Privacy policy pursuant to Art. 13 of the European Regulation No. 679/2016

Gruppo Italiano Vini S.p.A. with registered office in Villa Belvedere, 37011 Calmasino - Bardolino, Verona (VR), in its capacity as data controller of the personal data processing (hereinafter, the "Data Controller" or "GIV") hereby informs you, pursuant to Art. 13 of the European Regulation no. 679/2016 (hereinafter, "GDPR" or "the Applicable Legislation") that your data will be processed in the manner and for the purposes indicated below.

In this regard, before communicating any personal data, the Data Controller invites you to carefully read this privacy policy (hereinafter, "Privacy Policy"), as it contains important information on the protection of personal data and the technical and organisational measures adopted to ensure their confidentiality in full compliance with the GDPR.

This Privacy Policy:

is intended for users of the website www.gruppoitalianovini.it (hereinafter referred to as "the Site"), and it is understood that it does not apply to other websites that may be consulted via external links.

This policy complies with Recommendation No. 2/2001 on minimum requirements for online data collection in the European Union, adopted on 17 May 2001 by the Article 29, Working Party.

1. DATA CONTROLLER

The Data Controller is Gruppo Italiano Vini S.p.A. with registered office in Villa Belvedere, 37011 Calmasino - Bardolino, Verona (VR) (hereinafter also the "Data Controller" or "GIV").

The External Data Processor is Webranking srl, with registered office in Via Oratorio n. 12A, Correggio -RE- (Italia).

The complete and up-to-date list of Data Processors can be obtained by simply sending an email to the Data Controller at Privacy@giv.it;

2. PERSONAL DATA BEING PROCESSED

The term “Personal Data” shall mean any information relating to an identified or identifiable natural person with particular reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more characteristics of that person's physical, physiological, genetic, mental, economic, cultural or social identity.

The Personal Data collected on the Site are as follows:

a) Browsing data

The Site's computer systems collect certain Personal Data, the transmission of which is implicit in the use of Internet communication protocols. This is information that is not collected in order to be linked to you, but which by its very nature could, through processing and association with data held by third parties, enable you to be identified.

These include the IP addresses or domain names of the devices you use to connect to the Site, the URI (Uniform Resource Identifier) addresses 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 given by the server (successful, error, etc.) and other parameters relating to your operating system and computer environment.

These data are used to obtain anonymous statistical information on the use of the Site and to check its correct operation; to allow, given the architecture of the systems used, the correct provision of the various functions requested by you, for security reasons and to ascertain responsibility in the event of hypothetical computer crimes against the Site or third parties.

b) Data provided voluntarily

Through the Site, you have the opportunity to voluntarily provide Personal Data such as your name and surname and e-mail address, which are used to contact the Data Controller via the "Contact Us" form or the "Complaints" section. GIV will process this data in compliance with the Applicable Legislation, assuming that it relates to you or to third parties who have expressly granted you permission to provide it based on an appropriate legal basis legitimising the processing of the data in question. In reference to these assumptions, you act as an independent data controller, assuming all obligations and responsibilities under the law. In this regard, you hereby grant the Data Controller the broadest possible indemnity concerning any dispute, claim, request for compensation for damage caused by processing, etc. that may be received by the Data Controller from third parties whose Personal Data have been processed through your use of the Site in breach of the Applicable Legislation.

c) Cookies and related technologies

As described more fully in the Cookie Policy, the Data Controller uses cookies and similar technologies (e.g. web beacons, pixels, ad tags and device identifiers), to recognise you and/or your devices. You can control cookies via your browser settings and other tools. You can also refuse the Data Controller's use of cookies and similar technologies that monitor your behaviour on other websites for third-party advertising.

3. PURPOSE AND LEGAL BASIS FOR PROCESSING

The Personal Data you provide through the Site to Gruppo Italiano Vini S.p.A. will be processed for the following purposes:

a) to respond to requests made by you via the "Contact us" section and/or the "Complaints" section;

b) for the transmission of promotional communications:

In accordance with the provision of the Data Protection Authority "Guidelines on marketing and against spam - 4 July 2013 [2542348]," if you decide to give your consent to receive information relating to marketing activities including market research, of the Data Controller, we inform you that such activities may be carried out, as provided for by the regulations in force, by means of paper mail, telephone contact by operators ("traditional methods"), email, sending of text messages, push notifications and use of social networks ("automated methods").

c) for the purpose of statistical research/analysis on aggregated or anonymous data, without therefore the possibility of identifying the user, aimed at measuring the operation of the Site, measuring traffic and assessing usability and interest;

d) for the fulfilment of legal obligations to which the Data Controller is subject;

e) to establish, exercise or defend a right in court or whenever the judicial authorities exercise their jurisdictional functions;

With reference to the purpose under a), the legal basis for the processing of your personal data is Art. 6 (b) of the GDPR; this activity does not require your consent.

With regard to the purpose under b), the legal basis for the processing of your personal data is the provision of your consent in accordance with Art. 6 (a) of the GDPR. In the absence of such consent, you will be able to use the other services requested but the Data Controller will not be able to send you marketing communications. We inform you that you may, at any time, decide to revoke the previously given consent for traditional or automated methods by notifying the Data Controller without any formal procedures simply by writing to privacy@giv.it.

With reference to the purpose under c), this activity does not involve the processing of Personal Data, whereas in relation to the purpose under d), it represents a lawful processing of Personal Data within the meaning of the Applicable Legislation since, once the Personal Data has been provided, the processing is necessary to comply with a legal obligation to which the Data Controller is subject pursuant to Art. 6(c) of the GDPR.

4. DATA RETENTION

Gruppo Italiano Vini S.p.A. will process your Personal Data for the time strictly necessary to achieve the purposes as per section 3.

With particular reference to the purpose under b) above, your data will be retained for a period of 10 years after it is provided. At the end of this period, your data will be deleted or permanently anonymised.

Notwithstanding the foregoing, the Data Controller will process your Personal Data for as long as permitted by Italian law to protect its interests (Art. 2947(1)(3) Italian Civil Code). At the end of this period, your data will be deleted or permanently anonymised.

5. RECIPIENTS OF DATA PROCESSING AND TRANSFER

Your Personal Data may be shared, for the purposes specified in section 3, with:

subjects necessary for the provision of services offered by the Site including, by way of example, the sending of emails and the analysis of the operation of the Site, who typically act as processors and/or sub-processors of GIV;

persons authorised by GIV for the processing of Personal Data who have committed themselves to confidentiality or have an appropriate legal obligation of confidentiality (e.g. employees and collaborators of the Data Controller); (the persons mentioned in numbers 1 and 2 are collectively "Recipients");

judicial authorities in the exercise of their functions when required by Applicable Law.

Your data may be transferred outside the European Economic Area only to entities bound by European standard contractual clauses permitted under Article 26(2) of Directive 95/46/EC or where the territory in which processing takes place has an adequacy finding under Article 25(6) of Directive 95/46/EC (including therein, for the avoidance of doubt, the USA/EU Privacy Shield).

6. RIGHTS OF THE DATA SUBJECT

You have the right to ask Gruppo Italiano Vini S.p.A. at any time to access, correct or delete your personal data or to object to their processing, you have the right to request the restriction of the processing in the cases provided for by Art. 18 of the DGPR, as well as to obtain, in a structured, commonly used and machine-readable format, the data concerning you, in the cases envisaged by Art. 20 of the DGPR.

Enquiries may be addressed to the email address listed under privacy@giv.it;

In any event, you always have the right to lodge a complaint with the competent supervisory authority (Data Protection Authority), pursuant to Art. 77 of the GDPR, if you believe that the processing of your data is contrary to the legislation in force.

7. CHANGES

The Data Controller reserves the right to update the Policy at any time and to inform users through the use of the most appropriate tools; for any further information or questions you can contact the Data Controller at the following email address: privacy@giv.it