Privacy Policy

In light of the legal provisions established by European and national legislation, the company we represent undertakes to protect your personal data when we process this data, in relation to our main object of activity. Before sending us your personal data, we encourage you to read this privacy policy and the terms and conditions contained therein. This document will provide you with information on how our company processes personal data

as part of the process of providing our services. The confidentiality of your personal data is one of the main concerns of Rewine S.R.L., as a data operator. This document has the role of informing you about the processing of your personal data, in the context of using the website www.finewineselection.com. (the "Website")

2.1. If you are a customer of the Website, Rewine S.R.L. will process your personal data, such as name and surname, telephone, e-mail address, billing address, delivery address, data on how you use the Website, for example your behavior / preferences / habits within Rewine S.R.L., as well as any other categories of data that you provide directly in the context of creating the user account, in the context of placing an order through the Website or in any other way resulting from the use of the Website. If you use your Facebook or Google account to create a user account on the Website, Rewine S.R.L. will process the following public profile data displayed by the respective applications: username, e-mail address. If you choose to create a user account just before completing the order for a product available on the Website, your e-mail address will be requested based on which an account will be created automatically. If you do not complete the order, the e-mail address and other data provided will not be stored by Rewine S.R.L., and the account created will be deleted automatically. II.2. If you are a visitor to the Website, Rewine S.R.L. will process your personal data that you provide directly in the context of using the Website, such as the data that you provide in the contact / questions / complaints section, to the extent that you contact us in this way. The entity you have contacted is the data controller regarding the personal data received and processed in connection with you, as part of the performance of the activities provided by the company to / against you or in connection with the commercial relations arising from any commercial agreement, agreement or any other existing legal relationship between the parties. When you contact Rewine S.R.L., we will process your information, including the personal data you have revealed to us or the

details regarding the shipment, such as name, surname, telephone number, postal address or e-mail address or other information. We recommend that you do not disclose sensitive personal data, other than those necessary for the development of existing legal relations between the parties, such as data that reveal racial or ethnic origin, religion, union membership, sexual orientation, health, etc. Rewine S.R.L. may also receive personal data about you from other data controllers for the purpose of fulfilling its legal obligations or the objectives set by the parties based on the legal relationships between them and for the purpose, provision or assistance by Rewine S.R.L. through the activities carried out or requests to or from you as the final beneficiary of a certain activity or service in connection with and in accordance with the activity of the company we represent. Rewine S.R.L. will process your personal data in accordance with the European and national legislation in force at the time of processing your data. Please note that personal data may be processed on a different legal basis, such as consent, contract, legal obligation, protection and pursuit of legitimate interests, etc. The legitimate interest could be for purposes related to the specific trade activity but also for activities specific to the activity of the commercial company and for promotion and marketing purposes. If, in exceptional circumstances, you provide Rewine S.R.L. personal data classified as sensitive personal data or personal data, Rewine S.R.L. will be obliged to process this sensitive personal data, only in accordance with the national and European legislation applicable and in force at the time of processing, for which your express consent is required first.

3.1. If you are a customer of the Website, Rewine S.R.L. processes your personal data as follows: A. for the proper implementation of the contractual relationship between you and Rewine S.R.L., respectively for taking over, validating, sending and invoicing the order placed on the Website, informing you about the status of the order, organizing the return of products ordered etc.; B. in order to fulfill the legal obligations incumbent on Rewine S.R.L. in the context of the services provided through the Website, including the obligations in fiscal matters, as well as in archiving matters. The processing of your data for this purpose is necessary based on legal obligations. Providing your data for this purpose is necessary and the refusal to provide data may result in the impossibility of Rewine S.R.L. to comply with its legal obligations and therefore unable to offer you services through the Website; C. for marketing activities, respectively for the transmission, through the means of e-mail and sms of commercial communications regarding the products and services offered by Rewine S.R.L., through the Website. The processing of your data for this purpose is based on your consent, if you choose to provide it. You can give your consent for the processing of data for this purpose by checking the appropriate box when you create your account, or after account creation, in the My Account Information section. In order to unsubscribe from receiving such commercial communications you can use the option at the end of each e-mail / sms containing commercial communications. In addition, you can unsubscribe by accessing the My Account Information section. Providing your data for this purpose is voluntary. Refusal to provide consent for the processing of your data for this purpose will not have negative consequences for you; D. in order to perform various analysis, reports on the operation of the Website, the creation of profiles of consumer preferences, mainly in order to improve the user experience offered on the Website. The processing of your data for this

purpose is based on the legitimate interest of Rewine S.R.L. to permanently improve the user and costumer experience on the Website. Providing your data for this purpose is voluntary. Refusal to provide data for this purpose will not have negative consequences for you.

3.2. If you are a visitor to the Website, Rewine S.R.L. processes your personal data as follows: A. for marketing activities, respectively for the transmission, through the means of distance communication (e-mail, sms), of commercial communications regarding the products and services offered by Rewine S.R.L., through the Website. The processing of your data for this purpose is based on your consent, if you choose to provide it. You can express your consent for the processing of data for this purpose by filling in and checking the corresponding box in the form for subscribing to the newsletter available on the Website. To unsubscribe from receiving such commercial communications you can use the option at the end of each e-mail / sms containing commercial communications. Providing your data for this purpose is voluntary. Refusal to provide consent for the processing of your data for this purpose will not have negative consequences for you; B. in order to resolve complaints, grievances and to monitor traffic and improve your experience on the Website. The processing of your data for this purpose is based on the legitimate interest of Rewine S.R.L. to ensure the correct functioning of the Website, as well as to permanently improve the experience of the visitors of the Website, including by solving various comments, questions or complaints. Providing your data for this purpose is voluntary. Refusal to provide data for this purpose will not have negative consequences for you. To the extent that you have expressed your consent to certain processing, you have the right to withdraw it at any time.

4.1. As a principle, Rewine. S.R.L. will process your personal data to the extent necessary to achieve the processing purposes mentioned above. In case you are a customer, we will process your data for the entire duration of the contractual relations and subsequently according to the legal obligations incumbent on Rewine S.R.L. (eg, in the case of financial-accounting documents, for which the retention period provided by law is ten (10) years from the date of the end of the financial year during which they were prepared).

4.2. If you are a customer and you exercise the option to delete the user account, by clicking the Delete account button in the My Account Information section, Rewine S.R.L. will interpret this action as your option to unsubscribe from receiving commercial communications by which we keep you informed about the products and services offered on the Website. In this sense, if you choose to delete your user account, we will no longer send you such emails and / or text messages. However, we would like to inform you that deleting your account will not automatically have the effect of deleting your personal data. If you no longer wish to have your personal data processed or if you wish to have your data deleted, you may exercise the rights set out in point VII below. If you request the deletion of your account

but you have an active order, the account deletion request will be registered only after the delivery of the products and the completion of the last active order.

4.3. If you withdraw your consent for the processing of data for marketing purposes, Rewine S.R.L. will cease to process your personal data for this purpose, without affecting the processing carried out by Rewine S.R.L. based on the consent expressed by you before its withdrawal.

4.4. Your personal data is processed for as long as necessary to fulfill the purposes mentioned above and in accordance with applicable law, especially if you have issued orders to or you have entered into a contract with Rewine S.R.L. or if Rewine S.R.L. has received personal data about you from customers with whom you have / have concluded a contract. Personal data are stored for processing for the time necessary and sufficient to achieve the purposes of processing mentioned above and subsequently according to the requirements of our internal policies and in accordance with legal requirements. It is also important to mention that some personal data are stored in order to comply with the rules in force regarding the type of document or the specific activity from which these data result.

5.1. For the purposes of processing, Rewine S.R.L. may disclose your data to partners, third parties or entities that support Rewine S.R.L. in carrying out the activity through the Website (for example courier companies, IT service providers), or to the central / local public authorities, as follows: a) for the administration of the Website; b) in situations where this communication would be necessary for the awarding of prizes or other facilities to the persons concerned, obtained as a result of their participation in various promotional campaigns organized by Rewine S.R.L. on the Website; c) for the maintenance, personalization and improvement of the Website and of the services carried out through it; d) in order to performi data analysis, testing and research, monitoring usage and activity trends, developing security features and user authentication; e) for the transmission of commercial and marketing communications, under the conditions and limits provided by law; f) when the disclosure of personal data is required by law, etc.

5.2. Your personal data (notion as it is defined and specified by the legal norms in force) may be shared with certain service providers or agents and service providers motivated by the specifics of the commercial activity carried out by the legal entity data operator. Any third party supplier used / contracted by Rewine S.R.L. will be obliged to process your personal data only in accordance with the instructions issued by Rewine S.R.L. and in order to maintain a reasonable security of your personal data. V.2. Also, the Rewine S.R.L. may transmit your personal data to legal partners or third party suppliers, such as other providers with the same field of activity as Rewine S.R.L., in order to offer you the specific services performed by the company.

5.3. In certain circumstances and in accordance with the relevant legislation in force, the company may be in a situation or obliged to communicate or disclose data to state authorities or institutions, related to the specifics of the activity of these institutions. We may also disclose your personal data to establish, exercise or defend our legal rights.

5.4. In case of a reorganization or a total or partial sale of the company's activity, the disclosure, if applicable, will take place in accordance with the legislation applicable periodically, which regulates the processing personal data.

5.5. Your personal data may be communicated to other companies in the group to which the company belongs, if applicable. Such group companies include companies located in non-EU / EEA countries that cannot provide the same level of data protection as EU / EEA countries. Before transferring your personal data to other companies in the company group or to third parties located outside the EU / EEA, the relevant entity of the group will conclude a transfer agreement with this beneficiary on the basis of the European Commission's standard contractual clauses to ensure an adequate level of data protection in connection with such transfers outside the EU / EEA.

5.6. In the context of fulfilling the processing purposes, Rewine S.R.L. may disclose the data thus collected to its legal or contractual partners, to its affiliates, to authorized persons who process your personal data on behalf of Rewine or to the central / local public authorities, in the following cases: for the administration, maintenance, personalization and improvement of this website and of the services provided through them; for the fulfillment of some contractual obligations by Rewine, such as customer service, printing and invoicing, etc .; in situations where this disclosure would be necessary for the awarding of prizes or other facilities, obtained as a result of your participation in various games or contests of a promotional nature, or other promotional campaigns organized by Rewine; in case of promotional campaigns organized by Rewine together with various contractual partners or affiliates of the company operating personal data; in order to perform data analysis, testing and research, monitoring usage and activity trends, developing security features and user authentication; for the transmission of advertising / promotional materials, under the conditions and limits provided by law; when the disclosure of personal data is provided by law.

Personal data provided to Rewine can be transferred outside Romania, but only to European Union countries.

7.1. Under the conditions provided by the legislation on the processing of personal data, as data subjects, you benefit from the following rights: the right for information, respectively the right to receive details regarding the processing activities performed by Rewine, according to those described in this document; the right of access to data, respectively the right to obtain confirmation from Rewine regarding the processing of personal data, as well as details regarding the processing activities such as the way in which the data are processed, the purpose for which the processing is done, the recipients or categories of recipients of the data, etc .; the right to rectification, respectively the right to obtain the correction, without justified delays, by Rewine of inaccurate / unjustified personal data, as well as the completion of incomplete data; the rectification / completion will be communicated to each recipient to whom the data were transmitted, unless this proves impossible or involves disproportionate effort. the right to delete data, without undue delay, ("right to be forgotten"), if one of the following reasons applies: they are no longer necessary for the purposes for which they were collected or processed; if the consent is withdrawn and there is no other legal basis for processing; if the data subject opposes the processing and there are no legitimate reasons to prevail; if the personal data have been processed illegally; if the personal data must be deleted in order to comply with a legal obligation; personal data have been collected in connection with the provision of information society services in accordance with EU law or national law under the incidence of the operator. It is possible that, following the request to delete the data, Rewine to anonymize these data (thus depriving them of personal character) and to continue in these conditions the processing for statistical purposes; the right to restrict processing to the extent that: the person disputes the accuracy of the data, for a period that allows us to verify the correctness of the data; the processing is illegal, and the data subject opposes the deletion of personal data, requesting instead the restriction of their use; the operator no longer needs the personal data

for the purpose of processing, but the data subject requests them for the ascertainment, exercise or defense of a right in court; or the data subject objected to the processing (other than direct marketing), for the period of time in which it is verified whether the legitimate rights of the operator prevail over those of the data subject. the right to data portability, respectively (i) the right to receive personal data in a structured, commonly used and easy-to-read format, and (ii) the right to have such data transmitted by Rewine S.R.L. to another data controller, insofar as the conditions provided by law are met; the right to object: regarding the processing activities the customer can exercise this right by sending a request according to those indicated below; at any time, for reasons related to the particular situation of the data subject, for the data concerning him to be processed on the basis of the legitimate interest of Rewine or in the public interest, unless Rewine can demonstrate that it has legitimate and compelling reasons justifying the processing and prevailing over the interests, rights and freedoms of the data subjects or that the purpose is to establish, exercise or defend a right in court; at any time, free of charge and without any justification, that the data concerning it be processed for the purpose of direct marketing; the right not to be subject to an automatic individual decision, respectively the right not to be the subject of a decision taken solely on the basis of automatic processing activities, including the creation of profiles, which produces legal effects concerning the data subject or affects him similar to a significant extent; the right to address to the National Authority for the Supervision of Personal Data Processing or to the competent courts, insofar as it deems necessary.

7.2. For any additional questions regarding the way in which personal data are processed and to exercise your rights mentioned above, please contact the email address: info@finewineselection.com.

7.3. This website uses cookies. For more information on how these files are used, please access the following link: COOKIES FILE POLICY.

8.1. Any consent you have given us during the process can be withdrawn at any time by a message (see contact details below). You also have the right to access the personal data processed in connection with you, subject to certain legal exceptions. In addition, you may challenge the collection and further processing of your personal data. Rewine does its best to protect the personal data of its partners.

8.2. Considering the introduction of the General Regulation on Data Protection (GDPR) starting with May 25, 2018, we assure that Rewine will strictly observe all newly introduced internal and European legal rules and regulations. All confidential data collected by Rewine will

be processed or transmitted for the processing of personal data in accordance with the legal rules in force and for fulfilling mutual objectives and obligations.

8.3. Rewine will apply in the use of your personal data the necessary and sufficient technical and organizational measures in order to ensure their security, protection against accidental or illegal destruction, modification, disclosure or unauthorized access.

9.1. When you contact Rewine, an exchange of information takes place. Among them, there may be personal data such as: name, surname, telephone numbers, e-mail addresses, transport details, collection or delivery addresses, data of any type but of personal nature.

9.2. Rewine wishes to further process the personal data provided in order to transmit to you information related to price offers, the stage of a transport, invoicing or any other information necessary for the smooth running of the

partnership between you and our company. For this we need your clear written consent in order to continue to use the data mentioned above.

9.3. Rewine guarantees that your personal data will be corrected, if necessary or expressly requested, will be deleted in certain circumstances but in compliance with legal provisions on the protection of personal data established by European and national legal norms.

If you wish to exercise any of your rights or if you have questions about this privacy policy or about the processing of your personal data, you can contact our DPO: RC Legal Industrial Consult S.R.L. - D.P.O., e-mail: legal.industrial.consult@gmail.com, tel: 0786 - 886.882 Complaints If you

wish to submit a complaint regarding the processing of your personal data, you can contact us by e-mail, telephone or letter, as indicated above. You can also file a complaint with your local data protection agency/authority