Privacy Policy

‍

Layer 1

Basic information on Data Protection‍.

Responsible: RAFAEL LÓPEZ ALONSO ABAITUA (hereinafter, WINETWOTRIP)

Purpose: Provision of online services, web user management, commercial communications related to our services.

Legitimation: Express consent and legitimate interest.

Recipients: No data will be transferred to third parties, except under legal obligation

Rights: Access, rectify and delete data, as well as other rights, as explained in the additional information.

Additional information:l Additional and detailed information on Data Protection can be found in the attached clauses at www.winetwotrip.com.

Layer 2

In WINETWOTRIP we work to offer you through our products and services the best possible experience. In some cases, it is necessary to collect information to achieve this. We care about your privacy and believe we should be transparent about it.

Therefore, and for the purposes of the provisions of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 (hereinafter, "GDPR") on the protection of natural persons with regard to the processing of personal data, and on the free movement of such data, and LAW 34/2002, of July 11, 2002, on Information Society Services and Electronic Commerce (hereinafter, "LSSI"), WINETWOTRIP informs the user that, as data controller, it will incorporate the personal data provided by users in an automated file.

Our commitment begins by explaining the following:

• Your data is collected to improve the user experience, according to your interests and needs.

• We are transparent about what data we collect about you and why we collect it.
• Our intention is to provide you with the best possible experience. Therefore, when we use your personal information, we will always do so in compliance with the regulations, and when necessary, we will ask for your consent.

• We understand that your data belongs to you. Therefore, if you decide not to authorize us to process it, you can ask us to stop processing it.

• Our priority is to ensure your security and to treat your data in accordance with European regulations.

If you would like more information about how your data is handled, please see the different sections of the privacy policy below:

Who is responsible for the processing of your personal data?

Identity: WINETWOTRIP

Registered office: XXXX

C.I.F. XXX

Email: XXX

WINETWOTRIP has appointed a Data Protection Officer or an internal contact person within its organization. If you wish to make a query regarding the processing of your personal data, you can contact him by mail XXXX

What personal data do we collect?

The personal data that the user may provide:

• Name, address and date of birth.

• Telephone number and e-mail address.

• Location.

• Information regarding payments and refunds.

• IP address, date and time you accessed our services, internet browser you use and data about the device's operating system.

• Any other information or data you choose to share with us.

In some cases, it is mandatory to fill in the registration form to access and enjoy certain services offered on the web; likewise, not providing the personal data requested or not accepting this data protection policy means the impossibility to subscribe, register or participate in any of the promotions in which personal data are requested.

Why and for what purpose do we process your data?

In WINETWOTRIP we process the information provided by interested parties for the following purposes:

• Manage the contracting of our services.

• Manage the delivery of the information requested.

• To develop commercial actions and perform the maintenance and management of the relationship with the user, as well as the management of the services offered through the website and information tasks, being able to perform automatic assessments, profiling and customer segmentation tasks in order to customize the treatment according to their characteristics and needs and improve the customer's online experience.

• Develop and manage contests, sweepstakes or other promotional activities that may be organized.

• In some cases it will be necessary to provide information to the Authorities or third parties for auditing purposes, as well as to handle personal data from invoices, contracts and documents to respond to claims from customers or Public Administrations.

We inform that the personal data obtained as a result of your registration as a user will be part of the Register of Activities and Processing Operations (RAT), which will be updated periodically in accordance with the provisions of the RGPD.

What is the legitimacy for the processing of your data?

The processing of your data may be based on the following legal bases:

• Consent of the interested party for the contracting of services and products, for contact forms, requests for information or registration in newsletters.

• Legitimate interest for the processing of our customers' data in direct marketing actions and express consent of the data subject for all matters relating to automatic assessments and profiling.

• Compliance with legal obligations for fraud prevention, communication with public authorities and third party claims.

How long do we keep your data?

The processing of data for the purposes described above will be maintained for the time necessary to fulfill the purpose of collection (for example, for the duration of the business relationship), as well as for the fulfillment of legal obligations arising from the processing of the data.

To which recipients is your data communicated?

In some cases, only when necessary, WINETWOTRIP will provide user data to third parties. However, data will never be sold to third parties. External service providers (e.g. payment providers or delivery companies) with whom WINETWOTRIP works may use the data to provide the corresponding services, however, they will not use such information for their own purposes or for transfer to third parties.

WINETWOTRIP endeavors to ensure the security of personal data when it is sent outside the company and ensures that third party service providers respect confidentiality and have appropriate measures in place to protect personal data. These third parties are obliged to ensure that the information is handled in accordance with data privacy regulations.

In some cases, the law may require disclosure of personal data to public bodies or other parties, only what is strictly necessary for the fulfillment of such legal obligations will be disclosed.

The personal data obtained may also be shared with other group companies.

Where is your data stored?

In general, data is stored within the EU. For data that is sent to third parties outside the EU, we will ensure that they offer a sufficient level of protection, either because they have Binding Corporate Rules (BCR) or because they have adhered to the "Privacy Shield".

What rights do you have and how can you exercise them?

You can send your communications and exercise your rights by sending a request to the following e-mail address: info@winetwotrip.com.

Under the provisions of the RGPD you can request:

In some cases, your request may be denied if you request deletion of data necessary to comply with legal obligations.

Also, if you have a complaint about the processing of your data, you can file a complaint with the data protection authority.

Who is responsible for the accuracy and veracity of the data provided?

The user is solely responsible for the accuracy and correctness of the data included, exonerating WINETWOTRIP from any liability in this regard. Users guarantee and respond, in any case, the accuracy, validity and authenticity of the personal data provided, and undertake to keep them updated. The user agrees to provide complete and correct information in the registration or subscription form. WINETWOTRIP reserves the right to terminate the contracted services that had been concluded with users, in the event that the data provided are false, incomplete, inaccurate or outdated.

WINETWOTRIP is not responsible for the veracity of the information that is not of its own elaboration and of which another source is indicated, so it does not assume any responsibility for hypothetical damages that may arise from the use of such information.

WINETWOTRIP reserves the right to update, modify or delete information contained in its web pages and may even limit or deny access to such information. WINETWOTRIP is exonerated from liability for any loss or damage that the user may suffer as a result of errors, defects or omissions in the information provided by WINETWOTRIP provided it comes from outside sources.

Likewise, the user certifies that he/she is over 14 years of age and that he/she has the necessary legal capacity to consent to the processing of his/her personal data.

How do we handle personal data of minors?

In principle, our services are not specifically directed to minors. However, in the event that any of them are directed to minors under fourteen years of age, in accordance with Article 8 of the RGPD and Article 7 of the LO 3/2018 of December 5 (LOPDGDD), WINETWOTRIP will require the valid, free, unequivocal, specific and informed consent of their legal guardians to process the personal data of minors. In this case, the ID card or other form of identification of the person giving consent will be required.

In the case of persons over fourteen years of age, data may be processed with the consent of the user, except in those cases in which the law requires the assistance of the holders of parental authority or guardianship.

What security measures do we apply to protect your personal data?

WINETWOTRIP has adopted the security levels of protection of Personal Data legally required, and tries to install those other additional technical means and measures at its disposal to prevent the loss, misuse, alteration, unauthorized access and theft of Personal Data provided to WINETWOTRIP.

WINETWOTRIP is not responsible for hypothetical damages that may result from interference, omissions, interruptions, computer viruses, telephone faults or disconnections in the operation of this electronic system, caused by reasons beyond WINETWOTRIP ; delays or blockages in the use of this electronic system caused by deficiencies or overloads of telephone lines or overloads in the Data Processing Center, the Internet system or other electronic systems, as well as damage that may be caused by third parties through unlawful interference beyond the control of WINETWOTRIP. However, the user must be aware that Internet security measures are not impregnable.

Links to other websites

On the website www.winetwotrip.com there may be links to other websites. By clicking on one of these links and accessing an external website, the visit will be subject to the privacy policy of that website, and WINETWOTRIP disclaims any responsibility for its privacy policy.

How do we use cookies?

The WINETWOTRIP website and social networks use cookies to optimize and personalize your browsing experience. Cookies are physical information files that are hosted on the user's own terminal, the information collected through cookies is used to facilitate user navigation through the portal and optimize the browsing experience. The data collected through cookies may be shared with the creators of the same, but in no case the information obtained by them will be associated with personal data or data that can identify the user.

However, if you do not want cookies to be installed on your hard drive, you can configure your browser to prevent the installation of these files. For more information, please see our Cookie Policy.

Can the privacy policy be changed?

This privacy policy is subject to change. We recommend that you review the privacy policy from time to time.

‍