PRIVACY POLICY
pursuant to EU Regulation no. 679/2016 ("GDPR") and of Legislative Decree 196/2003 as amended by Legislative Decree 101/2018

PRIVACY POLICY

This information (hereinafter "Disclosure") is made pursuant to EU Regulation 679/2016 and the subsequent national adaptation legislation (hereinafter referred to as "GDPR") and describes how the companies identified in point 2 below collect and process the Personal Data (with the term "Personal Data" will mean all the categories reported in the following point 3., considered together) of users or customers and covers data collection activities - both online and offline - through the various channels, such as sites web in particular www.selfwines.it ("Sites" or "Site") apps, social networks, physical stores, and, more generally, all collection activities in which express reference is made to this Privacy Policy .

SelfWines.it and SelfWines of Self 2010 SAS. - as identified below - they may modify, supplement or update this Notice periodically, also in consideration of any changes to the applicable legislation or provisions of the Guarantor for the Protection of Personal Data. Substantial changes and updates to the Policy will be applied and brought to the attention of interested parties as soon as they are adopted by updating the link to the Privacy Policy in the footer of the Site. SelfWines.it and SelfWines of Self 2010 SAS. invite the user to regularly consult this Statement to know the latest updated version so as to always be informed about the way in which Personal Data is collected and used by them. In case of changes that significantly affect the registered user rights of SelfWines.it and SelfWines of Self 2010 SAS will inform registered users via e-mail and the communication will be made with reasonable notice.


WHO WE ARE

Self 2010 SAS (hereinafter "SelfWines.it.") As independent data controllers (hereinafter the "Owners"), pay the utmost attention to the security and confidentiality of personal data when carrying out their activities.
Self 2010 SAS. deals with:
- manage the websites https://www.selfwines.it / (eg. Site operation, cookies, e-commerce)
- organize activities related to virtual stores and manage the purchase of products and services from the virtual store.
. SelfWines.it and SelfWines of Self 2010 SAS deals with:
- manage web stores under the SelfWines brand;

WHAT PERSONAL DATA CONCERNING IT MAY BE COLLECTED

The Holders can collect autonomously for their business some categories of personal data that concern you (with the term "Personal Data" will be understood all the categories listed below, jointly considered). In particular, in the respective activities of competence, SelfWines.it and SelfWines of Self 2010 SAS. can collect:
- Contact details - name, surname, address, telephone number, e-mail address and any other data spontaneously released by you within the Sites to proceed with online orders and to register.
- Demographic data and interests - data describing your demographic characteristics or habits, for example the date of birth, age or age range, gender, geographical origin (postal code / postal code), preferred products, hobbies and interests and information about the family or lifestyle.
- Payment data - information relating to the purchase made by you and the related payment (eg credit / debit card number, IBAN). These data will be processed only to the extent necessary in the case of periodic payments, and if you have not opposed the processing by changing your settings from "My Account" of the Sites, from the "Payment Methods" section saved for subsequent purchases.
- Use of the website - information relating to the ways in which it uses the Sites, opens or forwards our communications, including information collected through cookies (it can find our Cookie Policy, which regulates the details); Data provided by third parties (eg: postal services, couriers, data entry companies) - all Personal Data that SelfWines.it and SelfWines of Self 2010 SAS. receives from other sources to carry out its services.
- Social Log-In - information about your Social account as well as other data you give to the Social Network used to log in to the Site, which can be communicated based on the privacy preferences that you have set on this Social Network .

SelfWines.it and SelfWines of Self 2010 SAS. can collect:
- Contact details - name, surname, address, telephone number, e-mail address and any other data you provide spontaneously and in any way (eg: as part of promotional activities in SelfWines stores or on the occasion of participation in the courses, etc.). - Demographic data and interests - data describing your demographic characteristics or habits, for example the date of birth, age or age range, gender, geographical origin (postal code / postal code), preferred products, hobbies and interests and information about the family or lifestyle.
- Payment data - information relating to the purchase made by you and the related payment (eg credit / debit card number, IBAN). These data will be processed only for the time necessary for the purchase or as necessary in the case of periodic payments.
- Data provided by third parties - (eg: postal service companies, couriers, data entry companies) - all Personal Data that SelfWines.it and SelfWines of Self 2010 SAS receives from other sources to perform its services.
- Social Log-In - information about your Social account as well as other data you give to the Social Network used to log in to the Site, which can be communicated based on the privacy preferences that you have set on this Social Network .

SelfWines.it and SelfWines of Self 2010 SAS. as a rule, they will not process Personal Data regarding personal beliefs, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, information relating to health, sexual life or sexual orientation (hereinafter " Particular Data Categories "). In the event that it is necessary to treat the Particular Categories of Dati, SelfWines.it and SelfWines of Self 2010 SAS. undertake to process such data in accordance with applicable legislation. The legal basis of such processing is, as a rule, compliance with a legal obligation, it being understood that SelfWines.it and SelfWines of Self 2010 SAS. they will ask for your explicit consent if there is no concrete legal obligation to process such data.


HOW WE COLLECT YOUR PERSONAL DATA

The Holders may collect and process your Personal Data, depending on their respective activities, in the manner described below.

SelfWines.it and SelfWines of Self 2010 SAS. collects your personal data:
- if you register on the Sites or if you register through apps, social networks or other websites in the ownership or availability of SelfWines.it and SelfWines of Self 2010 SAS .;
- if you make online purchases or sign up for loyalty programs, or prize events, or to issue the SelfWines Card;
- if you subscribe to the newsletter related to the virtual store.
- if you contact Customer Service;

SelfWines.it and SelfWines of Self 2010 SAS. collects your personal data:
- if you provide Personal Data in physical stores (eg: in the context of promotional activities, prize events, participation in courses and events, request for information and registration for loyalty programs, release of SelfWines Cards, etc.).
- if you contact Customer Service;

If you provide Personal Data on behalf of someone else, you must always make sure, in advance, that we have read this Privacy Statement and have given your consent where necessary. The Owners ask you to help them keep your Personal Data updated, informing them of any changes.

OBLIGATORY OR OPTIONAL NATURE OF PROVIDING DATA AND CONSEQUENCES OF AN EVENTUAL REFUSAL

The Personal Data required for registration to the Sites or identified with an asterisk in the forms relating to the various activities are necessary to allow the registration itself, as well as the data required to allow the use of the purchase and / or booking function to be used. / or online order or for the provision of the specific service requested. Unnecessary Personal Data is not identified with an asterisk in the various forms and may not be returned without any consequence.


FOR WHAT PURPOSE ITS PERSONAL DATA CAN BE USED

The Owners may process your Personal Data for one or more of the purposes set out below and on the basis of the legal assumption from time to time indicated. All the purposes indicated below apply to both Holders unless one of the two companies is specifically indicated.

A) Fulfillment of purchase orders formulated through the Sites and activities related to the management of orders (eg: supplying e-commerce services, sales and after-sales customer assistance, communications with the customer on the status of the order, receiving his requests for information relating to the products purchased, management of payments, reports, home delivery and / or collection on your part at the agreed point of sale, etc.); as well as to guarantee the correct fulfillment of the obligations provided for by the law, including the legislation on prize events in the event of your participation in them;
Your contact details and payment data can be processed by the cardholders in order to process your purchase order formulated by filling in the special form on the sites.

Condition for processing: execution of a contract of which the interested party is a party and fulfillment of the legal obligations connected to this contract. The provision is mandatory to process your order; in default we will not be able to give you course.

B) Website registration, also through the Social Log-In system - to simplify registration operations using the information already provided to one's Social Network


SelfWines.it and SelfWines of Self 2010 SAS. you may process the Contact Data to enable you to complete the Site registration process and allow you to access your Personal Area in order to: (i) download documents related to the services you have purchased from your Personal Area; (ii) to process other requests made through the website. Registration on the Site may take place, where you voluntarily decide to use it, even with the Social Log-In mechanism. In this way you will not have to enter the data necessary for registration (such as contact data), which will instead be communicated by the Social Network through which the Log-In is carried out. Please note that in this case SelfWines.it and SelfWines of Self 2010 SAS. may process the data of the Social Log-In, that is not only those relating to your Social account but also any other personal data that could be made visible according to the preferences set by you or based on the privacy policy of the Social Network itself. We therefore invite you to read the privacy policy of your Social Network, also for further information regarding these preferences.

Condition for processing: fulfillment of contractual obligations, to allow you to register on the Site, it being understood that you are not obliged to use the Social Log-In to complete the registration.

C) Account management in case of registration to the Sites for the use of the relative services
The use of the Sites does not require the creation of a personal account; however, to access some pages reserved for registered users, you will have to create one and become, in this way, a registered user.

The Personal Data you provide may be processed by SelfWines.it and SelfWines of Self 2010 SAS. for managing your personal account on the Sites.
Prerequisite for processing: execution of pre-contractual measures required by the interested party and execution of a contract to which the interested party is a party. The conferment is obligatory for the creation and management of the account; in default we will not be able to give you course.

D) Join and execute loyalty programs organized by the Holders (eg cashback) and / or agreements signed between SelfWines.it and SelfWines of Self 2010 SAS. and various organizations (both public and private) and to proceed with the issue and management of the relative cards (eg SelfWines Card) necessary to take advantage of the related prizes and / or discounts connected to such programs and / or agreements.
Your contact details and payment data can be processed by SelfWines.it and SelfWines of Self 2010 SAS. for the purpose of managing loyalty programs and / or to adhere to the aforementioned conventions, as well as for issuing the relative card and allowing the use of the relative bonuses and / or discounts associated with such programs and / or agreements. The conferment is mandatory to allow participation in such programs and conventions.

Condition for processing: execution of a contract of which the interested party is a party and fulfillment of the legal obligations connected to this contract.
The provision is mandatory to implement the aforementioned loyalty programs; in default we will not be able to give you course.


E) Marketing activity
Your contact details can be processed by SelfWines.it and SelfWines of Self 2010 SAS. for marketing and advertising communication purposes (also customized, in the case of consent given in accordance with point G below), carried out using automated contact methods (e-mail, SMS and other massive messaging tools, etc.) and traditional methods of contact (for example, paper mail, telephone call with operator) or for market research and statistical surveys, if you give us appropriate consent and within the limits of what is described in the relevant formula.

Your contact details may also be processed by SelfWines.it and SelfWines of Self 2010 SAS. for the periodic sending of communications aimed at informing you about promotional sales initiatives, even periodical (eg. Newsletter aimed at keeping you updated on products and services or initiatives promoted by the owners).

Condition for processing: the consent of the interested party.

Failure to grant consent to marketing activities does not entail consequences on contractual relationships. The consent can be revoked at any time by means of the contacts indicated below in the section "Your data protection rights". In addition, you may at any time indicate the preferred contact method among those listed above and may object to the receipt of promotional communications through all or some of these contact methods.

F) Sending of newsletters for the promotion of products and services similar to those covered by a previous purchase.

Your contact data concerning only the email addresses can be used by SelfWines.it and SelfWines of Self 2010 SAS. for promotional purposes relating to products and services similar to those covered by your purchase. After making a purchase on the Sites, the user will receive the Newsletter related to similar products or services offered on the Sites.

Prerequisite for processing: legitimate interest of SelfWines.it and SelfWines of Self 2010 SAS. to maintain an effective contractual relationship with you.

Your right to object to this processing right away (i) through the appropriate link at the end of each e-mail remains, (ii) modifying your preferences from the "My account" section on the Sites, or (iii) for by means of the contacts indicated below in the section "Your data protection rights". Users can also modify or enrich their preferences at any time via the special "Newsletter" drop-down menu on www.selfwines.it or in the "My account" section on www.selfwins.it, expressing their consent to be contacted about offers on specific stores, or products of interest.

G) Profiling Activities
Each Holder may use the Personal Data for profiling purposes, including, but not limited to, the processing of Personal Data relating to your choices, purchase habits and preferences, the geographical area of ​​reference, analysis of data relating to any registration to the Sites and the use of the same, goods or services purchased, consumption range, level of expenditure incurred, active services, frequency of use, as well as for the creation of profiles (individual and / or aggregated) for the improvement of services and / or products offered by SelfWines.it and SelfWines of Self 2010 SAS., as well as to propose customized commercial communications that could be of interest to you in the event of consent pursuant to point E) above. The profiling activity can be carried out also using the data collected for the purposes referred to in the previous point D).

Condition for processing: the consent of the interested party.

Failure to grant consent to profiling activities does not entail consequences on contractual relationships. Consent may be revoked at any time by means of the contacts indicated below in the section "Your data protection rights", also in relation to the methods of processing your data.

H) Defense of rights in the course of judicial, administrative or extrajudicial proceedings, and in the context of disputes arising in relation to the services offered
Your Personal Data may be processed by SelfWines.it and SelfWines of Self 2010 SAS. to defend their rights or act or even make claims against them or third parties.

Prerequisite for processing: legitimate interest of SelfWines.it and SelfWines of Self 2010 SAS. to protect their rights.

You have the right to object at any time, for reasons connected to your particular situation, to the processing of your personal data carried out by the owners for the pursuit of their legitimate interest. The opposition request must be addressed to the following address: info@selfwines.it

I) Analysis and improvement of services
Your Personal Data may be processed by the Data Controllers to analyze and improve their services with a view to customer satisfaction by identifying the degree of customer satisfaction with the services and / or products supplied (eg purchases, course delivery, events etc.). ) and to gather other useful information in order to adapt its processes to what will emerge from the survey itself.

Condition for processing: SelfWines.it and SelfWines SAS's self-interest in SAS 2010 to maintain an effective contractual relationship with you.

You have the right to object at any time, for reasons connected to your particular situation, to the processing of your personal data carried out by the owners for the pursuit of their legitimate interest. The opposition request must be addressed to the following address: info@selfwines.it


HOW WE KEEP YOUR PERSONAL DATA SAFE

SelfWines.it and SelfWines of Self 2010 SAS use adequate security measures in order to improve the protection, security, integrity and accessibility of your Personal Data. All your Personal Data are stored on our secure servers (or hard copy archived copies) or on those of our suppliers, and are accessible and usable according to our standards and our security policies (or equivalent standards for our suppliers) .


FOR HOW LONG WE KEEP ITS DATA

The Holders keep your personal data only for the time necessary to achieve the purposes for which they were collected or for any other related legitimate purpose.
Your personal data that are no longer necessary, or for which there is no longer a legal prerequisite for its conservation, will be irreversibly anonymized or destroyed in a secure manner.

Below are the storage times in relation to the different purposes listed above:

to. Fulfillment of purchase orders formulated through the website and activities related to the management of orders: the Personal Data processed for the execution of the purchase order through the Sites will be kept by SelfWines.it and SelfWines of Self 2010 SAS. for the time necessary to manage the contractual obligations and subsequently for 10 years.
b. Account management in case of registration to the Sites for the use of the related services: the Personal Data processed for the management of the accounts on the Sites will be kept by SelfWines.it and SelfWines of Self 2010 SAS. for 24 months from the date of your registration to the Sites.
c. Adhere to and implement the loyalty programs organized by SelfWines.it and SelfWines of Self 2010 SAS. (es.cashback) and / or the agreements stipulated between the Holders and different bodies (both public and private): the Personal Data processed for the execution of the loyalty programs and / or agreements will be held by SelfWines.it and SelfWines by Self 2010 SAS. for the time necessary to manage the contractual obligations and subsequently for 10 years.
d. Promotion of products analogous to that of a previous purchase: the Personal Data processed for this purpose may be kept by the Holders for 24 months from the date of your previous purchase (except for an objection formulated earlier).
is. Marketing activity to provide promotional offers: Personal Data processed for this purpose may be kept for 24 months from the date on which the Owners obtained your last consent for this purpose (except for a revocation formulated earlier).
f. Profiling Activities: Personal Data processed for this purpose may be stored for 12 months from the date on which the Holders obtained your last consent for this purpose (except for a revocation formulated earlier).
g. Defend their rights in the course of judicial, administrative or out-of-court proceedings, and in the context of disputes arising in relation to the services offered: the Personal Data processed for this purpose will be kept by the Holders for 10 years.
h. To analyze and improve our services: Personal Data processed for this purpose will be kept by the Holders for 12 months.


WITH WHOM WE CAN SHARE YOUR PERSONAL DATA

Your Personal Data may be accessed by other companies of the Self 2010 SAS Group - meaning Self 2010 SAS and all companies directly or indirectly controlled by it - as independent data controllers and / or data processors, as well as the employees of the Data Controllers duly authorized, as well as external suppliers, appointed, if necessary, controllers, who provide support for the provision of services, including those necessary for the functioning of the Sites. You can consult the updated list of companies belonging to the Self2010 SAS Group at the following link

Please contact us at the addresses below if you wish to request to see the list of data processors and other subjects to whom we communicate Personal Data.

For SelfWines.it and SelfWines and Self 2010 SAS .: info@selfwines.it

CONTACTS

The contact details of the Holders are as follows:

- SelfWines.it and SelfWines of Self 2010 SAS., With registered office in San Marzano di S.G. (TA), Via Vittorio Emanuele 127 / A, CAP 74020, Tax Code / VAT number: 02813670730, PEC address self2010sas@pec.it;

by the Cardholders can be contacted at the following e-mail address: info@selfwines.it. The person in charge of personal data protection (DPO) appointed


YOUR RIGHTS IN THE FIELD OF DATA PROTECTION AND YOUR RIGHT TO PREPARE CLAIMS BEFORE THE CONTROL AUTHORITY

Under certain conditions you have the right to ask:
- access to your personal data;
- a copy of the personal data you provided (c.d. portability),
- the correction of the data in our possession;
- the cancellation of any data for which the Owners no longer have any legal basis for processing;
- revocation of your consent, if the processing is based on consent;
- the limitation of the way in which the Data Controllers process your personal data, within the limits established by the current legislation.

Right of opposition: You have the right to object at any time, for reasons related to your particular situation, to the processing of your personal data carried out by the owners for the pursuit of their legitimate interest. The opposition request must be addressed to the following address: info@selfwines.it

The exercise of the aforementioned rights is subject to certain exceptions aimed at safeguarding the public interest (for example the prevention or identification of crimes) and the interests of the Owners. In the event that you exercise any of the aforementioned rights, it will be the responsibility of the Owners to verify that you are entitled to exercise it and will be given feedback, as a rule, within a month.

For any complaints or reports on how to process your data, the owners will make every effort to respond to your concerns. However, if you wish, you can forward your complaints or reports to the authority responsible for data protection, using the relevant contact details: Guarantor for the protection of personal data - E-mail: garante@gpdp.it - Certified mail: protocol@pec.gpdp.it.