1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal
data of our website visitors and service users; in other words, where we determine the
purposes and means of the processing of that personal data.
1.3 By using our website and agreeing to this policy, you consent to our use of cookies in
accordance with the terms of this policy.
1.4 In this policy, "we", "us" and "our" refer to Alegrete 1375, Lda
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
2.2 We may process data about your use of our website and services ("usage data"). The
usage data may include your IP address, geographical location, browser type and version,
operating system, referral source, length of visit, page views and website navigation paths, as
well as information about the timing, frequency and pattern of your service use. The source
of the usage data is our analytics tracking system. This usage data may be processed for the
purposes of analysing the use of the website and services. The legal basis for this processing
is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your personal data that are provided in the course of the use of our
services ("service data"). The service data may be processed for the purposes of operating
our website, providing our services, ensuring the security of our website and services,
maintaining back-ups of our databases and communicating with you. The legal basis for this
processing is our legitimate interests, namely the proper administration of our website and
business.
2.4 We may process information contained in any enquiry you submit to us regarding goods
and/or services ("enquiry data"). The enquiry data may be processed for the purposes of
offering, marketing and selling relevant goods and/or services to you. The legal basis for this
processing is our legitimate interests, namely the proper administration of our business.
2.5 We may process information contained in or relating to any communication that you
send to us ("correspondence data"). The correspondence data may include the
communication content and metadata associated with the communication. The
correspondence data may be processed for the purposes of communicating with you and
record-keeping. The legal basis for this processing is our legitimate interests, namely the
proper administration of our website and business and communications with users.
2.6 We may process any of your personal data identified in this policy where necessary for
the establishment, exercise or defence of legal claims, whether in court proceedings or in an
administrative or out-of-court procedure. The legal basis for this processing is our legitimate
interests, namely the protection and assertion of our legal rights, your legal rights and the
legal rights of others.
2.7 We may process any of your personal data identified in this policy where necessary for
the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining
professional advice. The legal basis for this processing is our legitimate interests, namely the
proper protection of our business against risks.
2.8 In addition to the specific purposes for which we may process your personal data set out
in this Section 2, we may also process any of your personal data where such processing is
necessary for compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person.
2.9 Please do not supply any other person's personal data to us, unless we prompt you to
do so.
3. Providing your personal data to others
3.1 We may disclose your personal data to our subcontractors insofar as reasonably
necessary for the proper administration of our website and business.
3.2 In addition to the specific disclosures of personal data set out in this Section 3, we may
disclose your personal data where such disclosure is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital interests or the vital
interests of another natural person. We may also disclose your personal data where such
disclosure is necessary for the establishment, exercise or defence of legal claims, whether in
court proceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your
personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 The hosting facilities for our website are situated in the United Kingdom.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to
help ensure that we comply with our legal obligations in relation to the retention and
deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer
than is necessary for that purpose or those purposes.
5.3 Notwithstanding the other provisions of this Section 5, we may retain your personal data
where such retention is necessary for compliance with a legal obligation to which we are
subject, or in order to protect your vital interests or the vital interests of another natural
person.
6. Security of personal data
6.1 We will take appropriate technical and organisational precautions to secure your
personal data and to prevent the loss, misuse or alteration of your personal data.
6.2 Data that is sent from your web browser to our web server, or from our web server to
your web browser, will be protected using encryption technology.
6.3 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data
over the internet is inherently insecure, and we cannot guarantee the security of data sent
over the internet.
7. Amendments
7.1 We may update this policy from time to time by publishing a new version on our
website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this
policy.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection
law. Some of the rights are complex, and not all of the details have been included in our
summaries. Accordingly, you should read the relevant laws and guidance from the regulatory
authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data
and, where we do, access to the personal data, together with certain additional information.
That additional information includes details of the purposes of the processing, the categories
of personal data concerned and the recipients of the personal data. Providing the rights and
freedoms of others are not affected, we will supply to you a copy of your personal data. The
first copy will be provided free of charge, but additional copies may be subject to a
reasonable fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking
into account the purposes of the processing, to have any incomplete personal data about
you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without
undue delay. Those circumstances include: the personal data are no longer necessary in
relation to the purposes for which they were collected or otherwise processed; you
withdraw consent to consent-based processing; you object to the processing under certain
rules of applicable data protection law; the processing is for direct marketing purposes; and
the personal data have been unlawfully processed. However, there are exclusions of the right
to erasure. The general exclusions include where processing is necessary: for exercising the
right of freedom of expression and information; for compliance with a legal obligation; or for
the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal
data. Those circumstances are: you contest the accuracy of the personal data; processing is
unlawful but you oppose erasure; we no longer need the personal data for the purposes of
our processing, but you require personal data for the establishment, exercise or defence of
legal claims; and you have objected to processing, pending the verification of that objection.
Where processing has been restricted on this basis, we may continue to store your personal
data. However, we will only otherwise process it: with your consent; for the establishment,
exercise or defence of legal claims; for the protection of the rights of another natural or
legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating
to your particular situation, but only to the extent that the legal basis for the processing is
that the processing is necessary for: the performance of a task carried out in the public
interest or in the exercise of any official authority vested in us; or the purposes of the
legitimate interests pursued by us or by a third party. If you make such an objection, we will
cease to process the personal information unless we can demonstrate compelling legitimate
grounds for the processing which override your interests, rights and freedoms, or the
processing is for the establishment, exercise or defence of legal claims.
8.8 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are
party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your
personal data from us in a structured, commonly used and machine-readable format.
However, this right does not apply where it would adversely affect the rights and freedoms
of others.
8.9 If you consider that our processing of your personal information infringes data
protection laws, you have a legal right to lodge a complaint with a supervisory authority
responsible for data protection. You may do so in the EU member state of your habitual
residence, your place of work or the place of the alleged infringement.
8.10 To the extent that the legal basis for our processing of your personal information is
consent, you have the right to withdraw that consent at any time. Withdrawal will not affect
the lawfulness of processing before the withdrawal.
8.11 You may exercise any of your rights in relation to your personal data by written notice
to us.
9. Third party websites
9.1 Our website includes hyperlinks to, and details of, third party websites.
9.2 We have no control over, and are not responsible for, the privacy policies and practices
of third parties.
10. Personal data of children
10.1 Our website and services are targeted at persons over the age of 21.
10.2 If we have reason to believe that we hold personal data of a person under that age in
our databases, we will delete that personal data.
11. Updating information
11.1 Please let us know if the personal information that we hold about you needs to be
corrected or updated.
12. About cookies
12.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by
a web server to a web browser and is stored by the browser. The identifier is then sent
back to the server each time the browser requests a page from the server.
12.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie
will be stored by a web browser and will remain valid until its set expiry date, unless deleted
by the user before the expiry date; a session cookie, on the other hand, will expire at the
end of the user session, when the web browser is closed.
12.3 Cookies do not typically contain any information that personally identifies a user, but
personal information that we store about you may be linked to the information stored in
and obtained from cookies.
13. Cookies that we use
13.1 We use cookies for the following purposes:
(a) personalisation - we use cookies to store information about your preferences and to
personalise our website for you;
(b) analysis - we use cookies to help us to analyse the use and performance of our website
and services; and
(c) cookie consent - we use cookies to store your preferences in relation to the use of
cookies more generally.
14. Cookies used by our service providers
14.1 Our service providers use cookies and those cookies may be stored on your computer
when you visit our website.
14.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers
information about website use by means of cookies. The information gathered relating to
our website is used to create reports about the use of our website. Google's privacy policy
is available at: https://www.google.com/policies/privacy/.
15. Managing cookies
15.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The
methods for doing so vary from browser to browser, and from version to version. You can
however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-
preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-
manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
15.2 Blocking all cookies will have a negative impact upon the usability of many websites.
15.3 If you block cookies, you will not be able to use all the features on our website.
16. Our details
16.1 This website is owned and operated by Alegrete 1375, Lda
16.2 We are registered in Portugal under registration number 515021571, and our
registered office is at Quinta Das Sesmarias Estrada Municipal 517, 7300-312 Alegrete
16.3 You can contact us:
(a) by email, using the email address enologia@susanaesteban.com