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 other solutions that you will find on the VINHOOD website or at third parties. This privacy information refers to the processing of your data when using the VINHOOD site or app (hereinafter “VINHOOD Platform”).
YOUR PRIVACY IS IMPORTANT TO US
We are aware that by using our services and entrusting us with your data you are placing your trust in us. The responsibility and duty to protect your data is our top priority.
We ensure you that your data, as well as the methods chosen by you for managing how your data 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 world of taste in an enjoyable, knowledgeable and customized way and, above all, within everybody’s reach. We help you create your Taste profile passport that you will find useful each time you interact with the world of taste. Therefore, you may use your Taste profile each time you need to, both on websites and on third-party VINHOOD partner platforms.
- You may take different types of tests, based on algorithms studied together with professionals, for identifying your Taste profile on various product categories, as a starting point leading to new experiences we offer you in the world of taste.
- We identify the #characters of your Taste profile to create your “taste passport” and to provide you with suggestions and services matching your profile.
- You may use our website vinhood.com to develop and 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 world of taste 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. Creating a profile linked to your #character allows us to recognize you and suggest you from time to time the services and produces suitable for you and your #character, depending on your environment and the experience you have chosen (e.g., test)
- 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.
VINHOOD is the data controller responsible for processing your personal data (“Controller”), acting through its pro tempore legal representative, with business address in Milan, Piazza della Repubblica 32.
In performing its activities, VINHOOD, as “Controller”, processes personal data in compliance with prevailing legislative provisions (Article 13 of Regulation (EU) 2016/679, “Regulation”) and Data Protection legislation applicable, adopting principles based on fairness, legality and transparency, protecting your privacy and your rights, in accordance with the principles 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 produce; fruit or vegetables that you like, etc.):
- When you take a test on our Platform (taste, for experts or matching with other products) and obtain a #character corresponding to your taste profile, as the result, we collect your answers.
- To find out more about your tastes, we may occasionally ask you for additional information as part of our initiatives. For example, we might ask you if you are a beginner or an expert on a specific product, ask for your comments and feedback on our tests, products and events, or ask if 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.
If you purchase a ticket to participate in one of our in-person or virtual events:
- Personal data, residence data, contact details and data related to any food intolerances / preferences you might have: when you buy a ticket for one of our events or experiences. These data are required for you to participate in the event; payment details are not processed by us, but by third party suppliers we use to complete ticket transactions.
- User image and voice recordings collected from an event: data will be collected during recording. Data that will be processed include: image and voice.
DATA WE COLLECT AUTOMATICALLY WHEN YOU USE OUR SERVICES
- 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 this context.
DATA THAT 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 sex life and sexual orientation. However, you may want to state any food intolerances when purchasing a ticket for one of our events or experiences. If this is the case, we will process your data to ensure the best experience for you at the event and will only store the data for the duration of the same and only with your explicit consent.
- 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)(b) of the Regulation, for performing pre-contractual 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)(b) of the Regulation, performance of precontractual 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 lawfulness 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.
If you purchase a ticket to participate in one of our in-person or virtual events:
- Booking and purchasing an event: your personal data will be processed to: allow you to book and purchase a ticket for our in-person or virtual experiences. The lawfulness for such processing is set out in article 6 (1)(b) of the Regulation, in that processing is necessary for performing pre-contractual and contractual measures, to which the data subject is a party.
The processing of your special category data regarding food intolerances provided at the booking stage is based on your explicit consent within the meaning of article 9 (2)(a) of the Regulation.
- For virtual events: allow you to interact live with questions and retain the recording of the debate in order to create content for internal use by VINHOOD. In order to balance interests, VINHOOD has taken into account the technical relevance of the subjects discussed, as well as the fact that the events are carried out by videoconference so that they are interactive and encourage debate and questions; anyone who participates can legitimately expect these events to be recorded and the content thereof made available at VINHOOD for internal use. This content may be used to create a learning archive so that events can be analyzed for subsequent improvement. The legal basis for processing is, as set out in article 6 (1)(f) of the Regulation, VINHOOD’s legitimate interest in the success and improvement of the events, and the formation of an internal learning archive.
You can at any time disable or ask VINHOOD to disable the option for you to be seen and/or heard in the videoconference during the event. You can also request the deletion of any interactions involving you by emailing VINHOOD at firstname.lastname@example.org. In both cases, the lawfulness of the processing carried out up to that time remains valid.
- Publishing the content recorded during the event: the Controller may record videos and/or take photos during the Event and publish the content, including the data subject’s image and voice, on social media channels (Facebook, Instagram, and LinkedIn) which are in the VINHOOD’s name, in addition to using such data in VINHOOD presentations, both for promotional purposes (Company Profile) and sales (sales offer made to a customer). If recording, VINHOOD will warn the user in advance, as well as during the course of the event. The legal basis for processing is, as set out in article 6 1(f) of the Regulation, a legitimate interest of VINHOOD. In order to balance interests, VINHOOD has taken into account the fact that the events are reserved for users who have purchased a ticket and who have been informed in advance that content will be recorded. Any areas that are to be filmed will be clearly identified. You can object to the processing at any time and request the removal of the published content. During the event, you can contact any of the VINHOOD staff who are present and ask for you not to be filmed.
WHEN WE DISCLOSE 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. Lawfulness for processing is set out in article 6 1(a) 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 and/or purchase event tickets.
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 can be found in each newsletter or message received. Or, alternatively, you may send a message to the address: email@example.com. If you withdraw your consent to receiving sales/promotional mailings, this will not affect the validity of the mailings sent to you up to that time.
WHAT IS THE METHOD USED FOR PROCESSING YOUR DATA
Processing of your data is performed both using hardcopy 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 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. These include third-party payment service providers that we use to allow you to purchase our experiences.
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 other than VINHOOD. If you have given your consent, we will only share your image on platforms that conform to the Regulation, but we still suggest that you read the specific privacy policies for each social network.
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, including the purchase of event tickets, after 10 (ten) years from the time of canceling the relevant registration.
- Your personal data processed for the purpose of sending sales and marketing information, invitations to our events/workshops, for taking part in customer satisfaction surveys and market research, including those that are personalized based on your profiling, and data consisting of your image published on our social networks, as well as the image and voice data recorded during the events and archived for VINHOOD’s internal use, after 5 years from the date of collection (or from the publication of the images on our social networks), or until consent or opposition is withdrawn, which you can explicitly send at any time.
We cannot guarantee that your data, once they have been deleted from our social profiles, will not be available elsewhere online, because someone else may have shared it in the meantime – including you!
In any event, we warrant to base data processing on principles of adequacy and minimization (we only process data which we actually need to meet the processing purposes previously explained),and we willcheck annually the need 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 anonymous form.
WE USE AUTOMATED DECISION-MAKING PROCESSES
As previously explained, we use low-level profiling of our users for the purpose of providing you with a customized service.
Profiling is based on parameters, such as the #characters and taste, knowledge of products and your actions on our Platform and your corporate 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 also receive personalized messages from us that we think are in line with your tastes and preferences (#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 for 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 rise 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 46 of the Regulation).
YOUR RIGHTS: YOU MAY FIND OUT ABOUT AND MANAGE YOUR DATA AT ANY TIME
You are guaranteed the following rights under article 15 et seq. of the Regulation:
- Right to information.
- Right to access of 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.
If you feel that the processing of your personal data has been performed in an unlawful manner, 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 abovementioned 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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