TERMS AND CONDITIONS

Privacy Policy
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Global Wines is committed to the protection of the personal data entrusted to it. For this reason, all personal information is treated and protected with due diligence, and always in accordance with the applicable law: EU Regulation 2016/679, General Data Protection Regulation (GDPR). This Privacy Policy explains who we are, for what purposes we may process your personal data, how we process it, to whom we may disclose it, such as customers and/or other Global Wines Group Companies, where they can be transferred or where they can access them and what their rights are. Global Wines, SGPS, S.A. , Global Wines S.A., Sociedade Agrícola de Santar, S.A., Herdade Monte da Cal – Vinhos do Alentejo S.A.,

Paço de Santar – Vinhos do Dão, S.A., Encostas do Douro Sociedade Viti, S.A., 4U – Business Services S.A., a Regiões Unidas – promoção de produtos regionais, Lda., a Quinta de Cabriz – Vinhos e Turismo, Lda, a 19|90 Wine and Tourism, Unipessoal Lda., Martim Joanes Gradil – Sociedade Vitivinícola Unipessoal, S.A., Encostas do Douro Sul – Sociedade Unipessoal, Lda., Quinta do Encontro – Sociedade Vitivinícola, Lda., Lagar do Mestre – Sociedade Produtora de Azeite, Lda. Dão Sul Vinhos Lda. (hereinafter jointly referred to as “Global Wines”) will process your data in accordance with the purposes described below. Global Wines is responsible for the processing of personal data.

Collection and Processing of Data
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The processing operations, carried out by Global Wines, comply with the fundamental principles of data protection and privacy, which ensure the proper functioning of processes, trust with customers and partners, as well as the image with the public: lawfulness, impartiality and transparency, purpose limitation, data minimization, accuracy, limitation of conservation, integrity, confidentiality and transmission. This Data Protection Policy applies exclusively to the collection and processing of personal data for which Global Wines is responsible for its processing, within the scope of the services and products made available to its Customers, Suppliers and workers and in all situations where personal data is processed by Global Wines. Personal Data
Personal data is any information, of any nature and regardless of its medium, including sound and image, relating to an identified or identifiable natural person.

A natural person who can be identified, directly or indirectly, including by reference to a name, identification number, location data, electronic identifiers or to one or more specific elements of his or her physical identity, shall be considered identifiable, physiological, genetic, mental, economic, cultural or social.

Grounds of lawfulness
Global Wines ensures that all personal data are processed lawfully, that is, in strict compliance with the legal grounds imposed by the GDPR. There is such a basis for lawfulness when at least one of the following situations occurs: The data subject has given his or her consent for one or more purposes that require it; it is the execution of a contract to which the data subject is a party, or for pre-contractual steps at the request of the data subject; for the fulfilment of a legal obligation to which the controller is subject;

it is the performance of a contract to which the data subject is a party, or for pre-contractual steps at the request of the data subject; for the fulfilment of a legal obligation to which the controller is subject; for the protection of vital interests of the data subject; for the exercise of functions of public interest or public authority; for the purpose of the legitimate interests of the controller.

Purposes of the Processing
In general, the personal data collected are based on and intended for the management of the contractual relationship, the provision of contracted services, the adequacy of services to the needs and interests of the Customer/ User, including for the purposes of accessing specific functionalities of the services, suggestions for content to information and marketing actions.

•Management of Human Resources
It includes the data processing necessary for the conclusion, fulfillment and termination of an employment contract, management of working times, absences and vacations, processing of wages and other benefits, relationship with the Tax Administration and Social Security, promotions and career development, training, evaluation, representation and communication expenses with workers, exercise of disciplinary power.

•Internal and business management
It includes activities such as project planning, recording working times, managing company assets, providing centralised services to increase efficiency of operations, conducting audits and investigations, implementing management controls, use of internal databases, archive management, insurance, prevention, preparation and conflict management.

•Safety, Hygiene and Health at work
It includes activities related to safety, hygiene and health at work, the protection of workers and company assets, worker authentication and access management.

•Provision of services and information
In order to provide you with our services efficiently, we process your personal data.

Your data may also be used for the provision of information requested by you and may also be processed for the provision of only with your express consent.

•Invoicing
After the provision of services, the personal data you have made available to us will only be processed for billing purposes.

•Commercial and marketing purposes
Your personal data is also processed for commercial and marketing purposes, if you have authorized it, by presenting offers or news that may be of interest to you.

•Compliance with legal obligations
It includes the processing of personal data strictly necessary for the fulfilment of its legal obligations, such as the disclosure of data following judicial mandates, collaboration with regulators and the defense of the legitimate interests of Global Wines.

•Protection of vital interests
Legitimacy for the processing of your data
Your data will only be used if one of the following applies:
1] You have given your consent by signing or accepting an online or paper form.
2] The data is necessary to comply with the legal obligations of the contract concluded with Global Wines
3] The data is necessary to comply with a legal obligation to which Global Wines is subject, such as the disclosure of data to the Tax Administration and Social Security, as well as other authorities
4] The data is necessary for the purpose of the legitimate interests pursued by Global Wines, provided that they do not prevail over the interests or rights, freedoms and guarantees of the data subject.

Transmission to third parties
Except as described below, the personal information you provide to Global Wines will not be shared outside of Global Wines, its subsidiaries and controlled subsidiaries, without your permission.

The provision of information or the provision of services by Global Wines may possibly imply the transmission or access to personal data by partners and subcontractors. Global Wines guarantees that it will only use entities that provide sufficient guarantees for the implementation of appropriate technical and organizational measures, so that the treatment ensures compliance with the applicable legislation. The categories of partners and subcontractors include: Disclosure to suppliers. Global Wines hires other companies to provide other services on our behalf. We provide these companies only the essentials of your personal information that they need to perform these services. These companies and their employees are prohibited from using your personal information for other purposes. Disclosure to distributors. At your request, we may share your personal information with the companies that distribute our products. In these cases, we provide these companies with only the essentials of your personal information, which they need to respond to your request, and these companies, and their employees, are prohibited from using that personal information for other purposes. In some cases, we may attempt to obtain your permission to share your information with distributors for marketing purposes for the sole purpose of fulfilling your request. In any case, we will not share your information for such marketing purposes unless we have your express consent to do so. The data provided may also be transferred to official entities in compliance with legal obligations.

Global Wines only transfers personal data to entities located in a country outside the EU, in compliance with legal obligations or if compliance with national and EU legal standards is guaranteed.

Global Wines does not sell, buy or otherwise trade personal data.

Personal Data
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The Personal Data transmitted by the holder may require your express consent, according to the purpose for which they are intended. In these cases, the consent is given freely, specifically, informed and explicitly by its owner, in each of the different means of interaction with Global Wines.   At any time the data subject may request the withdrawal of any of the consents

for the respective treatment. The withdrawal can be made using our contact form correctly completed by unambiguous identification of the holder. The withdrawal of consent, in relation to a certain processing of personal data, does not compromise the lawfulness of the processing already done based on this consent.

Security
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Global Wines is committed to protecting the security of your personal information. We use various security technologies and procedures, which help protect your personal information from access, use and disclosure

unauthorized. For example, we store the personal information provided by you in computer systems of limited access, located in facilities whose access is limited.

Review your personal information
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You can request a review and correct your personal information collected through our websites, or ask Global Wines to stop providing it, using our correctly completed contact form. We can act to verify your identity before

to authorize access to your personal information. You can help us maintain the accuracy of your information by notifying us of any changes to your address, phone number, or email address.

Rights of the holders
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Data protection legislation gives the data subject the right to information about the purposes and treatments for which their data are intended, and also to access, rectify, delete, limit the processing, as well as

portability of your data and also to oppose automated individual decisions. For the exercise of the rights described above, the holder must contact through http://www.globalwines.pt/contactos

Retention period of personal data
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Where there is no specific legal requirement, Personal Data will only be stored for the time strictly necessary to fulfil the purposes for which

destinam. O período de tempo durante o qual os dados são guardados depende da finalidade para a qual a informação é tratada.