PRIVACY POLICY
Pursuant to Regulation (EU) 2016/679 (GDPR)
This notice is provided in accordance with Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data (“GDPR”).
1. Data Controller
The Data Controller is Rewine Italia S.r.l., headquartered at Via Del Borgo 52, 40126 Bologna (Italy), VAT No. 04145041200 (hereinafter referred to as “Rewine” or “Controller”). Rewine is responsible for ensuring the confidentiality, protection, and proper management of personal data collected through the Rewine® software.
2. Purpose and Context of Data Processing
Rewine® is a wine infotainment software available on interactive tablets provided to users in wine-tasting environments such as wineries, restaurants, wine bars, hotels, and cruise ships. The software offers users both educational content and entertainment (e.g., quizzes, technical wine sheets, ratings). Its use involves the collection and processing of users’ personal data.
3. Types of Data Collected
Access to the software is restricted to users aged 18 and above, verified by scanning a QR code. Users may authenticate via Google, Facebook, or by manually entering their data. During this process, Rewine collects the following personal information:
- Full name
- Gender
- Email address
- Phone number
- Date of birth
- Country of residence
- Preferences regarding the wines tasted
4. Purpose of Data Processing
The personal data collected are processed for specific, explicit, and legitimate purposes, in compliance with GDPR principles. These purposes include:
- Access and use of the service: enabling authentication and full access to Rewine® features, including quizzes and wine-related content;
- Age verification: confirming the user is at least 18 years old before accessing the platform;
- Generation of personalized certificates: after completing the wine quiz, users may receive a customized certificate displaying their name, score, and the logo of the venue;
- Data sharing with the hosting venue: user data may be shared with the establishment (winery, restaurant, etc.) where Rewine® was used, to foster personalized engagement;
- Promotional communications and personalized marketing: sending informative and promotional emails based on user preferences, from both Rewine and the operator;
- Statistical analysis and profiling: compiling aggregated data to understand consumer behavior, trends, and wine preferences;
- Commercial management: Rewine reserves the right to use the data to develop new features, improve services, or to transfer or assign such data to third parties, in compliance with applicable regulations.
5. Legal Basis for Processing
Rewine processes personal data based on the following legal grounds:
- Explicit consent: freely given by the user upon registration or authentication. Consent is required for access and promotional communications;
- Performance of a contract: use of the software establishes a contractual relationship, even implicitly, requiring data processing for service delivery;
- Legitimate interest: Rewine and its licensed partners have a legitimate interest in developing effective marketing strategies, provided this does not override the rights and freedoms of the data subject.
6. Data Processing Methods and Security
Data are processed electronically using appropriate measures and procedures to ensure their security, integrity, and confidentiality. Rewine adopts suitable technical and organizational measures to prevent unauthorized access, disclosure, alteration, or destruction of personal data.
7. Data Sharing and Disclosure
All collected data remain the exclusive property of Rewine Italia S.r.l., which may share them with the venue where the software was used. This allows operators to:
- Contact the user;
- Understand their wine preferences;
- Send tailored promotional content.
Rewine may also transfer or assign data to third parties for commercial, statistical, or marketing purposes, while ensuring compliance with data protection regulations.
8. Data Retention
Personal data will be retained indefinitely unless the data subject exercises their rights or
legal provisions impose a different retention period.
9. Transfer of Data to Non-EU Countries
Personal data may be transferred to entities located outside the European Union, particularly when using services such as Google or Facebook. In such cases, Rewine ensures appropriate safeguards are in place, such as standard contractual clauses approved by the European Commission.
10. Rights of the Data Subjects
Users of Rewine® have the right to exercise, at any time, the rights outlined in Articles 15–22 of the GDPR. Specifically, users may:
- Access their data and obtain confirmation regarding their processing, the purposes, third parties involved, and retention period;
- Request rectification of inaccurate or incomplete data;
- Request deletion of data in circumstances defined by Article 17 of the GDPR (e.g., data no longer needed, consent withdrawal, unlawful processing);
- Request restriction of processing under certain conditions (e.g., data accuracy contested, objection to processing);
- Object to processing for legitimate reasons or when used for direct marketing;
- Request data portability, receiving data in a structured, commonly used, and machine-readable format to transmit to another controller;
- Withdraw consent at any time, without affecting the lawfulness of prior processing;
- File a complaint with the Data Protection Authority if the processing is believed to violate applicable regulations.
To exercise their rights, users may contact Rewine Italia S.r.l. at: amministrazione@rewine.biz.
11. Use of Cookies and Similar Technologies
The Rewine® software may use technical cookies required for its proper operation. Profiling or analytical cookies will only be used with the user’s prior explicit consent, as outlined in the Cookie Policy available within the software.
Last updated: 11/06/2025