We commit ourselves to protect the privacy of everybody using our site, and we regard as extremely confidential the personal information supplied.
With this information on the processing of personal data, pursuant to art. 13 of Regulation (EU) 2016/679 ("GDPR"), Adros Spa, owner of the domain www.xtrawine.com and of the registered trademark "Xtrawine", with registered office in Forlì, Via Sant'Anna ,18 , C.F. 04343670404 e P.IVA 04413480403 (hereinafter referred to as "XTRAWINE"), as Data Controller, intends to illustrate the purposes and methods by which XTRAWINE collects and processes its personal data, which categories of data are processed, what are the rights that are recognized as being involved in the processing and how they can be exercised.
Users, using this site, accept this statement and are therefore invited to review it before providing personal information of any kind.
1. Data controller
Adros SPA, Via Sant'Anna 18 - 47121 Forlì is the data controller of personal data collected through the platform.
2. Categories of personal data
XTRAWINE will process your personal data collected during the conclusion of the contract and during the contractual relationship.
By way of example, the Data Controller will acquire the following types of personal data:
- 1)personal data, such as name and surname, place and date of birth, address of residence;
- 2)contact details, such as shipping address, telephone number and e-mail address;
- 3)bank details (eg IBAN), if provided for a refund;
- 4)navigation data, such as IP address, time of access to the site and / or registration to the platform, possible registration referer, methods of access to the server, numerical code indicating the status of the response given by the server (good order, error, etc.);
- 5)data relating to purchases, such as the average purchase price, the type of product purchased, the frequency of purchase, the total amount purchased over time and the total number of orders placed.
Through the Website, the Data Controller will not acquire data of a sensitive nature or in any case belonging to the particular categories referred to in art. 9 of the GDPR or data relating to criminal convictions or offenses.
Your Data will be processed by XTRAWINE exclusively for the purposes and within the limits indicated in the following paragraph.
3. Purpose and legal basis of the treatment
XTRAWINE will use its Data for the following purposes
a) for the execution of the contract
The Data indicated in paragraph 2, nos. 1-4, will be processed by XTRAWINE to allow registration on the Site and use of services specifically related to it. By way of example, your Data will be processed for the management of purchase orders, maintenance and technical assistance, as well as to improve the quality of services offered. The Data will therefore be processed for the execution of the contract in place with the Owner.
The provision of data is necessary to allow the establishment and management of the contractual relationship; failing this, it will not be possible to execute the contract and provide the requested service.
b) for marketing purposes
Direct sales. With your specific consent, XTRAWINE may process your Data for sending advertising material or commercial communications relating to any promotions or for market research. The sending of such communications can be done through the use of automated systems (eg e-mail, SMS, push notifications).
For this treatment purpose the data referred to in paragraph 2, nos. 1 and 2.
The consent given is revocable at any time, even with reference to automated contact systems only, by writing to [email protected]
Newsletter. The Data indicated in paragraph 2, n. 2, provided when subscribing to the newsletter will be used by XTRAWINE for the sole purpose of providing the newsletter service requested. The Data will therefore be processed for the provision of the service requested by the Owner. You can at any time request to cancel your newsletter subscription by following the instructions indicated from time to time in each communication made for the purposes referred to in this point.
Soft spam. The Data referred to in paragraph 2, n. 2, acquired in the context of the sale of XTRAWINE products through the platform can be used to send commercial communications relating to products similar to those being sold. This treatment does not require your express consent pursuant to art. 130 of Legislative Decree 30 June 2003, n. 196. You may in any case oppose such processing by following the instructions indicated from time to time in any communication made for the purposes referred to in this point.
c) for profiling purposes
XTRAWINE may process your data to understand your purchase habits and preferences in relation to the products and services offered through the platform in order to offer you products and services in line with your profile.
For the pursuit of this purpose, XTRAWINE may process the Data referred to in paragraph 2, nos. 1-2 and 5.
These data will be processed by XTRAWINE on the basis of its legitimate interest in the optimization of its purchasing procedures, through the offer of products and services that are more functional and useful to the specific needs of customers. The legitimate interest of XTRAWINE has been appropriately balanced with your interests and expectations in the impact assessment on data protection, where certain technical and legal measures have been envisaged in order to minimize the impact of profiling performed by XTRAWINE on your legal sphere.
We remind you that, pursuant to art. 21 of the GDPR, you may object to this treatment at any time, for reasons connected with your particular situation, by writing to [email protected]
d) for the communication of your data to third parties for marketing purposes
The information relating to our customers constitutes a significant part of our company assets and for this reason the sale to third parties is completely excluded.
4. Period of data retention and duration of treatments
Your personal data will be stored mainly at the Aruba SPA servers located in the European Union.
Your Data will be kept for the entire duration of the contractual relationship with XTRAWINE. Following the termination of the relationship, the Data will be kept for a period of 10 years exclusively for the needs of protection of the rights of the owner and for the fulfillment of legal obligations.
With reference to the processing for marketing purposes indicated in paragraph 2, lett. b), we inform you that the Data will be processed for the entire duration of the contract, subject to possible revocation of your consent or exercise of your right to oppose the treatment.
With reference to the data processed for the purpose of profiling, we inform you that the Data will be processed for a maximum period of 12 months or for the different period that should be provided by law or by the provisions of the Guarantor Authority, unless you exercise your right to opposition to treatment. After this period or in case of opposition, the data will be stored if necessary to pursue other purposes or will be permanently deleted.
5. Defense in judgment
Your data may be used for XTRAWINE's defense in court or in the preparatory stages for its eventual establishment.
6. Credit card data
The data relating to your credit card will not be processed by XTRAWINE as processed and/or stored directly from the banking circuit. XTRAWINE uses the professional payment services Braintree, a company of the group PayPal, Inc., which provide the consumer with maximum protection and confidentiality.
8. Users rights
We inform you that, in accordance with current regulations, has the following rights:
- ask and obtain information about the existence of your data in the availability of XTRAWINE and access to such data;
- for data processed with automated systems, request transfer to another holder;
- ask and obtain the modification and / or correction of your personal data if you believe that they are inaccurate or incomplete;
- request and obtain the cancellation - and/or the limitation of processing - of your personal data in the case of unnecessary data or information - or no longer necessary - for the above purposes, then after the retention period indicated in the preceding paragraph.
These requests may be sent to the Data Controller by writing to [email protected] or by raccomandata A/R addressed to Adros Spa, via Campo dei Fiori n. 4, 47122 - Forli (FC).
We also inform you that pursuant to current regulations, you can lodge any complaints regarding the processing of your personal data to the Guarantor for the protection of personal data.
XTRAWINE reserves the right to modify or simply update the content of this Privacy Notice, in whole or in part. XTRAWINE will inform you of these changes as soon as they are introduced.