1. Introduction & scope

This Privacy Policy describes how BODEGAS VIRTUS S.L. with registered office at Pago de la Fuentecilla s/n 47.313 Aldeyuso (Valladolid) collects and processes information about you that directly or indirectly identifies you («Personal Data»), either alone or in combination with other available information, through interactions with us (including www. virtuswine.com) or through any other Bodegas Virtus website, application or other service (whether online or offline) that links to, incorporates or provides you with a copy of this Privacy Policy (collectively the «Services»).

Bodegas Virtus is responsible for the processing of your personal data, as it decides why and how it is processed, and therefore acts as the «Data Controller». The Privacy Policy covers how we respect your data protection rights with respect to the processing of your data in connection with the Services and/or for the purposes described in this Privacy Policy.

If you have any questions regarding the processing of your personal data or this Policy, please send your concerns to contact@virtuswine.com.

We may change or update this Privacy Policy in the future by posting a new privacy policy on this website. Please continue to check this Policy regularly to ensure you are aware of any changes.

2. Handling of children’s data

How do we handle information from children under the age of 14?

Our services are not directed at children. We do not knowingly collect any personal data about children under the age of 14 on our website or for the purposes mentioned in this Privacy Policy. If you have provided us with personal data about children in error and would like to request deletion of such personal data, please contact us at contact@virtuswine.com.

3. Types of personal data processed and purposes of processing

What personal data do we process and for what purposes?

We may collect and process personal data that directly identifies you, such as your name, contact details and email address in order to proceed with an order received. We may also collect certain personal data that does not directly identify you, but which makes identification possible through the combination of other information or identifiers, such as your company name, job title or tax identification number. Personal data may also include information such as computer or device serial numbers, IP addresses or information relating to a company («legal entity»). If you submit personal data relating to other individuals either to us or to our service providers in connection with the Services, you represent that you have sufficient authority to do so and to allow us to use the data in accordance with this Privacy Policy.

1. Information you voluntarily provide to us

A.1 User registration

In order to ship your orders to the delivery point determined by you, you must provide your name, email address, login ID, security questions and answers, encrypted passwords, postal address, telephone number.

We process and store the personal data you provide during registration exclusively to enable you to access content specifically relevant to you. The legal basis for processing your personal data may be the fulfilment of obligations under an agreement with you or your consent.

A.2 Contact, customer service or feedback requests

For enquiries via our contact form, you must provide your name, postal address, email address, telephone number, the reason for contact and your message. You may provide your social media profile information, including name, email address, contact details, comments and feedback when you interact with us on social media platforms or use your social media login credentials to authenticate on our website.

We process and store the personal data you provide in the contact request only to process and respond to your request about our products and services and to contact you.

The legal basis for processing your personal data is the fulfilment of our contractual obligations to communicate with you in relation to any relevant concerns by virtue of which you have contacted us.

A.3 Newsletters and/or Newsletter

In the future we may have operational the subscription to our newsletter and/or newsletter service, you must provide your name, e-mail address and/or postal address.

Insofar as you have given us your consent to data processing when registering for the newsletter service, we process and store the personal data you provide when subscribing to the newsletter only to provide the newsletter service in connection with the newsletter service you have subscribed to in order to inform you about events, products, services and/or promotions of Bodegas Virtus.

If you have given your consent by subscribing to the newsletter, we may also analyse your user behaviour when opening the relevant newsletter and process the data collected for the personalisation of future newsletters and other promotional communications.

The legal basis for the processing of your personal data is your consent.

A.4 Orders and services

When ordering products via the website, you must provide your name, e-mail address and postal address and, if applicable, your payment details.

We process and store the personal data you provide when placing an order to provide you with the products and services you have requested and for our business purposes, including improving our products and personalising your experience. The legal basis for processing your personal data is the performance of contractual obligations and our legitimate interests.

1. Information collected automatically

B.1 Website usage analytics

We may also collect and process information about your visit to this website, such as the pages you visit, the website you came from and the searches you perform. We may use such information to help improve the content of the website and compile aggregate statistics about the people who use our website for our internal usage statistics and market research purposes. In doing so, we may set «cookies» or similar technologies that collect the user’s domain name, internet service provider, operating system and the date and time of access. Cookies are created and stored on the user’s computer, phone or other devices when the user’s browser loads a particular web page. Each time the user returns to the same web page, the browser retrieves and sends this «cookie» file back to the web page. Cookies are useful because they serve key purposes, such as helping a website remember your preferences and settings, performing analytics to improve services, providing you with relevant content or advertisements, and authenticating you to websites. Cookies do not harm your computer. You can set your browser to notify you when you receive a cookie, allowing you to decide whether or not to accept it. You can also refuse cookies altogether. However, if you do not accept our cookies, you may not be able to use the full functionality of our website. When you visit our web pages, you may be presented with a cookie settings banner that allows you to manage your settings and accept or decline cookies. You are legally permitted to store cookies on your machine if they are essential to the operation of the website, but for all other types of cookies we need your permission to do so. On the Bodegas Virtus website, you have the option to accept the use of cookies using the Cookie settings banner that appears when you first visit the website or you can manage these settings at any time thereafter. This cookie policy gives you the option to accept or refuse consent for each category of cookies (with the exception of necessary cookies). Please see our website for more information on what types of cookies we use (the purpose for which they are used, their lifetime and where they come from) and how you can manage your preferences.

Some of our Services, including web pages, may use the web analytics service «Google Analytics» from Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA («Google») to optimise them. Google uses the information obtained by the cookie to store a profile of the pages you have visited within a session. The information generated by the cookie about your use of the Services is transmitted to and stored on Google’s servers. To increase the security of your personal data, we use the «IP anonymisation» function or other functions provided by Google to anonymise you. For more information on how IP anonymisation works, click https://support.google.com/analytics/answer/2763052.

Google will use this information on our behalf to evaluate your use of the website, compile reports on website activity for us and provide us with other services relating to website activity and internet usage. Virtus Winery uses the data received from Google Analytics for business planning, for its own business activities and for marketing measures to better understand how to improve the content of our web services and the associated experience.

Some of our web pages also use OneTrust cookies to allow you to manage cookies easily and to help us obtain your consent to our placement and use of cookies on your device. We need these cookies to remember the choices you have made regarding your cookie settings.

The legal basis for processing your personal data when we do website analytics is your consent or our legitimate business interests.

B.2 Other tracking technologies

We may use cookies or other tracking technologies (also known as action tags, single-pixel GIFs, clear GIFs, invisible GIFs and 1-for-1 GIFs) provided by third-party advertising companies to serve you relevant ads (interactive or non-interactive) based on your interests or browsing history. We generally use the services of social media companies and other third party advertising companies to collect information such as your browser details, unique customer ID, etc. so that we can show you advertisements on our websites and on other websites you may use. Please see our «Cookie Settings» to learn more about our marketing or advertising cookies and to manage your preferences.

Our Services, including web pages, may use Google Tag Manager («GTM»), which is a tag management system operated by Google to manage JavaScript and HTML tags used for tracking and analytics on web pages. Tags are small pieces of code that, among other things, are used to measure traffic and visitor behaviour: to understand the effect of online advertising and social channels; to establish remarketing and targeting; and to test and optimise web pages. GTM makes it easy for us to integrate and manage our tags.

We may use other technologies, including tags that may collect some of your information, such as IP address, to support website analytics offered by vendors, including but not limited to those listed below:

– Megaphone (Megaphone LLC, 1255 23rd St. NW, Suite 650 Washington DC, 20037) Privacy Policy

– GlobeNewswire (Intrado Corp. 11808 Miracle Hills Drive Omaha, NE 68154 United States) Privacy Policy

– Fouanalytics (Marketing Science Consulting Group, Inc. 425 Fifth Ave #33A, New York, NY 10016, US) Privacy Policy

– Kaltura (Kaltura Inc., 250 Park Avenue South, 10th Floor, New York, NY 10003, United States) Privacy Policy

The legal basis for processing your personal data is your consent or our legitimate business interests.

3 Website Preferences and Security

We may collect certain information about you, such as your IP address, unique device identifiers such as Media Access Control (MAC) address, computer type (Windows or Mac), browser type and version, screen resolution, operating system name and version. We can also deduce your location information from your IP address. We use this information to protect our websites and network systems, as well as to improve our services by recording your preferences, maintaining service levels, diagnosing and resolving technical problems.

The legal basis for processing your personal data is our legitimate business interests.

We may combine, aggregate or anonymise Personal Data with data we may collect from or about you from other sources, such as public databases, demographic information providers, marketing partners, public social media platforms (data made public by you) and other third parties.

We may use your data for our business purposes, including audits, to monitor and prevent fraud, infringement and other potential misuse of our products and services, and to modify our services.

We may also use your Personal Data:

– if we are required to do so by applicable law, requests from government authorities (including court orders, subpoenas or government regulations), including outside your country of residence;

– we need to enforce our terms and conditions;

– when we believe in good faith that the use of Personal Data is necessary to protect the legal rights, security or integrity of this website;

– to protect your safety or the safety of others;

– as part of any criminal or legal investigation or proceedings in your country or in other countries; or,

– to the extent reasonably necessary for the conduct or to proceed with a negotiation or completion of a corporate or commercial transaction.

We do not generally collect Sensitive Personal Data.

4. Recipients and further disclosure of Personal Data

 When and to whom may we provide your Personal Data?

This Privacy Policy describes the circumstances under which we may share your Personal Data.

We will not sell, share or transfer your Personal Data to third parties other than as set out in this Privacy Policy.

5.  Security of Personal Data

How do we protect your Personal Data?

We have implemented appropriate technical and organisational measures designed to provide an adequate level of security and confidentiality for your Personal Data.

The purpose of these measures is to protect personal data against accidental or unlawful destruction or alteration, accidental loss, unauthorised disclosure or access and against other unlawful forms of processing.

6.  Retention of personal data

How long will we keep your personal data?

We will only retain your personal data for as long as is necessary to fulfil the purpose for which it was collected or to comply with legal or regulatory requirements.

7.  Rights of individuals

What are your rights and how can you exercise them?

Whenever we process personal data, we take reasonable steps to keep your personal data accurate and up to date for the purposes for which it was collected. We will provide you with the possibility to exercise the following rights under the conditions and within the limits set out in the law.

– the right to be informed about what personal data we hold about you and how we process your personal data;

– the right to access your personal data processed by us and, if you believe that any information relating to you is incorrect, out of date or incomplete, to request that it be corrected or updated;

– the right to request the erasure of your personal data or the restriction of the processing of your personal data to specific categories;

– the right to withdraw your consent at any time, without affecting the lawfulness of the processing prior to such withdrawal;

– the right to object, in whole or in part, to the processing of their personal data. With certain exceptions, this includes the right to object to direct marketing;

– the right to request data portability, i.e. to have the personal data you have provided to us returned or transferred to a person of your choice, in a structured, commonly used and machine-readable format without hindrance from us and subject to your obligations of confidentiality; and

– the right to object to automated decision-making, including profiling that produces a legal or significant effect, i.e. you may request human intervention in any automated decision-making process relating to the processing of your data that produces a legal or significant effect, and where such processing is not based on your consent, is authorised by law or is necessary for the performance of a contract. However, we do not currently make decisions using automated processes that have a significant or legal effect on an individual.

If you have any questions or wish to exercise the above rights, you may send an email to contact@virtuswine.com.

8.  Updating the Privacy Policy

How often do we update this Privacy Policy?

We periodically review this Privacy Policy. This policy was last updated in September 2022.