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Privacy Policy (Terms and Conditions)

We are glad for your interest in relation to the data protection in our website. We want you to feel happy and safe during your visit in our website and to consider the data protection application as a quality characteristic towards the client. With the following data protection labels, we inform you in relation to the way and the scope of your personal data processing by the Cooperative Union under the name “Cooperative Union of Thiraic products” and distinctive title SANTOWINES (herein Santowines) which is seated in Pyrgos kalistis, Santorini, PC 847 00e-mail: info(at) santowines.gr - tel.: +30 22860 22596, tax Identification number: 096007229 – tax Office: Thira, and it is an agricultural cooperative.

The personal data are information that is classified or can be classified directly or indirectly for you. The General Regulation for data protection 679/2016, broadly known as GDPR is applied as legal basis for the data protection.

 
Content Overview

 





  1. Overview

Upon logging in to Santowines various information are exchanged between your terminal and our server. In this case there may also be personal data processing. Selected information in this way will be used, inter alia, mainly for the optimization of the Website or for advertising in the internet browser of your terminal.

 





  1. Login to our Website
Purposes of data processing/ legal basis:
Upon login to our Website there are automatically sent by the web browser of your terminal and without any action of your own:
  • the IP address of the device with access to the internet, which submitted the request, 
  • the date and time of the access,
  • the name and the URL of the requested file,
  • the website/application, from which the access took place (referrer-URL),
  • the web browser that you use
  • the operational system of your computer/terminal
  • and the name of the access provider

The above information is sent to our Website’s forwarder and is temporarily stored in a logfile for the below purposes:

  • guarantee of proper connection,
  • guarantee of comfortable use of our website/application
  • assessment of the security and stability of the system

If you consented with the so-called geolocation in the web browser or your operational system or following other settings of your terminal, we will use this function in order to to provide you customized services that relate to your current position. We are committed to processing your location data obtained in such a way exclusively for this function. 
Legal basis for the process of the IP address is article 6, para 1, point vi. of the General Regulation for the Personal Data Protection 679/2016 (hereinafter GRPR). Our legitimate interest arises by the abovementioned purposes of the data processing. 
Recipients/ Recipients categories:

In principle we exclude the transfer of this data to third parties.

Data storage time/criteria for determining the storage duration:

The data are stored for a maximum time of 50 months and then are deleted automatically.  As soon as you stop using our Website, the geolocation data are deleted.

 





  1. Contact form/ email communication / telephone calls/ customer research

Purposes of the data process/legal basis:

The personal data that you provided us upon the completion of a contact form, by telephone call or email, will obviously be treated confidentially by us. We will use your data for special purposes only, i.e. to process your request. Legal basis for this process is article 6 para 1, point vi. of GDPR. Both ours and your legitimate interest in the processing is based on the goal of providing you with an answer and potentially of solving any existing problems, and by this way to maintaining and reinforcing your satisfaction as a client or user of our website.

If you participate in our customer research, this is done on a purely voluntary basis. During this anonymous research no information is stored that allows conclusions to be drawn for the participant. Only the date and time of your participation is saved. Every personal information that you provide while responding to our research, is considered to have been given voluntarily and is saved pursuant to GDPR. Please do not mention in the free text fields your name or relevant details, which allow conclusions to be drawn for you or other individuals. 

In case of providing a declaration of consent in the context of a customer research, legal basis for the data processing -which is grounded on the consent- is article 6 para 1, point 1 of GDPR. Provided you have given your consent in the context of a customer research, this consent may be revoked at any time with force for the future. More detailed provisions about these cases are in the special principles about data protection of each customer research.

Recipients/ recipients’ categories:

The transfer of data to third parties is generally excluded. Exceptionally the data are processed by processors on our behalf. Those are selected each time carefully, checked by us and are contractually bound pursuant to article 28 of GDPR.

Moreover, it may be required to transfer excerpts of your request to our counterparties (e.g. to suppliers for requests relating to products) in order to process your request. If the transfer of your data is required in an individual case, we will inform you accordingly to obtain your consent.

The results of our customers research are normally used only for internal assessments. In principle the transfer of data to third parties is excluded. We do not transfer personal data to third parties, unless we obtain your explicit consent.

Storage duration/ criteria for determining the storage duration:

All personal details that you granted us in the context of the requests via our Website (proposals, praise or criticism) or by email are deleted by us or become anonymous the latest within 120 days after the final answer is provided. The experience has shown that normally no clarifying questions to your answers arise after 120 days.

 





  1. Contests

Purposes of the data processing/ legal basis:

You have the right, through our newsletter, sms/Viber/similar digital services (e.g. inbox) or in the future through Santowines application to participate in contests. If not otherwise provided in the special principles of data protection of each contest or if you have not given us additional express consent, the personal data you provided to us in the context of your participation in the contest, will be used exclusively for the processing of the competition (e.g. announcement of winners, notification of winners, sending the prize) and after the passing of sufficient time of 90 days for any objections or disputes by other participants, they will be deleted. Legal basis for the data process is article 6 para 1, point b’ of GDPR. In case of providing the declaration of consent in the context of a contest, article 6 para 1, point a’ of GDPR constitutes the legal basis for the data processing. If you provided your consent in the context of a contest, you have the right to revoke this consent at any given time with force for the future. More detailed provisions for these cases are in the special principles of data protection of each contest.

Recipients/ categories of recipients:

The data transfer to third parties is done only if this is needed for the processing of the contest (e.g. sending the prize through a cooperating company). As a rule, further data transfer to third parties is excluded.

Storage duration/ criteria for determining the storage duration:

After the end of the contest, the announcement of the winners, and the passing of sufficient time of 90 days for any objections or disputes by other participants, participants’ personal data will be deleted. In case of material prize, the winners’ data are saved for the entire duration of the existence of legal guarantee claims, so that a subsequent restoration or exchange, in the event of a defect, is possible.

 





  1. Data processing for advertising purposes

Purpose of the data process/ legal basis:

Following your consent, we analyze the usage behavior, in the context of our own online presence and the newsletters we send to you. The assessment of the user’s behavior includes in particular the sections of the website you are visiting and which links you use. With these data we create customized usage profiles, which are classified by person and/or email address, so that Santowines advertising in the form of a newsletter, ad messages on the website and print advertising better adjusts to your personal interests and our online offers are improved.

Legal basis for the abovementioned process is article 6 para 1, point vi of GDPR or in the existence of a corresponding consent, article 6 para 1, point a’ of GDPR. The process of existing client data for own advertising purposes or for third parties advertising purposes should be considered as a legitimate interest.

Right of objection:

You can object to your data processing for the abovementioned purposes at any time and without any cost, separately for each communication channel and with force for the future. It only takes the sending of one email or letter to the contact details mentioned in point 14.

Recipients/ categories of recipients:

As a rule, further data transfer to third parties is excluded.

Storage duration/ criteria for determining the storage duration:

If you withdraw your consent to specific advertising media or object to specific advertising media, your data will be deleted from the respective email distributions.

 If you object, the contact address in question will be excluded from subsequent processing of advertising data. We point out to you that in exceptional case, the sending of promotional material may temporarily continue also after the receipt of the objection. This technically depends on the required time for the implementation of the advertising messages and it does not mean that we do not apply your objection. We thank you for your understanding.

 





  1. Newsletter sending

Purposes of the data processing/ legal basis:

In our Website, we offer you the option to subscribe to our newsletter. If you consent to the receipt of our newsletter, we will use your email address and possibly your name for the sending of information for our products (if possible, separate ones) promotions, contests, news, as well as customer satisfaction surveys. We save and process these data for the purpose of newsletter sending.

The newsletter content contains promotions (offers, discount offers, contests etc.) and Santowines products and services.

Following your consent, we analyze your usage behavior in the websites linked to  www.santowines.gr in mobile apps and in our newsletters. The assessment of usage behavior includes in particular the sections of each webpage, the mobile application, or the newsletter in which you stayed on and the links that you activated. With these data we create usage profile which are classified per person and/or email address, so that advertising, especially in the form of a newsletter, advertising messages in the website and print advertising, is better customized to your personal interests and we improve our online offers. Your consent is the legal basis for the data processing in the context of the newsletter sending, according to article 6 para 1a’ GDPR.

To ensure that you did not enter an error when entering your email address, we established a double opt-in procedure. With this procedure, after you enter your email address in the specified field, we send you a confirmation link. Only if you select the relevant confirmation link, your email address will be sent to our distributors.

You may revoke your consent to the newsletter receipt, your participation in the customer satisfaction questionnaire and in the creation of customized usage profiles at any time with force for the future, e.g. if you unsubscribe from our newsletter through our Website. The link to the unsubscribe page is here or in the end of each newsletter. By unsubscribing from our newsletter, your consent for the creation of a customized usage profile and the receipt of customized newsletter is also revoked. In this case your usage data are deleted.

Recipients/ categories of recipients:

If in order to carry out the newsletter sending are used external distributors, they must be contractually bound pursuant to article 28 of GDPR.

As a rule, further data transfer to third parties is excluded.

Storage duration/ criteria for determining the storage duration:

If you revoke your consent for the receipt of Santowines newsletter your email address is blocked from the newsletter receipt. Your data are deleted after 6 months from the respective email distributors.

 





  1. Online presence-communication and websites optimization

7.1 Cookies – General Instructions

In our Website we use cookies, pursuant to article 6 para 1 point vi of GDPR. Our interest in optimizing our website, must be considered lawful within the meaning of the abovementioned provision. Cookies are very small files, which are saved in your terminal device (computer, portable computer, tablet, smartphone etc.) when visiting our Website. Cookies do not harm your terminal device, do not contain viruses, trojan or other malware programs. Cookies collect information which each time arises in connection with the specific terminal device that has been used. This does not mean that we have immediate knowledge of your identity because of these. Cookies usage aims to offer you a more comfortable use. For this reason, we use the so-called session cookies in order to identify that you have already visited individual pages of the Website. These are automatically deleted once you logout from our website. Other than that, we use temporarily cookies for the purpose of usage facilitation, which are saved for specified time period in your terminal device. If you re-visit our website to use our services, we automatically recognize that you have already visited us and in which entries or settings you have proceeded, in order not to have to proceed again to the same actions.

On the other hand, we use cookies to statistically analyze the Website use for the purpose of services optimization and the display of information that are custom made to you. These cookies allow us to automatically recognize in a subsequent visit of yours to our Website that you have visited us before. These cookies are automatically deleted after a predetermined time period, which normally does not exceed six (6) months. Most web browsers automatically accept cookies. However, you can configure your web browser so that cookies are not saved in your terminal device or keep prompting before saved. However, the complete deactivation of cookies may result to the inability to use some of our Website’s functions.

More information for the used cookies and your right to object to them, you can find in the Cookies Policyas well as in here, articles 7 to 9.

7.2 Google Analytics 

Purpose of the data process/ legal basis:

For the purpose of configuration and continuous optimization of our websites, we use Google Analytics, pursuant to article 6 para 1, point vi of GDPR, an internet analytics service of Google Inc. («Google»). Our legal interest arises from the aforementioned purposes. In this context, pseudo animated usage profiles are created and cookies are used. Τhe cookie records the following information in relation to the use of the website:

  • type/edition of web browser
  • operating system
  • Referral to the url address that you visited before
  • Access computer name and Internet Protocol (IP) address
  • Server request time

The information is used for the assessment of the usage of our Websites, for reporting in relation to the website’s activities and for the provision of additional services in connection with the Website’s and internet’s use for market research purposes and websites configuration based on (clients’) needs. The Internet Protocol addresses (IP) become anonymous, so that it is not possible to match them by deleting one or more digits (also known as IP-masking). 

You can prevent the installation of cookies through a relevant setting of your web browser.  We would like, however, to notify you that in this case the usage of all of your website’s functions might not be possible. You may also prevent the analysis of the data created by the cookie and relate to the usage of this webpage (including the IP address) as well as the process of these data by Google if you install Google Chrome Extensions. Instead of this program, you may also -especially in portable devices browsers- prevent analysis from Google Analytics, if you click on the corresponding link at the bottom of each page. It is thereby created an opt-out cookie, which prevents the future analysis of your data when visiting this website. The opt-out cookie is valid only for this particular web browser, only for our website and is stored only in your device. If you delete cookies from this specific web browser, you will need to install again the opt-out cookie. You will find more information about data protection in connection with Google Analytics in google analytics webpage.

Recipients/ categories of recipients:

The information generated by the cookie is transferred to a Google forwarder in the U.S.A. and saved there. Your IP address is by no means merged with other data by Google. Moreover, this information may be transferred to third parties, considering that this is provided by law or third parties process these data following authorization.

Storage duration/ criteria for determining the storage duration:

After the “anonymization” of the IP address, the association with you is no longer possible. The generated data for statistical purposes is deleted by Google Analytics after 50 months. In the reports compiled based on Google Analytics there is no more reference to individuals.

7.3 Website targeting and website optimization

Purpose of the data process/ legal basis:

On our Website -by the use of cookies- is analyzed and evaluated, information for the purpose of optimizing our websites and the ads displayed on them.  In this manner, it is secured that it will be displayed on your terminal device only the ad that is customized to your real or potential interests, based on current usage behavior. The information that is processed for these purposes contain, for instance, data relevant to the products for which you show interest. Legal basis for this process is article 6 para 1, point vi. of GDPR. Therefore, the optimization of our webpages aiming at the best shopping experience and the avoidance of ads that are of no interest to you, are to our mutual best interest. The analysis and assessment is carried out exclusively under a pseudonym and does not allow us to identify you. In particular, the information is not merged with your personal data.

Recipients/ categories of recipients:

Data recipients are the above-mentioned service providers, which process your data on a contractual basis having a special destination and according to our instructions.

Storage duration/criteria for determining the storage duration:

The cookies that are used and the information contained therein, are stored pursuant to the Cookies Policy and are deleted immediately in case of objection.

7.4 Re-targeting

Purpose of the data process/ legal basis:

We also use the re-targeting technologies of various providers. This allows us to configure our online presence in a compelling way for you. For this purpose, a cookie that collects data by using a pseudonym, is generated. In particular, is collected information about the browsing behavior for marketing purposes in an anonymous basis, which is stored in cookies files in your computer and analyzed through an algorithm. Following that, it is possible that targeted product recommendations and ad banners with products that are of interest to you, are displayed on the websites of our partners. These data can by no means be used to identify the website visitor. No process of your direct personal data is done and the usage profiles are not merged with personal data. Said data process is done pursuant to article 6, para 1, point vi of GDPR. With the above used measures, we want to ensure that only the ad that is tailored to your real or potential interests will be displayed on your terminal devices. It is to our mutual interest not to burden you with indifferent advertising.

If, however, you do not wish a personalized ad banner of Santowines e-shop to appear to you, you can oppose to this collection and data storage for the future, as follows:

By selecting the symbol that appears on each banner ad (e.g. “I”) you will go to the respective provider’s website. There, the systematics of the retargeting technology is clarified again and the opt-out option is also provided. If you unsubscribe from a provider, the opt-out cookie is saved in your computer and hinders in the future the appearance of each provider ad banner. Please note that this unsubscription can be done only from your computer and the respective opt-out cookies cannot be deleted from your computer and if for any reason they are deleted, you must repeat the opt-out procedure.

  • Alternatively, you may use the objection options provided in point5 of the present data protection terms.

Recipients/ categories of recipients:

We use in our website re-targeting technologies of various providers, which process the abovementioned data within the present framework. Further information about the cookies used by the said providers, you may find in the Cookies Policy.

Storage duration/ criteria for determining the storage duration:

The cookies that are used for re-targeting purposes and the information contained therein are saved for as long as it is provided by the Cookies Policy and then deleted automatically.

7.5 Further digital communication

We also use periodically short messages such as sms/Viber/or similar digital services (e.g. inbox) in order to serve you better and respond more effectively to your needs.

7.6 Opt-out option

You can block the re-targeting technologies, analyzed in points 7.3 and 7.4, by using the relevant cookies setting in your web browser (see also point 7.1). In parallel, you have the opportunity to block the personalized-interest based ad, by using the so-called online choices manager or by activating the available opt-out cookies.

 





  1. Recipients outside EU

With the exception of the process described in point 7, we do not provide your data to recipients outside the European Union or the European Economic Area. The process mentioned in point 7 leads to data transmission to the forwarders of the authorized by us providers of tracking and targeting technologies. Some forwarders are in the USA (more information can be obtained in the respective reports for the specific recipients). Data transmission is done pursuant to the principles of the so-called PrivacyShield and the standardized contractual clauses of the European Commission.

 





  1. Your rights as data subjects

9.1 Overview

Together with the right to revoke the provided consents, you also have the following rights, given that the respective legal conditions are met: 

  • access right to your personal data that we save pursuant to article 15 of GDPR
  • error correction right or right to fill in incorrect data pursuant to article 16 of GDPR
  • right to delete the data that we saved pursuant to article 17 of GDPR
  • right to restrict data processing pursuant to article 18 of GDPR
  • right to data portability pursuant to article 20 GDPR
  • right of objection pursuant to article 21 GDPR

9.2 Access right pursuant to article 15 of GDPR

You have the right to be informed upon request and without any cost, pursuant to article 15 para 1 of GDPR, about the personal data we have saved about you. This more specifically includes:

  • the purpose of the personal data processing
  • the relevant personal data categories that we process
  • the recipients or the recipient categories to which your personal data are disclosed or are about to be disclosed
  • if it is possible, the time period for which the data will be saved, or if this is not possible, the criteria that determine such a period
  • the right to submit a request to the data officer for correction or deletion of personal data or data processing restrictions that pertain to the subject data or right of objection to the said processing
  • the right to file a complaint with the competent supervisory authority
  • when the personal data are not collected by the data subject, any available information on their origin
  • the existence of automated decision making, including profiling, as provided in article 22 para 1 and 4 of GDPR and at least for these cases, important information as to the rational followed, the importance and the anticipated consequences of the said process for the data subject

When personal data are transmitted to a third country or international organization, the data subject has the right to be informed for the appropriate guarantees in connection with the transmission, pursuant to article 46 of GDPR.

9.3 Error correction right pursuant to article 16 of GDPR

You have the right to demand from us without undue delay, the correction of inaccurate personal data related to you. Having in mind the purposed of the processing, you have the right to request the completion of incomplete data, through a supplementary statement, inter alia.

9.4 Right to delete the saved data pursuant article 17 of GDPR

You have the right to request from us to delete your personal data without undue delay, if one of the following reasons apply:

  • the personal data are no longer necessary in relation to the purposes for which collected or otherwise processed,
  • you revoke your consent upon which the processing is based pursuant to article 6 para 1 point (a) or article 9 para 2 point (a) of GDPR and there is no other legal basis for the processing,
  • you object to the processing pursuant article 21 para 1 or para 2 of GDPR and there are not imperative and legitimate reasons for processing pursuant to article 21 para 1 or para 2 of GDPR,
  • the personal data was submitted for processing illegally,
  • the data must be deleted in order to comply with any obligation,
  • the personal data have been collected in connection with the provision of information society services, as provided in article 8 para 1 of GDPR.
  • When we have disclosed the personal data and are obliged to delete them, taking into account the available technology and application cost, we will take reasonable steps to inform third parties who process your personal data, that you require from them to delete any links to your data or copies or reproductions thereof.

9.5 Right to restrict data processing pursuant to article 18 of GDPR

You have the right to request from us data processing restrictions, when one of the following conditions apply:

  • you question the accuracy of the personal data
  • the process is illegal and you request, instead of deletion, the restriction of the personal data usage
  • the data officer no longer needs the personal data for the process purposes, but these data are required by the data subject for the foundation, exercise or support of legal claims
  • you have objections for the processing pursuant to article 21 para 1 of GDPR, pending verification of whether the legal reasons of the process officer prevail over the reasons of the data subject.

9.6 Right to data portability pursuant to article 20 of GDPR                               

You have the right to obtain the personal data related to you and that you have provided to us in a structured, broadly used and machine-readable format, as well as the right to transmit such data without objection from us, when:

  • the process is based on consent pursuant to article 6 para 1, point a; or article 9 para 2 point a’ or in a contractual relationship pursuant to article 6 para 1, point b’ of GDPR and
  • the processing is performed by automated means

When exercising your data portability right, you have the right to request that the data be transmitted directly from us to another data process officer, in case that this is technically feasible.

9.7 Right of objection pursuant to article 21 of GDPR  

Under the conditions of article 21 para 1 of GDPR, you can object to the data processing for other reasons arising from the particularity of the situation. The above general right of objection is valid for all purposes of data processing, which are processed pursuant to article 6 para 1 point vi of GDPR. Contrary to the special right of objection pertaining to data processing for advertising purposes (see above in particular points 9 and 7.6), we have obligation pursuant to GDPR to exercise the general right of objection only if you provide us reasons of paramount importance e.g. a potential risk for life or health. Beyond that, there is the possibility to address yourself to the competent supervisory authority for SANTOWINES or to the Data Protection Officer Law Firm Tsilonis-Vogiatzoglou (Newlaw), 10 Tsimiski, 546 24, Thessaloniki, tel. 2310 551 501, fax: 2310 261 503, e-mail: dataprotect (at) newlaw (dot)gr

 





  1. Contact persons

10.1 Contact persons for inquires or the exercise of your data protection related rights

For inquires related to the Websites or the exercise of your right during your data processing (personal data protection) you can contact the email address: info(at)santowines(dot)gr; the email is received by the customer service department.

10.2 Contact person for inquiries about data protection

If you have further inquiries about your data protection, you may address yourself to the  Data Protection Officer for Santowines, Law Firm Tsilonis-Vogiatzoglou (Newlaw), 10 Tsimiski, 546 24, Thessaloniki, tel. 2310 551 501, fax: 2310 261 503, e-mail: dataprotect (at) newlaw (dot)gr

10.3 Right to file a complaint with the data protection supervisory authority

Moreover, you have ant any time the right to file a complaint to the competent data protection authority. You can contact the data protection supervisory authority, especially in the Member State where you have your residence or your place of work or the place of the alleged infringement or at the authority of the State, in which the controller is established.

 





  1. Name and contact details of the controller and contact details of the data protection officer

These data protection terms are valid for the data processing done by the Cooperative Union under the title “COOPERATIVE UNION OF THIRAIC PRODUCTS” and distinctive title SANTOWINES (herein Santowines), which is seated in Pyrgos of Kalisti, Santorini, P.C. 847 00e-mail: info(at) santowines.gr - tel.: +30 22860 22596, Tax Identification Number: 096007229 – Tax Office: Thira, constitutes an agricultural cooperative and is the «Controller» for the website www.santowines.gr. For further information or queries about your data processing or for the exercise of any legal right, the User can contact the Data Protection Officer for Santowines, Law Firm Tsilonis-Vogiatzoglou (Newlaw), 10 Tsimiski, 546 24, Thessaloniki, tel. 2310 551 501, fax: 2310 261 503, e-mail: dataprotect (at) newlaw (dot)gr

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