Privacy Policy
At SOBREÑO, S.A. we are committed to the protection of privacy and the correct use of the personal data we process and that you provide us with, both online on this website and, as the case may be, on any of its subdomains, microsites and/or mobile applications, as well as offline.
Please carefully read this policy and make sure you understand and agree with it before providing us with your personal data. If you do not agree with this policy, do not use this website or its services and do not provide us with your data either online or offline. By accessing this site, using any of its services or providing us with your data, either online or offline, we will take this as a clear affirmation that you give us your consent (when it is required) to process your data for the purposes that are later outlined.
2.- Who is the controller of your data?
SOBREÑO, S.A.
Postal address: CARRETERA NACIONAL 122 KM 423 TORO ZAMORA
Email address: sobreno@sobreno.com
3.- How did we get your data?
From the data subject him/herself: If you are a current or potential client, you provided us with your personal data, either online or offline, when you requested our products or services so we could maintain a contractual or pre-contractual relationship with you, or if you have come to our cellar, you provided us with your data when you accessed it as a visitor.
This information includes, for example:
- Your contact details, including your name and surname(s), address (delivery or billing), date of birth, email address and, optionally, your phone number. We need your email address and (optionally) your phone number so we can contact you if we have any questions or information about your order;
- Other necessary information in order to process your order, such as the information on products you have requested, the billing and delivery address and the details of your bank or credit card;
Automatically when visiting our website: If you have provided us with your data through this website or any of its subdomains and/or microsites, we collect information, for example, when you sign up as a user, fill out any form with personal data, edit your profile and/or load information or content, buy in our shop or communicate with us directly via email.
When you visit our website, data is sent from your browser to our server, in order to optimise our services and improve your experience as a user, for example when you access the site or when you sign into our Services through external services such as social media or Google. This data can be collected and automatically stored by us or third parties on our behalf. This data may include:
- the user’s IP address
- the date and time of visit
- the URL of the site the user came from
- the pages visited on our website
- information on the browser used (type and version of the browser, operating system, etc.)
We can process and register these uses, sessions and related information, either independently or with the support of external services, as well as through the use of “cookies” or other tracking technology such as flash cookies and web analytics.
When you provide us with your personal data, you guarantee that you are authorised to provide this information and that the information is correct, true, accurate and up to date, that it is not confidential, that it does not breach any contractual condition or third party’s rights and that you agree to not impersonate other users by using their registration data for different services and/or content of the website.
You are responsible for keeping your data correct and up to date, and SOBREÑO, S.A. denies all responsibility if you fail to do so.
Subject’s data given by a third party:
In the event it was not the data subject him/herself but rather a third party who provided us with the former’s data, we have received your data, in this case, via our sales or distribution network prior to it being passed on to a member of our sales team; or via someone who has reserved a group visit to the cellar... The data categories we process could be: Identification details. We do not process sensitive or secure data
In the event it is not the data subject him/herself but rather a third party who has provided us with the former’s data, it is the third party who explicitly guarantees that they have the subject’s authorisation to provide this data, relieving us of any responsibility in the event of a legal claim from the data subject. The responsibility will be assumed only by the person who provided the data in the name or interest of the data subject.
Third party’s data given by the data subject:
Regarding other people’s data, you must respect their privacy and take special care when communicating or publishing their personal data. Only the holder can authorise the processing of their personal data. If you provide us with third parties’ data, it is your responsibility to get their prior and explicit consent to use and communicate it, and it is your responsibility to inform them of the processing by us. Publishing third parties’ data without their consent can infringe the data protection regulation as well as the Spanish law regarding these third parties’ right to honour, privacy and personal image. If you provide us with third parties’ personal data, in acceptance of this privacy policy, you explicitly guarantee that you have the subject’s authorisation to provide this data, relieving us of any responsibility in the event of a legal claim from the data subject. The responsibility will be assumed only by the person who provided the data in the name or interest of the data subject.
4.- For which purposes do we process your data for?
The data you provide us with, as well as any other data generated during the development of the contractual, pre-contractual, commercial or any other type of relationship we maintain with you may be processed by us for various purposes. For example:
The data you provide us with, as well as any other data generated during the development of the contractual, pre-contractual, commercial or any other type of relationship we maintain with you may be processed by us for various purposes. For example:
If you are a current or potential client, we process your data in order to keep in contact and communicate with you and manage the contractual and/or commercial relationship.
If you are simply a user of our website, the sender or recipient of an email or a visitor of our cellar, we process your data in order to manage requests you may make online or offline.
In both cases, we process your data in order to keep in contact and communicate with you, conduct opinion and/or satisfaction surveys and send you information on our activities, products and/or services (including commercial/advertising communication for the purpose of art. 21 LSSICE 34/2002 [Spanish Law on Information Society Services and Electronic Commerce]). The commercial/advertising information we send you via email will include the option to stop receiving them in the email itself. If you select this option we will stop sending you this type of communication from then on.
We inform you that during visits to the cellars, events or activities we organise photos and/or videos may be taken and published on this website, on any of our social media profiles, such as youtube, to give information about the event/activity, document it and to form part of our photographic/videographic memory of it.
5.- How long will your data be stored for?
As long as the data subject does not request its erasure, and even if requested, we will store the personal data you provide us with for the period that is necessary and restrict its processing to only being for the purposes of compliance with legal/contractual obligations we are subject to and/or for the legal periods set out, for the assignment of any responsibilities on our part and/or the exercise or defence of legal claims resulting from the relationship maintained with the data subject.
6.- What is the legal basis for the processing of your data?
The legal basis that allows us to process your data is the commercial relationship we have if you are a current client/provider, the offer, quote, request or pre-contractual relationship of any type that exists between parties if you are a potential client/provider, or, for example, your consent if you have made a request through our website if you are simply a user of it or if you are a visitor of the cellar. You give us this consent explicitly when you provide us with your data online or offline, as this act is considered a clear affirmation of your consent. The legal basis may also be compliance with a legal obligation such as the LSSICE [Spanish Law on Information Society Services and Electronic Commerce], the Law on Consumers and Users or the regulatory law on the prevention of food contamination.
It is mandatory to provide the data requested as it is essential for the purposes previously outlined. If you do not provide them, we will not be able to perform such purposes.Given the relevant, appropriate relationship you maintain with us as a current or potential client/provider, user of our website, visitor of the cellar..., we have a legitimate interest in processing your data in order to be able to send you information on our cellar and our wines (including commercial/advertising communication for the purpose of art. 21 LSSICE 34/2002 [Spanish Law on Information Society Services and Electronic Commerce]) within the maintenance and management of this relationship.
SOBREÑO, S.A. informs its data subjects that, in the event a prior contractual relationship exists, we will send you information on our activities, products and/or services (including commercial/advertising communication for the purpose of art. 21 LSSICE 34/2002 [Spanish Law on Information Society Services and Electronic Commerce]) based on our legitimate interest. If you do not want us to send you this type of information and you want us to stop processing your data for this purpose, please send us an email to that effect to sobreno@sobreno.com. Your data will remain protected for the establishment, exercise or defence of legal claims. The withdrawal of your consent for sending this type of communication does not restrict the processing of your data for the remaining purposes described in the privacy policy.
In the event a prior contractual relationship does not exist, according to recital 47 of the European General Data Protection Regulation, our legitimate interest to send you information on our activities, products and/or services (by traditional or electronic means) may constitute a legal basis for processing, provided that your interests or fundamental rights and freedoms are not overriding, taking into consideration your reasonable expectations that we may send you this type of information because of the time at which and the context in which you provided us with your personal data. For example, if you gave us a contact card at a fair or commercial visit, you sent us an email, you contacted us requesting information, you carried out an application on our website, you subscribed to our Newsletter or you gave us your details during a visit to the warehouse. Nevertheless, your interests and fundamental rights will always override our legitimate interest if, at the time you provide us with your data, you do not reasonably expect, or do not want us to send you this type of informative or commercial communication. Therefore this communication (if sent via email) will include the option to unsubscribe in order to stop receiving them. If you select this option we will stop sending you this type of communication from then on. You will also be able to request that we stop processing your data for that purpose by sending us an email to the address indicated in the previous paragraph.
7.- Which recipients can we send your personal data to?
We inform you that the data you provide us with may be communicated to other entities in order to comply with purposes directly related the legal duties of assignor and assignee, such as:
1. To the shipping companies in charge of the logistics of the shipment and delivery of our wines.
2. To banks for the management of charges and payments.
3. To entities and organisations we are legally obliged to communicate data to (Tax administration...).
4. Your data may be communicated between SOBREÑO, S.A. / ALTOS DE RIOJA VITICULTORES AND BODEGUEROS, S.L. in order to carry out intragroup administrative and commercial management.
International Transfers of Data
We inform you that we may make international transfers of data in the event of, for example, the shipment of merchandise to clients, payments to providers outside the European Economic Area, or in the event we work with American providers who may have access to personal data for the purpose of offering support services for our activity (accommodation, housing, software as a service, remote backups, IT support or maintenance, email operators, the sending of emails and email marketing, etc.). These companies may be different and vary over time. However, whatever the case, we will choose companies which have signed up to the Privacy Shield agreement between the USA and the EU, or which belong to countries that have been declared countries with an adequate level of protection, meaning they are obliged to comply with the equivalent requirements to European countries in terms of data protection.
In any case, by accepting this data protection policy you explicitly authorise data to be communicated to these companies, knowing this involves an international transfer of data to a country which does not belong to the European Economic Area and you give your explicit consent for this transfer.
8.- What are your rights when you provide us with your personal data?
Right to access: You can ask us which personal data we are processing and even request a copy of it.
Right to rectification: You can request the rectification of incorrect personal data or that we complete data which is incomplete, including through an additional declaration.
Right to erasure (to be forgotten): You can request we erase your personal data when: it is not necessary for the purposes it was taken for, you withdraw your consent, an illicit processing of the data has been detected or due to compliance with a legal obligation.
Right to restriction of processing: You can request we restrict the processing of your data, in which case we will only store it for the exercise or defence of legal claims.
Right to data portability: You can request we return (to you or a third party you indicate to us) your personal data in structured, commonly used and machine-readable format.
Right to object: You can object to the processing of your data if this processing is based on the legitimate interest of the file controller or it is for advertising purposes.
In order to exercise all these rights you can send us a written and signed request to the postal or email address indicated in section 2 of this privacy policy, attaching a copy of your DNI (Spanish Identification Document). In the event your personal data has changed you must notify us at the same address. The company denies all responsibility if you fail to do so.
Once any of the previous requests are received we will reply to you within the legal period.
You can file a complaint with the Spanish Data Protection Agency. For more information on the rights you can exercise and to request sample forms for the exercise of rights you can visit the Spanish Data Protection Agency’s website www.aepd.es
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