Pursuant to Regulation (EU) 2016/679 (GDPR)
This privacy notice is provided in accordance with Regulation (EU) 2016/679 concerning the protection of natural persons with regard to the processing of personal data (hereinafter referred to as the “GDPR”).
1. Data Controller
The Data Controller is Rewine Italia S.r.l., with registered office at Via Del Borgo 52, 40126 Bologna (Italy), VAT No. 04145041200 (hereinafter, “Rewine” or the “Controller”). Rewine is responsible for ensuring the confidentiality, protection, and proper handling of personal data collected through the Rewine® software
2. Types of Data Processed
Personal Data voluntarily provided by the User
The Controller collects personal data and other information directly from Users during the online registration process on the website rewine.biz, in order to provide the requested services. This includes:
- Email address
- First and last name
- City
- Address
Users assume responsibility for any third-party personal data they publish or share via rewine.biz and confirm that they have the right to communicate or disclose such data, thereby releasing the Controller from any liability toward third parties.
Usage Data automatically collected when the User uses rewine.biz
The IT systems and software procedures used to operate rewine.biz acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols, such as:
- Device information (e.g., IP address, operating system, browser ID)
- Log data (e.g., server access logs indicating access type and origin IP address)
- Website usage data (e.g., access time, browsing activity)
- Website statistics (e.g., reports on delivery/opening of emails sent by our clients)
This data is not accompanied by additional personal information and is used to:
- Identify potential cybercrimes;
- Obtain anonymous statistical information about site usage;
- Monitor how the site is used.
Personal Data automatically collected from emails and communications
When we send emails or communications, we use tracking systems, such as pixels or web beacons, to detect whether a message is opened, which links are clicked, the IP address and browser used, and similar details.
Unless otherwise specified, all personal data requested by rewine.biz is mandatory. If the User refuses to provide such data, rewine.biz may be unable to provide the service.
3. Purpose of Processing
User data is collected for the following purposes:
- To provide the requested service;
- To fulfill legal obligations;
- To respond to legal requests;
- To protect the rights and interests of the Controller, Users, or third parties;
- To detect malicious or fraudulent activities.
A. CONTACT MANAGEMENT AND MESSAGE DELIVERY
By subscribing to the newsletter, the User’s email address is added to a contact list used to send email messages with service-related information.
This activity is managed through the REWINE platform, owned by REWINE ITALIA S.R.L.
Personal Data processed:
Email, First name, Last name
B. STATISTICAL PURPOSES
This involves monitoring and analyzing website traffic and tracking User behavior using:
Google Analytics (GA4) with IP Anonymization
Provided by Google Ireland Limited, Google Analytics is used to analyze site usage, compile reports, and share data with other Google services. IP addresses are anonymized before being logged.
Data processed: City; Usage data; browser/device info; city latitude/longitude; number of Users; session statistics; tracking tools.
Legal base: USA
Google Privacy Policy
C. TAG MANAGEMENT
These services allow centralized management of tags or scripts used on rewine.biz. Data may be transmitted through and retained by these tools.
Google Tag Manager
Provided by Google Ireland Limited.
Data processed: Cookies, Usage data
Google Privacy Policy
4. Legal Basis for Processing
The processing of personal data by Rewine is based on the following legal grounds:
- Explicit consent: voluntarily given by the User during registration or login; required to access services and receive promotional communications;
- Contract performance: use of the software constitutes a (possibly implied) contractual relationship requiring data processing;
- Legitimate interest: Rewine has a legitimate interest in developing marketing strategies, provided such interest does not override the User’s rights.
Usage data processing is based on the necessity to enable the functionalities of rewine.biz.
Personal data voluntarily provided is processed with the User’s consent or, alternatively, if:
- Processing is necessary to comply with legal obligations;
- Processing is necessary for a task carried out in the public interest or under official authority;
- Processing is required for legitimate interests pursued by the Controller or third parties.
5. Processing Methods and Data Retention
Data is processed electronically, using appropriate tools to ensure security, integrity, and confidentiality. Rewine applies technical and organizational measures to protect data from unauthorized access, disclosure, alteration, or destruction.
Data is stored only as long as necessary to fulfill the purposes for which it was collected, in compliance with legal obligations.
If a User requests deletion, all their personal data will be erased, unless retention is required by law. In any case, Rewine enforces a maximum data retention policy of three years, in accordance with data minimization principles.
6. Data Disclosure and Sharing
Collected data is owned by Rewine Italia S.r.l. and may be shared with the operator where the User used the software, for the following purposes:
- Contacting the User;
- Accessing tasting preferences;
- Sending personalized promotional messages.
Rewine may also transfer data to third parties for commercial, statistical, or marketing purposes, in compliance with applicable data protection laws.
7. Authorized Personnel and Processors
Data is processed by Rewine’s internal staff, duly authorized and instructed in accordance with applicable regulations.
Where necessary for the purposes described, personal data may also be processed by:
- Professionals or consultants providing support to the Controller;
- Companies or organizations offering ancillary services (e.g., market research, IT maintenance);
- External providers managing services such as notifications, email verification, statistics, marketing platforms, data storage, and customer service.
8. Data Retention Period
Unless otherwise requested by the data subject or required by law, personal data will be retained indefinitely.
9. Transfers to Third Countries
Data may be transferred to countries outside the EU (e.g., when using Google or Facebook services). In such cases, Rewine ensures appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission.
10. Data Subject Rights
Users may exercise their rights at any time under Articles 15 et seq. of the GDPR, including:
- Accessing their personal data and information on its processing;
- Requesting rectification or integration of inaccurate/incomplete data;
- Requesting erasure of data in the cases provided under Article 17 GDPR;
- Restricting processing under specific circumstances;
- Objecting to processing for legitimate reasons or direct marketing;
- Requesting data portability in a structured, commonly used, machine-readable format;
- Withdrawing consent at any time, without affecting prior lawful processing;
- Lodging a complaint with the Data Protection Authority if they believe their rights have been violated.
To exercise these rights, Users may contact Rewine Italia S.r.l. at: amministrazione@rewine.biz
11. Use of Cookies and Similar Technologies
Please refer to the Cookie Policy page for more information.
12. Legal Defense
User data may be used in legal proceedings or preparatory phases to defend against improper use of rewine.biz or its associated services.
Users acknowledge that the Controller may be required to disclose personal data upon request by public authorities.
13. Changes to This Privacy Policy
The Controller reserves the right to modify this Privacy Policy at any time. Users will be notified on this page or, if technically feasible, through direct notification via contact details held by the Controller. Please check this page regularly, referring to the last updated date below.
DEFINITIONS
- “Personal Data”: Any information relating to an identified or identifiable natural person (“data subject”); including identifiers such as name, ID number, location data, online identifier, or characteristics of identity (physical, genetic, mental, economic, cultural, or social).
- “User”: The individual using rewine.biz, who is also the data subject unless otherwise specified.
- “Data Subject”: The individual to whom the personal data refers.
- “Data Controller”: The entity that determines the purposes and means of processing personal data.
- “Data Processor”: Any entity processing personal data on behalf of the Controller.
- “rewine.biz”: The software/hardware platform through which personal data is collected and processed.
- “Service”: The service(s) provided by rewine.biz, such as newsletters and updates to registered Users.
Last updated: 09 July 2025
