Data Protection and Privacy Policy

Definitions

"Personal data"

«Personal data», information relating to an identified or identifiable natural person («data subject»); An identifiable person is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier. Personal identifiers are considered, for example, a name, an identification number, location data, electronic identifiers or one or more specific elements of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

«Processing of Personal Data»

"Processing" means an operation or a set of operations carried out on personal data or on sets of personal data, by automated or non-automated means, such as collection, recording, organization, structuring, conservation, adaptation or alteration , retrieval, consultation, use, disclosure by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, erasure or destruction.

"Cookies"

«Cookies» are small text files with information considered relevant that the devices used for access (computers, mobile phones or portable mobile devices) load, through the internet browser (browser), when a website is visited online by the Customer or User.

Entity responsible for the treatment

Ribafreixo Wines, Lda, headquartered at Adega do Moinho Branco, registered at the Commercial Registry Office of Vidigueira, under the registration and legal person number 508191181, is the entity responsible for the online sites «www.ribafreixo.com» and corresponding sub -sites, as well as computerized applications, hereinafter referred to as channels or applications, through which Users, Candidates or Clients have remote access to the services and products of Ribafreixo Wines, Lda that are presented, marketed or provided, at any time, through of the same. The use of the channels or applications by any User, Candidate or Client may imply the carrying out of personal data processing operations, whose protection, privacy and security by Ribafreixo Wines, Lda as the entity responsible for the respective treatment, is ensured, in accordance with the terms of this Data Protection and Privacy Policy.

Responsible for Data Processing – Contact

For the purposes of contacting the Data Protection Officer of Ribafreixo Wines, Lda, please send an email to marketing@ribafreixo.com describing the subject of the request and indicating an email address, a telephone contact address or an email address. correspondence.

For any other purpose, the following general contacts of Ribafreixo Wines, Lda may be used:

Postal Address: Adega Moinho Branco 7960-212 Vidigueira

Tel: 284 436 240

Collection and processing of Personal Data

Ribafreixo Wines, Lda processes the personal data strictly necessary for the provision of information and its operation, according to the uses made by Users, Candidates or Clients, whether those provided by Users or Candidates for the purpose of registering orders or obtaining information, whether those provided by Customers for the purpose of joining, or those resulting from the use of services provided by Ribafreixo Wines, Lda through them, such as access, queries, instructions, transactions and other records relating to its use.

In particular, the use or activation of certain functionalities of the channels may imply the treatment of various direct or indirect personal identifiers, such as name, home address, contacts, device addresses or geographic location, whenever there is for this purpose the express consent of the User, Candidate or Client.

In all cases, Users, Candidates or Clients will always be informed of the need to access such data in order to use the functionalities of the channels in question.

The personal data collected by Ribafreixo Wines, Lda are processed, in certain cases, in a computerized and/or automated way, including the processing of files or the definition of profiles and within the scope of the management of the pre-contractual, contractual or post-contractual relationship with the Users, Candidates or Clients, in accordance with current national and community regulations.

Legal Principles

All data processing operations comply with fundamental legal principles in the field of data protection and privacy, namely regarding their circulation, lawfulness, loyalty, transparency, purpose, minimization, conservation, accuracy, integrity and confidentiality, with Ribafreixo Wines , Lda available to demonstrate its responsibility towards the data subject or any other third party that has a legitimate interest in this matter.

Fundamentals of Legitimacy

All data processing operations carried out by Ribafreixo Wines, Lda have a foundation of legitimacy, namely, either because the data subject has given his consent for the processing of his personal data for one or more specific purposes, or by the the fact that the processing is considered necessary for the performance of a contract to which the data subject is a party, or for pre-contractual measures at the request of the data subject, or because the processing is necessary for the fulfillment of a legal obligation to which the controller is subject, either because the processing is necessary for the legitimate interests pursued by Ribafreixo Wines, Lda or by third parties.

Purpose of Treatment

All personal data processed within the scope of Ribafreixo Wines, Lda are exclusively intended for the provision of information to Users, the management of Candidates' personal information considered necessary for selection, recruitment or training purposes, as well as the provision of services contracted by Customers and, in general, managing the pre-contractual, contractual or post-contractual relationship with Users or Customers.

The personal data collected may, even eventually, be subject to processing for statistical purposes, for information dissemination or promotional actions and for commercial or marketing actions, namely to promote actions to disseminate new functionalities or new products and services, through direct communication, whether by correspondence, email, messages or telephone calls or any other electronic communications service.

Prior information and the collection of express authorization for the latter purposes being always ensured, Users or Customers may, at any time, exercise their right to oppose the use of their personal data for other purposes that go beyond the management of the contractual relationship, namely for marketing purposes, for sending informative communications or for inclusion in lists or informative services, and for this purpose, a written request must be sent, in accordance with the procedures indicated below.

Data Conservation

Personal data will only be kept for the period necessary for the purposes that led to its collection or further processing, ensuring compliance with all applicable legal rules on archiving.

Use of Cookies

Ribafreixo Wines, Lda may eventually use two major categories of «cookies»: «cookies» within the scope of online sites and «cookies» within the scope of direct electronic communication channels, always guaranteeing, in any of the categories, the respective deactivation by Users or Customers.

Ribafreixo Wines, Lda uses "cookies" on its online sites in order to improve the performance and browsing experience of Users and Customers, increasing, on the one hand, the speed and efficiency of response and, on the other hand, eliminating the need to repeatedly enter the same information.

The use of "cookies" helps online sites to recognize Users' and Customers' devices the next time they visit them, and is also, in some cases, essential for their operation.

The "cookies" used by Ribafreixo Wines, Lda in all its channels, do not collect personal information that allows identifying Users or Customers, saving only generic information, namely the form or geographic location of access and the way in which they use the channels, between others. The "cookies" only retain information related to the preferences of Users and Customers, personal identifiers are not registered.

Users, Candidates and Clients may, at any time, through the computer application they use to browse the internet ("browser"), decide to be notified about the receipt of "cookies", as well as to block the respective entry in the your system.

Regarding the type of intended purposes, Ribafreixo Wines, Lda may, eventually, whenever justified, use three different types of «cookies», according to the following specifications: (i) essential «cookies» – some «cookies» are essential to access specific areas of the online channels, allowing navigation and the use of their applications, such as access to secure areas of the websites, through user registration – without these «cookies», the services that require it will not can be provided; (ii) functionality "cookies" - functionality "cookies" allow remembering the user's preferences regarding navigation on online sites, thus not needing to reconfigure and personalize each time he/she visits; (iii) analytical «cookies» – these «cookies» are used to analyze how users use online sites, allowing to highlight articles or services that may be of interest to users, monitoring the performance of sites, as well as knowing which the most popular pages, which method of linking pages is most effective or to determine why some pages are receiving error messages - these "cookies" are used only for the purposes of creation and statistical analysis, without ever collecting information of a personal nature.

For these purposes, Ribafreixo Wines, Lda can provide a high quality experience to Users or Customers, customizing information and offers and identifying or correcting any problems that may arise within the scope of their use.

Regarding the type of validity, there are two types of «cookies»: (i) permanent «cookies» – these are «cookies» that are stored on the devices used to access the channels (computers, mobile phones, etc.), at the application level computer used to browse the internet ("browser"), being used whenever Users or Customers visit any channel again - in general, they are used to direct navigation according to the interests of the User or Customer, allowing Ribafreixo Wines to , Lda provide a more personalized service; (ii) session "cookies" - these are temporary "cookies", which are generated and are only available until the session is closed, since the next time the Customer/User accesses their internet browser ("browser") the «cookies» will no longer be stored – the information obtained allows you to manage sessions, identify problems and provide a better browsing experience.

Users and Customers may deactivate part or all of the «cookies» at any time – they must, to this end, follow the instructions available in each of the computer applications used to browse the internet ("browser"), however, with deactivation, losing access to some functionalities of the sites.

Ribafreixo Wines, Lda, within the scope of direct electronic communication channels, may also use "cookies" when opening different electronic communications sent, such as "newsletters" and email, for statistical purposes - allowing you to know whether these communications are open and verify clicks through links or advertisements within those communications.

Also in this category of "cookies", Users and Customers always have the possibility of deactivating the sending of electronic communications through the specific option at the bottom of the same.

Communication of Data to third parties

The availability of information or the provision of services by Ribafreixo Wines, Lda to its Users or Customers through the channels may eventually imply the use of services from third-party subcontracted entities, including entities based outside the European Union, for the provision of certain services, this may imply access, by these entities, to personal data of Users or Customers.

In these circumstances and whenever necessary, Ribafreixo Wines, Lda will only resort to subcontracted entities that provide sufficient guarantees for the execution of appropriate technical and organizational measures in a way that the treatment meets the requirements of the applicable standards, such guarantees being formalized in a contract signed between Ribafreixo Wines, Lda and each of these third parties.

Data Recipients

Except in the context of compliance with legal obligations, under no circumstances will personal data of Users, Candidates or Clients be communicated to third parties that are not subcontracted entities or legitimate recipients within the scope of management consulting and human resources management consulting processes , and no other communication is made for purposes other than those mentioned above.

International Data Transfers

Any transfer of personal data to a third country or an international organization will only be carried out within the framework of compliance with legal obligations or ensured compliance with applicable community and national legal rules in this matter.

Security measures

Taking into account the most advanced techniques, application costs and the nature, scope, context and purposes of the treatment, as well as the risks, of varying probability and severity, for Users or Customers, Ribafreixo Wines, Lda and all entities that are its subcontractors apply the appropriate technical and organizational measures to ensure a level of security appropriate to the risk.

For this purpose, various security measures are adopted in order to protect personal data against its dissemination, loss, misuse, alteration, treatment or unauthorized access, as well as against any other form of illicit treatment.

It is the sole responsibility of the Users, Candidates or Clients to keep the access codes secret, not sharing them with third parties, and, in the particular case of the computer applications used to access the channels, to maintain and conserve the access devices in conditions of security and follow the security practices advised by the manufacturers and/or operators, namely regarding the installation and updating of the necessary security applications, namely, among others, antivirus applications.

If there is a need to subcontract services to third parties that may have access to the personal data of Users or Customers, subcontractors of Ribafreixo Wines, Lda will be obliged to adopt security measures and protocols at the level of the organization and security measures. technical nature necessary to protect the confidentiality and security of personal data, as well as to prevent unauthorized access, loss or destruction of personal data.

Exercise of the Rights of the Subjects of Personal Data

Users and Clients of Ribafreixo Wines, Lda may, as holders of personal data, at any time, exercise their data protection and privacy rights, namely the rights of access, rectification, deletion, portability, limitation or opposition to the treatment, under the terms and with the limitations provided for in the applicable rules. Any request to exercise data protection and privacy rights must be addressed, in writing, by the respective holder, to the Data Protection Officer, in accordance with the procedure and contact details described below.

Complaints or Suggestions and Reporting of Incidents

Users and Customers of Ribafreixo Wines, Lda have the right to file a complaint, by submitting a complaint to the regulatory authorities. Users and Clients of Ribafreixo Wines, Lda may also make suggestions via email sent to the Data Protection Officer.

Incident Reporting

Ribafreixo Wines, Lda has implemented an incident management system within the scope of data protection, privacy and information security.

If any User or Customer notices the occurrence of any situation of violation of personal data, which causes, accidentally or unlawfully, the destruction, loss, alteration, disclosure or unauthorized access to personal data transmitted, preserved or subject to any other type of treatment, you must immediately contact the Data Protection Officer or use the general contacts of Ribafreixo Wines, Lda described.

Change of Privacy Policy

In order to guarantee the respective update, development and continuous improvement, Ribafreixo Wines, Lda may, at any time, make changes, which are considered appropriate or necessary, to this Data Protection and Privacy Policy, ensuring its publication in the different channels to guarantee the respective transparency and information to Users and Customers.

Express Consent and Acceptance

The terms of the Data Protection and Privacy Policy are complementary to the terms and provisions, in terms of personal data, provided for in the General Conditions of Use of the channels of Ribafreixo Wines, Lda. The free, specific and informed availability of personal data by the respective holder implies knowledge and acceptance of the conditions contained in this Policy, considering that, by using the channels or by making their personal data available, Users, Candidates and Customers are expressly authorizing their treatment, in accordance with the rules defined in each of the applicable collection channels or instruments.

Data Protection Officer

For the exercise of any type of data protection and privacy rights or for any matter relating to data protection, privacy and information security, Users, Candidates and Clients of Ribafreixo Wines, Lda may contact the Data Protection Officer via email marketing@ribafreixo.com describing the subject of the request and indicating an email address, a telephone contact address or a mailing address for reply.