PRIVACY POLICY

1. INTRODUCTION

This Website is owned by DIOSARES, S.L. who is the owner of the trademark BODEGAS VOELOS, which from now on will appear as the owner of the data.

At BODEGAS VOELOS we are committed to the protection of privacy and the correct use of the personal data that we process and that you provide us, both online on this website and, where appropriate, any of its subdomains and microsites, as well as off- line.

Please read this policy carefully and make sure you understand and agree to it, before providing us with your personal data. If you do not agree with it, do not use this website or its services or provide us with your data.

The fact of accessing this site, using any of its services or providing us with your data, either online or offline, we will understand as a clear affirmative action by which you give us your consent (when it is necessary) to process your data for the purposes indicated below.

2. WHO IS RESPONSIBLE FOR THE TREATMENT OF YOUR DATA?

DIOSARES, S.L.
Postal address: Carretera. Navaridas, s/n (01300), Laguardia (Álava / Araba)
Email: voelos@voelos.com
Telephone: +34 945 600 678

3. HOW HAVE WE OBTAINED YOUR DATA?

3.1. Obtaining the interested person himself.

If you are a client (current or potential), or user of our website, you have provided them, either offline or online, when requesting our products or services, or contacting us requesting information. You have also been able to provide us in person, if you have come to our facilities.

By providing us with your data, you guarantee that you are enabled to do so and that the information is true, up-to-date and that it does not violate any contractual restrictions or rights of third parties. You have the responsibility to keep your data and your profile correct and updated, declining all responsibility BODEGAS VOELOS in case of not doing so. You agree not to impersonate other Users by using their registration data for the different services and / or contents of the Website.

Adult content: the content of this website is reserved for people over 18 years of age / age: to use our services or request our products you must be at least 18 years old. Therefore, the provision of data on this website by minors of that age is not allowed.

3.2. Obtained automatically when visiting our website:

When you visit our website or any other of our platforms (social networks, mobile applications …), we collect information through cookies and other tracking technologies and web analytics. This means that data is sent from your browser to our servers to optimize our services and improve your user experience. This data may be collected and stored automatically by us or by third parties on our behalf. You can check our cookie policy.

3.3. Communication by a third party of the data of the interested party.

It is possible that your data has not been provided to us directly by you, but has been provided to us by a third party with whom we work, to whom you have previously provided that data.

Additionally, by accepting this privacy policy, and where appropriate, by the express consent that you have granted, you authorize BODEGAS VOELOS so that it may require from third parties the necessary data for the fulfillment of the provision or services.

3.4. Communication by the data subject of third parties:

With regard to the data of other people, you must respect their privacy by taking special care when communicating or publishing their personal data. Only its owner can authorize the processing of your personal data. The publication of data from third parties without their consent may violate, in addition to the regulations on data protection, those relating to the right to honor, privacy or the image of said third parties. al derecho al honor, a la intimidad o a la propia imagen de dichos terceros.

If you provide us with third-party data, it is your responsibility to have their prior and express consent to use them, and it is your duty to inform them of the treatment that we are going to carry out with their data. By accepting this privacy policy, you expressly guarantee that you have the authorization for said contribution, exonerating us from any responsibility in case of any claim by an interested person.

4. WHAT TYPES OF DATA DO WE PROCESS?

The categories of data that we process can be:

• Obtained from the interested person: identification data (name and surname, NIF), contact information (telephone, postal address, email address, invoice or delivery address), commercial and economic data (information about the products requested, customer history, and those necessary for payment: bank, credit card …), online profile data (information, preferences and interests).
• Obtained automatically when visiting our website: the user’s IP address, the date and time of the visit, the URL of the site the user comes from, the pages visited on our website, information about the browser used (type and browser version, operating system, etc.).
• Communicated by a third party: identifying data; personal characteristics data; data on social, academic and professional circumstances; economic, financial and insurance data; transaction data for goods and services, employment details.

Regarding data with special protection: We do not treat special categories of data.
We do not treat special categories of data.

5. WHAT DO WE PROCESS YOUR DATA FOR?

The data that you provide us, as well as all that generated during the development of the relationship that we maintain with you, we can process for different purposes:

• If you are a current or potential client: to maintain contact and communication with you, and manage the contractual and / or commercial relationship …
• If you are a user of our website, or sender or recipient of an email: to manage the requests you make to us online, and to contact you.
• In the case of accessing our facilities as a visitor: to manage access and control of visits.
• In the case of providing us with your CV: to contact you and manage the selection processes that we carry out. In this case, it is mandatory that you accept the privacy policy, checking the field enabled for it. If you do not give your consent, we will not be able to take your CV into account.
• To send you, through electronic communications,, information about our activities, products and / or services similar to those requested, including advertising and / or commercial communications for the purposes of article 21 LSSICE 34/2002. If we already have a prior contractual relationship, we will send such communications based on our legitimate interest. In the case of not having a prior contractual relationship, we will only send you that type of communication, if you authorize us by checking the option that is expressly included for this purpose in the corresponding forms. The electronic communications that we send you will include, in the communication itself, the option to stop receiving them. If you choose to do so, we will stop sending you this type of communication in the future.
• To transfer your data to other companies or entities, directly related to BODEGAS VOELOS, in order to be able to provide you with the service or product you have requested, and the administrative-accounting management that such provision requires. Specifically, we may communicate your data to the recipients that are collected in the specific section that you will find later in this policy.

6. HOW LONG WILL WE KEEP YOUR DATA?

6.1. General conservation period

We will keep the personal data that you provide us as long as the contractual, pre-contractual or commercial relationship is maintained and, once these are terminated, as long as the interested person does not request its deletion. Even if the deletion is requested, we can keep them for the necessary time and limiting their treatment, only to:

• Comply with the legal / contractual obligations to which we are subject,
• and / or during the legal periods established for the prescription of any liability on our part,
• and / or the exercise or defense of claims derived from the relationship with the interested person.

In coordination with the above criteria, the deletion of personal data either in computer records or on paper may be carried out, at the discretion of the organization, depending on logistical and / or storage space needs that make it advisable to delete information or documentation.

7. WHAT IS THE LEGITIMATION FOR THE PROCESSING OF YOUR DATA?

The legal basis that legitimizes us for the processing of your data can be diverse:

• Compliance with the existing contractual or commercial legal relationship if you are already a client, supplier, or participant in our activities. In case you are a potential customer or supplier, it is the pre-contractual relationship that binds us.
• The provision of the requested data is mandatory as it is essential to formalize and / or maintain the contractual or pre-contractual relationship and comply with the legal obligations derived from it; If you do not provide them, we will not be able to provide the service derived from said relationship.
• Consent: it can also be your consent if you have made a request or request yourself, or have given it to us for a specific purpose: For example, if you have entered our website, if you have sent us your CV, if You are a visitor to our facilities, if you have given your consent to send commercial communications, etc … You give us unequivocal consent when you provide us with your data online or offline, such contribution being considered a clear affirmative act that expresses said consent.The provision of the requested data is mandatory as it is essential to meet your request; If you do not provide them, we will not be able to carry it out.You can withdraw that consent at any time by sending us an e-mail in this regard to voelos@voelos.com Said withdrawal does not condition the processing of your data for the rest of the purposes described, but it may mean that we cannot answer your request.

• Compliance with a regulation or legal obligation: such as those established in the fiscal, tax, social security, occupational risk prevention, consumer and user regulations, on the prevention of money laundering, criminal code (article 31 bis: establishment of complaints channel), etc …
• Our legitimate interest as an organization also constitutes a legal basis for using your data, provided that that legitimate interest is foreseeable for you and you can reasonably expect us to use it for that interest when we collect it based on the relationship or service that joins us. E.g. for:- Our legitimate interest as an organization also constitutes a legal basis for using your data, provided that that legitimate interest is foreseeable for you and you can reasonably expect us to use it for that interest when we collect it based on the relationship or service that joins us. E.g. for:
  Inform you of our activities, products and / or services, including through electronic communications, if we already have a prior contractual relationship with you. If not, we will only send you that type of communication, if you authorize it by checking the option that is expressly included for this purpose in the corresponding forms.

  – In any case, the indicated treatment of your data we consider to be proportionate and has a minimal impact on your privacy, but your interests, rights or freedoms will always prevail over our legitimate interest, so if you do not want us to treat your data for these purposes please send us an e-mail in this regard to the client email, and we will do so.

  – Answer the requests or requests that you make us,, eg. through the forms on our website.

  – Communicate your data in accordance with recital 48 of the RGPD to other companies of the group to provide the client with a comprehensive or specialized service that requires the intervention of interdisciplinary teams; or use your data for internal administrative purposes (eg processing of personal data of customers or employees).

8. TO WHICH RECIPIENTS WILL WE BE ABLE TO COMMUNICATE YOUR DATA?

We inform you that the data you provide us may be communicated to third parties for the fulfillment of purposes directly related to the legitimate functions of transferor and assignee, such as:

• To banking entities: for the management of collections and payments.
• To our labor, accounting and tax advice: for the management of our accounting and billing, management of the workforce, and the rest of the legal obligations of the organization.
• To our legal advice, for the provision of legal advice and consulting.
• To entities or bodies to which there is a legal obligation to communicate data: for example, the Tax Administration, Social Security …
• To the Executive Service of the Commission for the Prevention of Money Laundering and Monetary Offenses to report suspicious transactions, as obligated subjects that we are.
• To Notaries, Courts or Tribunals, Registries, Attorneys, Experts, etc.
• To insurance companies: for the management and insurance of commercial risks.
• To transport companies: in charge of the logistics of shipping and delivery of our services and products.
• To stores or distributors: for the assembly and delivery of the purchased product or to resolve requests from our customers.

9. INTERNATIONAL DATA TRANSFERS

At BODEGAS VOELOS we will ensure that personal data is always processed and located in the European economic area. However, in certain circumstances, we may make international data transfers, for example, if it is necessary for the conclusion or execution of a contract, in the interest of the interested party, between BODEGAS VOELOS and another natural or legal person; or in case it is necessary for the execution of a contract between the interested party and BODEGAS VOELOS, for example when using service providers located outside the European Union, who may have access to personal data, for the provision of auxiliary services to our activity (hosting, housing, SaaS, remote backups, computer support or maintenance services, email managers, sending emails and email marketing, file transfer, etc …) or for the execution of pre-contractual measures adopted at the request of the interested party.

These entities may be different and vary over time, but we will try to choose entities, either belonging to countries that have a level of protection equivalent to the European one in terms of data protection, or that have the appropriate guarantees to achieve that level. or they will be made on the basis of any of the exceptions provided for this purpose in the RGPD.

Outside of those cases that have just been indicated, in the case of having to make transfers to a country that does not have that level of protection comparable to that of Europe, for example, because it does not have a data protection authority or regulation that protects Rights of the interested parties, by accepting this data protection policy, you authorize the transfer, for the purposes indicated in this clause.

10. SOCIAL MEDIA AND INSTANT MESSAGING APPLICATIONS.

10.1 Use of WhatsApp instant messaging

In the event that we put at your disposal an instant messaging App to speed up communication with you, use it responsibly, read the privacy policy of the same and configure it according to your preferences before sending information with personal data by said means.

Although this type of instant messaging application can be useful in certain circumstances, we remind you that the information you publish on the Internet is accessible to many people, known or unknown, so there is a risk to your privacy and that of others.

We recommend not providing personal, private and / or intimate information or that you want to keep confidential, since there are safer ways to do so. We cannot be responsible for the operation and availability of the service since it is not provided by us but by third parties outside of us.

10.2. Use of social networks

• Users have the opportunity to join the pages or groups that the organization has on different social networks. They must bear in mind that, unless the organization requests their data directly (for example, to answer queries in a private environment), their data will belong to the corresponding Social Network. Therefore, users are recommended to carefully read the terms and conditions of use and the privacy policies of the corresponding Social Network, as well as make sure to configure their preferences regarding the treatment of their data.
  
  
• Features of Social Networks incorporated into our website

Our services may include certain Social Media features and widgets, such as “Connect to Facebook” connectors, the “Like” button, the “Share it” button, or other common interactive social media mini-programs. We are not responsible for the correct operation of these.

• Rules of use of social networks:

Keep in mind that, if you decide to participate, publish or share content through our official page on a social network, said content will be public, and it will be your sole responsibility that said content comply with legal regulations.

You can prevent the inclusion of your personal data associated with said participation, configuring your privacy, or pseudonymizing your data (eg, using a “Nick” or “alias”).

We remind you that, with respect to the data of other people, you must respect their privacy by taking special care when communicating or publishing their personal data. Only its owner can authorize the processing of your personal data.

The user may only publish on this page, or on our official page on social networks, personal data, photographs and information or other content whose ownership and property belong to him or for which he holds the authorization of third parties. If you provide us or publish third party data, it is your responsibility to have their prior and express consent to use, communicate and publish them, and it is your responsibility to inform them of the processing of their data by us or its publication by you. The publication of data from third parties without their consent may violate, in addition to the regulations on data protection, those relating to the right to honor, privacy or the image of said third parties.

Social Networks are not hosted directly on our Services. Your interactions with them are governed by their policies and not ours. Read the privacy policies of these social networks for detailed information on the collection and transfer of personal data, your rights and on your privacy settings.

• Data we collect through social networks

In addition, if you log into one of these social networks during your visit to one of our websites or mobile applications, the social network may add that information to your profile and that information will be transferred to the social network. If you do not want this data transfer to take place, exit your session in the social network before entering our websites or mobile applications, since it is not in our power to influence this collection and transfer of data through the connectors social.

• Sample of other third-party pages within our website

Likewise, through our website, we can offer third-party content or services (through page frame or framing techniques), preserving the appearance of our website, and showing within it the appearance of a third party that provides the service. Keep in mind that the information you provide will be provided to those third parties, and not to us, so the policies of said third parties and not ours will govern.

11. WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US WITH YOUR DATA?

You can, when appropriate, exercise your rights of access, rectification, deletion, limitation and opposition to their treatment, as well as other rights, at the postal or email address indicated at the beginning of this privacy policy; in both cases by means of a written and signed request attaching a copy of your ID or passport or other valid document that identifies you. In case of modification of your data you must notify it at the same address, this entity declining all responsibility in case of not doing so

• Right of access: You can ask us what personal data we are dealing with, or even request a copy of it.
• Right of rectification: You can ask us to rectify inaccurate personal data or that we complete incomplete ones, including by means of an additional declaration.
• Right of deletion (right to be forgotten): You can ask us to delete your personal data when: they are not necessary for the purposes for which they were collected, you withdraw your consent, there has been an illicit treatment of them or due to compliance with an obligation legal.
• Right to limitation of treatment: You can request the limitation of the treatment of your data, in which case we will only keep it for the exercise or defense of claims.
• Right of opposition: You can oppose the treatment that is made of your data if said treatment is based on the legitimate interest of the person responsible for treatment or is for advertising purposes.
• Right to object to automated decisions: You can oppose being the subject of a decision based solely on the automated processing of your personal data, including the creation of profiles that produce legal effects on you or that significantly affect you. E.g. analyze or predict aspects related to job performance, economic situation, health, personal preferences or interests, etc. In this case we can make profiles about your preferences, if you do not object to it.

Once any of the above requests have been received, we will respond to you within the legally established deadlines. You can make a complaint to the Spanish Data Protection Agency. If you want more information about the rights that you can exercise and to request models of forms for the exercise of rights, you can visit the website of the Spanish Data Protection Agency, www.aepd.es.