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Privacy

Privacy Policy

Update date February 2025

This privacy notice, provided pursuant to Articles 13 and 14 of the GDPR, explains how the data of users and customers, also when interacting with the Callmewine website (the “Website”, owned by Callmewine), is processed by Callmewine. 

Data Controller:  Callmewine S.R.L., registered office at Via Natale Battaglia 8, 20127 Milan, Tax/VAT No. 07130650968 (hereinafter “Callmewine”), can be contacted at the following details: Via Natale Battaglia 8, 20127, Milan, Phone: +39 02 81480430 (Monday-Friday 9:30 AM - 1:30 PM and 3:00 PM - 6:00 PM), Email info@callmewine.com

Callmewine has appointed a Data Protection Officer , reachable at the email address privacy.dpo@callmewine.com

Processing methods

The processing of personal data of data subjects will primarily be carried out using electronic or otherwise automated means, according to methods and with tools suitable to ensure the security and confidentiality of the data in accordance with the GDPR. In particular, all necessary technical, IT, organizational, logistical, and procedural security measures will be adopted to ensure the minimum level of data protection required by law, allowing access only to persons authorized to process data on behalf of Callmewine or the processors appointed by Callmewine.

The processing of personal data does not involve fully automated decision-making processes, and the security measures related to data processing for the purposes indicated in letter E of the table below have been adequately evaluated through specific assessments carried out by the Controller.

The collected information and the processing methods will be relevant and not excessive in relation to the type of services provided. The data will also be managed and protected in environments whose access is under constant control. In particular:

• Navigation data is collected through the use of cookies. To better understand how cookies work and how to enable or disable them, please refer to our Cookie Policy  .

• Data for marketing purposes is processed through automated systems such as e-mail, SMS, WhatsApp, or other instant messaging systems, or through traditional methods (e.g., postal mail or brochures).

• Plug-ins and social interaction: by accessing any area of the Website equipped with these tools, the Internet browser will connect users directly to the servers of the third-party sites in question, thus transferring their personal data to the operators of those sites, as indicated in the Cookie Policy  .

Depending on the specific agreements with the operators of these third-party sites, Callmewine may act as an independent controller or as a joint controller with regard to these data transfers. For information on privacy protection methods and the processing of personal data collected by the operators of third-party sites involved in these interactions, please refer to the relevant websites.

• Payment method data: Callmewine may become aware of some information related to the checkout system used by the user or customer (e.g., payment method, first and last digits of the card used) but will in no way have direct access to the clear payment data of users or customers. In the case of payment with one of the types of payment cards indicated on the Website, the data will be entered on a page that communicates through a secure encryption protocol directly with the payment service provider, who acts as an independent controller. Likewise, in the case of payment via PayPal, Scalapay, Klarna, or other payment service providers, the user will be redirected to an external page outside the Website.

Data retention

• Personal account on the website: until the account is deleted. The retention period may be extended if necessary to comply with a legal obligation to which Callmewine is subject or to protect a right of Callmewine in pre-litigation, judicial, extrajudicial, and/or before a competent authority.

• Data processed for contract execution and purchases: a maximum of 10 (ten) years from the purchase itself, subject to extension if necessary to comply with a legal obligation or to protect a right of Callmewine in pre-litigation, judicial, extrajudicial, and/or before a competent authority.

• Marketing activities: until consent is revoked, and in its absence, no longer than 48 months from the date of consent;

• Soft-spam: until opt-out is exercised in the case of communications related to products similar to those purchased by customers on the Website (soft-spam), and in any case no longer than 48 months from the last purchase.

• Profiling activities: until consent is revoked, and in its absence, no longer than 12 months from the date of consent;

• Preferences and personalized offers: until the data subject exercises the right to object, and in its absence, no longer than 12 months from the collection of data through cookies;

• Abandoned cart: for a maximum of 24 months from the interruption of the purchase.

• Data provided when contacting customer service: retention period: for the period strictly necessary to respond to requests from data subjects and in any case within 2 years from handling the request.

• Browsing data: these data are stored only for the time strictly necessary for the purposes for which they were collected, according to the Cookie Policy  .

Communication and dissemination of data

Personal data collected will be processed by personnel authorized by Callmewine who need to know them in the course of their activities and/or by external parties providing services on behalf of Callmewine, such as IT system management, competent authorities and/or public bodies and supervisory authorities for legal obligations, communication agencies and companies, acquired companies or buyers in the event of extraordinary operations (e.g., mergers, acquisitions, etc.), external professionals and consultants, and other parties collaborating in any capacity – for the achievement of institutional purposes and the provision of services to data subjects – with the Controller and who may act as data processors or independent controllers. A complete list of these subjects is available upon request from the Controller using the contact details provided.

Data relating to data subjects will not be disseminated, except in anonymous and aggregated form, for statistical or research purposes. 

Transfer of data outside the EEA

Callmewine may transfer personal data of data subjects to countries outside the European Economic Area (“EEA”), which includes, in addition to EU Member States, Norway, Liechtenstein, and Iceland, when necessary to pursue the purposes of processing described in this Privacy Notice. In such cases, Callmewine ensures that any transfers to such countries are made in a way that guarantees full protection of the rights and freedoms of data subjects, using adequacy decisions by the European Commission, and, where necessary, adopting the safeguards provided by Articles 46 and following of the GDPR, including the standard contractual clauses approved by the European Commission. The list of countries to which data is transferred and the safeguards adopted to enable lawful transfers is available upon request from the Controller.

Rights of the data subject

Pursuant to Articles 15-22 of the GDPR, the data subject has the right to:

• receive confirmation of the existence of their personal data and access their content (right of access);

• request the Controller to update, modify, and/or correct their personal data (right to rectification);

• request the deletion or limitation of the processing of data processed unlawfully, including data whose retention is not necessary for the purposes for which the data were collected or otherwise processed (right to erasure and right to restriction);

• object to processing: i) in case of processing based on legitimate interest, unless the Controller demonstrates compelling reasons that justify continuing the processing despite the objection; ii) in case of processing based on consent (e.g., data processing for marketing and/or profiling purposes), without the possibility for the Controller to continue processing after the exercise of the objection and/or, in any case, in case of revocation of previously given consent (right to object);

• in cases where processing is based on consent or contract and carried out using automated means, exercise the right to data portability, i.e., receive personal data in a structured, commonly used, and machine-readable format and, if technically feasible, transmit them to another controller without impediments.

The above rights may be exercised by submitting a request without formalities to the Data Protection Officer at privacy.dpo@callmewine.com.

At any time, the data subject may also file a complaint with the Data Protection Authority, as well as seek other remedies provided by applicable laws.

Changes

Callmewine reserves the right to make changes to this privacy notice at any time, providing appropriate notice via the Website or by email.

Types of data processed, purposes, and legal basis of processing

Callmewine will process the personal data collected according to the methods and for the purposes described below: