Privacy Policy:

This page describes some management rules for Agatheia Srl websites regarding the personal data of users who consult them.

These rules apply in all cases where you access our sites by browsing the pages without registering or filling in or entering data into web forms. By visiting Agatheia Srl sites, you accept the terms and conditions outlined below. If you do not agree to these terms, please do not access or use the content and services offered through our sites.

For users of web services that require personal data

Information for the processing of personal data provided pursuant to and for the effects of art. 13 Legislative Decree 196/03 and art. 13 of EU Regulation 2016/679.

Types of data we collect during user navigation

While you visit our sites, the computer systems responsible for their operation acquire, during their normal operation, certain data whose transmission is implicit and necessary for the operation of the Internet. These are pieces of information that are not collected to be associated with identified subjects, but which by their nature could, through processing and associations with data held by third parties, allow users to be identified. This category of data includes, for example, IP addresses or domain names of computers used by users who connect to the sites, URIs (Uniform Resource Identifiers) of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.), and other parameters relating to the operating system and the user’s computer environment.
Agatheia Srl uses this data solely to obtain anonymous statistical information about the use of the sites and to monitor their proper functioning. The data could be used to ascertain responsibility in case of hypothetical computer crimes. Except for this possibility, such data persist on our computer systems for a period normally not exceeding thirty days.
On Agatheia Srl sites, you can also find social buttons/widgets, which are those particular “buttons” featuring icons of social networks (e.g., Facebook and Twitter) that contain content from social networks.
These “buttons” allow users browsing Agatheia Srl sites to reach and interact with social networks with a single click.
Thanks to your click on Social buttons/widgets and/or interactive social walls, the social network acquires data related to your visit. Outside of these cases, where you voluntarily choose to share your browsing data with the selected social networks through a click, Agatheia Srl does not share any navigation information or user data acquired through its sites with the social networks accessible via Social buttons/widgets and interactive social walls. For any other information about the interactive social walls and social buttons/widgets used on our sites, write to privacy@wineforclimate.eu.

WITH WHOM DO WE SHARE NAVIGATION INFORMATION?

The data acquired during navigation may be known by third-party companies that provide Agatheia Srl with computer assistance and data processing services (for example, in the case of hosting activities entrusted to third parties and connected to the use of our websites), appointed as data processors for this purpose.
The list of entities appointed as data processors can be obtained by writing to the address privacy@wineforclimate.eu.

The data may also be known and processed within Agatheia Srl by personnel entrusted with processing to the extent necessary for the performance of their duties, carrying out only the operations necessary for the execution of the same. In the event of an express request and under circumstances authorized by law, the data may be communicated by Agatheia Srl to Public Security Authorities and Police forces. No navigation data is ever disseminated.

SPONTANEOUS EMAIL SUBMISSION

When you spontaneously send an email to one of the email addresses indicated on our sites, we acquire the sender’s address and any other personal data you have entered in the message and attachments. The email boxes corresponding to the addresses indicated on our sites, as well as any other email boxes of Agatheia Srl, are not personal even when they contain the name and/or surname of a natural person. They belong to the corporate organization and have the primary purpose of enabling effective work activities within Agatheia Srl. This means that messages forwarded to the email boxes of Agatheia Srl may be known not only by the recipient but also by other individuals within the organization. By sending emails to the email addresses indicated on our sites, you declare that you have read and accepted the processing conditions contained in this policy.

COMPLETION OF WEB FORMS

When you access Agatheia Srl websites and decide to use their services interactively (e.g., newsletter requests, registration on sites and communities, purchases, participation in events, campaigns, etc.), you may be asked to fill out web forms with some of your personal data. We provide you with some useful information below to understand how we process the data you send us.

Processing methods and purposes

To access services and content provided through our sites, you may be required to provide personal data such as, for example, name, surname, address of residence/domicile, email, date of birth, etc. Through the web forms available on the sites, we never ask for sensitive data (e.g., related to revealing racial and ethnic origin, religious, philosophical, or political beliefs, health status, sexual life, etc.) or judicial data (data concerning criminal records, or pertaining to the status of accused or investigated, etc.). Data processing will be carried out using computer, telematic, and paper tools and supports in compliance with legal provisions aimed at guaranteeing security and confidentiality, as well as accuracy, updating, and relevance of data with respect to the declared purposes. You can help us ensure that your data is always accurate by informing us of updates at the address privacy@wineforclimate.eu. The data you provide will be processed by personnel expressly designated by the Data Controller as authorized representatives and/or data processors, according to their respective authorization profiles assigned. Authorized representatives and processors may carry out consultation, use, processing, comparison, and any other appropriate operation, even automated, only where expressly authorized to do so. We will process the personal data you provide us only for the purpose that is relevant to each individual service requested and used. In all cases where we intend to use your data for purposes other than or different from the provision of the requested service, before proceeding with the processing, we will ask for your consent.
The provision of data for certain specific purposes (e.g., newsletter subscription, registration for reserved areas, product purchases, Customer care, direct marketing, profiling, loyalty programs) will involve the insertion of the data itself into the Agatheia Srl Customer Relationship Management (CRM) system dedicated to customer management, accessed only by personnel specifically authorized by Agatheia Srl.
Below is a list of services available on our sites for which we ask you to provide us with your personal data. For each service, the processing purpose is indicated.

Newsletter subscription:

the newsletter is a communication with promotional and advertising content sent to all interested parties who request it. On some of our sites, newsletter subscription involves sending targeted promotional communications based on the language, gender, and country of origin of the interested party. This means that we process the data we receive in order to divide subscribers into distinct groups by language, gender, and country of origin so that the newsletter sent is as close as possible to what you have requested and may be interested in. The data you provide for newsletter subscription will be kept until we receive a request for unsubscribing from you, in which case we will delete your data from our databases within 72 hours of the unsubscription request. The sending of such commercial communications will be carried out only with your consent which will constitute the legal basis with which we will process your data.

Participation in events, events, competitions and thematic initiatives of an extraordinary and temporary nature: we will use the data to allow you to participate in the specific initiatives you intend to join from time to time. For each event we will provide you with specific information which will describe the type of data processed, the retention times of the same and the specific processing purposes. We will collect your data only with your consent which will constitute the legal basis with which we will process them. Requests for information or

contact (e.g. request for commercial and technical information, contact requests, etc.):
we will use the data you provide us to send you exclusively what you requested.

Direct marketing:

we may ask for your consent to use your data to send you targeted communications (e.g. greetings for your birthday), or promotions and generalized advertising messages, as well as to carry out market research and survey activities (e.g. through questionnaires) of your degree of satisfaction with our products and services, through the traditional mail service, e-mail, SMS, landline and mobile telephone, etc.
Your consent to receive these communications will be valid both for sending through the use of automated systems without the intervention of an operator (e.g. email, text message), and for traditional contact methods (e.g. paper mail). You can always, by writing an email to privacy@noicompensiamo.it, revoke your consent to the processing of your data for this purpose, even separately, for example by choosing to only receive advertising via paper mail and reject that sent via automated systems.
We would like to point out that the Privacy Code (art. 130, paragraph 4, Legislative Decree 196/2003) allows so-called “soft spam”. This means that without having to obtain your express consent, we may use the email address you provided as part of a previous purchase, for the purpose of direct sales of our products similar to those you have already purchased, provided that you do not object to this use by sending an email to privacy@wineforclimate.eu. Outside of the cases of “soft spam”, we will collect your personal data to send commercial communications only with your consent.

Communication of data to third parties:

Only with your consent, we will transmit your data to other companies belonging to the sustainability categories who will be able to send you commercial communications and promotional offers relating to their products.

Consent to processing

In all cases in which your consent is required for the processing of your data, we will collect it in advance specifically for the individual purposes, in an express, free and unconditional form.

COMMUNICATION AND DIFFUSION

Agatheia Srl communicates your personal data to third parties exclusively when this is necessary and functional to achieve the purpose of data processing pursued in relation to the service requested by you, and in any case proceeds with the communication only after having informed you, and where necessary, having collected your consent to do so.
In general, the data collected through the individual services and for the purposes indicated in this information are normally communicated to the following categories of subjects:
• subjects to whom the right to access them is granted by provisions of law or regulations (e.g. public security authorities and police forces);
• data processing and IT services companies (e.g. web hosting, data entry, management and maintenance of IT infrastructures and services, e-mail marketing, etc.);
• companies and firms providing consultancy services;
In particular, some specific services provided through our site also include communication to other categories of subjects, such as:
• purchase of products: Banks, Paypal, shipping companies, financial institutions, companies that provide postal and correspondence services
Agatheia Srl normally does not disclose your data. In some specific cases, however, we may ask you to provide us with your personal data (including photographic and audio-video images) to allow you to participate in events, competitions and thematic initiatives of an extraordinary and temporary nature, which by their intrinsic nature provide for its communication and dissemination. In these cases we will notify you and ask you to give express and specific consent in this regard.

RIGHTS OF THE INTERESTED PARTY

at any time you can exercise the rights that the law recognizes you.
In particular, you can exercise by writing to the address: privacy@wineforclimate.eu

right of access
You will be able to obtain confirmation from the data controller as to whether or not personal data concerning you is being processed and, in this case, obtain a copy of the data being processed in progress.
right of rectification
You will be able to obtain rectification (i.e. modification, integration or updating) of inaccurate personal data concerning you, in case of inaccuracy, incompleteness or obsolescence.
right of cancellation
You can obtain the deletion of personal data concerning you. The data controller will delete them without unjustified delay if:
• your personal data are no longer necessary in relation to the purposes for which they were collected or processed;
• as an interested party, you have

the consent on which that processing is based has been revoked and there is no other legal basis to support it
• as an interested party, you have opposed the processing and there is no overriding legitimate reason to proceed with the processing;
• your personal data has been processed unlawfully;
• your personal data must be deleted to comply with a legal obligation.
right to limit processing
As an interested party, you have the right to obtain the limitation of processing when one of the following hypotheses occurs:
• In the event of a dispute regarding the accuracy of your data, for the period necessary for the data controller to verify the accuracy of such personal data;
• The processing is unlawful and you have requested the limitation of its use;
• Although the owner no longer needs them for the purposes of the processing, the personal data are necessary for you for the establishment, exercise or defense of a right in court;
• You have objected to the processing, pending verification of the possible prevalence of the legitimate reasons of the data controller with respect to those of the interested party.
right of opposition
You have the right to object at any time to the processing of personal data concerning you based on the legitimate interest of the owner, including profiling. You also have the right to object at any time to the processing of personal data concerning you for direct marketing purposes, including profiling to the extent it is connected to such direct marketing.
right to data portability
You have the right to receive the personal data concerning you provided to a data controller in a structured, commonly used and machine-readable format and you have the right to transmit such data to another data controller without impediments on the part of the data controller of the treatment to which it has provided them if:
• the processing is based on consent or a contract; And
• the processing is carried out by automated means.
When exercising your rights regarding data portability, you also have the right to obtain the direct transmission of personal data from one data controller to another, if technically feasible.
right to lodge a complaint with a supervisory authority
Where necessary, you can lodge a complaint with the competent Supervisory Authority for the protection of the rights guaranteed to you by Legislative Decree 196/2003 and by European Regulation 679/2016.
right to withdraw consent
you have the right to withdraw consent in relation to all processing based on it. To exercise this right, you can at any time write to privacy@wineforclimate.eu

Extra-EU transfer of Users’ Personal Data

The personal data collected through this website may be transferred outside the EU (in particular, to the United States) to be stored on the servers of Customer Relationship Management service providers. The transfer is carried out upon stipulation of Standard Contractual Clauses or upon verification of the Privacy Shield certification of the service provider (specially appointed as Data Processor. The list of subjects appointed as Data Processors can be obtained by writing to the address

This page describes some management rules for the Agatheia Srl websites, with reference to the personal data of the users who consult them.

These rules apply in all cases in which you access our sites by browsing the pages without registering and without filling in or entering data into web forms.
By visiting the Agatheia Srl sites, you accept the terms and conditions set out below. If you believe you do not accept these terms, please do not access or use the contents and services offered through our sites.

for those who use web services that require personal data

information for the processing of personal data provided pursuant to and for the purposes of the art. 13 Legislative Decree 196/03 and art. 13 of EU Regulation 2016/679

what types of data we collect while the user is browsing

While you visit our sites, the computer systems responsible for their functioning acquire, during their normal operation, some data whose transmission is implicit and necessary for the functioning of the Internet. This is information that is not collected to be associated with identified subjects, but which by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes, for example, the IP addresses or domain names of the computers used by users who connect to the sites, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used in submitting the

request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s IT environment.
Agatheia Srl uses this data for the sole purpose of obtaining anonymous statistical information on the use of the sites and to check their correct functioning. The data could be used to ascertain responsibility in the event of hypothetical computer crimes. Except for this eventuality, such data persists on our computer systems for a period normally not exceeding thirty days.
On the Agatheia Srl sites it is also possible to find social buttons/widgets, i.e. those particular “buttons” depicting social network icons (for example, Facebook and Twitter) which present content from social networks.
These “buttons” allow users who are browsing the Agatheia Srl sites to reach and interact directly with social networks with a “click”.
Thanks to your click on the social buttons/widgets and/or on the interactive social walls, the social network acquires the data relating to your visit. Outside of these cases, in which you spontaneously want to share your browsing data with the chosen social networks with the click, Agatheia Srl does not share any browsing information or user data acquired through its sites with social networks networks accessible thanks to social buttons/widgets and interactive social walls. For any other information on the interactive social walls and social buttons/widgets used by our sites, write to us at privacy@wineforclimate.eu.

WITH WHOM DO WE SHARE NAVIGATION INFORMATION?

The data acquired during navigation may be known by third-party companies that provide Agatheia Srl with IT assistance and data processing services (for example in the case of hosting activities entrusted to third parties and connected to the use of our websites) appointed to such purpose Data controllers.
The list of subjects appointed as Data Controllers can be obtained by writing to privacy@wineforclimate.eu.
The data may then be known and processed within Agatheia Srl by the personnel in charge of processing to the extent that this is necessary for the performance of their duties, carrying out only the operations necessary for the execution of the same. In the event of an express request and in the circumstances authorized by law, the data may be communicated by Agatheia Srl to the Public Security Authorities and the Police forces. No navigation data is disclosed in any way.

Data Controller and Data Protection Officer:

The data controller of the personal data of users who consult and use all WineForClimate sites is Agatheia Srl, with administrative headquarters in Via G.A. Plana, 43 – Milan (MI), Italy.

The data controller and the Data Protection Officer can be contacted at the addresses indicated below:
For Agatheia Srl as Data Controller and Data Protection Officer: privacy@wineforclimate.eu )