PRIVACY POLICY 

  1. WHO IS THE DATA CONTROLLER?

MIGUEL TORRES, S.A. (from now on, TORRES), with registered office at calle Miquel Torres i Carbó, 6, 08720 Vilafranca del Penedès (Barcelona) and Tax Identification Number A-08933251.

 

  1. FOR WHAT PURPOSE DO WE PROCESS YOUR DATA, WHAT ARE THE LEGAL GROUNDS FOR PROCESSING? HOW LONG WILL WE KEEP YOUR DATA?

Your data will be processed in accordance with:

Processing/Purpose

Legal grounds

Duration

Membership of Familia Torres Wine Club: If you subscribe as a member of Familia Torres Wine Club, your data will be processed to(i) manage the subscription and its benefits, such as sending you discounts on products, invitations to events, sending you a birthday or Christmas greeting, new subscriptions, through electronic and/or electronic means, etc., (ii) manage the payment of the corresponding fee, proceed with the shipment of the products, (iii) to manage any incident arising from the subscription and to carry out the necessary communications for the provision of the service (product information, changes in terms and conditions, etc.), (iv) resolve any questions or queries, including via WhatsApp, in which case we will process your data in order to(1) (1) manage the corresponding authorization and acceptance of the Membership Conditions, (2) provide you with answers to the questions you may ask us, (3) manage the conversations held and carry out the corresponding actions.

We remind you that to become a member of Familia Torres Wine Club, you must complete the subscription and payment that best suits you.

Contractual relationship and legitimate interest

If you are a member of Familia Torres Wine Club, your data will be processed for as long as you are a member and until you unsubscribe or object to such processing.
Period after which your data will be kept for a period of 10 years.

 

Profile of our users: we create profiles of the users who interact with us. The profile enables us to offer better services, tailored to the preferences of our customers, providing quality and personalized content. For more information about this treatment, please refer to section 7 of this privacy policy.

We also inform you that we carry out the processing based on legitimate interest. TORRES is interested in knowing its users in such a way as to enable us to better target the advertising messages that the user receives about our products and services. The benefit for TORRES is savings on advertising costs. The benefit for users is that they do not receive indiscriminate advertising about products and services that are of no interest to them.

For more information on legitimate interest, please refer to section 9 of this privacy policy.

Legitimate interest

We will process your data for as long as you maintain the user account and until you unsubscribe as a user or you object to the processing.

Sending of commercial communications: if you give us your consent and provide us with your contact details, we will use them to send you information and commercial communications about products, as well as discounts, promotions, invitations to events or opinion surveys of Familia Torres.

Consent

We will process your data until you unsubscribe or withdraw your consent.

Contact us: When you contact us, we will process your data to resolve any doubts or queries that you may have.

We also inform you that we carry out the processing based on legitimate interest. TORRES is interested in answering any questions you may have. The benefit that this creates for TORRES is to improve those matters that users may have doubts or questions about. The benefit for users is to provide an answer to the query and offer information without the user having to ask questions.

For more information on legitimate interest, please refer to section 9 of this privacy policy.

Legitimate interest

We will retain your data for 1 year after the query has been resolved. 

Participation in contests, promotions and draw: In the event that you participate in contests, promotions and draws, your data will be processed to manage your participation in same, as well as to comply with the provisions of the terms and conditions.

In the event of winning, we may process your data to arrange the announcement and delivery of the prize, and to comply with any legal obligation arising from the delivery of the prize.

Contractual relation and legal obligation

We will retain your personal data for 10 years after the contest, promotion and/or draw has ended.

 

Attendance at our events, wineries, tastings, experiences or reservations at our restaurants: in the event that you register or hire any of our events, tastings and/or experiences or wish to attend one of our wineries and/or restaurants, your data will be processed to manage the registration and/or reservation, manage payment if necessary, as well as any assistance that may involve, among others, the preparation of access cards, etc.

We may also be able to manage the transfer of image rights, should you authorize us to do so.

Consent and/or contractual relationship

We will retain your data for 2 years after the end of the event, tasting and/or experience, unless there are longer periods established in the image rights transfer documents.

In connection with receiving information about our events and tastings, your data will be processed until you unsubscribe or withdraw your consent.

Clients and offline services: in the event that you interact with us and purchase our products or services offline, we will process your data to manage the purchase or service requested, payments and collections, to ship the product, manage the contract between both parties if necessary and to resolve any questions or queries you have.

Also, as a customer we may process your data to send you business information that may be of interest to you in the event that you have expressed an interest by ticking the relevant box.

Contractual relation

We will retain your data for the duration of the business relationship and/or existing contract and up to 15 years following termination of the relationship with TORRES.


 

When sending commercial information, your data will be retained until you inform us by any channel that you no longer wish to receive this type of information.

Suppliers and distributors: If you are one of our suppliers and/or distributors, we may process your data to manage the relationship between both parties, to make the relevant payments and to manage our contracts. Also, as a supplier and/or distributor, we may process your data to send you commercial information that may be of interest to you.

Contractual or pre-contractual relation

We will retain your data for the duration of the business relationship and/or existing contract and up to 15 years following termination of the relationship with TORRES.

 

Work with us: if you register in the form to work with us, we will process your data (including identification data and curriculum vitae) in order to manage your application for our vacancies. In order to do so, we will need to be able to contact you for any necessary procedure in relation to one of our vacancies (inviting you to an interview or a test that will allow us to check and assess your skills or suitability), all with the aim of hiring the right candidate for the job. Also, if you give us your consent, we may keep your data for future vacancies.

Precontractual relationship and legitimate interest

Your data will be processed for 1 year from the evaluation of your application, unless you authorize us to process them for future openings in which case they will be processed for 3 years.

 

Collaborations: we can also process your data as influencer”, "public person" or "promoter" of an event, experience and/or tasting, draw, contest and/or promotion, your data will be processed to contact you, manage the business relationship that binds us, and if applicable, manage attendance to the event, when applicable, and the transfer of image rights in the event that you authorize us to use them.

Legitimate interest, contractual relationship and consent

We will retain your data for 2 years after the end of the collaboration, unless there are longer periods established in the image rights transfer documents.

 

 

  1. TO WHOM WILL WE DISCLOSE YOUR DATA?

If you make a purchase and on the basis of the existing contractual relationship, TORRES may communicate your data to third parties who will act as data controllers, and who will therefore determine the purposes and means for which the data will be used. These parties may be logistics companies that deliver goods to the address indicated.

Except for data communication described in the previous paragraph, your data will not be transferred, sold, rented or made available in any other way to third parties, except for the service providers who perform certain activities for us (database management, and the like) but who will in no case process the data for their own purposes.

Some of these providers may be located outside the European Union or the European Economic Area as indicated in the following section.

 

  1. DO WE TRANSFER DATA INTERNATIONALLY?

If the third parties assisting us in the provision of services process your personal data outside the European Union or the European Economic Area, TORRES will ensure that your data is always protected with the necessary safeguards, which may include:

  1. EU-approved standard clauses

  2. Third-Party Certifications

You may at any time request further information about the guarantees taken in each case by contacting our Data Protection Officer at dataprotect@torres.es

 

  1. WHAT INFORMATION DO WE COLLECT FROM THIRD PARTIES (THROUGH TOOLS SUCH AS SOCIAL LOGIN)?

In cases when you can register on the Web, through your social media user accounts, such as Facebook or Google, and if you use this option, you authorise TORRES to use, collect and process this information, mainly your email address, in accordance with the social media’s privacy policies.

This option is already configured by the Social Media and is offered as a service to users and third party companies, to facilitate registration or access without users having to enter data. The data are transmitted from social media for the described purposes, and in accordance with the rules applicable to them. Users’ processing settings are always respected. In any case, we will duly inform you of the information we collect from social media at the time of the data request.

 

  1. WHAT INFORMATION DO WE COLLECT THROUGH COOKIES?

Through cookies, we can process and store information about how you use the website, and we can see the sections you visit, make influence maps, track behavioural patterns, and when you leave the website.

We obtain this information mainly through Cookies, so your processing will depend on the Cookies you have accepted.

Remember that you can manage cookies from our configuration option and change your preferences at any time. For more information, including the types of Cookies used and how to configure the Cookies installed on our website, please see our Cookies Policy.

 

  1. ARE WE PROFILING USERS AND MAKING AUTOMATED DECISIONS?

As described below, TORRES can use all the information provided by you to profile you.

Such a profile will take into account for example:

  • Your browsing behaviour on the website, based on the products selected, cursor movements, interests, preferences, and products purchased.

  • Your behaviour when you receive our newsletters; for example, the content you find interesting according to which newsletters you open and the frequency.

  • Interaction that you may perform through other channels such as queries through our information channels, or contact.

  • Information you may provide to us through satisfaction surveys.

We also inform you that, for some services, we may process your personal data using automated means. This means that certain decisions are taken automatically without human intervention; for example, segmenting you according to your interest in certain sections of the website or that you may use other services that we may offer.

If you have chosen to receive commercial communications, these may be adapted and personalised, according to your interests, either based on the products and services requested, or based on data that we can deduce or obtain from your browsing, interest in certain content, reaction to our communications, among others.

This personalisation is partially automated, in the sense that we determine the parameters of the personalisation, but it is the technological platform that generates the user's profile. We do not send general communications that have not been segmented using the above procedure, as we consider that it is in our and the user's interest to send or receive relevant information, and because not segmenting would not alter the number of communications received, but only their content. If you do not wish to be segmented, please do not subscribe to commercial communications.

In the following section is more information about the sending of commercial communications and informative newsletters.

 

 

  1. WHEN AND HOW DO WE SEND COMMERCIAL COMMUNICATIONS AND INFORMATIVE NEWSLETTERS?

If you have given your consent, we will process your data and send you commercial communications as well as our informative newsletter which may contain information about our products, discounts, promotions, invitations to events or opinion polls.

As a user, you should bear in mind that all our communications and newsletters may be personalised according to the interests shown, based on the products you have purchased, or the data we can obtain from the browsing behaviour shown on our website by our cookies.

This personalisation is partially automated.

We remind you that you may withdraw your consent at any time, and that all our newsletters have a link so users can unsubscribe from this information.

 

  1. WHY CAN WE CARRY OUT PROCESSING ON GROUNDS OF LEGITIMATE INTEREST?

Under the second section of this privacy policy, TORRES processes your data on legitimate interest grounds. To assess the legitimate interest, we have assessed the legitimate interest and analysed our own benefits as data controllers and the benefits of third parties, and in which we conclude that our legitimate interest in processing prevails over the interests, rights and freedoms of users.

You may request further information about the assessment of legitimate interests by contacting our Data Protection Officer at the address stated in section 13 of this privacy policy. We would like to remind you that you may object to processing on the grounds of legitimate interest.

 

  1. HOW LONG WILL WE KEEP YOUR PERSONAL DATA?

All data provided will be retained for the period indicated in the second section of this privacy policy.

Notwithstanding these time limits, your data may be retained in anonymised form for statistical or market research purposes, where possible, or appropriately blocked when necessary to comply with our legal obligations which may require us to retain certain data for a specified period.

 

  1. CAN I UPDATE MY DETAILS IF I AM ALREADY REGISTERED?

If you have registered as a user you can edit and update your data in the specific section called "Edit my profile" available in your own user account.

 

  1. HOW CAN I EXERCISE MY RIGHTS?

You may exercise your rights of access, rectification, deletion, opposition, limitation of processing and portability of your data by writing to calle Miquel Torres i Carbó, 6, 08720 Vilafranca del Penedès (Barcelona), or by e-mail to the following address dataprotect@torres.es, including the reference "Personal data" and in both cases providing a photocopy of your ID card or passport whenever necessary.

You may also withdraw your consent to processing operations based on consent and/or object to other processing operations where this is possible in accordance with the regulations in force. Notwithstanding the foregoing, revocation/opposition to any processing may mean that we are unable to provide you with our services.

 

  1. HOW CAN I CONTACT THE DATA PROTECTION OFFICER (DPO)?

If you have any doubts, questions, queries or complaints about the way in which we process your personal data, you can contact our Corporate Data Protection Officer at dataprotect@torres.es or by writing to the following address: calle Miquel Torres i Carbó, 6, 08720 Vilafranca del Penedès (Barcelona) with the reference "DPO".

We inform you that if you do not receive a response within a reasonable period, you may lodge a complaint with the Spanish Data Protection Authority.

 

  1. HOW WILL WE PROCEED IF WE CHANGE OUR PRIVACY POLICY?

Please note that we will inform you, where possible by email and/or information on our website, of any significant changes to our privacy policy so that you are informed of the changes made to the processing of your data and, if you consider it appropriate, exercise your rights on your personal data.