WINEnROUTE is a service that allows users (hereinafter also referred to as "user", "you", "your") to select and book programmes and experiences associated with the wine tourism sector on its e-commerce platform. Our website, websites for mobile devices and associated applications (hereinafter referred to collectively as "our website") are managed and processed by WINEnROUTE (hereinafter "we", "us", or "our") as the personal data controller.
We acknowledge the trust users place in us by submitting their personal data. We value it highly and are fully committed to ensuring the security and confidentiality of the personal data you provide us when you access our website or use our services, and to handling such data lawfully, fairly, and transparently.
1. Collection of personal data of users
Personal data means any information about a person from which it is possible to identify them either directly or indirectly, such as first and last name, telephone number, address and e-mail address, date of birth, password, and payment information. This information does not include data from which the identity has been removed (anonymous data).
During our business, we collect and process personal data in a variety of ways. In addition to collecting personal data that you provide directly to us, we may collect data by recording how you interact with our services, for example by using cookies on our website. In addition, we may receive information from third parties.
You may choose not to provide us with such personal information. However, you will generally need to provide us with certain personal information in order, for example, to book programmes or experiences, receive offers (from us or from sellers) and access other benefits to which you have access as a registered user. In addition, some information may also be required so you can ask questions to WINEnROUTE.
On our website, mandatory information is marked with an asterisk. If you do not provide us with mandatory information, your request may not be processed or will be processed later.
Information provided by the user
We collect and store information that you provide us through our website or send us by other means.
Information about third parties
Each time you make a purchase on behalf of a third party or invite customers through WINEnROUTE, you will need to enter the personal details of that third party. It is up to the user to obtain the prior authorisation of the third-party data subjects, so that they provide us with the respective personal data with the consent of the data subject.
Information from other sources
Automatic collection of information
When you access our website, we automatically collect some information from your computer or mobile device. For example, we collect session data, including IP address, browser software used and referring website. We may also collect information about your online activity such as content viewed, pages visited and searches. This type of information is collected automatically to better understand the interests and preferences of our users, to further personalise their experience.
Geographic location and other information extracted from the user's mobile devices
From the moment you use the WINEnROUTE mobile version on your mobile device, we may collect and use your information in the same way and for the same purposes applicable to the use of the website. In addition, we may collect your location information with your consent if your mobile device has been configured to send this type of information to the WINEnROUTE application (see the privacy settings of your mobile device). For example, we may use this information to provide ratings about vendors near you. You can change the privacy settings of your mobile device at any time and disable the feature for sharing location information. However, disabling the sharing of geolocation information may affect some features of the application. Please contact your mobile device manufacturer to obtain help regarding the privacy settings.
2. Lawfulness of processing and how we use your personal data
The processing of personal data is carried out based on contractual performance, pursuant to Article 6(1)(b) of Regulation (EU) No 679/2016 of April 27, General Regulation on the Protection of Personal Data (“RGPD”)
All personal data collected is adequate, relevant, and limited to what is necessary considering the purpose for which they are processed.
We use the personal data we collect about you only for specified, explicit and legitimate purposes and ensure that the data collected is not further processed in a way incompatible with those purposes. These purposes include:
1. Offer our services to the user.
2. Manage the user's registration and account, including the access and use they make of our website.
3. Publish user ratings, scores, and photos.
4. Manage our commercial activities, promotional operations, incentive programmes or marketing operations (including email campaigns, loyalty programmes, targeting, retargeting, profiling, and segmentation).
As previously stated, our personal data processing activities may also include profiling activities (i.e., any form of automatic processing of personal data to evaluate certain aspects about a natural person, including their personal preferences, interests, behaviour, location or movements) in order to define customer types for our products and services, to keep our website up-to-date and relevant (to optimise your experience), to develop our business and to carry out our marketing strategy.
In addition, we use your personal data as part of our recruitment process and for the professional training of our teams.
Deactivate the user's WINEnROUTE account
We may use the information we collect about you in determining whether to deactivate your account, especially in the following cases:
a. Several situations where the user did not buy/book.
c. Confirmation of fraud on our website, including the publication of a fraudulent review.
d. Information contained in accounting documents (e.g., invoices, receipts, current accounts).
The user will be notified of the account deactivation by e-mail.
As a result of account deactivation, all current purchases are cancelled, and all accumulated order history is deleted.
To assist the user to benefit from our services and/or special offers featured on our website, WINEnROUTE may send emails and/or push notifications with information about offers and services that may be of interest.
We will only send you marketing and promotional messages if you have given us permission if you have asked us to or if you purchase goods or services from us.
Whenever you receive such an email, you can indicate and immediately unsubscribe from marketing and promotional messages, refuse to display push notifications on the application or change your mobile device settings to this effect. You can unsubscribe from our marketing communications at any time by clicking on the unsubscribe link at the bottom of any message sent by us.
Please note that we may continue to send you communications relating to the service, such as administrative messages about your account or messages about transactions pertaining to one of your bookings until you close your account.
3. With whom we share your personal data
We may share your personal data with others, including other companies within the group and third parties, affiliated websites or applications and service providers acting on our behalf and, more generally, any of our business partners or suppliers. If we sell or dispose of our business (or part of it) and your personal information relates to that part which is sold or disposed of, or if our business merges with another business, we will share your personal information with the new owner or merging partner, respectively. If we are legally bound, we will share personal data to protect our customers, our website, as well as our company and our rights and property.
If you choose to create a profile on our website, some of the information in your profile will be in the public domain and can be viewed whenever someone clicks on your username. You can view your profile as it is presented to the public. We require all third parties to respect the security of your personal data and process it lawfully. We do not allow our external service providers and/or partners to use your personal data for their own purposes and only allow them to process such personal data for specific purposes and according to our instructions.
For more information about the entities that may have access to personal data of users, see below:
Hotel units, tour operators, promoters of experiences, restaurants, wineries, museums, exhibitions, and other partners associated with the wine tourism sector.
We share your information with partners for the purpose of making and managing bookings and to resolve any complaints and disputes.
Third-party service providers
Third party service providers are those entities that provide services to us or act on our behalf, including in matters such as business analysis, data or payment processing, customer service, marketing, public relations, surveys, prize draws or for fraud prevention purposes.
The user's credit card details are kept by the payment service provider only for the purpose of completing the transaction and for as long as necessary to respond to any complaints from the cardholder. This payment information is encrypted and protected by the service provider Stripe Payments Europe, Ltd. External providers may also be permitted to collect information on our behalf, including, for example, as necessary to ensure the functionality of our website or to improve the presentation of online advertisements targeted to your interests. External service providers have access to the information and may collect it to the extent strictly necessary to carry out their functions. They are not allowed to share it or use it for other purposes.
If you have been redirected to our website from another website or application, we may share information about you (first name and initial of surname) and your purchase with that affiliate.
Companies that belong to our group
We may also share your information within our group or with third parties if, in our discretion, we believe that the disclosure of such information is necessary:
a. To comply with summons, court orders or other legitimate and enforceable legal process; to establish or exercise our legal rights; to defend ourselves against legal claims or as otherwise required by law. In such cases, we reserve the right to exercise or waive any objection or legal right available to us.
b. If we are required by law to do so, we will share the data we collect with law enforcement authorities and other government agencies.
d. Within the scope of a corporate transaction, such as a disposal, merger, acquisition, consolidation, or sale of assets.
You will be informed when your personal data are shared with third parties outside the scope of the previous provisions and you may request that they are not shared.
We may also share anonymous or aggregated information with third parties, including advertisers and investors. For example, we may tell our advertisers the number of visitors to our website or the most popular sellers. This information does not contain personal data.
4. How long do we keep your personal data?
We may retain in our records some of the information associated with your account, including for analysis or record keeping purposes. The retention period for your personal data depends on the purpose for which it was collected and the use we make of it.
We keep your personal information only for as long as is strictly necessary for the purposes set out in section 2, " How long do we keep your personal data", or to comply with legal obligations. For marketing purposes, the retention period is 3 (three) years from the date of your last activity. We may retain some personal information for a longer period, even after your account has been closed, if it is necessary to comply with our legal obligations or to maintain security, prevent fraud and abuse, and defend or enforce our rights. In general, if you choose to close your account, your personal data will no longer be viewable by others on our website after 14 (fourteen) days.
5. Cookies and other web technologies
You can also find more general information about cookies, including how to determine which cookies are installed on your (mobile) device and how to manage and delete them.
1. To identify your browser when you return to our website, to record and remember any preferences you set during your last visit. For example, if you are registered with our website, cookies may allow us to retain your login information so that you do not need to re-enter it each time you visit us.
2. Personalise the user's browsing experience and the content of our website. For example, when the user visits a website, we, our service providers or our partners automatically install a cookie that recognises your browser when you access the Internet and allows us to present information according to what we consider to be your interests.
3. Evaluate and document the effectiveness of different features, offers and electronic communications (by determining which emails have been opened and whether the user has clicked on a link included in the email).
The "Settings" option, available on the toolbar of most browsers, should provide information on how the user can prevent their browser from accepting new cookies, get a notification when they receive a new cookie or how to disable cookies that are not useful. Please note that if you do not accept cookies, you may not be able to access many of the tools, content or features that our website provides.
Cookies are managed by the Cookiebot consent management platform (CMP) and therefore compliant with Google's "Consent Mode" attribute.
Our website may also use Web beacons (also called GIF or invisible pixels), small digital images with a unique identifier that function in a similar way to cookies and are placed in the code of a web page. The use of web beacons is intended to know the browsing patterns of our users who access a page from another page within our website, to provide or convey information to cookies, but also to determine whether the user is accessing our website from online advertising displayed on a third-party website. Lastly, they are used to improve the performance of our website.
Data collected by business partners and advertising networks to display targeted advertising.
The user's Internet browser may transmit a DNT signal (Do Not Track) to inform WINEnROUTE and other websites that it does not wish to be tracked. Due to differences between the default settings of internet browsers and the way DNT signals are integrated, website operators are not always sure whether users have selected the DNT parameter or are aware that they can set it. Currently, WINEnROUTE does not consider DNT signals.
6. User rights
You can verify, complete, and update the information you have provided to us by logging into the personal information section of your account. You may also close your WINEnROUTE account in this section or by sending an e-mail to email@example.com. If you choose to close your WINEnROUTE account, we will deactivate the account and delete your profile information. Please remember that when the account is closed, you will no longer have access to your login and personal information. You can, however, open a new account at any time.
You can change your marketing preferences at any time.
According to the applicable laws and regulations, you have the right to access, rectify and delete your personal data, the right to limit the processing of such data, data portability, as well as the right to oppose the processing of your personal data. You also have the right to determine how your personal data is used and how your rights are exercised after your death.
Further details and information on how and when you can exercise your rights can be seen below. We will respond to your request within 1 (one) month, although we have the right to extend this period by 2 (two) months if necessary, depending on the complexity and number of requests.
For more information related to your rights, please see below:
You have the following rights concerning your personal data:
a. The right to request access to your personal data. This allows you to receive a copy of the personal data we have about you and to check whether we process it lawfully.
b. The right to request the rectification of your data if it is inaccurate. In addition, you may complete any incomplete data that we hold, in view of the purpose of the processing.
c. The right to request the deletion of your personal data if:
d. Your personal data is no longer necessary for the purposes for which we collected or processed it; you withdraw your consent, if the processing of your personal data is based on consent or there are no longer legal grounds for such; you object to the processing of your personal data and we have no compelling legitimate grounds to carry out the processing; your personal data are processed unlawfully; or your personal data must be deleted to comply with a legal obligation.
e. The right to object to the processing of your personal data. We will comply with your request, unless we have an overriding legitimate interest which justifies the processing or we need to further process your personal data to initiate, carry out or defend a legal claim.
f. The right to limit the processing of personal data if:
g. The accuracy of your personal data is contested by you during verification.
h. the processing is unlawful, and you object to the deletion of your personal data and request the enforcement of restrictions.
i. We no longer need your personal data for processing purposes, although you still need it for legal proceedings.
j. The user objects to the processing during the period in which we must verify prevailing legitimate grounds.
k. The right to data portability. You may ask us to send you your personal data in a structured, commonly used, and machine-readable format. You may also request that we forward such personal data to third parties, if feasible. This right only applies to personal data you have provided, if the processing is based on your consent or is necessary for establishing a contact between you and us, or if the processing is carried out by automated means.
You can exercise several of your rights through the personal information section of your account. The remaining rights can be exercised by sending an e-mail to firstname.lastname@example.org
You do not have to pay any fee for accessing your personal data (as well as for exercising any rights). We may nevertheless charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.
To help us confirm your identity and to ensure your rights to access your personal data (or exercise any other rights), we may ask you to provide us with a copy of your identification document. This is a security measure to ensure that your personal data is not disclosed to those who are not authorised to receive it.
Furthermore, we may contact you to request additional information related to your request to expedite our reply.
7. How do we protect the users' personal data?
We want our website to be used with transparency and trust. For this reason, we are committed to protecting the information we collect. Although no website can guarantee absolute security due to the complexity of online activities, we have implemented and maintain suitable structural, technical, administrative and physical measures to protect the personal data you provide us against unlawful access, use or disclosure, as well as accidental loss, damage, alteration or destruction.
For instance, we use data encryption when we transfer billing information between our system and those of other parties with whom that information is shared. We also use firewalls and intrusion detection systems to prevent unauthorised access to user information.
8. Information relating to minors
Our website is only intended for adults and does not offer services aimed at minors. We do not knowingly collect data from minors. If we become aware that a person under the age of 18 has submitted personal data to us, that information will be deleted or destroyed as soon as reasonably possible.
9. External links
10. International transfers
Transfers of personal data are carried out:
1. For a country that, according to the European Commission, provides an adequate level of protection.
2. For a country that does not offer adequate protection, but the transfer is governed by the Commission's standard contractual clauses.
12. Contact information
If you have any questions or complaints about the way we process your personal data, you can contact us at email@example.com. Additionally, you have the right to lodge a complaint with the Data Protection Authority regarding the way we process your personal data. Nevertheless, WINEnROUTE will seek to address your concerns before appealing to said supervisory authority, so please contact us beforehand.
WINEnROUTE is not responsible for the processing of data on external websites.
For any question concerning the processing of your personal data you may contact us by the following means:
Telephone: + 351 969 884 123
Address: Avenida da Boavista, 2450/60, 4100-118, Porto
As a user of this website, if you do not accept the terms of this Privacy Notice, you should not access, browse, or register your data or that of third parties in the forms provided for that purpose.
Last updated: 2021/08/06