TASTE S.r.l. is a company incorporated and operating under Italian law with registered office in Milan, Piazza della Repubblica 32, (“VINHOOD”), owner of the website www.vinhood.com, mobile applications or solutions that you will find on the VINHOOD website or at third parties (“VINHOOD Platform”).
YOUR PRIVACY IS IMPORTANT TO US
We are aware of the trust you place in us using our services and providing us with your data. We take the responsibility and duty to safeguard your data very seriously.
We ensure you that your data, as well as the methods chosen by you for managing how these are used, are constantly monitored.
This policy allows you to better understand which data and information we collect, why we collect them, and how to update, manage, export, and erase the data and information you have provided us.
To allow you to better understand the purpose and the way we process your data, we will start by telling you about us, and the scopes of “VINHOOD”, an innovative organization in the World of taste.
“VINHOOD” helps you have fun while enhancing your relationship with the World of taste. How do we do this? We make a range of tools and customized experiences available to you on our Platform, such as tests, games and other content (“Services”) which, based on a number of features, such as, type of product, the #character of your Taste profile, behavior, your degree of product knowledge, and your interests are used to help you explore and interact with the Taste World in an enjoyable, knowledgeable and customized way and, above all, within everybody’s reach. We help you create your Taste passport that you will find useful each time you interact with the Taste World. Therefore, you may use your Taste passport each time you need to, both on websites and on third-party VINHOOD partner platforms.
- You may take different types of tests, based on scientific algorithms, for identifying your Taste profile on various product categories, as a starting point leading to new experiences, we will offer you in the Taste World.
- We identify the #characters of your Taste profile to create your “taste passport” and to provide you with suggestions and Services in line with your profile.
- You may use various channels (apps, websites, widgets, and kiosks, etc.) to enrich your innovative and customized experience.
- We will provide you with exclusive content and you may take part in customized events that we will suggest to you based on the #character of your Taste profile, the level of knowledge you have about products, and your behavior and interests.
- You may suggest content to us linked to the Taste World and tell us what you think about our products or our Services.
As a VINHOOD user, you are entitled to manage your privacy and configure your privacy settings for monitoring which information we collect about you and how we use such information, and, as a result, you may use our Services adopting various modes.
Based on your privacy settings, you may, for example:
- Take our taste tests, discover your taste #character and sign up on the “VINHOOD Platform”, creating a profile linked to your #character, and use our Services.
- Choose to visit and browse content on the “VINHOOD Platform”, without signing up (privacy mode) or by using the “incognito” browsing mode from any web browser.
Take our tests using the VINHOOD widget on third-party platforms and get customized recommendations about products and Services without needing to access your account and, therefore, anonymously.
VINHOOD is the data controller responsible for processing your personal data (“Controller”), acting through its pro tempore legal representative, with a business address in Milan, Piazza della Repubblica 32.
In performing its activities, VINHOOD, as “Controller”, processes personal data in compliance with prevailing legislation (Article 13 of Regulation (EU) 2016/679, “Regulation”) and Data Protection legislation applicable to VINHOOD, adopting principles based on fairness, legality, and transparency, protecting your privacy and your rights, in accordance with the criteria shown in this document.
WHICH DATA WE PROCESS ONLY IF YOU PROVIDE THEM TO US ON A VOLUNTARY BASIS
- Data regarding your preferences (for example, food that you like to match with a certain type of wine; fruit or vegetables that you like, etc.):
- When you take a test on our Platform (taste test, test for experts, or matching with other products) and obtain a #character corresponding to your Taste profile, as a result, we collect your answers.
- To get a better idea of your tastes, we will ask you from time to time for some additional information in the context of our projects and events. We may, for example, ask you if you are a beginner or expert on a specific product, for comments and feedback on our tests, products, and events, and whether you are interested in other products. These data are used for providing you with an experience that is constantly enhanced, and for ensuring your enjoyment.
- Personal and contact details for creating your Taste profile, for allowing you to become part of the VINHOOD world and for using our tools and Services: When you have finished a test, we will send you the result via e-mail, if you ask us to do this in the special section of the Platform. It is the start of creating your Taste profile. The standard data you provide us for creating this profile are: name, last name, and e-mail. You may also create your profile using social media networks. Based on the consents you have given to the social media networks you are using, this provides us the option of gaining access to additional personal data compared to those required on signing up on the Platform.
- Personal and contact details in the “Contacts” section: for responding to a contact request sent to us via the Contact Us section, we collect and process the following data that you give us: name, last name, e-mail and any data and information that you have provided in the “message” section.
- Personal and contact details for sending promotional messages regarding our Services: When you voluntarily sign up to receive our newsletter or give your consent to receiving marketing and promotional messages from VINHOOD regarding our Services, for the sole purpose of sending you such messages by e-mail or postal mail, we collect and process the following data that you give us: name, last name, and e-mail.
DATA WE COLLECT AUTOMATICALLY WHEN YOU USE OUR SERVICES
We use so-called cookies for collecting some data:
- Data collected when you use our Services: When you access VINHOOD Services from our Platform, from our app, from the VINHOOD widget on other platforms, from our newsletters, both via one of your devices and via a kiosk that contacts our servers, we collect information and data that help us to improve the features and customize our Services (for example, for updating our algorithms and creating even more customized and innovative content). The information we collect includes unique identifiers, type of browser and settings, type of device and settings, and operating system. We also collect information about interaction with the VINHOOD Platform, app, kiosk, and widget placed on other browsers and devices featuring our Services, including IP address, outage reports, system activities, and date, time and URL regarding your request.
- Data regarding your activities collected when you use our Services: When you use our Services, we collect information regarding your activities on the Platform for improving our Services and for customizing them to better suit your interests and your needs. For example, for recommending articles you may like or for improving our solution interfaces. The information regarding your activities may include the number of tests, the answers to test questions, the type of activities undertaken and your purchases, and the activities on third-party websites and apps using our Services.
- Browsing data: We collect some personal information and data whose transmission is implicit in the use of Internet communication protocols.
- Without your consent, we collect such information in an anonymous form.These data are used for the sole purpose of obtaining anonymous, statistical information on Platform use and for monitoring its proper working, and they are erased immediately after processing. Data may be used for establishing liability in the event of cases of cybercrime against the Platform.We collect and process, for example, IP addresses or domain names that you use for connecting to the Platform, URIs (Uniform Resource Identifier) for requested resources, the time of the request, the method used to send the request to the server, the size of the response file, the numeric code showing the status of the response given by the server (successful and error, etc.) and other parameters regarding the operating system and your computer environment.
- With your consent, we collect the actions you perform on the VINHOOD Platform (VINHOOD Platform and third-part websites where we are present) for providing you VINHOOD Services and customized experiences for the VINHOOD service for which you signed up.
- Data provided and shared on VINHOOD social network pages: We collect and process personal data directly provided by you and shared on social network pages belonging to VINHOOD (Facebook and Instagram, etc.) and for whose management you should refer to the third parties providing such services. We collect and process, for example, for the sole purpose of improving our communication on social media and for giving you a customized experience, the following data: likes, comments, images, and, in general, all content and information that may be posted within such a context.
DATA WE DO NOT PROCESS
- Special category data: We will never ask for, and we never process your data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, and biometric data for the purpose of uniquely identifying a natural person, as well as data regarding the state of health, sex life, and sexual orientation.
- Children’s data: our Services, including the Platform, are not intended for children, and VINHOOD, therefore, does not intend to collect children’s personal data.
WHAT DO WE USE YOUR DATA FOR
We collect your data for the following purposes:
- For creating your personal profile on our Platform: We use your data so that you can create your personalized profile on our Platform and use our Services directly or via using an already existing social media account. The legal basis for processing is set out in article 6(1)(a) of the Regulation, for performing pre-contracted measures to which the data subject is a party.
- For managing your contact requests: Your personal data will be processed for managing the requests you send us. The legal basis for such processing is set out in article 6(1)(a) of the Regulation, the performance of pre-contracting measures to which the data subject is a party.
- For sending you marketing/promotional messages and invitations to our events/workshops: Your personal data are used, whenever you have given your express consent, for sending you invitations and for telling you about our events, for sending you promotional messages about our activities (including new studies and surveys, etc.) for recommending products with affinity to your #character and for sending you market research and statistical studies. The legal basis for processing is set out in article 6(a) of the Regulation, that is, the data subject’s consent. You may revoke your consent at any time.
WHEN DO WE TRANSFER DATA TO OTHERS
Disclosure of data to third-party partners: We may disclose data you have provided to third parties, individuals or companies that work with VINHOOD for business and marketing purposes only if you have given your express consent to the transfer to a specific VINHOOD partner. The legal basis for processing is set out in article 6(f) of the Regulation, that is, the data subject’s consent.
YOU DECIDE WHETHER TO PROVIDE US WITH YOUR PERSONAL DATA
Giving your Personal Data for using the Services, for creating a personal profile, for managing contact requests, for sending marketing/promotional messages, for telling you about our events/workshops, to be disclosed to third-party partners is always optional. However, you should be aware that failure to give your data may adversely affect the chance to use some Services, for example, you may not create a personal profile.
You may revoke your consent to the sending of marketing/promotional messages at any time and without providing any reason. The simplest way to do this is to click on the “Unsubscribe” link that you will find in each newsletter or message you receive. Or, alternatively, you may send a message to the address: email@example.com.
WHAT IS THE METHOD USED FOR PROCESSING YOUR DATA
Processing of your information is performed both using hard copy supports and data transmission technology, with the aid of modern IT systems and using manual methods, only by authorized persons who have been expressly appointed for this task.
Processing will be performed by adopting rationales and organizational forms that are strictly linked to the obligations and tasks or other purposes that we have explained in detail in the preceding points.
We use precise technical and organizational measures for protecting your data from any tampering, loss, and destruction and for preventing unauthorized access. Security measures are constantly monitored and improved, also based on advancements in technology.
WITH WHOM AND IN WHICH CONTEXTS DO WE SHARE YOUR DATA
Your personal data will be processed by parties which have been duly appointed processors or processing agents, authorized to perform such tasks and which have adopted security measures specifically for ensuring your privacy and for preventing unlawful access by third parties or unauthorized personnel.
Your personal data, whenever provided, and always with your consent, as well as the limits strictly linked to the obligations, the tasks and the purposes outlined above, may be shared with companies, organizations or individuals outside VINHOOD.
Your personal data may be shared with Competent Authorities for the purposes of preventing, investigating, or repressing crimes, in compliance with legal provisions governing such matters.
The updated list of all Processors is available at the VINHOOD offices and may be requested at the following e-mail address: firstname.lastname@example.org. This list may be supplemented and/or updated as required.
FOR HOW LONG DO WE PROCESS AND RETAIN YOUR DATA
We warrant to erase from our systems:
- Your data provided in relation to requests forwarded via our Platform and our Services after 1 (one) year from the time such data were provided.
- Your personal data provided for signing up on the Platform and for using the relevant Services, after 10 (ten) years from the time the registration was deleted.
- Your personal data processed for the purpose of sending information of a business and marketing nature, as well as for taking part in surveys and market research, including personalized studies, based on your profiling, after 5 (five) years from the time of collection, or up to the time of any objection which you may send expressly at any time.
In any event, we warrant to base data processing on principles of adequacy and minimization (we only process data which we really need for meeting the processing purposes previously explained) and we will check the need annually for retaining data for a period longer than required for satisfying the purposes for which data were collected and processed.
We may retain your data for the purposes of legal compliance or for ascertaining, exercising or defending a right in court.
Once the purposes have been satisfied for which your personal data were collected and processed, we will take suitable measures to render them anonymous to prevent identification of the data subject, however, without prejudice to the option of using personal data in an anonymous form.
WE USE AUTOMATED DECISION-MAKING PROCESSES
As previously explained, we profile our users for the purpose of providing you with a customized service.
Profiling is based on parameters, such as taste #characters, knowledge of products, the actions taken on our Platform, and your business category.
Taste profiling is done using our algorithms that use predictive skills for identifying, for example, your #character in relation to a certain product category (e.g. wine, coffee, beer, and bitter liqueurs, etc.) and for providing you with tips in line with your preferences about a certain product.
Following such analyses, you may use the Platform Services customized for you, and receive personalized messages from us that we think are in line with your tastes and preferences (e.g. #character).
We have successfully conducted a balancing test for the purpose of determining that processing linked to your categorization is conducted legally based on VINHOOD’s legitimate interest in obtaining maximum efficiency in creating a single “taste passport” and in marketing activities.
TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES
All processing of your data is performed in Italy and in European Union Member States.
Whenever a need may arise to transfer your data to Third Countries, we warrant to:
- Ensure that the State to which Data provided by you will be sent guarantees an adequate level of protection, as provided under article 45 of the Regulation;
- Monitor and make transfers only in the case that we, or the Processor, can provide appropriate safeguards for enforcing your rights and effective legal remedies (in accordance with article of the Regulation).
YOUR RIGHTS: YOU MAY FIND OUT ABOUT AND MANAGE YOUR DATA AT ANY TIME
You are entitled to know about your rights that basically consist of receiving information from VINHOOD on how your personal data are processed, as well as having access to your data and requesting rectification, supplementation, updating, erasure or blocking. In addition, you are entitled to obtain a copy of the data you have provided, to restrict their processing and/or also object to their processing. You are entitled to data portability and to lodge a complaint with the competent supervisory authority under the terms, conditions, and limits shown under article 13 of the Regulation).
You are guaranteed the following rights under article 15 et seq. of the Regulation:
- Right to information
- Right to access the Data Subject
- Right to rectification
- Right to erasure (Right to be forgotten)
- Right to restriction of processing
- Right to data portability
- Right to object
You may ask which personal data are held by VINHOOD, their source and how they are used, request their updating, rectification or supplementation, as well as, in cases provided under legislative provisions in force, their erasure, restriction or object to their processing.
You may, if you like, ask to receive a copy of your personal data held by us that concern you in a format that can be read by electronic devices and, where technically feasible, we will transfer data directly to a third party specified by you.
If you feel that the processing of your personal data has been performed unlawfully, you may lodge a complaint with one of the supervisory authorities responsible for monitoring data protection compliance. In Italy, a complaint may be lodged with the Garante per la Protezione dei Dati Personali (Italian Data Protection Authority) (http://www.garanteprivacy.it/).
HOW YOU CAN EXERCISE YOUR RIGHTS
To exercise the above-mentioned rights, you may send a message to the e-mail address: email@example.com, showing in the message header the wording “Privacy – exercising rights”.
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- What are cookies and what cookie categories we use
Cookies are small text strings that the Platform you visit sends to your computer, smartphone tablet, etc., where they are stored and then resent to the Platform on your next visit.
Cookies used on this Platform may be identified using the following guidelines:
a) Based on who manages the cookies:
(i) Proprietary or first-party cookies: these are cookies directly installed by Us via the Platform.
(ii) Third-party cookies: these are installed via the Platform by other third parties.
b) Based on the time they persist and remain active:
(i) Session cookies: these cookies store the information required during a browsing session and they are deleted immediately after the session is closed, or after the browser is closed.
(ii) Persistent cookies: these cookies are stored on your hard drive and the Platform reads them each time you visit the website. A persistent cookie has a fixed expiry date, after which it will stop working.
c) Based of the purposes:
Several cookies are needed for allowing a user to browse the Platform and use its features (so-called technical cookies). Others are used to obtain statistical information, in aggregate/non-aggregate form, on the number of users that access the Platform and how the Platform is used (so-called cookie analytics). Finally, others are used to trace your profile, so that advertising may be displayed on the Platform that matches your interests, in that it is consistent with your tastes and your consumer habits (so-called profiling cookies).
Technical cookies, cookie analytics and profiling cookies are used on the Platform.
By changing the settings on the browser you use, you can decide at any time to block cookie installation, in whole or in part. The configuration of each browser is different and is described in the browser “Guide” menu. If you want to learn about cookie settings, you can consult the instructions provided by the most common browsers:
- Cookies used by VINHOOD
Technical cookies are those that Vinhood uses only for allowing you to visit the Platform and to use it. These may further break down into:
(i) Web cookies: these guarantee normal browsing and enjoyment of the Platform, allowing you, for example, to make a purchase or sign-in for accessing private areas. These are normally session cookies that are automatically deleted when you close the web browser.
(ii) Functionality cookies: allow you to browse, based on a series of selected features (for example, language or country of origin) for enhancing the service provided on the Platform. These are persistent cookies that are stored on the computer you use also after closing the web browser, until the expiry date set for each cookie (normally from two months to two years) is reached or until you decide to remove them.
Technical cookies are not used for purposes other than those described above.
The following technical cookies are currently used on the Platform:
You can disable proprietary and third-party technical cookies by changing your browser settings. However, you should be aware that by removing or blocking these cookies, several of the websites you visit (or the relevant features) may not work properly or efficiently.
The cookie analytics on this Platform are directly installed by Us, but also by third parties and they are used on the Platform for collecting statistical information, in aggregate and non-aggregate form, on the number of users accessing the Platform and on how they visit the Platform.
The following third-party cookie analytics are installed on the Platform without your prior consent, because in they are less invasive, in that they and anonymized, preventing third parties from accessing unbundled analytics at IP address level (in other words, when using these cookies, third parties cannot cross-check data for tracing a user’s identity) and the third parties cannot cross-check data obtained using cookies with other data they already hold:
Third-party Cookie Analytics
|Google Analytics||The service allows Us to understand how you interact with the Platform. This service, with no active advertising features and by hiding your IP address, uses a set of cookies for collecting information and generating statistics on Platform use.|
You are free to block the installation of cookie analytics at any time, using the following link: Cookie settings; however, the option of visiting the Platform and enjoying its content will be compromised. For further details, carefully read third-party cookie policies, following the link shown in the above table.
Profiling cookies are used to create your profile based on your preferences and interests, as you reveal them during web browsing, so that we can display customized content to you. As provided under data protection legislation in force, your prior consent is required to install these cookies. For this reason, when you access the Platform, a banner will be displayed telling you that: (i) profiling cookies are used on the Platform and that (ii) you can consent to the installation of cookies by clicking on the relevant button inside the banner. Whenever you give your consent to installation of cookies using this method, we will track consent via a technical cookie for this purpose. In this way, the banner with the cookie notice will not appear again on your subsequent visits to the Platform.
You are free to block the installation of profiling at any time, however, the option of visiting the Platform and enjoying its content will be compromised; use the following link to block installation: Cookie settings. However, if you choose to disable these cookies, this does not mean that you will see no more ads on the Platform, only that the banners you display may not match your interests or preferences.
All profiling cookies are installed by third parties, acting as independent controllers (third-party cookies). Here is a list of all third-party profiling cookies currently used on the Platform, showing the link to the information pages created by their developers:
Third-party profiling cookies
Though these data, it is possible to monitor the performance of advertising campaigns and calculate conversion rates.
In addition, these data allow statistical data to be provided on people that use Facebook products, on people that interact with ads, advertiser websites and apps, and on companies that use Facebook products.
The Platform also features “social buttons“, i.e. plugins for interacting with social networks and that allow you to share your information and content with social networks, to identify users and store information about the use of the Platform on their profiles. You can review the information regarding social media data management, using the social buttons which will take you to the following links:
- Amendments and Updates