PRIVACY POLICY

We take your right to privacy very seriously when you use our websites, our mobile applications, our pages on social networks, online forms and whenever else you communicate electronically with us (our “Digital Services”). That’s why we’ve developed this Privacy Policy to explain how we collect, store, use and process the Personal Data you share with us through our Digital Services.

Please read this Privacy Policy carefully as it contains important information on who we are and how and why we collect, store, use and share your Personal Data. It also explains your rights in relation to your Personal Data and how to contact us or the relevant supervisory authorities in the event you have a complaint. If you do not agree to this Privacy Policy or our Cookies Policy, please do not use our Digital Services.

“We”, “us” and “our” refer to Portofoliowines


We are the data controller when processing your Personal Data on the conditions described in this Privacy Policy, which includes any Personal Data you submit to this website or another website that links you to this Privacy Policy, such as a microsite that we use to run a promotion or competition (the “Website”).

Topics

1. What Personal Data do we gather about you and how do we collect it?
2. How and why do we use tracking technologies?
3. For what purposes do we use your Personal Data and on which legal grounds?
4. What happens if you do not wish to provide your Personal Data?
5. Who do we disclose your Personal Data to and why?
6. How do we keep your Personal Data secure?
7. What are your rights regarding Personal Data?
8. How do we treat children's information?
9. How can you contact us or lodge a complaint to the relevant supervisory authority?
10. Changes to our Privacy Policy

1. What Personal Data do we gather about you and how do we collect it?

Personal Data means any information that can be used to personally identify you or contact you online or elsewhere. 

We may collect and use the following Personal Data about you:

  • your name and contact information, including postal address, email address and telephone numbers.

  • information to enable us to check and verify your identity, e.g. your date of birth

  • your gender information, if you choose to give this to us

  • location data

  • your personal or professional interests, household, lifestyle, habits and preferences

  • information from accounts you link to us, e.g. Facebook

  • information about how you use our website, IT, communication and other systems

  • your responses to surveys, competitions and promotions

  • your IP address and your mobile/tablet/device ID

  • information provided to us for your attendance at events, including which events you attend as well as information about access or dietary requirements.

The types and amount of information collected for the above-mentioned features and services may be updated and vary depending on the activities of Portofoliowines

Personal Data we collect from you

We collect most of this Personal Data directly from you - in person, by telephone or email and/or via our website and apps. This usually occurs when you take part in one of our promotional activities or subscribe to one of our Digital Services, for example:

  • Registration or sign-up online: e.g. mobile app, websites, social media or subscribing to a newsletter specific to our Digital Services or creating an account to be a member of a club;

  • ‘Send to a friend’ marketing communications;

  • Sweepstake and contest;

  • When doing e-commerce on certain of our websites;

  • Using a QR Code displayed on products;

  • Events (invitation forms or online forms on tablets filled out by our representatives with your input);

  • Tastings;

  • Brand Home;

  • Feedback, questions, enquiries, surveys or comments through ‘Contact us’;

  • Any other request that requires the submission of Personal Data.

The type and amount of information we collect for the features listed above will vary and depends on the activity.

Personal Data we collect from other sources

We may also collect information:

  • directly from a third party, e.g.: “Send to a friend” marketing communications or a third party sign-up form from one of our partners;

  • from a third party with your consent, e.g. your bank

  • from cookies on our website (see below, How and why do we use tracking technologies?)

  • via door entry systems and reception logs;

  • from automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems; or

  • from one of our Portofoliowines affiliates.

Subject to applicable law requirements, we may use a variety of technologies that collect and provide information about how our Digital Services is accessed and used by you. We may also use demographic information about the users of our Digital Services, which we may obtain from third parties such as Google or social media that you use (“Usage Information”).

Usage Information may consist of the pages you viewed, the time you viewed them, which beverage information or other content you accessed or provide, in what language, including demographic information about you (such as your age, gender and interest areas, where available) and what pages you looked at before viewing the current page, etc. We collect this information to gain a better idea of how people interact with our brands so we can then tailor and improve them accordingly. Most Usage Information that we collect can't be linked to you individually, but if we can link it to you, then we treat it in accordance with this Privacy Policy.


2. How and why do we use tracking technologies?

We use tracking technologies such as cookies, IP address recording or log files, to gather technical information such as your web browser type and which operating system you use, the webpage you came from, your path through our website and your Internet Service Provider. This is so we can improve the functionality of our websites and better understand how visitors like you use our Digital Services and the tools they offer.

Often, individuals will interact with us in multiple ways and will provide us with personal information in different contexts. We may use your personal information to obtain a profile of your different interactions with us and to understand your preferences.

These tracking technologies help us tailor our Digital Services to your personal needs:

  • Subject to your consent where required by applicable law, our Digital Services use cookies and similar technologies (“Cookies”). Cookies are small files that are placed on your device that serve a number of purposes like letting you navigate between pages efficiently, remembering your preferences, and generally improving your experience. The use of cookies on our Digital Services allows you to enjoy more seamless visits and more accurately measures your behavior on our Site. You can learn more about the cookies we use and how you can disable cookies in the Cookies Policy.

  • An IP address is a number that is used by computers on the network to identify your computer every time you log on to the Internet. We may keep track of IP addresses to (among other things): (i) troubleshoot technical concerns, (ii) maintain website safety and security, (iii) restrict access to our Digital Services to comply with applicable law or contractual restrictions, and, (iv) better understand how our Digital Services is used;

  • We (or a third party on our behalf) may collect information in the form of logs files that record activity on the Digital Services and gather statistics about users' browsing habits. These entries are generated anonymously, and help us gather (among other things) (i) a user’s browser type and operating system, (ii) information about a user’s session (such as the URL they came from, the date and time they visited our Digital Services, and which pages they've viewed on our Digital Services and for how long), and, (iii) other similar navigational or click-stream data. We also use information captured in log file for our internal marketing and demographic studies, so we can constantly improve and customize the online services we provide you. Log files are used internally only, and are not associated with any particular user.

3. For what purpose do we use your Personal Data and based on which legal grounds?

Under data protection law, we can only use your Personal Data if we have a proper reason for doing so, e.g.:

  • To comply with any legal and regulatory obligations.

  • Respond to your request of service or for the performance of a contract:

o When you register or sign-up in our Digital Services (mobile app, websites, social media, etc.), your Personal Data is used to provide you with the relevant features and services you subscribe to, and to offer you the benefits and privileges that typically come along with your registration (e.g. receiving the communications you select at the time of registration, being invited to events, participating in a sweepstake, etc.);​

  • Send you transactional or administrative communications: (e.g. confirmation email when you sign up for, or unsubscribe from, a specific registration or activity), as well as certain service-related announcements (e.g., notices about updates to our privacy notices, discontinued features or programs on our Digital Services, changes to our online services or technical support policies, or other related changes).

  • Allow us to send you marketing information when you consent:

o In addition to the purpose for which you submitted your Personal Data, you may also be given the option (through a check box or otherwise) to have your Personal Data used for an activity or service different from the primary activity or service that you are requesting. For example, if you are signing up for a contest or other promotion, you may also be invited to sign up for newsletters or alerts from our Digital Services hosting the promotion or from other websites. If you choose to receive these additional services, we will use your Personal Data to provide them to you.

o When you use the “Send to a friend” feature: this Personal Data is used only once to send the communication and is not further retained by us, as appropriate according to local law;
o When you use a QR Code or equivalent feature displayed on Portofoliowines products: we use your Personal Data to send you more information on the products where the QR code or equivalent feature is displayed or other products;

  • Because it is also Porotfoliowines legitimate interest to better serve you:

o Subject to your consent when required, we may occasionally combine, update, or otherwise enhance the Personal Data collected through our Digital Services with data we receive from outside records or third parties. For instance, we may combine purely demographic or survey information (e.g. age, gender, household information, and other interests, etc.) not linked to any Personal Data about you with Personal Data collected though our offers (such as during account registration).

We may use the combined above-mentioned information and/or demographic information for our internal marketing and demographic studies and to constantly improve, personalize, and customize the products and services we provide you to better meet your needs. Some of the tools we use may involve automated individual decision-making subject to applicable law.

Feedback, questions, or comments through our “Contact Us” form and our “Tell Us” compliance reporting system: if you contact us via an online contact form, your Personal Data is used to respond to your inquiry or comment.

o We will ensure that your Personal Data remains accurate and up-to-date and avoid duplication in our database, by verifying each of your interactions with us and/or one of our affiliates to ensure your Personal Data is still accurate or needs to be completed or updated with the additional information you will have provided.
o We may conduct profiling based on monitoring your browsing activities on our Digital Services to better understand your preferences and center of interests and adapt our marketing communications to your profile, unless you object in the conditions set forth in Section 9 of this Privacy Policy.

We may process Personal Data involving automated decision making, including for the performance of a contract (e.g. avoid fraudulent payment) or subject to your explicit consent, to better serve your needs in accordance with your preferences.

Please note that the automated tools used are regularly checked to ensure that the Personal Data is processed fairly. Specific measures such as data minimization are implemented when creating profiles. You are invited to express your point of view through the right of access described above. You can also object the result of the automated decision by sending an email to the contact details in Section 11 below.


4. What happens if you do not wish to provide your Personal Data?

If you choose not to submit any Personal Data when requested, you may not be able to participate in certain activities and personalized features, or the Digital Services and special offered to you may be limited. For example, if you refuse to share your email address, you will not be able to receive our newsletters or otherwise register on our Digital Services. However, to simply browse our Digital Services and learn more about Portofoliowines and our products, you do not need to give us any Personal Data. In any event, we will always inform you of the Personal Data that is necessary in order to benefit from a service.


5. Who do we disclose your Personal Data to and why?

We will never share your Personal Data with any third party that intends to use it for direct marketing purposes, unless we have specifically told you and you have given us explicit permission to do this.

  • Within Portofoliowines 

  • We may share your Personal Data for the purposes mentioned in Section 2 and Section 3 within Portofoliowines, including its affiliates worldwide.

  • With third parties


6. How do we keep your Personal Data secure?

We take all necessary technical and organizational measures to protect the confidentiality and security of your Personal Data collected from this website and/or our applications, including sensitive Personal Data. These efforts include but are not necessarily limited to: (i) storing your Personal Data in secure operating environments that are not available to the public and that are only accessible to Portofoliowines

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.


7. What are your rights regarding your Personal Data?

  • If your Personal Data has been processed on the basis of your consent, you can withdraw your consent at any time, without impact on lawfulness of processing based on consent before its withdrawal.

  • You can request to access your Personal Data.

  • You can request to rectify your Personal Data if it is inaccurate, incomplete or out of date.

  • You can request the erasure of your Personal Data (i) if your Personal Data is no longer necessary for the purpose of the data processing, (ii) you have withdrawn your consent on the data processing based exclusively on such consent, (iii) you objected to the data processing, (iv) the Personal Data processing is unlawful, (v) the Personal Data must be erased to comply with a legal obligation applicable to Portofoliowines. Portofoliowines will take reasonable steps to inform the other entities of the Portofoliowines of such erasure.

  • You can request the restriction of the processing (i) in the event the accuracy of your Personal Data is contested to allow Portofoliowines to check such accuracy, (ii) if you wish to restrict your Personal Data rather than deleting it despite the fact that the processing is unlawful, (iii) if you wish Portofoliowines to keep your Personal Data because you need it for your defense in the context of legal claims (iv) if you have objected to the processing but Portofoliowines conducts verification to check whether it has legitimate grounds for such processing which may override your own rights (v) if the data processing is based on the legitimate interest of Portofoliowines.

  • You can request the portability of the Personal Data you provided to us, in particular if the Personal Data processing is based on your consent or the performance of a contract.

  • You always have the option not to share any of your Personal Data with us. If you choose this option, you may be limited in the activities and features we can provide you.

  • You have the right to object to the processing of your Personal Data by us, including for marketing purpose based on profiling, or if the data processing is based on the legitimate interest of Portofoliowines (except if we can demonstrate compelling legal grounds for the processing).

According to the local law, you have also the right to give general or specific instructions on how your personal data processed under this Privacy Policy may be used after your death.


8. How do we treat children's information?

Our webpage are not intended for children under the age of majority (“Minor”), so we do not knowingly collect Personal Data from Minors. You must be at least twenty five years old to visit our page. By entering the site, you confirm that you are at least tewnty five years old.  If we are notified or learn that a Minor has submitted personal data to us through our Digital Services, we will delete their Personal Data.


9. How can you contact us?

If you have any questions, complaints, or comments regarding this Privacy Policy or our information collection practices, please contact us by  email to: info@portofoliowines.se

 

We hope that we can resolve any query or concern you may raise about our use of your information. You also have the right to complain to the Supervisory Authority in the European Union where you work, normally live or where any alleged infringement of data protection laws occurred.


10. Changes to our Privacy Policy

We keep our Privacy Policy under regular review and we will place any updates on this web page.

This Privacy Policy was last updated in May 2020.