PRIVACY POLICY

This privacy policy applies to the Toro Loco Wine website in its English version accessible at www.toroloco.wine (hereinafter referred to as the “Site“). While using the Site,
BVC Bodegas (hereinafter “We“) may collect certain personal information about you, in accordance with the provisions of Regulation 2016/679/EU, known as the General Data Protection Regulation (GDPR).
BVC Bodegas is responsible for processing the personal data concerning you within the meaning of this regulation (Data Protection Officer’s contact details: DPO@Advini.com).
This Privacy Policy informs you of the methods of collection, processing, and use of your personal data (“Personal Data“) concerning you and your rights regarding the protection of this data.
Before using the Site, please read this Privacy Policy carefully. If you do not wish for us to collect your data in accordance with this Privacy Policy, please note that we may not be able to respond to some of your requests.

PRIVACY POLICY

1. What type of Personal Data do we collect?
2. How and why do we use cookies and tracking technologies?
3. For what purposes do we use your Personal Data?
4. What happens if you refuse to provide us with your Personal Data?
5. Why and to whom do we disclose your Personal Data?
6. Where, how, and why are your Personal Data likely to be transferred outside the European Union?
7. How long do we retain your Personal Data?
8. How do we secure your Personal Data?
9. What are your rights?
10. How do we process children’s Personal Data?
11. How do you exercise your rights, contact us, or lodge a complaint with the CNIL?
12. Amendment of our Privacy Policy

1. What type of personal data do we collect?

We only collect your Personal Data for the purposes stated in Section 3 and each time you use one of the features or services offered by the Site.
The categories and volume of Personal Data collected for the use of features and services may be updated and evolve with changes in our services and activities.
Subject to applicable legal obligations, we may use various technologies that collect and provide information about how you access our Site and how you use it. We may also use demographic information, which we may obtain from third parties, such as Google or the social networks you are registered on (the “Usage Information“). Usage Information may include the pages you have viewed, the time you viewed them, information about specific drinks or other content you have accessed or provided, the language in which you viewed our Site, including demographic information about you (such as your age, gender, and interests, if applicable), and the pages you viewed before viewing this page, etc.

2. How and why do we use cookies and tracking technologies?

We use tracking technologies, such as cookies, IP addresses, or browsing histories. These tracking technologies help us tailor our Site to your needs.
For more information on the cookies we use and how you can disable them, please consult our Cookie Policy.

3. For what purposes do we use your personal data?

We collect Personal Data about you for the following purposes:
• Respond to your service requests or perform a contract: When you register or subscribe to the Site, your Personal Data is used to provide you with the features and services you have subscribed to and to offer you the benefits and privileges that generally result from your registration (for example, receiving the communications you selected at the time of registration, being invited to events, participating in contests, placing an order for Products, etc.);
• Send you operational or administrative communications: (for example, a confirmation email when you register (or unsubscribe) to a service or feature), as well as certain notifications concerning the services (for example, notifications of updates to our privacy notifications, interruption of features or programs on our Site, changes affecting our online services or our IT support policies, or related to other related changes, etc.).
• Allow us to send you marketing communications, when you have given us your consent:
1/ In addition to the purpose for which you provided us with your Personal Data, you may be asked to consent (for example, by means of a check box) to the use of your Personal Data for an activity or service different from the main activity or service object of your request. For example, if you register for a contest or another promotional action, you may also be invited to subscribe to newsletters or alerts sent by the Site hosting the promotion activity or by other websites. If you consent to receive our targeted advertisements, emails, and SMS messages, we will use your Personal Data for this purpose.
2/ When you use the “Send to a Friend” feature (if this feature is present): the Personal Data collected in this way will only be used once to send the message and will be deleted in accordance with applicable local law;
3/ When you use a QR Code or a similar application displayed on Toro Loco products: we will use your Personal Data to send you more information about products bearing the QR Code or a similar application or about other products;

• Because it is also in the legitimate interest of BVC Bodegas to better serve you:
Subject to obtaining your consent where required, we may, be led to combine, update, or consolidate your Personal Data collected via our Site with data we receive from third-party sources. For example, we may combine purely demographic information or survey data (e.g., age, gender, family information, and other interests, etc.) that are not linked to any of your Personal Data with Personal Data collected through our offers (when registering an account, for example).
We may use the combined information and/or the aforementioned demographic information for our internal marketing and demographic studies and for the purpose of continuously improving, personalizing, and adapting the products and services we provide to better meet your needs. Some of the tools we use may involve an automated decision-making process under conditions permitted by applicable law.
• Managing and tracking your requests and comments via our “Contact Us” form: as part of contract execution in particular.
We will ensure that your Personal Data remains accurate and up-to-date or must be supplemented with additional information you have provided. We will also strive to avoid duplicates in our database by verifying each of your interactions with us and/or our affiliates and checking whether your Personal Data concerning you is still accurate or whether it needs to be supplemented or updated with the additional information you have provided.
We may analyze your activities and browsing habits on the Site to better understand your preferences and interests and tailor our communications to your tastes and preferences, unless you object as indicated in Section 9 of this Privacy Policy.
We may also use automated decision-making processes, including for the purpose of contract execution.
Please note that the automated tools used are regularly checked to ensure that Personal Data is processed lawfully. Specific measures, such as data minimization, are implemented when creating profiles. You can also challenge the outcome of the automated decision by sending an email to the address indicated in Section 11 below and requesting additional information.

4. What happens if you refuse to provide us with your personal data?

If you refuse to submit the requested Personal Data, you may not be able to participate in certain activities, benefit from certain personalized features, or the Site and special services offered to you may be limited. For example, if you refuse to provide your email address, you will not be able to receive our newsletters or register on the Site. However, you are not obliged to provide us with your Personal Data to browse our Site and learn about BVC Bodegas and our products. In any case, we will always indicate which Personal Data is necessary to benefit from a service.

5. Why and to whom do we disclose your personal data?

• To BVC Bodegas and the Advini Group
For the purposes mentioned in Section 3, the Personal Data concerning you may be transmitted to the various subsidiaries worldwide of the Advini group.

• To third parties
We may transmit your Personal Data to third parties, but only in the following cases:

1. For marketing purposes if you have given us your consent for this purpose.
2. For assistance purposes: We may use service providers, agents, or contractors to provide us with support and maintenance services for our Site and to help us administer the Site or the various features, programs, and promotions on it. These third parties undertake to provide your Personal Data with the same levels of security as those offered by BVC Bodegas;
3. For joint and co-sponsored programs and for promotional purposes: When we conduct joint or co-sponsored promotional activities on our Site in partnership with other companies or trusted third parties, and, as part of this event, we collect and process Personal Data, we may share your Personal Data, subject to obtaining your consent where required by law. In the event that Personal Data concerning you is collected by, or transmitted to, a company other than BVC Bodegas as part of this promotional activity, we will inform you at the time of collecting Personal Data concerning you;
4. For legal and security purposes: We may also be required to disclose your Personal Data if the law requires us to do so or if we believe, in good faith, that such disclosure is reasonably necessary to comply with legal proceedings, respond to claims, or preserve the security or rights of BVC Bodegas, their customers, or the public;
5. In the event of a merger, acquisition, or sale of all or part of BVC Bodegas to another company or in the event of a sale or transfer by BVC Bodegas of all or part of its business, the acquirer would have access to information that may include Personal Data, subject to applicable law. Similarly, some of your Personal Data may be transferred in the context of a restructuring, insolvency proceedings, or other similar event, if permitted by applicable law and in accordance with applicable law.

6. Where, how, and why your personal data may be transferred outside the European Union?

Given the international dimension of the Advini group, and for the aforementioned purposes, your Personal Data may be transferred abroad, especially to countries that have data protection laws of a different level than those of the country in which you submitted your Personal Data. It may also happen that your Personal Data is transferred from one company of the Advini Group to another and that these two companies are located in different countries. BVC Bodegas and Advini take appropriate measures to ensure the security of Personal Data, both during transfer and at the destination, by implementing contractual clauses as prescribed by the European Commission, in accordance with applicable law.
When our service providers for the operation of the Site are based in the United States, transfers of Personal Data to these service providers are made in accordance with applicable laws and are based on standard contractual clauses, as prescribed by the European Commission, or on the Privacy Shield. These service providers are also bound by a contract that ensures a high level of confidentiality protection and requires them (among other provisions) to act only on instructions from BVC Bodegas and to constantly implement all necessary technical measures to maintain the security of Personal Data concerning you.

7. How long do we retain your personal data?

We will store your Personal Data in our databases as long as your account is active, for the duration mentioned in the contract we have entered into with you, or, as needed, to provide you with the services you desire, to address inquiries, or to resolve issues and provide enhanced and new services. We may also retain your Personal Data in accordance with our internal retention procedure to the extent necessary to comply with our legal and regulatory obligations, resolve disputes, and enforce our contracts.

We may thus be required to retain Personal Data concerning you after you have ceased to use our Site’s services, in accordance with legal requirements.

8. How do we secure your personal data?

BVC Bodegas will take all necessary technical and organizational measures to protect the confidentiality and security of your Personal Data collected via the Site. These measures include, but are not limited to: (i) storing your Personal Data in secure operating environments that are not accessible to the public and are accessible only to authorized BVC Bodegas staff and our agents and contractors, and (ii) verifying the identity of registered users before they can access your Personal Data.

9. What are your rights?

• If your Personal Data has been processed with your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
• You can request access to your Personal Data.
• You can request rectification of your Personal Data if it is inaccurate, incomplete, or not up-to-date.
• You can request the erasure of your Personal Data where: (i) the Personal Data concerning you is no longer necessary for the purposes for which it was collected, (ii) you have withdrawn your consent to processing based solely on that consent, (iii) you have objected to processing, (iv) the processing of your Personal Data is unlawful, (v) Personal Data must be erased to comply with a legal obligation applicable to BVC Bodegas. BVC Bodegas will take reasonable steps to inform other entities of the Advini Group that such erasure has been carried out.
• You can request restriction of processing: (i) if you contest the accuracy of your Personal Data to allow us to verify this accuracy, (ii) if you wish to restrict your Personal Data rather than delete it in case of unlawful processing, (iii) if you wish BVC Bodegas to retain Personal Data concerning you because you need it to establish, exercise, or defend legal claims, (iv) in case you have objected to processing but BVC Bodegas is conducting an investigation to determine whether it has legitimate grounds for such processing that may override your own rights, if processing is based on BVC Bodegas’s legitimate interests.
• You can request the portability of Personal Data you have provided to us if the processing of Personal Data is based on your consent or the performance of a contract and is implemented in an automated manner (excluding paper records).
• You always have the choice not to provide us with your Personal Data. In this case, you may be limited in the activities and features we will be able to provide you.
• You have the right to object to the processing of your Personal Data at any time for direct marketing purposes, for marketing based on profiling, or if data processing is based on BVC Bodegas’s legitimate interest (unless we can justify the existence of a legal obligation).
• You also have the right to give general and specific instructions regarding the fate of your Personal Data after your death.

10. How do we process children’s personal data?

Our Site is not intended for children who are not of legal age to consume alcohol (“Minors“), so we do not knowingly collect any Personal Data from Minors. You must be at least eighteen years old to create an account and engage in transactions on our Site. In the event that we become aware that a Minor has submitted Personal Data to us via our Site, we will delete it.

11. How to exercise your rights, contact us, or lodge a complaint with the CNIL?

For any questions, complaints, comments, or to exercise your rights, please contact us by email at the following address:
bvc@maisonbvc.com
We undertake to respond within a maximum period of one month from the receipt of your request. This period may be extended by two months due to the complexity and number of requests.
Please note that you can also submit a complaint to the Supervisory Authority of the country in which you are located if you have any doubts about the conditions of processing your Personal Data by BVC Bodegas.

In France, you can contact the Commission Nationale de l’Informatique et des Libertés (CNIL), whose website is accessible here: https://www.cnil.fr/

12. Modification of our privacy policy

We regularly review our Privacy Policy, and any updates to it will be posted on this web page.