PRIVACY POLICY

PRIVACY AND DATA PROTECTION POLICY

Whilst respecting the provisions of current legislation, Bodegas Góngora (hereinafter referred to as the Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Laws that incorporate this privacy policy

This privacy policy is adapted to the existing Spanish and European regulations regarding the protection of personal data on the Internet. In particular, it respects the following rules:

Regulation (EU) 2016/679 of the European Parliament and of the Council, of the 27^th of April, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data (GDPR).

Organic Law 3/2018, of the 5^th of December, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).

Royal Decree 1720/2007, of the 21^st of December, which approves the Regulations for the development of Organic Law 15/1999, of the 13^th of December, on the Protection of Personal Data (RDLOPD).

Law 34/2002, of the 11^th of July, on Services of the Information Society and Electronic Commerce (LSSI-CE).

The identity of personal data controller

The controller in collecting and processing the personal data in Bodegas Gongora is José Gallego Góngora, S.A., with TAX ID number A-41026428 and registered with COMMERCIAL REGISTRY of SEVILLE with the following registration information in VOLUME 236, BOOK 92, SECTION 8^th for COMPANIES, PAGE 139, SHEET 6.113, 1st REGISTRATION, whose representative is José Gallego Góngora, S.A. (hereinafter referred to as responsible for data processing) and whose contact details are as follows:

Address: C/ Stmo. Cristo de la Vera Cruz, num. 59. Zip code 41808. Villanueva del Ariscal, Seville. Spain

Contact telephone number: +34 954 11 37 00

Contact email: atencionalcliente@bodegasgongora.com

Personal Data Registration

In fulfilment of the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Bodegas Góngora, through the extended forms on its pages, will be incorporated and will be processed in our file so as to be able to facilitate, streamline and fulfill with the commitments established between Bodegas Góngora and the User or the maintenance of the relationship established in the forms that the User fills out, or to respond to a request or enquiry from the User. Furthermore, in fulfilment of the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in article 30.5 of the GDPR is applicable, a record of treatment activities is maintained that specifies, according to its purposes, the data processing activities carried out and all other circumstances established in the GDPR.

Principles applied to the processing of personal data

The processing of the User’s personal data will be subject to the following principles gathered in the GDPR article 5^th and in the Organic Law 3/2018 article 4^th, of the 5^th of December, on the Protection of Personal Data and guarantee of the digital rights:

Principle of legality, loyalty and transparency: the User´s consent will be required at all times, after the User has been completely and transparently informed on the purposes for which the personal data is collected.

Purpose limitation principle: personal data will be collected for specific, explicit and legitimate purposes.

Principle of data minimization: the personal data collected will only be the strictly necessary in relation to the purposes for which they are processed.

Accuracy principle: personal data have to be exact and always updated.

Principle of limitation of the term of conservation: the personal data will be kept only in a way that enables the identification of the User for the time that it is necessary for treatment´s purposes.

Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.

Proactive responsibility principle: The Data Controller will be responsible for ensuring that the mentioned principles are fulfilled.

Categories of personal data.

The categories of personal data that are processed in Bodegas Góngora are only identifying data. Under no circumstances are special categories of personal data processed in the sense of Article 9^th of the GDPR.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is the consent. Bodegas Góngora is committed to collect the express and verifiable consent of the User for the processing of his personal data for one or more specific purposes.

The Users shall be entitled to withdraw their consent at any time. It will be as easy to withdraw the consent as it is to give it. As a general rule, the withdrawal of consent will not be a condition to use the Website.

On the occasions in which the Users have to or may provide their data through forms to make queries, request information or for reasons related to the content of the Website, they will be informed if the completion of any of them is mandatory because they are essential for the correct development of the requested operation.

The purposes of the processing of personal data

The personal data is obtained and managed by Bodegas Góngora in order to be able to enable, streamline and fulfill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the Users fill out or to respond to a request or enquiry.

Furthermore, the data might be used for a commercial personalization, operational and statistical purpose, and corporate purpose activities of Bodegas Góngora, as well as for the extraction, storage of data and marketing surveys to adapt the Content offered to the User, as well as to improve the quality, operation and browsing of the Website.

At the same moment that the personal data is obtained, the User will be informed about the specific purpose or purposes of the treatment of the personal data; that means, the use or uses that will be given to the information collected.

Retention periods for Personal Data

Personal data will be retained only for the minimum time necessary for its treatment and, in any case, only during the next period: 18 months, or until the User requests its removal.

At the time the personal data is collected, the User will be informed about the period during which the personal data will be kept or, when this is not possible, the criteria used to determine this period.

Recipients of personal data

The User’s personal data will not be shared with third parties.

In any case, at the time the personal data is obtained, the User will be informed about the recipients or categories of recipients of the personal data.

Personal data of minors

Respecting the provisions of articles 8^th of the GDPR and 7^th of Organic Law 3/2018, of the 5^th of December, on the Protection of Personal Data and guarantee of digital rights, only those over the age of 14 may grant their consent for the treatment of their personal data lawfully by Bodegas Góngora. If it is a minor under the age of 14 years, the consent of the parents or guardians will be necessary for the treatment, and this shall be only considered lawful in the way that they have authorized it.

Secrecy and security of personal data

Bodegas Góngora is committed to adopt the necessary technical and organizational measures, these measures shall ensure a level of security appropriate to the risk of collected data, in such a way as to guarantee the security of personal data and to avoid accidental destruction, loss or alteration or illicit transmission of personal data, stored or treated in any other way, or unauthorized access or communication to such data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data is transmitted in a secure and confidential way, as the transmission of data is between the server and the User, and in feedback, it is fully encrypted.

Nevertheless, as Bodegas Góngora cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller is committed to notify the User without undue delay when a violation of the security of personal data occurs and it entails a high risk for the rights and freedoms of personal persons. In accordance with the provisions of article 4^th of the GDPR, the security breach of personal data is understood as any breach of security that causes the accidental or unlawful destruction, loss or alteration of personal data transmitted, conserved or treated in any other way, or unauthorized access or communication to such data.

The personal data will be treated as confidential by the Data Controller, who is committed to inform and guarantee through a legal or contractual obligation that this confidentiality will be respected by employees, associates, and any person to whom the information can be accessible.

Rights derived from the processing of personal data.

The User has the following rights on Bodegas Góngora and may, therefore, exercise the rights with the Data Controller, they are recognized in the GDPR and Organic Law 3/2018, of the 5^th of December, on the Protection of Personal Data and guarantee of digital rights:

Right of access: the Users have the right to obtain confirmation of whether or not Bodegas Góngora is treating their personal data and, if so, to obtain information about their specific personal data and the treatment that Bodegas Góngora has carried out or carries out, as well as, among others, the information available on the origin of such data and the recipients of the communications made or planned for that data.

Right of rectification: the Users have the right to rectification of their personal data where they are shown to be inaccurate or incomplete, taking into account the purposes of the treatment.

Right of suppression (the right to oblivion): the Users have the right, provided that the current legislation does not establish otherwise, to obtain the suppression of their personal data when these are no longer necessary for the purposes for which they were collected or treated; the Users have withdrawn their consent to the treatment and this does not have other legal basis; the User opposes the treatment and there is no other legitimate reason to continue with it; the personal data has been unlawfully processed; the personal data have to be removed in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a child under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its application, will have to take reasonable measures to inform those responsible for processing the personal data of the interested party’s request to delete any link to those personal data.

Right to limit the treatment: the Users have the right to limit the treatment of their personal data. The Users have the right to obtain the limitation of the treatment when they contest the accuracy of their personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs it to make claims; and when the User has opposed the treatment.

Right to data portability: In case that the treatment take place by automated means, the Users will have the right to receive their personal data from the Data Controller in a structured format, of common way and mechanical reading, and to transmit them to another person in charge of the treatment. Whenever this is technically feasible, the Data Controller will transmit the data directly to that other controller.

Right of opposition: the User has the right not to carry out the processing of his personal data or to cease the processing of the same by Bodegas Góngora.

Right not to be subject to a decision which is based solely on automated processing of data, including profiling: the User is entitled not to be subject to a decision which is based solely on automated processing of his personal data, including profiling, unless the current legislation establishes otherwise.

In this way, the User may exercise their rights by written communication addressed to the Data Controller with the reference “RGPD-www.bodegasgongora.com”, specifying the next:

Name, surnames of the User and copy of their ID. In cases where representation is admitted, it will also be necessary to present identification of the person representing the User by the same means, as well as the document accrediting the representation. The photocopy of the ID might be replaced by any other legally valid document that proves the identity.

Request with the specific reasons for the request or information to which you want to access.

Address for notification purposes.

Date and signature of the applicant.

Any document that accredits that the request has been made.

This application and any other attached document may be sent to the following address and/or email:

Postal address: C/ Stmo. Cristo de la Vera Cruz, 59 41808 Villanueva del Ariscal, Seville Spain

Email: atencionalcliente@bodegasgongora.com

Links to third party websites

The Website might include hyperlinks or links that allow access to websites of third parties other than Bodegas Góngora, and therefore are not operated by Bodegas Góngora. The owners of those websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices.

Claims to the supervisory authority

In case the Users consider that there is a concern or infringement of current regulations in the way in which their personal data is being treated, they will have the right to effective judicial protection and to file a claim with a control authority, particularly, in the State in which they have their habitual residence, workplace or place where the infringement occurred. For Spain, the control authority is the Spanish Data Protection Agency (https://www.aepd.es/).

ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

It is necessary that the User has read and is in agreement with the conditions on the protection of personal data contained in this Privacy Policy, as well as the acceptance of the treatment of the personal data, so that the Data Controller can process them in the way, during the periods and for the purposes indicated. The use of the Website will imply the acceptance of its Privacy Policy.

Bodegas Góngora reserves the right to modify its Privacy Policy, according to its own criteria, or due to a legislative, jurisprudential or doctrinal change of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to be informed of the latest changes or updates.

This Privacy Policy was updated to be adapted to Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27^th of April, 2016, regarding the protection of personal persons concerning the treatment of personal data and the free circulation of these data (GDPR) and Organic Law 3/2018, of the 5^th of December, on the Protection of Personal Data and guarantee of digital rights.