POLICY REGARDING THE PROTECTION OF PERSONAL DATA – PPD
The new EU Data Protection Act, GDPR (General Data Protection Regulation) entered into force on May 25, 2016, but will begin to produce effects as of May 25, 2018. This law is the most significant change in personal data protection over the last 20 years, and has objectives that go far beyond just protecting the private space.
The protection of your personal data is important to us, therefore we pay special attention to protecting the privacy of visitors that access our site www.liliac.com, as well as those whose personal data has been provided to us by third parties, or to which we had access from another source in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council from April 27, 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data (hereinafter referred to as GDPR).
Please pay special attention when reading the next Policy (“PPD”) to understand how your information will be treated (“personal data”).
PPD explains AMB WINE COMPANY’s practices regarding the application of the GDPR provisions, as well as the rights that you benefit of with regard to how your information is processed by AMB WINE COMPANY.
The processing of personal data by AMB WINE COMPANY will always be done in accordance with GDPR provisions, as well as with the personal data protection regulations specific to each country where AMB WINE COMPANY operates.
Through the PPD, AMB WINE COMPANY wishes to inform the subjects about the nature of the personal data we collect and process, as well as about the purposes of the processing. In addition, the subjects are informed via the PPD also about the rights they benefit of.
WHO ARE WE?
We are AMB WINE COMPANY S.R.L., a company with its headquarters in Bucharest, sector 1, Copilului street no. 20, ground floor, office no. 1, with serial number at the Trade Registry J40/10077/2010 and unique registration code 17995031. We have as main field of activity “Manufacture of grape wines”, NACE code 1102 and our legal representative is the administrator Miron Radic.
WHAT ARE THE PERSONAL DATA?
“Personal Data” means any data or information that can identify you directly (for example, your name) or indirectly (for example, your pseudonymous data such as a unique number code). This means that personal information includes things like email address, home address, mobile phone, username, profile photos, personal preferences and shopping habits, user-generated content, financial information and financial status information. This could include unique numeric identifiers, such as your computer’s IP address or MAC address of your mobile device, as well as cookies.
WHAT MEANS PROCESSING OF PERSONAL DATA?
“Processing “means any operation or set of operations performed on personal data or on personal data sets with or without the use of automated means such as collecting, recording, organizing, structuring, storing, adapting or modifying, extracting, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
WHICH ARE YOUR PERSONAL DATA THAT WE PROCESS?
Your personal data that are processed are as follows: last name, first name, e-mail address.
PERSONAL DATA OPERATOR
The Personal Data Operator (hereinafter referred to as “the Operator”) is AMB WINE COMPANY.
DATA PROTECTION OFFICER (DPO)
AMB WINE COMPANY, as operator, designated Mrs. Mădălina Oprea as Data Protection Officer (DPO), having the obligation to verify compliance with the GDPR provisions in the data processing operations performed by the operator and to represent the operator in relationship with the subjects and the Supervisory Authority.
The subjects concerned have the opportunity to address at any time the DPO directly on any matter related to this DPP using the contact details below:
The site visitors may at any time directly address the DPO on any matter related to this DPP using the contact details below:
Name DPO: Mădălina Oprea
E-mail DPO: email@example.com
Mailing address DPO: Bucharest, sector 1, 9 Transilvaniei street.
PRINCIPLES REGARDING THE DATA PROCESSING
AMB WINE COMPANY undertakes to comply with the principles of personal data protection (hereinafter referred to as the “Principles”) provided by GDPR to ensure that all data are:
- Prepared in a fair, legal and transparent manner;
- Collected for specified, explicit and legitimate purposes;
- Relevant, adequate and limited in relation to the purposes for which they are processed;
- Correct and up-to-date;
- Retained in a form which does not allow the identification of the subject for longer than it is necessary in relation to the purpose of the processing;
- Processed in accordance with the rights of the subject, in a manner that ensures adequate processing security so that the data is complete, confidential and available.
LEGAL BASIS AND PURPOSES OF THE PERSONAL DATA PROCESSING
- For the purpose of concluding and executing contracts – according to art. 6 par. 1 let. b) of the GDPR, personal data may be processed for the purpose of concluding or executing the contract. In order to be able to offer you our products, we need to process your personal data.
- For the purpose of fulfilling legal obligations – according to art. 6 par. 1 let. c) of the GDPR, personal data may be processed for the purpose of fulfilling legal obligations. We request a series of personal data, including, in some cases, the personal numeric code, in order to fulfill our obligations towards the tax authority regarding invoicing and reporting towards the tax authorities.
- For marketing purposes – according to art. 6 par. 1 let. a) of the GDPR, personal data may be processed if the subject has given his / her consent to the processing of his or her personal data for one or more specific purposes. Thus, in certain circumstances, your personal data will be used to: (i) send you marketing messages, information or commercial messages (offers, promotions, advertising and marketing messages on AMB WINE COMPANY and third parties with whom AMB WINE COMPANY has relationships of any kind); ii) participation in competitions, promotions.
By providing any personal data through the site www.liliac.com, you understand and agree that your data will be processed in accordance with the provisions of the PPD of AMB WINE COMPANY.
AMB WINE COMPANY undertakes not to process personal data provided for any purpose other than that for which it was transmitted, except in cases where your express consent for use for other purposes has been given.
AMB WINE COMPANY may also have access to other personal data by establishing a link with AMB WINE COMPANY by processing the data communicated following telephone conversations, e-mail, presentations at our headquarters to obtain information, etc.
By contacting AMB WINE COMPANY in any of the above ways or any other method that involves a mediated or direct communication between you and AMB WINE COMPANY, you understand and agree that your data will be processed in accordance with the provisions of the PPB of AMB WINE COMPANY.
If you subscribe to the AMB WINE COMPANY Newsletter, your personal data will be used solely for the purpose of transmitting marketing materials, product and / or promotional information launched by AMB WINE COMPANY in a specific period of time.
Your personal data is to be deleted immediately when you cancel the AMB WINE COMPANY Newsletter subscription.
You can unsubscribe at any time via the link attached to the Newsletter received or by a written request addressed to the Data Protection Officer of AMB WINE COMPANY.
AMB WINE COMPANY reserves the right to select the persons to whom it will send newsletters and / or alerts and the right to remove from its database any Member or Customer who has previously expressed its consent to receive newsletters and / or alerts, without any further commitment from AMB WINE COMPANY or any prior notice thereof.
DISCLOSURE OF PERSONAL DATA TOWARDS THIRD PARTIES
The personal data processed by AMB WINE COMPANY will only be disclosed and / or transferred to third parties if your express consent to do so exists, except for the cases when there is a legal / contractual obligation for AMB WINE COMPANY to proceed that way.
Please be aware that it is possible under certain circumstances to have the obligation to disclose your personal data towards partners with whom AMB WINE COMPANY cooperates and / or other third-party service providers of AMB WINE COMPANY.
DATA PROCESSING BY THIRD PARTIES, OTHER SITES AND SPONSORS
The SITE www.liliac.com may contain, at a time, access links to other sites whose data processing policies may be different from those of AMB WINE COMPANY.
Please consider and consult the personal data protection policies of such other sites, AMB WINE COMPANY not accepting responsibility for the information sent or collected by these third parties.
AUTOMATIC DATA PROCESSING. COOKIE
PERIOD OF TIME IN THAT DATA ARE STORED
AMB WINE COMPANY can store processed data for different periods of time, as deemed reasonable for the purposes indicated above. We only retain your data for the period of time necessary to achieve the purpose for which we hold the data, to meet your needs or to fulfill our statutory obligations.
To know how long your data can be stored, we use the following criteria:
- If you create an account, we retain your personal data until you ask us to delete it or after a period of inactivity (without an active interaction with us). In this regard, please note that data processed for this purpose will be deleted 5 years after the last user account interaction (for example, login to your account);
- If you have given your consent to marketing communications, we retain your personal data until you unsubscribe or ask us to delete it or after a period of inactivity. In this regard, we mention that the data stored in our databases for the purpose of direct marketing communications are deleted from the records of these databases 5 years after the last interaction with you;
- If you participate in a promotional offer, we retain your personal data during the promotional offer;
- In case you contact us for a question, we keep your personal data for as long as your questions are processed, but no more than 5 years after the last mail sent;
- If cookies are stored on your computer, we keep them for as long as it is necessary for them to achieve their goals (for example, during a shopping cart cookie session or ID cookies sessions) and for a period defined in accordance with local regulations and guidelines. In this regard, we mention that the data processed through the cookies used to provide online behavioral advertising, to customize our services for you, and to allow our content to be distributed on social sites (distribution buttons to display the SITE) will be retained for a maximum of 5 years from collection, based on your consent.
RIGHTS OF THE SUBJECTS
According to GDPR, you have a number of rights regarding the personal data that AMB WINE COMPANY processes:
- Right of accessing processed – You have the right to access the personal data that we hold. The first supply of information is free of charge. If you will need further copies of the information already supplied, we may charge a reasonable fee, taking into account the administrative costs of supplying information. The clearly unreasonable, excessive or repeated requests for information may not be answered.
- Right to data rectification – You may request your data to be rectified if they are inaccurate or obsolete and / or to be completed if they are incomplete. If you have an account, it may be easier to correct your own data through the “My Account” feature.
- Right to delete the data (“the right to be forgotten”) – In some cases, you have the right to obtain the deletion or destruction of your data. This is not an absolute right, because sometimes we may have the obligation to keep your data for legal or juridical reasons.
- Right to restrict processing – You are entitled to request the restriction of the data processing. This means that your data processing is limited so we can keep the data, but we may not use or process them. This right applies in the specific circumstances set out in the General Data Protection Regulation, namely:
– the accuracy of the Data is contested by the subject (namely by you) for a period of time that allows the operator (namely AMB WINE COMPANY) to verify the accuracy of the Data;
– the processing is illegal and the subject (namely you) opposes the deletion of the Data and requests the restriction of the use thereof;
– the operator (for example, AMB WINE COMPANY) no longer needs Data for processing, but they are required by the subject (namely by you) to establish, exercise or defend legal claims;
– the subject (namely you) raised objections to the legitimate reasoning of the operator (in this case AMB WINE COMPANY to verify if the legitimate reasons of the operator (AMB WINE COMPANY) exceed those of the subject (namely you).
- Right to data portability – You may move, copy or transfer the data you are interested in from our database to another. This applies only to the data you have provided when the data processing is done with your consent or based on a contract and is implemented by automatic means.
- Right of opposition – You may at any time oppose the processing of your data when such processing is based on a legitimate interest.
- Right to withdraw consent at any time – You may withdraw your consent to the processing of your data when such processing is based on consent. Withdrawal of consent does not affect the lawfulness of processing on the basis of consent prior to its withdrawal.
- Right to file a complaint with the competent supervisory authority – You have the right to file a complaint with the data protection authority in your country of residence or domicile to challenge the data protection practices offered by AMB WINE COMPANY.
- 9. The right to oppose processing of your data for direct marketing purposes – You can unsubscribe or opt-out of our direct marketing communication at any time. It is easier to do this by clicking the “unsubscribe” link in any email or communication we send you.
- 10. The right to oppose the processing of your data by us when conducting actions in the public interest or in our legitimate interests or by a third party – You may oppose at any time the processing of your data when such processing is based on a legitimate interest.
- 11. Right to disable cookies – You have the right to disable cookies. Settings in internet browsers are usually programmed by default to accept cookies, but you can easily adjust them by changing your browser settings. Many cookies are used to increase the usability or functionality of web sites / applications; therefore, disabling cookies may prevent you from using certain parts of our sites or applications, as detailed in the relevant Cookie table. If you want to restrict or block all cookies set up by our websites / applications (which may prevent you from using certain parts of the site) or any other sites / applications, you can do so through your browser settings. The Help feature in your browser will tell you how. For more information, see the following links: http://www.aboutcookies.org/;
You may exercise any of these rights with respect to the personal data that AMB WINE COMPANY processes by addressing a simple request to the AMB WINE COMPANY DPO. In such a situation, it is very possible to request proof of your identity.
We access, retain and provide your information to regulatory authorities, law enforcement entities or other entities:
- In response to any legal request, when we consider, in good faith, that the law requires us to do so. We may also respond to legal claims when we consider, in good faith, that the response required by the laws of that jurisdiction affects users in that jurisdiction and complies with internationally recognized standards.
- When we consider, in good faith, that it is necessary to: detect, prevent and respond to acts of fraud, unauthorized use of any material belonging to us, violations of our terms or policies or other harmful or unlawful activities, to protect us (including our rights, property or materials), yourself and others, inclusive during investigations or investigations by regulatory authorities, or to prevent imminent death or injury. For example, if relevant, we provide information to and receive information for third partners about the reliability of your account to prevent fraud, abuse and other harmful activities inside and outside of our materials.
The information we receive about you may be accessed and stored for a longer period of time when they are subject to a legal inquiry or legal obligation, to a governmental inquiry or investigation regarding possible violations of our terms or policies, or in other cases to prevent damage.
RELATIONSHIPS WITH OTHER OPERATORS
Depending on the context, we may find ourselves in the situation of the absolute need to provide information at a higher level, both globally and internally or externally, to our partners and to those with whom we transfer GDPR data in the virtue of providing the most professional services possible. The information controlled by AMB WINE COMPANY could be transferred, transmitted or stored and processed in the EU or in countries other than the country where you live, for the purposes described in this policy. These data transfers are necessary to deliver the highest level of service and to continue to provide to you our materials at the highest level of professionalism. We use standard contractual clauses approved by the European Commission, and we rely on the appropriateness of the European Commission’s decisions on certain countries, as the case may be, in respect to transfers of data from the EEA data to the United States and other countries.
AMB WINE COMPANY has adopted technical and organizational data processing measures, updated in accordance with GDPR requirements, to protect your personal data against any unauthorized access, improper use or disclosure, unauthorized modification, accidental destruction or loss. All employees and partners of AMB WINE COMPANY, as well as any third parties acting on behalf and for AMB WINE COMPANY, are bound to respect the confidentiality of your information and the GDPR requirements, in accordance with the provisions of the PPD.
THE SITE www.liliac.com may link to other sites and / or other webpages that are not owned by AMB WINE COMPANY. AMB WINE COMPANY assumes no responsibility for the content of these sites and therefore can not be held responsible for the content, advertising, goods, services, software, information or other materials available on or through these sites. AMB WINE COMPANY will not be held responsible for the loss of personal data, of any adverse effects on visitors’ personal data, or other moral and / or patrimonial damages caused by the access to those sites.
UPDATING OF THE PERSONAL DATA PROTECTION AND PROCESSING POLICY
Please note that this Policy may be subject to periodic content changes by updating the SITE www.liliac.com.
How will we let you know about the changes made to this Policy?
We will send you a notification before making any changes to this Policy and we will give you the opportunity to review the revised PPD before choosing to continue using our materials.
Please do not continue to use the SITE www.liliac.com if you do not agree to such changes. We also recommend that you check this page for any updates.
PPD terms shall be interpreted in accordance with the applicable law.
If you have any questions or concerns about the way we treat and use your personal data or want to exercise any of your rights, please contact us by accessing our DPO contact details.