Privacy policy

EFFECTIVE DATE: 01/03/23

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Note: The Privacy Policy has been updated. Please review the updated privacy policy carefully before using the Website. By using the Website, you consent to the terms of the updated Privacy Policy.

PUNINWINE Privacy Policy

All personal data is collected and processed in compliance with the applicable data protection regulations of the General Data Protection Regulation (GDPR).

When posting changes to this Privacy Policy, the last updated date specified at the beginning of the document will change.

1. Responsible

Responsible for the collection, processing and use of your personal data within the meaning of Art. 4 No. 7 GDPR is CWS COLLECTION OF WINE SAMPLES LTD (hereinafter - PUNINWINE).

If you wish to object to the collection, processing or use of your data by us in accordance with these data protection regulations as a whole or for individual measures, you can address us your objection.

Also, you can save and print out this Privacy Policy at any time.

2. General purposes of processing

PUNINWINE uses personal data for the purpose of operating the website, as well as for fulfilling customer contracts and inquiries.

3. Which data is used by PUNINWINE

3.1. Hosting.

The hosting services we use serve to provide the consulting services in the field of informatization.

PUNINWINE or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta- and communication data of customers, interested parties and visitors to this website on the basis of our legitimate interests in an efficient and secure provision of our website in accordance with GDPR.

3.2. Order data.

PUNINWINE collects information about you when you use this website via registering or sending the order. We automatically collect information about your usage behavior and interaction with us and record data about your computer or mobile device. PUNINWINE collects, stores and uses data about every access to our website (so-called server log files). Access data includes:

- Name;

- Geo-data;

- Date and time of access;

- Browser type and browser version;

- Operating system;

- Referrer URL (i.e. the previously visited page);

- E-mail and telephone number

- IP address and the requesting provider

PUNINWINE use this log data without allocation to your person or other profiling for statistical evaluations for the purpose of operating, security and optimization of our website, but also for anonymous recording of the number of visitors to our website (traffic) and the extent and type of use of our website and services, as well as for billing purposes in order to measure the number of clicks received from cooperation partners. Based on this information, we can provide personalized and location-based content, analyze traffic, troubleshoot and correct errors, and improve our services.

This is also our legitimate interest pursuant to Art 6 para. 1 sentence 1 f) GDPR.

PUNINWINE reserves the right to check the log data subsequently if there is a justified suspicion of illegal use based on concrete evidence. We store IP addresses in the log files for a limited period of time if this is necessary for security purposes or for the provision or billing of a service, e.g. if you use one of our offers. After the order process has been canceled or payment has been received, PUNINWINE will delete the IP address if this is no longer required for security purposes. PUNINWINE also stores IP addresses if we have a concrete suspicion of a criminal offense in connection with the use of our website.

3.3. PUNINWINE Cookies.

PUNINWINE uses so-called session cookies to optimize our website. A session cookie is a small text file that is sent by the respective servers when you visit a website and stored temporarily on your hard drive. This file as such contains a so-called session ID, with which you can assign various requests of your browser to the common session. This will allow your computer to be recognized when you return to our website. These cookies are deleted after you close your browser.

PUNINWINE also uses persistent cookies to a small extent, which remain on your terminal device and enable us to recognize your browser the next time you visit. These cookies are stored on your hard disk and are deleted automatically after the specified time. Their life span is from 1 month to 10 years. This enables PUNINWINE to present our services to you in a more user-friendly, effective and secure manner and, for example, to display information on the site that is specifically tailored to your interests.

Our legitimate interest in the use of cookies pursuant to GDPR is to make our website more user-friendly, effective and secure.

The following data and information are stored in the cookies:

• Information about the number of visits to PUNINWINE website and use of individual functions of the website.

When the cookie is activated, it is assigned an identification number and your personal data is not assigned to this identification number. Your name, IP address or similar data that would allow the cookie to be assigned to you will not be placed in the cookie. Based on the cookie technology, we only receive pseudonymous information, for example about which pages of our website were visited, which products or offers were viewed, etc.

You can set your browser so that you are informed in advance about the setting of cookies and can decide in individual cases whether you want to exclude the acceptance of cookies for certain cases or in general, or that cookies are completely prevented. This may limit the functionality of the website.

3.4. Data for contractual obligations.

PUNINWINE processes personal data that we need to fulfill our contractual obligations, such as name, address, e-mail address, ordered service, invoice and payment data, if available and requested. The collection of this data is necessary for the conclusion of the contract. The data will be deleted after expiry of the warranty periods and statutory retention periods. Data associated with a user account will always be retained for the duration of the account. The legal basis for the processing of this data is GDPR articles, because this data is required so that we can fulfill our contractual obligations towards you.

3.5. Marketing.

PUNINWINE will send you from time to time marketing materials by email. In this way, PUNINWINE will provide you with more information about products from our offer that you may be interested in based on your recent purchases from PUNINWINE. 

3.6. Email Contact.

If you contact PUNINWINE (e.g. via contact form or e-mail), we will process your details to process your inquiry and in case follow-up questions arise.

If the data processing takes place for the execution of pre-contractual measures which take place at your request or, if you are already our customer, for the execution of the contract, the legal basis for this data processing is GDPR.

PUNINWINE will only process further personal data if you give your or if we have a legitimate interest in processing your data GDPR. For example, replying to your email.

4. Google-Analytics

PUNINWINE uses Google Analytics, a web analysis service of Google Inc. "("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about the use of this website by page visitors is usually transferred to a Google server in the USA and stored there.

This is also our legitimate interest pursuant to GDPR.

Google has signed and certified itself under the Privacy Shield Agreement between the European Union and the USA. By doing so, Google undertakes to comply with the standards and regulations of European data protection law.

The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, note that if you do this you may not be able to use the full functionality of this website.

You can also prevent the transmission to Google of data generated by the cookie and relating to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing the browser plug-in.

5. Storage time

PUNINWINE only stores personal data for as long as is necessary to fulfill the purposes pursued. In some cases, the legislator provides for the storage of personal data, for example in tax or commercial law. In these cases, the data will only be stored by PUNINWINE for these legal purposes but will not be processed in any other way and deleted after expiry of the legal retention period.

6. Your rights as a data subject

According to the applicable laws, you have various rights regarding your personal data. If you wish to assert these rights, please send your request by e-mail or by post to the address specified in section 1, clearly identifying yourself.

6.1. Right of access by the data subject.

You have the right to receive confirmation from PUNINWINE at any time as to whether personal data relating to you will be processed. If this is the case, you have the right to request from us free of charge information about the personal data stored about you together with a copy of this data.

If personal data are transferred to a third country or an international organization, you have the right to be informed of the appropriate guarantees in accordance with GDPR in connection with the transfer.

6.2. Right to rectification.

You have the right to request PUNINWINE to rectification of inaccurate personal data concerning you without delay.

6.3. Right to erasure (‘right to be forgotten’)

As a pursuant under GDPR you have the right to obtain from the us the erasure of personal data concerning you without delay, and we have obligation to erase personal data without undue delay where one of the following grounds applies:

1. the personal data are no longer necessary for the purposes for which they were collected or otherwise processed.

2. you file an object to the processing pursuant to Article 21(1) of GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of GDPR.

3. you withdraw your consent on which the processing is based pursuant according to point (a) of Article 6(1) of GDPR, or point (a) of Article 9(2) of GDPR, and where there is no other legal ground for the processing.

4. the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which we are subject.

5. the personal data have been unlawfully processed. 

6.4. Right to restriction of processing 

You have the right to request PUNINWINE to restriction of processing if one of the following conditions is met:

1. you dispute the accuracy of your personal data for a period of time that enables us to verify the accuracy of your personal data;

2. the processing is unlawful, and you have refused to erasure the personal data and have instead requeste the restriction of the use of the personal data;

3. PUNINWINE no longer needs the personal data for the purposes of processing, but they are required by you for the establishment exercise or defence legal claims 

4. you have filed an objection against the processing pursuant according to to Article 21(1) of pending the verification whether the legitimate grounds of our company outweigh yours.

6.5. Right to data portability 

You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly use and machine-readable format, and you have the right to transmit those data to another person in charge without our hindrance to which the personal data have been provided, where:

1. the processing is based on consent or on a contract pursuant according to conditions of GDPR and US data protection laws and

2. the processing is carried out by automated means. When exercising your right to data portability in accordance with paragraph 1, you have the right to request that the personal data transmitted directly by us to another person responsible, where technically feasible.

6.6. Right of object.

You have the right to object on grounds relating to your particular situation, at any time to processing of personal data concerning is based on point (e) or (f) of Article 6(1) of GDPR, including profiling based on those provisions. We no longer process the personal data unless we can demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

If PUNINWINE processes personal data for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising.

You have the right to object to the processing of personal data concerning you, for scientific or historical research purposes or statistical purposes in accordance with to Article 89(1) of GDPR for reasons arising from your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

6.7. Automated individual decision-making, including profiling.

You have the right not to be subject to a decision based solely on automated processing, including profiling - including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her. An automated decision making based on the collected personal data does not take place.

6.8. Right to withdrawal consent according to data protection law.

You have the right to revoke your consent to the processing of personal data at any time.

6.9. Right to lodge a complaint with a supervisory authority.

You have the right to lodge a complaint with a supervisory authority, in particular in the Member State, in particular in the Member State of you habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes of GDPR.

7. Data security

PUNINWINE makes every effort to ensure the security of your data in accordance with the applicable data protection laws and technical possibilities, but unfortunately a complete protection of data against access by third parties is not possible.

To secure your data, PUNINWINE maintains technical and organizational security measures in accordance with GDPR.

7.1. Disclosure of data to third parties.

In general, PUNINWINE only uses your personal data within our company.

In case PUNINWINE outsources certain parts of data processing ("order processing"), we contractually obliged contractors to use personal data only in accordance with the requirements of data protection laws and to ensure the protection of the rights of the data subject.

A data transmission to places or persons outside the EEA outside the case mentioned in this declaration in paragraph 4 does not take place and is not planned.

7.2. Data Protection info.

If you have any questions about data protection, please contact PUNINWINE at: [email protected]