PRIVACY POLICY

1. WHO IS THE DATA CONTROLLER?

MIGUEL TORRES, S.A. (from now on, TORRES), with registered office at calle Miquel Torres i Carbó, 6, 08720 Vilafranca del Penedès (Barcelona) and Tax Identification Number A-08933251.

2. FOR WHAT PURPOSE DO WE PROCESS YOUR DATA, WHAT ARE THE LEGAL GROUNDS FOR PROCESSING? HOW LONG WILL WE KEEP YOUR DATA?

Your data will be processed in accordance with:

Processing/Purpose	Legal Grounds	Duration
Create an account/Register: when you create an account or register we will process your identification and contact details to manage and maintain your user account. Your account will include any information we may collect about you, such as your content or product preferences and other information we may collect directly through surveys, promotions or by your browsing the website.	Consent	We will process your data for as long as you maintain your user account and until you cancel it or object to the processing.
Profile of our users: we profile users who interact with us. The profile allows us to offer better services, tailored to our customers’ preferences and to provide quality and personalised content. For more information about this processing, please refer to section 7 of this privacy policy. We profile users who interact with us. The profile allows us to offer better services, adapted to our customers’ preferences and to provide quality and personalised content. For more information about this processing, please refer to section 7 of this privacy policy. We also inform you that we process your data on the grounds of legitimate interest. TORRES's interest is to get to know its users so we can better target the advertising messages we send to users on our products and services. The benefit for TORRES is the saving in advertising costs. The benefit for users is that they do not receive indiscriminate advertising about products and services they are not interested in. For more information about legitimate interest, please refer to section 9 of this privacy policy.	Legitimate interest	We will process your data for as long as you keep your user account and until you cancel your user registration or object to the processing.
Contact us: when you contact us, we will process your details to deal with any doubts or queries you may have. When you contact us, we will process your details to deal with any doubts or queries you may have. We also inform you that we process your data on the grounds of legitimate interest. It is in TORRES’s interest to respond to any queries you may have. This enables TORRES to improve any matters that users have doubts or queries about. Users benefit from receiving an answer to the query and other information without the need to make queries. For more information about legitimate interest, please refer to section 9 of this privacy policy.	Legitimate interest	We will keep your data for 1 year after the query has been resolved.
Participation in competitions, promotions and prize draws: if you participate in contests, promotions and sweepstakes, your data will be processed to manage your participation in them, and to comply with the provisions of the legal grounds. If you win a prize, we may process your data to manage the communication and delivery of the prize, and to comply with any legal obligation derived from delivering it.	Contractual relationship and legal obligation	We will retain your data for 10 years after the end of the competition, promotion and/or prize draw.
Attendance at our events, tastings and experiences: if you register or book one of our events, tastings and experiences, your data will be processed to manage your registration, payment if necessary, and attendance that may involve, among other things, making access cards, and similar. We may also manage the transfer of image rights if you authorise us to do so in accordance with the pertinent clause. If you have attended our events or experiences, we may send you information and invitations to our upcoming events, if you have indicated your interest by ticking the appropriate box. TORRES informs you that if you attend as an influencer, public person or promoter of the event, we will process your data to manage the contractual relationship that binds us, the attendance to the event and the transfer of image rights if you authorise us to use them.	Consent and/or contractual relationship	We will retain your data for 2 years after the end of the event, tasting or experience unless longer periods are set forth in the image rights release documents. In connection with receiving information about our events and tastings, your data will be processed until you unsubscribe or revoke your consent.
Collaborations: we may also process your data as an influencer, public person, or promoter of an event, tasting and/or experience, competitions, promotions and/or prize draws, for which your data will be processed to contact you and, where appropriate, to manage your attendance at the event, where applicable, and the transfer of image rights if you authorise us to use them.	Legitimate interest, contractual relationship and consent.	We will retain your data for 2 years after the end of the collaboration, unless longer periods are set forth in the image rights release documents.

3. TO WHOM WILL WE DISCLOSE YOUR DATA?

If you make a purchase and on the basis of the existing contractual relationship, TORRES may communicate your data to third parties who will act as data controllers, and who will therefore determine the purposes and means for which the data will be used. These parties may be logistics companies that deliver goods to the address indicated.

Except for data communication described in the previous paragraph, your data will not be transferred, sold, rented or made available in any other way to third parties, except for the service providers who perform certain activities for us (database management, and the like) but who will in no case process the data for their own purposes.

Some of these providers may be located outside the European Union or the European Economic Area as indicated in the following section.

4. DO WE TRANSFER DATA INTERNATIONALLY?

If the third parties assisting us in the provision of services process your personal data outside the European Union or the European Economic Area, TORRES will ensure that your data is always protected with the necessary safeguards, which may include:

a) EU-approved standard clauses
b) Third-Party Certifications

You may at any time request further information about the guarantees taken in each case by contacting our Data Protection Officer at dataprotect@torres.es

5. WHAT INFORMATION DO WE COLLECT FROM THIRD PARTIES (THROUGH TOOLS SUCH AS SOCIAL LOGIN)?

In cases when you can register on the Web, through your social media user accounts, such as Facebook or Google, and if you use this option, you authorise TORRES to use, collect and process this information, mainly your email address, in accordance with the social media’s privacy policies.

This option is already configured by the Social Media and is offered as a service to users and third party companies, to facilitate registration or access without users having to enter data. The data are transmitted from social media for the described purposes, and in accordance with the rules applicable to them. Users’ processing settings are always respected. In any case, we will duly inform you of the information we collect from social media at the time of the data request..

6. WHAT INFORMATION DO WE COLLECT THROUGH COOKIES?

Through cookies, we can process and store information about how you use the website, and we can see the sections you visit, make influence maps, track behavioural patterns, and when you leave the website.

We obtain this information mainly through Cookies, so your processing will depend on the Cookies you have accepted.

Remember that you can manage cookies from our configuration option and change your preferences at any time. For more information, including the types of Cookies used and how to configure the Cookies installed on our website, please see our Cookies Policy.

7. ARE WE PROFILING USERS AND MAKING AUTOMATED DECISIONS?

As described below, TORRES can use all the information provided by you to profile you.

Such a profile will take into account for example:

Your browsing behaviour on the website, based on the products selected, cursor movements, interests, preferences, and products purchased.
Your behaviour when you receive our newsletters; for example, the content you find interesting according to which newsletters you open and the frequency.
Interaction that you may perform through other channels such as queries through our information channels, or contact.
Information you may provide to us through satisfaction surveys.

We also inform you that, for some services, we may process your personal data using automated means. This means that certain decisions are taken automatically without human intervention; for example, segmenting you according to your interest in certain sections of the website or that you may use other services that we may offer.

If you have chosen to receive commercial communications, these may be adapted and personalised, according to your interests, either based on the products and services requested, or based on data that we can deduce or obtain from your browsing, interest in certain content, reaction to our communications, among others.

This personalisation is partially automated, in the sense that we determine the parameters of the personalisation, but it is the technological platform that generates the user's profile. We do not send general communications that have not been segmented using the above procedure, as we consider that it is in our and the user's interest to send or receive relevant information, and because not segmenting would not alter the number of communications received, but only their content. If you do not wish to be segmented, please do not subscribe to commercial communications.

In the following section is more information about the sending of commercial communications and informative newsletters.

8. WHEN AND HOW DO WE SEND COMMERCIAL COMMUNICATIONS AND INFORMATIVE NEWSLETTERS?

If you have given your consent, we will process your data and send you commercial communications as well as our informative newsletter which may contain information about our products, discounts, promotions, invitations to events or opinion polls.

As a user, you should bear in mind that all our communications and newsletters may be personalised according to the interests shown, based on the products you have purchased, or the data we can obtain from the browsing behaviour shown on our website by our cookies.

This personalisation is partially automated.

We remind you that you may withdraw your consent at any time, and that all our newsletters have a link so users can unsubscribe from this information.

9. WHY CAN WE CARRY OUT PROCESSING ON GROUNDS OF LEGITIMATE INTEREST?

Under the second section of this privacy policy, TORRES processes your data on legitimate interest grounds. To assess the legitimate interest, we have assessed the legitimate interest and analysed our own benefits as data controllers and the benefits of third parties, and in which we conclude that our legitimate interest in processing prevails over the interests, rights and freedoms of users.

You may request further information about the assessment of legitimate interests by contacting our Data Protection Officer at the address stated in section 13 of this privacy policy. We would like to remind you that you may object to processing on the grounds of legitimate interest.

10. HOW LONG WILL WE KEEP YOUR PERSONAL DATA?

All data provided will be retained for the period indicated in the second section of this privacy policy.

Notwithstanding these time limits, your data may be retained in anonymised form for statistical or market research purposes, where possible, or appropriately blocked when necessary to comply with our legal obligations which may require us to retain certain data for a specified period.

11. HOW CAN I EXERCISE MY RIGHTS?

You may exercise your rights of access, rectification, deletion, opposition, limitation of processing and portability of your data by writing to calle Miquel Torres i Carbó, 6, 08720 Vilafranca del Penedès (Barcelona), or by e-mail to the following address dataprotect@torres.es, including the reference "Personal data" and in both cases providing a photocopy of your ID card or passport whenever necessary.

You may also withdraw your consent to processing operations based on consent and/or object to other processing operations where this is possible in accordance with the regulations in force. Notwithstanding the foregoing, revocation/opposition to any processing may mean that we are unable to provide you with our services.

12. HOW CAN I CONTACT THE DATA PROTECTION OFFICER (DPO)?

If you have any doubts, questions, queries or complaints about the way in which we process your personal data, you can contact our Corporate Data Protection Officer at dataprotect@torres.es or by writing to the following address: calle Miquel Torres i Carbó, 6, 08720 Vilafranca del Penedès (Barcelona) with the reference "DPO".

We inform you that if you do not receive a response within a reasonable period, you may lodge a complaint with the Spanish Data Protection Authority.

13. HOW WILL WE PROCEED IF WE CHANGE OUR PRIVACY POLICY?

Please note that we will inform you, where possible by email and/or information on our website, of any significant changes to our privacy policy so that you are informed of the changes made to the processing of your data and, if you consider it appropriate, exercise your rights on your personal data.