests on the site www.patriwine.fr,
- Use of data collected on the site.
Some of this data directly provided by you (e.g. as part of the registration or purchasing processes). Other information is automatically collected (e.g. when visiting our site or by clicking on the newsletter).
Porpose of treatment :
We process your data primarily to perform services related to Patriwine shipments, including information produced according to your interests.
Legal basis :
The processing of your data is primarily necessary for the purpose of carrying out Patriwne mailings and for the pursuit of our legitimate interests.
As long as an agreement is required by law (e.g. for certain advertisements by e-mail or for certain categories of cookies) we will ask you for your agreement.
Receiver categories of your data :
In addition to the responsible authorities, external service providers who assist us in the execution of our services will also have access to your data. Exceptionally, it is also possible that other third parties (e.g. official authorities, external advisors or business partners) have access to your data. Currently, your data is not processed outside of the EU.
Shelf life of your data :
In principle, we process and store your data for the duration of our contractual relationship.
Your rights regarding the protection of your data, including your right of recourse :
Under certain conditions, you can assert your rights relating to the protection of your data with us. We especially want to draw your attention to your right of recourse. For certain reasons resulting from your situation, you have the right to oppose the processing of your data, if we base the legitimacy of data processing on an examination of the interests or if the data processing concerns profiling or direct advertising. In principle, we will no longer process your data in this case.
Voluntary nature of the provision of data :
There is no legal obligation to make your data available to Patriwine. However, you cannot participate in the sending of information if you do not provide us with your data. The provision of your data is completely voluntary. If you do not want to provide your data, you will not experience any legal inconvenience, but you will not be able to enjoy the benefits and communication of Patriwine.
Detailed legal information regarding data protection
1. Authorities responsible for data processing and contact details
The diversity of PATRIWINE's actions induces sending by multiple structures. Therefore several companies are responsible for the processing of your data in the context of mailings within the meaning of art. 26 of DSGVO.
WINE CITY
350 avenue du Prado
13008 MARSEILLE
056347544
remi.serie@patriwine.fr
PATRIWINE, your partner for sending information, is particularly responsible for the management, the preservation of your purchase data and your interest in our products and advertising by e-mail.
Wine City is a trademark that develops the sale of wines between individuals.
The two entities are co-responsible for data processing, within the meaning of art. 26 of DSGVO ("co-responsible"). The purpose of data processing for customers and e-mail advertising, defined jointly by the company PATRIWINE is determined in detail in a contract of co-responsibility. Upon request, we will gladly provide you with a summary of the main provisions of this co-responsibility agreement. Despite this co-responsibility in the data processing, the two entities do not constitute mutual legal representatives.
Data Protection Officer: The Data Protection Officer for both Patriwine and Wine City can be contacted as follows:
remi.serie@patriwine.fr
2. Categories of data
For the purpose of sending advertising by e-mail, we collect and process the following categories of personal data.
| Data category |
Examples |
| Patriwine and Wine City customes phone numer | Name, sex, mailing address, date of birth, e-mail address |
| Preference for email advertising reaction | Agreement for advertising by e-mailn languagen frequency |
| Preference for postal advertising reaction | Opposition to postal advertising, language, frequency |
You give us some of this data directly (e.g. as part of the registration or a purchase) and we collect the others automatically (e.g. when visiting our site or at one of our offices or by clicking on the e-mail newsletter)
3. Treatment goals
We process your personal data in accordance with the provisions of the French General Data Protection Regulation (DSGVO), the French Data Protection Act (BDSG) and other applicable data protection requirements for the following purposes:
• Analysis of your purchase behavior at Patriwine and your visit to the sites and in a customer profile, so that you receive tailor-made offers in the sites, invitations to special events
• Advertising by e-mail and post
• Communication and personalized and individual product recommendations, according to your customer profile
• Custom online store based on your interests
• Improved products, services from Patriwine and Wine City
• Execution of commercial decisions under company law
• Compliance with legal provisions
• Right to assert, exercise and protect legal rights
4. Legal basis
The processing of your data for proposal purposes is authorized because this is necessary for the fulfillment of the contractual relationship with you and because we have a preponderant legitimate interest. We must ensure any conflict of interest as defined in the Position -Recommendation DOC - 2009-23 applicable to September 16, 2009. Reference text Section 313-18 to 313-19; 313-20 to 313-22 of the general regulations.
We justify our overriding legitimate interest as follows: you show your interest in personalized information about the products and services of the different entities, we analyze your behavior and interest in our products with the help of information and we do not take any information automated decision with legal effect or the like.
To the extent that an agreement is required by law, for example for advertising by e-mail or for certain categories of cookies, we ask you this agreement. If you do not give us the consent, we do not execute the data processing processes that require a binding agreement. In addition, legal authorization standards, such as tax retention periods or the right to assert, exercise and protect our legal rights, allow the processing of your data.
5. Recipients or categories of recipients of your data
5.1 Spirit
Patriwine as the Responsible Authority, has access to your data only to the extent necessary to achieve the objectives in accordance with the internal distribution of tasks. To do this, we grant access to your data only to services and employees who really need it.
5.2 Service Providers
We involve service providers who have access to your data as subcontractors and process it for purposes that are specifically defined by us. These subcontractors may be marketing service providers, site hosting providers, IT support providers or website analysis providers.
5.3 Other third parties
In certain circumstances, we transmit your data to the authorities, external advisors, business partners or the courts.
5.4 International transmission of data
Although all recipients are currently settled in the EU / EEA, we should expect that in the future recipients could be settled in a country outside the EU / EEA, which offers no data protection appropriate to the level of European data protection. In particular, it is possible that service providers will be installed in the USA in the future. Where applicable, Patriwine will choose providers that are either certified by the US-EU Privacy Shield Program (Article 45 paragraph 1 of the DSGVO) or have accepted with Patriwine the European standard contract clauses as authorized by the European Commission ( section 46 paragraph 2 (c) or (d) of the DSGVO).
6. Shelf life of your data
In principle, we process and store your data for the duration of our contractual relationship. This also includes the creation of a contract (pre-contractual legal relationship).
In addition, we are subject to various conservation and documentation obligations, most of which come from the French Commercial Code and the French Tax Code. The retention periods and documentation mentioned are up to ten years after the end of the contractual relationship or the pre-contractual legal relationship.
In addition, some special legal provisions may require a longer shelf life, such as the retention of evidence under the statutory limitation provisions. If the data are no longer necessary for the fulfillment of contractual or legal obligations and rights, these are regularly removed, unless their treatment with a limited duration is necessary to achieve the objectives mentioned above, from an interest preponderant legitimate interest of the employer.
7. Your rights to the protection of your data
Under certain conditions, you can assert your rights to protect your data with us:
• Right of revocation of the agreement: if you have given your opinion for certain data processing activities, you may revoke this agreement with effect for the future at any time. However, this revocation does not in any way affect the legality of the processing of your data prior to the revocation of your agreement or as long as the processing can be justified by another legal basis.
• Right of information: You have the right to receive information from us concerning your personal data registered, in accordance with the provision of art. 15 of DSGVO (if applicable, with limitations)
• Right of correction: at your request, we correct your personal data registered according to art. 16 of the DSGVO, if they are incorrect or erroneous.
• Right of cancellation: if you wish, we delete your data according to the provisions of art. 17 of DSGVO, as long as it does not conflict with other legal provisions or overriding interest on our part (e.g. to protect our rights).
• Right to limit treatment: taking into account the conditions of art. 18 of DSGVO, you may require that we restrict the processing of your data.
• Right to challenge: You can also file an appeal against the processing of your data in accordance with art. 21 of the DSGVO. This right of objection is applicable for certain reasons arising from your situation and only for data processing whose legitimacy is based on an examination of interests, which concerns profiling or for direct advertising purposes. If so, we will not process your data unless we have the legal right to refuse your challenge. However, opposition to direct marketing, including profiling, is binding on us and we are no longer allowed to process your data for these purposes.
If you have agreed to direct advertising and do not wish to receive it, you must revoke your agreement.
• Right of transmission of data: you also have the right to receive your data or to transmit it to a third party in a structured, usual and readable format in an automated manner according to art. 20 of the DSGVO.
• Complaints to data protection authorities: In addition, you have the right to lodge a complaint with the relevant data protection supervisory authority (DSGVO Article 77). However, we always recommend starting by sending a complaint to our data protection officer, so that we can solve your problem as quickly as possible and in a focused manner on your needs.
In order to guarantee prompt processing, please send your request for the exercise of your rights in writing to the following address or directly to our data protection officer.
WINE CITY
350 Avenue du Prado
13008 MARSEILLE
remi.serie@patriwine.fr
8. Extent of your obligations to provide us with your data
There is no legal obligation to make your data available to Patriwine. However, you can not take part in Patriwine and Wine City shipments if you do not provide us with your data. The provision of your data is done on a voluntary basis. If you do not provide us with your data, you will not experience any legal inconvenience. However, you will not be able to enjoy the benefits and services of Patriwine and Wine City.
9. Miscellaneous
This data protection information was last updated on 25 May 2018. PATRIWINE reserves the right to update this data protection information from time to time. "