Privacy Policy
DEALTURA, S.L. (hereinafter, “DEALTURA”), as the owner of the website www.dealturawines.com and the associated iOS / Android mobile applications (hereinafter, the “Portals”), is aware of the value of your personal information, and therefore constantly strives to protect the privacy of its users.
This document has been prepared in accordance with art. 13 of EU Regulation 2016/679 (hereinafter, the “GDPR”) in order to inform you of our privacy policy, understand how your personal information is processed when you browse our Portals and, where appropriate, give your express and informed consent to the processing of your personal data.
The information and data provided by you will be processed in accordance with the provisions of the GDPR and the confidentiality obligations that inspire DEALTURA’s activity.
In accordance with the rules of the GDPR, the processing carried out by DEALTURA will be based on the principles of lawfulness, fairness, transparency, purpose limitation of processing, data minimization, accuracy, integrity and confidentiality.
INDEX
Data controller
Personal data subject to processing
Browsing data
Data provided voluntarily by the data subject
Cookies
Purpose of processing
Legal basis and mandatory or optional nature of processing
Recipients of personal data
Retention of personal data
Rights of the data subject
Modifications
1. Data controller
The controller of your data is DEALTURA, S.L. with C.I.F. B86069093, registered office at Calle Gustavo Fernández Balbuena, 11 – 28002 (Madrid) and contact email address privacy@DEALTURA.com and socios@DEALTURA.com.
2. Personal data subject to processing
We inform you that DEALTURA will only process the personal data that is strictly necessary for proper browsing of the Portals and for the purposes described in point 3 “Purposes of processing” below (hereinafter, “Personal Data”).
The Personal Data processed through the Portals are as follows:
a. Browsing data
The computer systems and software procedures used to operate the Portals acquire, during their normal operation, some Personal Data whose transmission is implicit in the Internet communication protocols. This information is not collected to be associated with identified users. However, by its very nature it could, through processing and association with data held by third parties, allow the identification of such users. This category of data includes the IP addresses or domain names of the computers used by users connecting to the Portals, the URI (Uniform Resource Identifier) of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.) and other parameters relating to the operating system and the computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Portals and to check their correct functioning, to identify anomalies and/or abuses, and are deleted immediately after processing. The data could be used to determine responsibility in the event of hypothetical computer crimes against the Portals or against third parties.
b. Data provided voluntarily by the data subject
If you are a registered user (“Client”), you will be required to provide: name and surname(s), email, postal address, telephone number, billing information, date of birth, gender. In the case of clients who are legal entities, their company name, postal address, billing information, name and surname(s), email, telephone number of the representative will be required.
If you are a (potential) supplier (“Supplier”), you will be required to provide: your company name, postal address, billing information, name and surname(s), email, telephone number of the representative.
If you are a job applicant (“Candidate”), you will be required to provide: name and surname(s), email, telephone number and curriculum data.
When you purchase certain products on the website (for example, the “gift card” or the “gift subscription to The Box”), or when you sponsor a potential client, we may process Personal Data of third parties that you send to DEALTURA. With respect to these cases, you are the independent owner of the processing, assuming all the obligations and responsibilities of the law. In this sense, you grant the broadest possible indemnity with respect to any dispute, claim, request for compensation for damages arising from the processing, etc. that may reach DEALTURA from third parties whose Personal Data have been processed through the functionalities of the Portals in violation of the applicable regulations on personal data protection. In any case, if you provide or otherwise process the Personal Data of third parties in the use of the Portals, you guarantee at this time – assuming all related responsibility – that this particular case of processing is based on an appropriate legal basis in accordance with art. 6 of the GDPR that legitimizes the processing of the information in question.
c. Cookies
The Portals use third-party analytical cookies to offer you services that match the preferences you have expressed when browsing the web. You can find specific information on this section by accessing the Cookies policy link.
3. Purposes of processing
The processing that we intend to carry out, with your express consent when necessary, has the following purposes:
Category of data subjects | Purpose |
|---|---|
User visiting the Portals
| Usability and quality analysis for the improvement of our services
|
Client |
|
All of the above | Comply with the legal, accounting and tax obligations that correspond to DEALTURA. |
4. Legal basis and mandatory or optional nature of processing
Purpose | Legitimation |
|---|---|
Usability and quality analysis for the improvement of our services. | Compliance with the contractual relationship (in particular, the Conditions of Use) (art. 6. 1 b) of the GDPR). |
| The processing is necessary for the maintenance of the contractual relationship or to respond to the requests of the interested party (art. 6. 1 b) of the GDPR). |
Sending commercial communications about DEALTURA products and services, including the magazine.
Development of commercial profiles through automated processing in order to develop commercial actions on DEALTURA products, based on the purchase history. |
|
| The processing is necessary to respond to the requests of the interested party (art. 6. 1 b) of the GDPR). |
Comply with the legal, accounting and tax obligations that correspond to DEALTURA. | The regulations applicable in each case (art. 6. 1 c) of the GDPR). |
5. Recipients of personal data
Your Personal Data may be shared, for the purposes established in section 3 above, with:
a. parties that typically act as data processors, i.e.: i) individuals, companies or professional firms that provide assistance and advice to DEALTURA in accounting, administrative, legal, tax, financial and credit collection matters; ii) parties with whom it is necessary to interact for the provision of services (for example, hosting providers, order delivery company); iii) parties delegated to carry out technical maintenance activities (including the maintenance of network equipment and electronic communication networks) (hereinafter, collectively, the “Recipients”);
b. persons, entities or authorities to whom it is mandatory to communicate your personal data, by virtue of legal provisions or orders from the authorities.
Some of your Personal Data is shared with Recipients who may be located outside the European Economic Area. In this regard, DEALTURA guarantees that the processing of your Personal Data by these Recipients is carried out in accordance with the GDPR. In fact, transfers may be based on an adequacy decision, on contractual clauses approved by the European Commission or on another appropriate legal basis.
More information can be obtained by contacting us directly (see contact details indicated in paragraph 7. Rights of data subjects).
6. Data retention
DEALTURA only stores your personal information to the extent that we need it in order to use it according to the purposes for which it was collected, and according to the legal basis of the processing thereof in accordance with applicable law. Your personal information will be kept as long as there is a contractual and/or commercial relationship or as long as you do not exercise your right of deletion, cancellation and/or limitation of the processing of your data.
Once the relationship with you has ended for any of the reasons indicated, the information will be kept duly blocked, without giving it any use, as long as it may be necessary for the exercise or defense of claims or may derive some type of judicial, legal or contractual responsibility of its processing, which must be attended to and for which its recovery is necessary.
7. Rights of data subjects
At any time, you may exercise the rights of access, rectification, deletion, limitation, cancellation, portability and opposition with respect to your personal data by communicating with DEALTURA whose contact details we indicate below:
- Registered office: Calle Gustavo Fernández Balbuena, 11 – 28002 (Madrid)
- Email address: socios@DEALTURA.com
- Telephone: 91 198 12 37 (Monday to Friday from 10:00 a.m. to 7:00 p.m.)
You can also contact our Data Protection Officer (“DPO”) at the following email address: privacy@DEALTURA.com
This communication must include your name and surname(s), the specific request, an address for notification purposes, the date, signature and a photocopy of your ID card or other valid document identifying you. The exercise of these rights is free of charge.
In the event that you have any conflict in relation to the protection of your personal data, you may file a complaint with the AEPD (www.aepd.es)
8. Modifications
DEALTURA reserves the right to modify or simply update the content, in part or in its entirety, also due to changes in applicable legislation. Consequently, we invite you to regularly visit this section to learn about the latest and most updated version of the privacy policy in order to be always updated on the data collected and the use made by DEALTURA.
In any case, when significant changes occur, the user will be notified through a notice on the Portals to offer the possibility of reviewing the changes before they become effective.
More information about the processing of your data
It is possible that through the Portals Users are allowed to be redirected or access to third party websites (service providers or distributors, among others). In any case, if you choose to leave any of our Portals through links to websites not belonging to our entity, neither the Portals nor their legal representatives are responsible for the content or the veracity of the privacy policies that such third parties may have, nor for the cookies that they may store on the user’s computer.
