1) INTRODUCTION AND PERSONAL DATA CONTROLLER
For that matter, this Policy will seek to demonstrate how we may collect, safeguard, process, share and transfer your personal data when establishing any relationship with the J. Portugal Ramos Vinhos, PLC, Group. This is the way we found to help you acquire all the information regarding our quality data treatment and protection practices.
Therefore, we urge you to read this policy carefully, being of the utmost importance that after its reading, we are granted with your express consent to the maintenance and treatment of your personal data, in order to authoring the sending of our communications / Newsletters.
J. Portugal Ramos Vinhos, PLC, corporate entity number 503091979, headquartered at Vila Santa, 7100-149, Estremoz, Portugal is the entity responsible for collecting and processing your personal data for the purposes laid down below, as well as the company that exercises control of the corporate group consisting of the following companies: Gestvinus- Investimentos e Serviços Vitivinícolas e Comerciais, PLC., corporate entity number 504582100, J. Portugal Ramos II - Wines & Spirits, Ltd., corporate entity number 509088627, Consulvinus - Produção e Comércio, Ltd., corporate entity number 502065923, Duorum Vinhos, PLC., corporate entity number 507996623 and Conde Foz de Arouce Vinhos, Ltd., corporate entity number 504754351.
In case you feel that you have not been properly informed about this policy, do not hesitate to contact us through our website www.jportugalramos.com, the following email email@example.com or by letter to the following address: Vila Santa, 7100-149 Estremoz.
2) WHAT TYPES OF PERSONAL DATA DO WE STORE AND HOW DO WE COLLECT THEM?
The GDPR considers personal data all of the information that allows to identify or pinpoint directly or indirectly any natural person. It is considered identifiable any natural person that can be identified, directly or indirectly, through an identifier (e.g. ID number, name, surname, physical address or email address)
J. Portugal Ramos Vinhos, LLC., in order to provide you with a better experience with our products, uses certain personal data strictly for the purpose of registering new clients, purchasing purposes and for sending our Newsletter containing our offers, promotions, news and any and all matters that are linked to our business.
Thus, for the purpose of client registry we ask that we are granted the following data:
- Client name or abbreviation;
- VAT number;
- Telephone number;
- Date of birth;
- Billing address and / or delivery address.
As for sending our Newsletter we use the following data:
- Client name; and
3) HOW DO WE USE YOUR PERSONAL DATA?
Your personal data is processed by J. Portugal Ramos Vinhos, LLC., strictly for our records regarding client registry and billing, as well as for sending our Newsletters. Accordingly, your consent will be exclusively for the purposes addressed above.
As for the Newsletters, we may periodically send you information that we consider to be of interest to you.
Thus, J. Portugal Ramos Vinhos, LLC., clarifies that it does not request or store, in any place or in any way, the remission and sending of personal data concerning philosophical or political beliefs, political party or union affiliation, religious beliefs, privacy and racial or ethnic origins, as well as the processing of data regarding health and sex life, including genetic data. That said, if such personal data is transmitted to J. Portugal Ramos Vinhos, LLC., it can not be held liable for its treatment under this policy.
4) HOW DO WE SAFEGUARD YOUR PERSONAL DATA?
Your personal data will be processed and stored in a computer and paper format, if need be.
J. Portugal Ramos Vinhos, LLC. is committed to ensuring the security and protection of the personal data provided to us. To this end, we have adopted a few measures and some of the best practices considered for this purpose. For instance, these are some of the procedures implemented: (i) password protection; (ii) electronic access restrictions with profiling for employees; (iii) physical entry restrictions to the locations where the personal data storage servers are located; (iv) firewalls; (v) secure communication through an http protocol; among other specific procedures set to ensure the protection of your data.
J. Portugal Ramos Vinhos, LLC. informs that the security measures previously mentioned are constantly reviewed and updated according to the needs and requirements inherent to the legislation in force. Additionally, it also works actively with the IT company with the aim to continuously improve the process of security and control of personal data in their systems.
If, for any reason, an accidental or unlawful breach of security provokes the destruction, loss, alteration, disclosure or unauthorized access to personal data, J. Portugal Ramos Vinhos, LLC. undertakes, in accordance with the applicable law, the responsibility to notify the competent authorities without undue delay and, whenever possible, within 72 hours of becoming aware of such occurrence. This communication will also be granted to the holder of the data object affected by the possible violation, in accordance with the applicable legislation.
In parallel to the measures implemented by J. Portugal Ramos Vinhos, LLC., we reinforce the data holder's need to implement its own security measures such as an active firewall, antivirus and spyware systems.
5) WHOM CAN WE SHARE YOUR PERSONAL DATA WITH?
Along the exercise of its activity, J. Portugal Ramos Vinhos, LLC. may use third party services, which may imply access to personal data by such entities.
Should this be necessary, J. Portugal Ramos Vinhos, LLC. undertakes the responsibility to carry out all measures within its reach to ensure that those third parties also offer a high level of control and data protection, in a written contract clause between J. Portugal Ramos Vinhos, LLC. and the third party.
It should be noted that J. Portugal Ramos Vinhos, LLC. will still remain responsible, solidarily, for the treatment of this data.
6) WHAT IS OUR LEGAL BASE FOR PROCESSING YOUR PERSONAL DATA?
J. Portugal Ramos Vinhos, LLC. needs your consent by means of a free, specific, informed and explicit manifestation of will, by means of an unequivocal statement or positive act, in order to have the legitimacy required to process your data for the purposes and activities previously described.
Therefore, your written consent will be our legitimate legal basis so that we may process your data, which may serve to:
- fulfill our legal obligations;
- protect yours, and other people's interests,
- as necessary to the public interest; and
- as may be necessary for our legitimate interest, including out interest in providing personalized products, unless our interests are overwritten by your interests or any fundamental rights and freedoms that require the protection of personal data.
All of our marketing actions follow what we believe best serves the interests of our customers. We may use your data to show you ads and other content on other websites.
7) HOW CAN YOU ASK FOR YOUR RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION?
According to GDPR, there is the right of access, rectification, portability, opposition and erasure of your data. There is also the right to challenge and limit the processing of your data. If you have any questions or want to contact us so that we can satisfy any of the following rights, please send us an email to firstname.lastname@example.org or a letter to the following address: Vila Santa, 7100-149 Estremoz with your request and identification. Below we present in a slightly more detailed manner the main rights foreseen in GDPR:
Right of opposition: in case we use your data when we consider necessary for our legitimate interests and there is no agreement from you in the regard, you may exercise your right to object to our data processing. Just send us an email to email@example.com or a letter to the following address: Vila Santa, 7100-149 Estremoz and we will respond to your request within 15 days (in some cases we may extend this period for another 15 days). In the face of your opposition, we will cease processing your data, except in the event that there compelling and legitimate reasons for such processing presented that prevail over the interests, rights and freedoms of the data subject, or for the purposes of declaration, exercise or defense of a right in a judicial process.
Right to withdraw consent: as our basis of legitimacy for the processing of your personal data, as regards customer registration or marketing actions, we use your consent, as such, it is guaranteed your right to withdraw your consent at any time you deem necessary. We remind you that the withdrawal of consent does not render unlawful the data treatments performed based on your previously granted consent.
Right of access: you have the right to ask us for access, at any time, to the information we have about you. In addition, you may ask us to amend, rectify, or update this information. Upon receipt of your request to be made via email (firstname.lastname@example.org) or a letter to the following address: Vila Santa, 7100-149 Estremoz, we can then proceed to its immediate resolution or request a confirmation of your identity, as well as additional information regarding your request. Our response will be given via email or letter, as applicable.
Right to erasure: you have the right to erase your personal data. This can occur through a formal request via email or letter to the following address: Vila Santa, 7100-149 Estremoz for certain situations in which we have unlawfully processed your data. We will respond to your request within 15 days (extendable for the same period, if necessary). Upon receipt of your request, we will erase your data, without prejudice to the fact that the request may be refused for compelling and legitimate reasons for such processing that prevail over the interests , rights and freedoms of the data subject, or for the purposes of declaration, exercise or defense of a right in a judicial process.
Right to data portability: you have the right to transfer your data that is in our possession to some other entity responsible for the treatment of such. If necessary, we will work to ensure that this transfer of your data is transmitted in an automatic and current reading format.
Right of complaint to a supervisory authority: you also possess the right to complain to the national supervisory authority..
Right to knowledge of the existence of a data breach: you have the right to become aware of any breach associated with your personal data.
Right to limitation of treatment: you have the right to contest: the accuracy; unlawfulness; the need for data for treatment purposes; or when such data is required by the holder for a judicial procedure; and whenever the owner of the data is opposed.
• In case you do not maintain interest in our marketing actions, you can cancel your subscription at any time by sending an email to email@example.com or a letter to the following address: Vila Santa, 7100-149 Estremoz.
• If you wish to know more about your rights regarding the personal data we have about you, you can send an email to firstname.lastname@example.org, or a letter to the following address: Vila Santa, 7100-149 Estremoz to which we will respond as soon as possible.
8) HOW LONG WILL WE SAFEGUARD YOUR PERSONAL DATA FOR?
How long we will keep your personal information will depend on how long our relationship is. We will store your data until we are no longer required to supply our Products to you or though unsubscribing as for the Newsletters. Thus, this is a determination that varies according to each case and will depend entirely on our relationship, as well as factors such as the nature of the data, the motive for why it is collected and processed, and the need for retention following relevant operational or legal needs.
The J. Portugal Ramos Vinhos, LLC. team!