Privacy Policy

INTRODUCTION

 

  • Symington Family Estates Vinhos SA, as Data Controller, is fully committed to protecting your privacy and personal data.
  • At Symington Family Estates we know that we have a legal duty to protect the personal data we process, whether from users of our website, employees, service providers, suppliers and customers, and we comply with and enforce the terms of the General Regulation on Data Protection Data, dated April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free movement of such data (GDPR) and respective national implementing law, Law No. 58/2019, of August 8th.
  • If you have any questions, comments or suggestions about our Privacy Policy, please contact us, using the contact details indicated in point 11 of this policy. 

GENERAL PRINCIPLES OF OUR PRIVACY POLICY

In your relationship with us, whether when you access our website, or when you provide us with your personal data or interact with us in such a way that we can collect it, we make it clear that you accept our Privacy Policy, which is based on the principles set out below :

  • Only authorised persons use authorised data for authorised purposes;
  • We understand that the security of your data is a priority that we review periodically in accordance with technological innovation;
  • We know that personal data does not belong to us, but to its holders.
  • We promote good practices in the areas of Privacy, Data Protection and Information Security, which we continually review because we understand that we are part of a process of continuous improvement, where it is always possible to do more and better.

     

    CONCEPTS AND INFORMATION FOR THE DATA SUBJECT

     

    1. What is Personal Data and how is it processed?

    a) For the purposes of this Policy, we follow the definition adopted by the General Data Protection Regulation (GDPR), namely, any information relating to an identified or identifiable person, with a person who can be identified being considered identifiable, directly or indirectly, namely by reference to an identification number or to one or more specific elements of your physical, physiological, mental, economic, cultural or social identity.

    b) Likewise, processing is an operation or set of operations carried out on personal data or on sets of personal data, by automated or non-automated means, such as collection, registration, organisation, structuring, conservation, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, broadcast or any other form of availability, comparison or interconnection, limitation, erasure or destruction.

     

     

    2. How does Symington Family Estates collect your personal data?

       

      a) As part of our activity, we collect and process your personal data through various means, including by telephone, in writing and when you contact us in person.

      b) The data we collect is only that strictly necessary for the development of our activity and the provision of our services.

      c) Symington Family Estates may use automated means to collect information about you, the devices you use and your interaction with our website. These automated means include trackingtechnologies such as cookiesand web server logs, which may collect information such as: IP address, access device, operating system, domain, website address and the address of the web page that brought you to our website.

       

      3. What personal data does Symington Family Estates collect ?

      a) The categories of data that we collect, for the purpose of providing our services to our customers, depend on the purpose pursued, namely the following, as applicable:

      • Identification data (e.g. name, date of birth, nationality)
      • Contact data (e.g. telephone number, email, address)
      • Payment and billing data (e.g. credit card details)
      • Browsing data (such as IP addresses, operating system, access device, language, browsing history and other information collected by cookies).
      • Image, both because certain facilities belonging to Symington are under video surveillance, we may capture your image, for use in documenting activities, among others.

      b) The personal data we collect is subject to computer processing and stored in databases, with current legislation relating to Data Protection and Information Security standards being strictly complied with.

      c) We will only process your personal data in accordance with a specific and legitimate purpose or purposes, determined at the time of collection, and such data will not be further processed in a way that is incompatible with those purposes, except if for the purpose of archiving in the public interest, scientific or historical research or, even, for statistical purposes, in which cases, under the terms of the GDPR, this incompatibility does not occur.

      d) If we collect and process special categories of personal data (“sensitive data”), this processing will only be carried out in accordance with the exceptions set out in article 9, paragraph 2 of the GDPR.

      e) If this data is collected from the holder and the processing of special categories of data (“sensitive data”) is carried out based on your consent, we will inform you of the right to withdraw consent, provided for in number 2, paragraph d ) referred to above, without, however, compromising the lawfulness of the processing carried out based on previously given consent.

       

       

      4. For what purposes does Symington Family Estates process your personal data?

         

        4.1. We process your personal data for the following purposes:

        a) To be able to provide services and sell products to our customers;

        b) To execute and manage orders and membership subscriptions;

        c) To provide the information requested and respond to requests sent to us;

        d) To monitor, comply with or evaluate:

        • the website terms and conditions;
        • the presentation of complaints;
        • website security;
        • To optimise the visit and the navigability and personalisation of the website.
        e) Management and execution of the contractual relationship, such as:
        • Provision of contracted services;
        • For billing and collection purposes for services provided;
        • iii. To communicate changes to the conditions for providing contracted services.

        f) To comply with legal obligations to which we are subject;

        g) To control access and safeguard the security of installations;

        h) To carry out statistical studies.

         

        4.2. Depending on the circumstances, the processing of your personal data may be carried out on the following legal basis:

        • conclusion or execution of a contract or for pre-contractual measures at the request of the data subject;
        • compliance with legal obligations to which we are subject;
        • the exercise of functions of public interest or the exercise of public authority;
        • our legitimate interests;
        • the consent given by the data subject, when consent is the legal basis for the processing;
        • the defence of the vital interests of the data subject.

           

          4.3. If you wish to withdraw your consent, you can contact us at dpo@symington.com

           

           

          5. How long does Symington Family Estates keep your personal data?

          a) The period of time during which data is stored and preserved varies according to the purpose for which the information is processed.

          b) There are legal requirements that oblige us to retain data for a minimum period of time, which we will respect.

          c) If there is no legal retention period, the data will be stored and preserved only for the minimum period necessary for the purposes that motivated its collection and subsequent processing, after which it will undergo appropriate treatment, being destroyed or anonymized.

           

           

          6. What are your rights as a data subject?

             

            6.1. In accordance with the provisions of the GDPR, we guarantee the exercise of your rights as a data subject, namely:

             

            • Right of Access – you have the right to request from us, among others, information regarding whether or not your data is being processed, what data we process and for what purposes. If you wish, you can ask us for a copy of the personal data being processed, and the provision of other copies may be subject to payment of a reasonable fee, taking into account administrative costs. If the request is requested in electronic format, and unless you indicate otherwise, the information will be provided by us in a commonly used electronic format.
            • Right to Rectification – you have the right to have us rectify inaccurate personal data concerning you without undue delay and have incomplete data completed.
            • Right to Cancellation – also known as the right to be forgotten – you can request, in certain circumstances, that your personal data be erased from our records, without undue delay, whenever any of the reasons set out in the GDPR apply.
            • Right to Object – you have the right to object, for reasons related to your particular situation, to certain types of data processing provided for in the GDPR, such as processing for direct marketing purposes, in which case we will cease processing for that purpose.
            • Right to Portability – you have the right to transfer your personal data that we keep to another organization or to receive it in a structured, commonly used and machine-readable format.
            • Right to Limitation of Processing – the right to obtain limitation of the processing of your personal data, when you wish, for example, to contest the accuracy of your personal data for a period of time that allows us to verify its accuracy, when the processing is unlawful or if you have deducted your right to object.
            • Complaint – the data subject also has the right to lodge a complaint with a supervisory authority, the Portuguese being the National Data Protection Commission.

               

              6.2. For the purpose of exercising these rights, please see point 11 of this Privacy Policy, below.

               

              6.3. After sending the email, you will be sent the Data Subject Exercise Form, which you must complete and return to us.

               

              6.4. Within the legal period of 30 (thirty) days you will receive a duly substantiated communication from us.

               

               

              7. What measures has Symington Family Estates implemented to ensure the security of your personal data?

                 

                We adopt appropriate technical and organisational measures to ensure a level of security appropriate to the risk, which we periodically review and improve, aimed at guaranteeing the security and protection of your personal data in terms of its availability, integrity and confidentiality, as well as those aimed at preventing the its loss, misuse, alteration, unauthorized treatment or access, as well as any other form of illicit treatment.

                 

                8. Does Symington Family Estates communicate your data to third parties?

                   

                  8.1. As part of our activity, we may use subcontractors who process your data on our behalf, which implies access, by these entities, to that data, and when this happens, we take the appropriate measures, contractually provided, in order to ensure that these third parties, subcontractors, provide sufficient and adequate guarantees for the execution of technical and organisational measures and will only act in accordance with our instructions.

                   

                  8.2. We use subcontractors in particular to provide the following services: payment processing, facility security, auditing, software supply and order dispatch.

                   

                  8.3. We may also share your personal data with third parties, in strict compliance with legal obligations or when we have obtained your consent to do so.

                   

                   

                  9. Does Symington Family Estates make international transfers of your personal data?

                  a) It may happen that we have to communicate personal data to third countries or international organisations. In this case, we will strictly comply with the applicable legal provisions and submit transfers to appropriate mechanisms, depending on the level of personal data protection guaranteed by the third country or international organisation in question.

                  b) In particular, security issues at the level of data transmission will be taken care of, if the third parties are contractually bound and respect the confidentiality of the data received, and will not use them under any circumstances for purposes other than those that motivated the transmission or for benefit own or third party.

                   

                  10. How does Symington Family Estates use “cookies” on its websites?

                    To find out more about cookies and how we use them on our website, please see our Cookies Policy.

                     

                     

                    11. Contact us

                      If you have any questions or concerns about the way we collect and process personal data, you can contact us using the following contact details:

                       

                      Contact

                      E-mail: dpo@symington.com

                      Morada: Travessa Barão de Forrester 86, Apartado 26, 4431-901 Vila Nova de Gaia

                       

                       

                      12. Review of our Privacy Policy

                      a) We reserve our right to change the content of this privacy policy without prior notice, without prejudice to informing and publishing it on our website, prominently, whenever this happens, making these changes an integral part of the Privacy Policy.

                      b) After this publication, the user is bound by the new terms when browsing our website and whenever interacting with us.