Privacy
This notice, provided pursuant to Articles 13 and 14 of the GDPR, describes how the personal data of users, job applicants, suppliers and customers — including in connection with interaction with the website www.callmewine.com (the "Site", owned by Callmewine) — are processed by Callmewine.
Data Controller: Callmewine S.R.L., with registered office at Via Natale Battaglia 8, 20127 Milan, Italy, VAT/Tax No. 07130650968 (hereinafter "Callmewine"), which may be contacted at the following details: Via Natale Battaglia 8, 20127 Milan, Phone: +39 02 81480430 (Monday-Friday 9:30 AM-1:30 PM and 3:00 PM-6:00 PM), Email: info@callmewine.com
Callmewine has appointed a Data Protection Officer, who can be reached at the email address privacy.dpo@callmewine.com
Processing methods
The processing of data subjects' personal data will mainly be carried out using electronic or otherwise automated means, in accordance with methods and tools suitable to guarantee the security and confidentiality of the data in compliance with the GDPR. In particular, all technical, IT, organisational, logistical and procedural security measures necessary to guarantee the minimum level of data protection required by law will be adopted, allowing access only to persons authorised to process data by Callmewine or by the data processors appointed by Callmewine.
The processing of personal data does not involve any decision-making processes based solely on automated processing, and the security measures relating to the processing of data for the purposes referred to in letter F of the table below have been adequately assessed through specific evaluations carried out by the Controller.
The information collected and the methods of processing will be relevant and not excessive in relation to the type of services provided. The data will also be managed and protected in environments whose access is under constant control. In particular:
• browsing data is collected through the use of cookies. To learn more about how cookies work and how to enable or disable them, please consult our Cookie Policy;
• Plug-ins and social media interaction: by accessing any area of the Site equipped with this type of tool, the data subject's Internet browser will connect directly to the servers of the third-party sites in question, thereby transferring their personal data to the operators of such sites, as indicated in the Cookie Policy. Depending on the specific agreements in place with the operators of such third-party sites, Callmewine may act as an independent controller or as a joint controller with regard to such data transfers. With regard to the privacy protection methods and the processing of personal data collected by the operators of third-party sites with which the interactions described take place, please refer to their respective websites;
Data retention
• Personal account on the Site: until the account is deleted. Callmewine reserves the right to extend this retention period where necessary to comply with a legal obligation to which Callmewine is subject, or to protect a right of Callmewine, including in pre-litigation, judicial, out-of-court proceedings and/or before a competent authority.
• Data processed for the performance of contracts and purchases: a maximum term of 10 (ten) years from the purchase itself, without prejudice to the possibility of extending this retention period where necessary to comply with a legal obligation to which Callmewine is subject or to protect a right of Callmewine, including in pre-litigation, judicial, out-of-court proceedings and/or before a competent authority.
• Marketing activities: until consent is withdrawn and, in any event, no more than 48 months from the date consent was given.
• Soft-spam: until opt-out is exercised in the case of communications relating to products similar to those purchased by customers on the Site (soft-spam), and in any event no more than 48 months from the last purchase.
• Profiling activities: until consent is withdrawn and, in any event, no more than 12 months from the date consent was given.
• Preferences and personalised offers: until the data subject exercises their right to object and, in any event, no more than 12 months from the collection of the data via cookies;
• Abandoned cart: for a maximum of 24 months from the interruption of the purchase.
• Data provided when contacting customer service: for the period strictly necessary to respond to data subjects' requests and, in any event, within 2 years of handling the request.
• Browsing data: This data is retained only for the time strictly necessary for the purposes for which it was collected, as indicated in the Cookie Policy.
- Applications: for the time necessary to manage the selection process and, in any event, for a maximum of 24 months.
- Suppliers: 10 years from termination of the contractual relationship with the supplier, without prejudice to the possibility of extending this retention period where necessary to comply with a legal obligation to which Callmewine is subject or to protect a right of Callmewine, including in pre-litigation, judicial, out-of-court proceedings and/or before a competent authority.
- Customer support and browsing assistance via the "chatbot": this data is retained in accordance with the retention rules set out for data provided when contacting customer service.
Communication and disclosure of data
The personal data collected will be processed by personnel authorised by Callmewine who need to be aware of it in connection with their duties and/or by external parties who provide services on behalf of Callmewine, such as, for example, IT system management services, competent authorities and/or public bodies and supervisory and control agencies for the fulfilment of any legal obligations, communication agencies and companies, companies acquired or acquiring in the event of extraordinary transactions (e.g. mergers, acquisitions, etc.), external professionals and consultants, and other parties that, in any capacity, collaborate with the Controller — for the achievement of institutional purposes and the provision of services to data subjects — and that may act as data processors or as independent controllers. The complete list of such parties is available upon request from the Controller at the contact details indicated.
Data relating to data subjects will not be disclosed, except in anonymous and aggregate form, for statistical or research purposes.
Transfer of data outside the EEA
Callmewine may transfer data subjects' personal data to countries outside the European Economic Area ("EEA"), where this proves necessary to pursue the purposes of the processing described in this Notice. In particular, in such cases Callmewine guarantees that any transfers of data to such countries will take place in a manner that ensures full protection of the rights and freedoms of data subjects, relying on adequacy decisions issued by the European Commission, as well as, where necessary, assessing the level of protection offered to personal data and adopting the safeguards provided for in Articles 46 et seq. of the GDPR, including the standard contractual clauses approved by the European Commission. The list of countries to which data is transferred and the safeguards adopted to allow lawful transfer is available upon request from the Controller.
Rights of the data subject
Pursuant to Articles 15-22 of the GDPR, the data subject has the right to:
• to receive confirmation of the existence of their personal data and to access its content (right of access);
• to ask the Controller to update, modify and/or correct their personal data (right to rectification);
• to request the erasure or restriction of processing of data processed in violation of the law, including data whose retention is not necessary in relation to the purposes for which it was collected or otherwise processed (right to erasure and right to restriction);
• to object to processing: i) where processing is based on legitimate interest, unless the Controller demonstrates compelling grounds justifying the continuation of processing even where an objection has been raised; ii) where processing is based on consent (for example, processing of data for marketing and/or profiling purposes), in which case the Controller may not continue processing following the exercise of the objection and/or, in any event, where previously given consent is withdrawn (right to object);
• in cases where processing is based on consent or on a contract and is carried out by automated means, to exercise the right to data portability, i.e. to receive their personal data in a structured, commonly used and machine-readable format, and, where technically feasible, to have it transmitted to another controller without hindrance.
The above rights may be exercised at the following email address: privacy.dpo@callmewine.com.
At any time, the data subject may also lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali), as well as resort to other remedies provided for by applicable law.
Amendments
Callmewine reserves the right to make changes to this notice at any time, providing appropriate notice via the Site or by email.
Types of data processed, purposes and legal bases of processing
Callmewine will process the personal data collected in the manner and for the purposes described below:
