1. Policy

This Policy is issued by Alpasion Group, which shall include its branches, its subsidiaries and its affiliates, from time to time (together, “Alpasion”, “we”, “us” or “our”) and is addressed to individuals outside Alpasion with whom we interact, including individual clients, Personnel of corporate clients, vendors and other recipients of our services (together, “you”).
This Privacy Policy describes how we collect, hold, use and disclose personal information that you provide, is provided on your behalf or is collected by us. Each Alpasion Group company is subject to any privacy and data protection laws that may be applicable in the country in which it is located. This Privacy Policy should not be viewed as a supplement to such local Privacy laws and shall not vary or diminish each Alpasion Group company’s obligations under the applicable local Privacy laws. To the extent this Privacy Policy conflicts with any provisions of local Privacy laws, such local Privacy laws shall take precedence over this Privacy Policy.
Any of Alpasion Group companies may be data processors or data controllers; this will depend on the circumstances in which personal information is collected, held or used. For Alpasion Group companies and their details, please visit: https://www.alpasion.com/
This Policy may be amended or updated at our discretion from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or any changes in applicable law.

2. Personal Data:

The categories of Personal Data about you that we Process, subject to applicable law, are as follows:
• Personal details: given name(s); preferred name(s); nickname(s), gender; date of birth; age; marital status; Social Security number; passport number(s); driving license number(s)); nationality; lifestyle and social circumstances; images of passports, driving licenses, and signatures; authentication data (passwords, mother’s maiden name, challenge/response questions and answers, PINs, facial and voice recognition data); photographs; visual images; and personal appearance and behavior.
• Contact details: address; telephone number; email address; and social media profile details.
• Employment details: Industry, role; business activities; Details on business Cards provided to us.
• Electronic Identifying Data: IP addresses; cookies; activity logs; online identifiers; unique device identifiers; and geolocation data.

3. Collection of Personal Data:

We collect Personal Data about you from a variety of sources as follows:
• Directly from you in the ordinary course of our relationship with you
• You manifestly choose to make public, including via social media, from third parties who provide it to us .
• We collect or obtain Personal Data when you visit any of our websites or use any features or resources available on or through our website. When you visit our website, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Site and other technical communications information), some of which may constitute Personal Data.

4. The Legal basis for Processing your Personal Data:

We seek to collect or otherwise Process your Personal Data, for the following legal basis:
• The Processing is necessary for compliance with a legal obligation under a contract with you;
• The Processing is necessary for the detection or prevention of crime (including the prevention of fraud) to the extent permitted by applicable law;
• The Processing is necessary for the establishment, exercise or defence of legal rights;
• We have, in accordance with applicable law, obtained your explicit consent prior to Processing your Personal Data (as above, this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way); or
• Processing is necessary for reasons of substantial public interest and occurs on the basis of an applicable law that is proportionate to the aim pursued and provides for suitable and specific measures to safeguard your fundamental rights and interests.

5. Purposes for which we may Process your Personal Data

The purposes for which we may Process Personal Data are:

• Maintaining and updating your contact information where appropriate
• Marketing and promotional activities.
• Providing you with information or assistance that you request from us;
• Notifying you or our Clients about changes to our services;
• Monitoring and improving the quality of our services;
• Quality assurance and training purposes;
• Complying with our legal and regulatory requirements

6. Disclosure of Personal Data to third parties

We may disclose your Personal Data to other entities within Alpasion, for legitimate business purposes (including providing services to you), in accordance with applicable law. In addition, we may disclose your Personal Data to:
• To your family, your associates and your representatives;
• Anti-fraud services;
• Governmental, Legal, regulatory or similar authorities, central and/or local government agencies, upon request or where required, including for the purposes of reporting any actual or suspected breach of applicable law or regulation;
• Accountants, auditors, financial advisors, lawyers and other outside professional advisors to Alpasion, subject to binding contractual obligations of confidentiality;
• Third party processors (such as payment services providers; shipping companies; etc.), located anywhere in the world,
• Any relevant party, claimant, complainant, enquirer, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights in accordance with applicable law;
• Any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security in accordance with applicable law;
• Any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation);
• Voluntary and charitable organizations.
If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

7. International transfer of Personal Data

Because of the international nature of our business. we may need to transfer your Personal Data within Alpasion Group, and to third parties as noted above in connection with the purposes set out in this Policy. For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements, including data protection laws of a lower standard to those that apply in the country in which you are located.
Where we transfer your Personal Data to other countries. we do so on the basis of:
• Adequacy decisions;
• Our Binding Corporate Rules;
• Suitable Standard Contractual Clauses; or
• Other valid transfer mechanisms.
If you want to receive more information about the safeguards applied to international transfers of personal data, please use the contact details provided below.

8. Data Security

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.
You are responsible for ensuring that any Personal Data that you send to us are sent securely.

9. Data Accuracy

We take reasonable steps designed to ensure that:
• Your Personal Data that we Process are accurate and, where necessary, kept up to date; and
• Any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.
From time to time we may ask you to confirm the accuracy of your Personal Data.

10. Data Minimization

We take reasonable steps designed to ensure that your Personal Data that we Process are limited to the Personal Data reasonably required in connection with the purposes set out in this Policy.

11. Retention of your Personal Data

We will retain your Personal Data in accordance with Alpasion Group Data Retention Policy.

12. Your legal rights

Subject to applicable law, you may have a number of rights regarding the Processing of your Personal Data, including:
• the right to request access to, or copies of, your Personal Data that we Process or control, together with information regarding the nature, processing and disclosure of those Personal Data;
• the right to request, on legitimate grounds:

• Erasure of your Personal Data that we Process or control; or
• Restriction of Processing of your Personal Data that we Process or control;

• where we Process your Personal Data on the basis of your consent, the right to withdraw that consent;
• the right to lodge complaints with a Data Protection Authority regarding the Processing of your Personal Data by us or on our behalf.
This does not affect your statutory rights. Subject to applicable law, you may also have the following additional rights regarding the Processing of your Personal Data:
• the right to object, on grounds relating to your particular situation, to the Processing of your Personal Data by us or on our behalf; and
• the right to object to the Processing of your Personal Data by us or on our behalf for direct marketing purposes.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided below.

13. Cookies

A cookie is a small file that is placed on your device when you visit a website (including our websites). It records information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Data through cookie technology, in accordance with our Cookie Policy.

14. Contact details

If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of Personal Data by Alpasion/COL Wines, please contact our “Chief Privacy Officer” @ g.soto@alpasion.com

Address
C/O Alpasion
Ruta Provincial 94, Los Sauces,
Mendoza, Argentina