This Privacy Policy regulates the processing of the personal data of users (hereinafter "User" or "Users") collected in connection with the use of the WineStone website (hereinafter "Website") by JMCWSG, S.A. and reflects its concerns regarding the privacy and processing of Users' personal data.
The provision of personal data in the context of browsing the website implies knowledge and express acceptance of the conditions contained in the Privacy Policy and Cookies Policy.
Website Usability
Users may browse the Website anonymously, without providing any personal information. Visiting the Website does not in itself imply the automatic recording of any personal data identifying the User.
However, the use of certain content, functionalities or services may imply that Users provide
personal data.
Therefore, JMSWGS, S.A. may (i) collect information about the behaviour of Users on the Website, which is not of a personal nature, in order to improve the navigability of the Website (in accordance with the Cookies Policy) and (ii) request the provision of personal data from Users so that they can use specific contents, functionalities or services of the Website (under the terms of this document).
Collecting and Processing Personal Data
To access and use certain features of the Website, the User must first register by creating a personal account, which involves providing some personal data.
JMCWSG, S.A. is the entity responsible for processing the personal data of Users, and processes this data and may, in certain cases, use subcontracted entities to provide services and technical support, which may have access to and process data for this purpose, under the terms of the contracts signed between JMCWSG, S.A. and these entities.
The personal data collected will be processed and stored in computerized form by JMCWSG, S.A., or by external entities subcontracted by it, for the purposes of publicizing the activity, institutional information, or the provision of services, and is intended to manage the registration of Users on the Website.
The data will also be processed for the purposes of communication with Users, namely, to respond to requests for information and clarification, complaints, as well as comments and/or suggestions that they send to JMCWSG, S.A.
In this context, the following personal data may be collected: first name and surname, tax identification number, address, postcode, town, telephone number and e-mail address.
The personal data collected through the Website will be processed under the terms described herein, as well as for the purposes of complying with JMCWSG, S.A.'s legal obligations.
JMCWSG, S.A. assumes that the data collected has been entered by the data subject and/or authorized by the data subject, and that it is true, current and accurate.
Processing of Personal Data
JMCWSG, S.A. uses other entities to provide certain services. The provision of these services may involve access by these entities to the personal data of its Users.
Therefore, any subcontractor of JMCWSG, S.A. will process the personal data of our Users in the name and on behalf of JMCWSG, S.A., under the strict obligation to follow our instructions. JMCWSG, S.A. shall ensure that such subcontractors provide sufficient guarantees for the implementation of appropriate technical and organizational measures so that the processing meets the requirements of the applicable law and ensures the security and protection of the rights of data subjects, under the terms of the subcontracting agreement signed with said subcontractors.
In certain situations, Users' personal data may also be transmitted to third parties, when such data communications are necessary or appropriate (i) in the light of applicable law, (ii) in fulfilment of legal obligations/court orders, (iii) by order of the National Data Protection Commission or other competent supervisory authority, or (iv) to respond to requests from public or government authorities.
In any of the aforementioned situations, JMCWSG, S.A. undertakes to take all reasonable measures to ensure the effective protection of the personal data it processes.
Retention of Personal Data
JMCWSG, S.A. will retain the User's personal data to the strictest extent necessary, considering the relationship established with the User and the fulfilment of the legal obligations to which it is subject.
Users' rights
Under the terms of the law, the User is guaranteed, at all times, the right to access personal data concerning him/her, as well as the rectification, deletion and portability of the data, and/or to limit and oppose its processing, directly through the User's reserved area on the Website or by written request addressed to JMCWSG, S.A., to the address Av. 24 de Julho, n.º 24, 1200 - 480 Lisboa or through privacidade@winestone.com.
Under the terms of the law, the User is also guaranteed the right to withdraw their consent to the processing of data whose consent constitutes the basis for the legitimacy of the respective processing. To this end, they have the right to withdraw their consent at any time, which does not, however, invalidate the processing carried out up to that date based on the consent previously given.
Without prejudice to any other administrative or judicial remedy, the data subject has the right to lodge a complaint with the CNPD or other competent supervisory authority under the terms of the law, if they consider that their data is not being processed legitimately by JMCWSG, S.A., under the terms of the applicable legislation and this Policy.
Data security measures
JMCWSG, S.A. makes every effort to protect Users' personal data from unauthorized access via the Internet. To this end, it maintains in operation all the technical means at its disposal to prevent the loss, misuse, alteration, unauthorized access, disclosure, destruction or misappropriation of the personal data provided or transmitted, undertaking to comply with the legislation on the protection of Users' personal data and to process this data only for the purposes for which it was collected, as well as ensuring that this data is processed with appropriate levels of security and confidentiality.
It is, however, the User's responsibility to guarantee and ensure that the computer they are using is adequately protected against harmful software, computer viruses and worms. In addition, you should be aware that without the adoption of appropriate security measures (e.g. secure browser configuration, up-to-date antivirus software, security barrier software and the use of software of dubious origin), the risk of personal data and passwords being accessed by unauthorized third parties is increased.
However, it should be noted that whenever data is collected over open networks, such as the Internet, your data may circulate without security conditions and there is a risk of it being seen and used by unauthorized third parties.
Third Party Sites
Through the Site, JMCWSG, S.A. provides links to third party websites, which are subject to independent Privacy Policies. The User should bear in mind that the JMCWSG, S.A. Website Privacy Policy does not apply to such sites and that JMCWSG, S.A. is not responsible for the collection of User information by said third parties through their respective websites, apart from data collection carried out by JMCWSG, S.A. subcontractors. However, if such subcontractors subsequently process the personal data of Users for the purpose of pursuing their own interests and purposes, going beyond the mandate given by JMCWSG, S.A., such entities will act as Data Controllers.
Contacts
The User may contact JMCWSG, S.A. for more information on the processing of their personal data, as well as any questions related to the exercise of the rights attributed to them by the applicable legislation, and particularly those referred to in this Policy, through the following contacts.
Telephone: +351 213 916 296
E-mail: privacidade@winestone.com
Changes to the Privacy Policy of JMCWSG, S.A.
JMCWSG, S.A. may change the Website's Privacy Policy at any time. These changes will be duly publicised to the User through the pages of the Website and, if they imply a substantial change in the way their data is processed, JMCWSG, S.A. will notify the User of such changes through the contact details they have provided.