Privacy Policy

Privacy by Callmewine

Privacy Policy

Data update February 2025

This privacy notice, provided pursuant to Articles 13 and 14 of the GDPR, explains how the data of users and customers - also in the context of interactions with the website www.callmewine.de (the "Website," owned by Callmewine)- is processed by Callmewine.

Data Processing Owner : with its registered office at Via Natale Battaglia 8, 20127 Milan, CF/VAT No. 07130650968 (hereinafter referred to as "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, who can be contacted at the email address privacy.dpo@callmewine.com.

Methods of processing

The processing of personal data of the data subjects will primarily be carried out using electronic or automated means, according to methods and with tools suitable to ensure the security and confidentiality of the data in compliance 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 authorized persons for processing by Callmewine or by the data processors appointed by Callmewine. The processing of personal data does not involve fully automated decision-making processes, and the security measures related to the processing of data for the purposes outlined in letter E of the table below have been adequately assessed through specific evaluations conducted by the Data Controller.

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

• Navigation data is collected using cookies. To better understand how cookies work, how to activate and eactivate them, please refer to our Cookie Policy

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

• Plug-ins and interaction with social media: 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, thereby transferring their personal data to the operators of those sites, as outlined in the Cookie Policy . The processing of personal data does not involve fully automated decision-making processes, and the security measures related to the processing of data for the purposes outlined in letter E of the table below have been adequately assessed through specific evaluations conducted by the Data Controller.

Depending on the specific agreements with the operators of these third-party sites, Callmewine may act as an independent data controller or as a joint data 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 the interactions described, please refer to the relevant websites.

• Payment method data: Callmewine may become aware of certain 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 not have any direct access to the payment data of users or customers. In fact, when paying through one of the payment card types listed on the Website, the data will be entered on a page that communicates via a secure encryption protocol directly with the payment service provider, which acts as an independent data controller. Similarly, in the case of payment via PayPal, Scalapay, Klarna, or other payment service providers, the user will be redirected to a page external to the Website.

Data retention

• Personal account on the website: until the account is deleted. However, 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 period of 10 (ten) years from the purchase itself, unless the retention period needs to be extended 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 the absence of consent, no longer than 24 months from the date consent was given.

• Soft-spam: until the opt-out right 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 24 months from the last purchase.

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

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

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

• Data provided when contacting customer service: Retention period: for the period strictly necessary to respond to the data subject’s requests and in any case, within 2 years from the management of the request.

• Browsing data: These data are stored only for the time strictly necessary for the purposes for which they were collected, as indicated in the Cookie Policy .

Communication and dissemination of data

The personal data collected will be processed by staff authorized by Callmewine who need to be aware of the data in the course of their duties and/or by external parties providing services on behalf of Callmewine, such as those involved in the management of the IT system, competent authorities and/or public bodies and oversight and regulatory bodies for the fulfillment of legal obligations, communication agencies and companies, acquired companies or buyers in the event of extraordinary transactions (e.g., mergers, acquisitions, etc.), external professionals and consultants, and other parties who collaborate in any capacity – for the achievement of institutional purposes and the provision of services to the data subjects – with the Data Controller and may act as data processors or independent controllers. A complete list of these subjects is available upon request from the Data Controller through the contact details provided.

The data related to the 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 the personal data of data subjects to countries outside the European Economic Area (EEA), which includes, in addition to the EU member states, Norway, Liechtenstein, and Iceland, where such transfers are necessary to pursue the purposes of the processing described in this Privacy Notice. In such cases, Callmewine ensures that any transfers of data to such countries will be carried out in a manner that guarantees the full protection of the rights and freedoms of the data subjects, using appropriate adequacy decisions from the European Commission, and, where necessary, adopting the safeguards provided by Articles 46 and subsequent 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 legitimate transfers is available upon request from the Data Controller. 

Rights of the Data Subject

In accordance with Articles 15-22 of the GDPR, Callmewine has the right to:

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

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

• Request the deletion or restriction of the processing of data processed in violation of the law, including those for which retention is not necessary in relation to the purposes for which the data was collected or otherwise processed (right to be forgotten and right to restriction);

• Object to the processing: i) in the case of processing based on legitimate interest, unless the Data Controller demonstrates compelling reasons justifying the continuation of the processing even in the presence of opposition; ii) in the case of processing based on consent (for example, data processing for marketing and/or profiling purposes), without the possibility for the Data Controller to continue processing after the exercise of opposition and/or, in any case, if the previously given consent is revoked (right to object);

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

The above rights may be exercised by submitting a request, without formalities, to the Data Protection Officer at the email address 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 the applicable laws.

Updates

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 bases of processing

Callmewine will process the personal data collected in the manner and for the purposes described below: