Privacy Notice

PRIVACY POLICY

This Privacy Policy is prepared in accordance with Art. 13 and Art. 14 of Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data and repealing Directive 95/46/EC  (“GDPR”). The privacy policy aims to inform you about the processing of your personal data, the purposes of such processing, the measures and guarantees for the protection of your personal data, as well as your rights under the GDPR and the legislation of the European Union and Republic of Bulgaria.

  1. Administrator information and contact information

Administrator within the meaning of the GDPR is “Edoardo Miroglio” Ltd. (hereinafter “Administrator”), a company validly established and existing under the laws of the Republic of Bulgaria, entered in the Commercial Register under IN: BG130111513 with registered office and address in the village of Elenovo, Sliven region, 8943, 1 Lozarski stan str., where you can send your requests, inquiries and / or comments in connection with the processing of your personal data, to the attention of Tedy Iliev.

In addition, any requests, inquiries and / or comments may also be sent to the following email address: Zhivko.Kostadinov@emiroglio.com

Edoardo Miroglio Ltd. is committed to protect your personal data. If we ask you to provide certain identifiable information, you can be sure that it will only be used in accordance with this Privacy Policy.

  1. Purposes and grounds for personal data processing

Edoardo Miroglio Ltd. collects your personal data from the website www.emiroglio-wine.com. Edoardo Miroglio Ltd. processes personal data in order to fulfill product orders and provide services to its customers, as well as to improve them over time.

Edoardo Miroglio Ltd. processes your information on the following legal grounds:

  • Art. 6, para. 1, b (a) of the GDPR – your consent;
  • Art. 6, para. 1, b “b” of the GDPR – to perform a contract for the sale of goods to which “Edoardo Miroglio” Ltd. is a party, as well as for the purposes of fulfilling other contractual obligations;
  • Art. 6, para. 1, b “c” of the GDPR – when the processing is necessary to comply with a legal obligation applicable to “Edoardo Miroglio” Ltd;
  • Art. 6, para. 1, b “f” of the GDPR – based on the legitimate interests of “Edoardo Miroglio” Ltd. to process the information.

When we process data on the basis of your consent, personal data are only processed if you have freely, specifically, informed and unambiguous expressed your consent to the processing.

The processing of data is carried out for the specific and precisely defined by law purposes, lawfully and in good faith and may not be further processed in a manner incompatible with these purposes.

  1. Your rights

For your convenience, we offer a detailed description of your rights as a Data Subject:

  1. Right of access: At any time you have the right to request information about your personal data that we store, the reason, the purposes, the terms of processing and storage, whether they are provided to a personal data processor, whether they are destroyed, etc.
  2. Right to rectification: You have the right to request correction of your personal data if it is incorrect, including the addition of incomplete personal data
  3. Right to erasure (‘right to be forgotten’): You have the right to delete all personal data processed by us and our personal data processors at any time, except when processing is necessary for at least one of the following purposes, namely:
  • for exercising the right of freedom of expression and information;
  • for compliance with a legal obligation which requires processing by Union or Member State law applicable to us;
  • for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 (1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
  • for the establishment, exercise or defence of legal claims.
  1. Right to restriction of processing: You have the right to ask us to restrict the processing of your personal data in the following circumstances:
  • the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
  • the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
  • the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims;
  • the data subject has objected to processing pursuant to Art. 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.
  1. Right to data portability: When we process your personal data in an automated manner on the basis of your consent or on the basis of a contract, you have the right to receive a copy of your data in a structured, widely used and machine-readable format transferred to you or another party. This includes only the personal information you have provided to us.
  2. Right to object to the processing on the grounds of legitimate interest: You have the right to object to the processing of your personal data on the basis of our legitimate interest. We will not continue to process your personal data unless it can be demonstrated that there are compelling legitimate grounds for doing so that take precedence over your interests and rights or due to lawsuits.
  3. Right to be informed about a violation under Art. 34 of the GDPR: When the personal data breach is likely to result in a high risk to your rights and freedoms, we will, without undue delay, notify you of the breach of personal data security with a message describing the nature of the of the personal data breach and contain at least:
  • the name and contact details of the data protection officer, from whom more information can be obtained;
  • the possible consequences of the personal data breach;
  • a description of the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to reduce any adverse effects.

The above information will not be sent in the event of a security breach when we have met any of the following conditions:

  • we have taken appropriate technical and organizational protection measures, and those measures were applied to the personal data affected by the personal data breach, in particular those that render the personal data unintelligible to any person who is not authorized to access it, such as encryption or
  • we have subsequently taken measures to ensure that the high risk to the rights and freedoms of data subjects is no longer likely to materialize; or
  • notification would lead to disproportionate efforts.

In the latter case, we will publish a message on our site so that data subjects are equally effectively informed.

Please note that you may not be able to take advantage of all features or our services if you request the deletion of your information, objections or withdraw your consent to the processing of information.

In addition to the above, you can exercise your rights under this item 3 by sending a written application to Edoardo Miroglio Ltd. at the address or e-mail specified in item 1 above.

Please note that when your requests are manifestly unfounded or excessive, in particular due to their repetitive nature, we may:

  1. to impose a fee, taking into account the administrative costs of providing the information or communication or taking the requested action, or
  2. to refuse to take action on the request.

We will use reasonable efforts to comply with your request within 30 days of receiving your request. If necessary, this period may be extended by another two months, taking into account the complexity and number of requests.

  1. Right of appeal to the Commission for Personal Data Protection and to the court

If you believe that your rights have been violated, you have the right to lodge a complaint with the Data Protection Commission or the competent administrative court.

More information can be found at: www.cpdp.bg.

  1. Your user profile on the website emiroglio-wine.com

 

You can register at www.em-wine.com by creating a user profile where you will see information about the history of your orders, as well as your personal information. The information in your user profile on the website www.em-wine.com is not publicly available or accessible to third parties. When registering a user profile, you provide us with the following personal data:

– Two names;

– Email;

– Phone number;

– Shipping address;

– History of orders;

When visiting the site, whether as a user with a registered user profile or without registration of a user profile, we collect information about the fact that each visitor to the site is 18 years old by checking the appropriate section of the site.

The information in your account may be used to fulfill your orders or for other purposes, as may be applicable under this Data Protection Policy.

  1. Erase your user account

 

If you are a registered user, we provide you with account settings to access or change the personal information you provide to us that is related to your account.

You can withdraw your consent to our Privacy Policy at any time by deleting your profile. This can be done from the Account Settings section of our website www.emiroglio-wine.com.

When you delete your account, your personal information will be deleted from our systems. Please note that even after deleting your account, we may need to process a limited amount of your personal data in order to fulfill our legal obligations – such as those related to the accounting of business transactions. Content that may be completely anonymous will not be deleted, but will no longer be able to link to your deleted account and will no longer lead to you.

 

  1. Communication and direct marketing

When you register on the website www.emiroglio-wine.com you need to provide an e-mail address. We may use your email address for direct marketing purposes and thus send you information about our products when you have given your consent through the appropriate checkbox when registering your profile. Your email address will also be used for direct marketing purposes when you register it on our website www.emiroglio-wine.com to receive the latest news and offers.

You can unsubscribe at any time and absolutely free of charge from any communication, notifications or emails sent from the website www.em-wine.com. All emails we send will contain a link to unsubscribe directly.

Unsubscribing from communication with us will be interpreted as an objection to the processing of your personal data, insofar as this is related to direct marketing.

We do not provide / sell your communication data to third parties and by registering on the website www.emiroglio-wine.com, you will receive information only from www.emiroglio-wine.com and no one else.

  1. Information you provide on the website www.em-wine.com

When you create or change the configuration of your user profile on the website www.emiroglio-wine.com, you provide us with certain personal data such as your name, surname, username and e-mail address.

The information in your profile is not publicly available. Your username and the information you use in your account cannot be found by search engines.

If you are not a registered user, when you buy wine from the online store www.emiroglio-wine.com, you must provide the information necessary to ensure receipt of the goods by you, as well as the smooth performance of our services within your expectations. This information contains:

  • The wine you ordered
  • Your name and surname
  • Your postal address or courier office
  • Phone number
  • Email address
  • Payment information
  • Delivery preferences

When you sign up on www.emiroglio-wine.com for our newsletter, you will only need to provide your email address.

  1. Information we collect about you through cookies

When you use the website and e-shop www.emiroglio-wine.com , we use digital tracking tools, such as cookies, to track your actions. We do this to detect bugs and errors in our systems, to understand which features are popular and unpopular, and to make recommendations that meet your preferences.

Cookies are small pieces of data that are sent to your browser from a web server and stored on your device so that the site can recognize your computer. There are two types of cookies – permanent and temporary or “session” cookies. Permanent cookies are stored as a file on your computer or mobile device for a long time. Session cookies are temporarily placed on your computer when you visit our Site, but disappear when you close the page, which means that they are not stored permanently on your device. Most companies use cookies on their websites to improve usability. Cookies cannot harm your files or increase the risk of viruses on your computer.

We may use the following types of cookies:

  • Functional

– To remember your preferences

– To provide multimedia content according to your technical needs

– To keep your authentication data

  • Cookies for better performance and strategic goals

–  To see how visitors use our site and e-shop

– Learn more about the movements of our users between pages

– To improve our website and e-shop and adapt them according to user preferences

  • Cookies for marketing purposes

– To make ads, content or online banners even more relevant to you and your specific interests.

– Create online advertising that engages the right people with the right information.

– To prevent the same ads from running all the time

  • Strictly necessary cookies:

– To allow you to move forward and backward between pages without losing previous actions from the same session

–  To be possible to balance the load for better performance of our website

– To remember your previous actions on the website, such as your previous consent to cookies

We use cookie information to make our websites more user-friendly and easier to use, and to provide you with personalized recommendations.

You can choose whether to accept cookies or not. If you want to know when your device receives a cookie, you can set your browser to notify you. This allows you to accept or decline a cookie. Your computer can be set to reject all cookies. If you want to know how to do this, visit www.aboutcookies.org. Please note that changes to your browser that disable the cookie feature, may prevent parts of our site from functioning properly, including the login feature.

Our servers automatically record information created by you when you use our services (“Visit Information”). Visit information may include data such as your IP address, your browser type, operating system, referral page, pages visited, location, mobile device, search terms and cookie information. We receive information about visits when you use our services, for example, when you visit our website and e-shop, register to use our services, or interact with our email notifications. We use Visit Information to provide, measure, customize and improve our services. Information about the visits will be stored for 6 months.

  1. Revealing personal data to third parties

We may engage suppliers to provide us with certain services (accountants, lawyers, auditors, etc.). These providers have the quality of personal data processors. We may share your personal information with such service providers, subject to our privacy obligations under this Privacy Policy and provided that they use your personal information only on our behalf and in accordance with our instructions.

We do not disclose personal data to third parties and recipients unless there is a legal basis for obtaining the data or the data is not publicly available due to its inclusion in a public register.

Apart from the cases of general availability of the data included in a public register, recipients of data according to the specific case may be:

  • State authorities and authorities entrusted with public functions, within their powers (NRA, NSSI, Ministry of Interior, etc.);
  • Banks – for the needs of the payments made;
  • Courier companies and postal operators – for the needs of deliveries and correspondence with individuals – data subjects

We do not transfer processed personal data to third countries outside the European Economic Area.

  1. Term for storage of personal data

We will store your personal data no longer than is necessary to achieve the purposes listed in this Privacy Policy and / or in accordance with the requirements of applicable law, incl. compliance with applicable legal provisions regarding minimum retention periods and / or, if necessary, the exercise of our legitimate rights (and those of third parties). For example, the personal data you provide to us in connection with orders and deliveries of wine are stored for a period of 5 years after the end of the last delivery, and this period is consistent with the limitation period for possible claims by / against us related with the relevant deliveries. When your Personal Data is contained in accounting documents on paper or electronic media, which may be required for the needs of tax control, the period of storage of this personal data will be 10 years. If you need additional information about how long we store your personal data, contact us at the addresses listed in item 1 above.

When we process your personal data on the basis of consent, this personal data will only be processed for the period for which your consent has been granted, unless you have withdrawn or limited your consent before the expiry of this period. In these cases, we will suspend the processing of the personal data concerned for the respective purposes, in compliance with the legal obligations regarding the processing of personal data and / or obligations arising from the need to process this personal data in order to exercise our legitimate rights.

  1. Our child-protection Policy

Our services are not intended for persons under the age of 18 years and we deliberately do not process data from such individuals. If you find that your child has provided us with personal data without your consent, please contact us at the address listed in item 1 above.

  1. Privacy Policy Changes

We may review this Privacy Policy from time to time. The most current version of the Policy will regulate the use of your information and will always be available at www.emiroglio-wine.com and if we make a change in these policies, which in our opinion is significant, we will notify you by email, associated with or provided by your account. By continuing to access your account or using our services, once these changes have taken effect, you agree to be bound by the revised Privacy Policy.