Where no legal requirement exists, the Personal Data shall be kept as long as is strictly necessary for the specified purposes. The period of time during which the data are stored depends on the purpose for which the information is processed.

You may ask to review and correct your personal data gathered on our websites, or ask Global Wines to stop providing such data by completing our contact form correctly. We may act to verify your identity before we grant you access to your personal data. You can help us to keep your information up to date by communicating to us any changes to your postal address, telephone number or email address.

Global Wines undertakes to guarantee the safety of your personal data. We use a variety of safety technologies and procedures that help to protect your personal data against unauthorised access, use and dissemination. For example, by storing the personal data that you have given us in computerised systems with limited access, located in premises to which access is restricted.

The Personal Data disclosed by the subject may require its express consent, depending on the purpose for which they will be used. In such cases, the data subject gives free, specific, informed and explicit consent in each of Global Wines's different means of interaction. The data subject may, at any time, request that any of its consents to processing his data be removed. To withdraw the consent, our contact form must be completed by unequivocally identifying the data subject. The withdrawal of the consent given for a specific processing of personal data does not compromise the lawfulness of the processing activities carried out on the basis of the consent given.

Principles Relating to Privacy and Protection of Data
Data are processed by Global Wines in compliance with the fundamental principles relating to data protection and privacy, which ensure the proper functioning of procedures, the trust of our customers and partners, and the preservation of our public image: lawfulness, impartiality and transparency, purpose limitation, data minimisation, precision, data preservation limitation, integrity, confidentiality and transmission. This Data Protection Policy applies exclusively to the personal data collected and processed by Global Wine, in the context of the services and products it provides to its Customers, Suppliers and Employees, and in all circumstances where Global Wines processes personal data. Personal Data Personal data means any information, of any nature on whatever medium, including sound and image, relating to an identified or identifiable natural person. Identifiable natural personal means any natural person who may be either directly or indirectly identifiable, in particular by reference to a name, identity number, location data, electronic identifiers or one or more elements of that person's physical, physiological, genetic, mental, economic, cultural or social identity.

Rules on Lawfulness
Global Wines ensures that all personal data are treated lawfully, i.e. strictly in compliance with the legal terms laid down in the GDPR. Such legal requirements are met where at least one of the following conditions applies: The data subject has given his consent to one or more of the purposes requiring the use of personal data; enforcement of an agreement which the data subject entered into, or for pre-contractual measures that the data subject has required; compliance with a legal obligation of the entity that processes the data; to defend the vital interests of the data subject; for functions carried out in the public interest or as public authority; under the legitimate interests of the entity responsible for processing the data.

Purpose of Data Processing
Generally speaking, the personal data are gathered for the purposes of contract management, delivery of the contracted services, adjusting the services to the needs and interests of the Customer/User, namely for providing access to specific functions under the services, content suggestions and information and marketing activities. •            Human resource management Includes processing of the necessary data for concluding, implementing and terminating a work contract, managing working time, absence and holidays, processing salaries and other benefits, managing the relationship with the Tax Administration and Social Security, promotions and career development, training, assessment, representation costs and communicating with employees, exercising disciplinary power.
•            Internal and business management
ncludes activities such as project planning, recording of working times, managing company assets, providing centralised services for increasing the efficiency of operations, conducting audits and investigations, implementing management controls, using the internal data base, managing the archive, insurance, conflict prevention, preparation and management.
•            Work Safety, hygiene and health
Includes activities concerning work safety, hygiene and health, the protection of employees and assets of the company, worker authentication and access management.
•            Service provision and information
To provide our services in an efficient manner we process your personal data. Your data may be also used to provide you with the information you request and may be processed for the provision of services to third parties, subject to your express consent.
•           Invoicing
After the services have been provided, your personal data are processed only for invoicing purposes.
•            Commercial and marketing purposes
Your personal data are also processed for commercial and marketing purposes, if you have authorised it, by presenting offers or new products or services which may be of interest to you.
•            Fulfilment of legal obligations
Includes processing of personal data which is strictly necessary for fulfilling its legal obligations, such as the dissemination of data following a judicial order, collaborating with regulators and defending the legitimate interests of Global Wines.
•            Protection of vital interests

Legitimate Processing of Your Data
Your personal data will be used where one of the following situations exists:
1] You gave us your consent by signing or accepting an online or paper form;
2] The data are necessary to ensure compliance with the legal obligations under the contract concluded with Global Wines;
3] The data were necessary to comply with a legal obligation binding Global Wines, such as the disclosure of data to the Tax Administration and Social Security, and other authorities;
4] The data were necessary for the purpose of ensuring the legitimate interests of Global Wines, as long as such interests do not overshadow the interests or rights, freedoms and guarantees of the data subject.

Transfer to third parties
With the exception of the situations described below, the personal data that you have given to Global Wines will not be shared, without your permission, with any entity outside of Global Wines, its affiliates and subsidiaries controlled by it. The provision of information and services by Global Wines may involve the transfer or access to personal data by its partners and subcontractors. Global Wines guarantees that it will only contact entities that use appropriate technical and organisational measures for ensuring secure data processing according to the applicable legislation. Partner and subcontractor categories include: Disclosure to suppliers. Global Wines subcontracts other companies for supplying other services on our behalf. We provide these companies with only the personal data they require for carrying out such services. These companies and their employees are banned from using the customer's personal data for other purposes. Disclosure to distributors. We may, upon your request, share your personal data with the companies that distribute our products. In this case, we provide these companies with only the personal data they need to respond to your request, and these companies and their employees are banned from using such data for other purposes. In some cases, we may request your permission to share your information with distributors for marketing purposes, only aiming at accommodating your request. In any event, we will not share your information for the aforementioned marketing purposes, unless you have given us your express consent. The data provided may also be transferred to official entities to fulfil legal obligations. Global Wines only transfers personal data to entities located in a country outside of the EU according to the provisions of the law or in conformity with domestic and EU legal rules.

Global Wines does not sell, purchase or trade in any form personal data.

Global Wines is committed to protecting the personal data entrusted to it. Consequently, all information of a personal nature is processed and protected with due care and always pursuant to the applicable legislation: Regulation (EU) 2016/679, General Data Protection Regulation (GDPR). This Privacy Policy Statement explains who we are, for what purposes your personal data may be used, how we process such information, to whom we may disclose them, such as customers and/or other Companies of the Global Wines Group, where they may be transferred to or where they may be accessed and what are your rights. 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 Vitivinícola, S.A., BS4U – Business Services 4U, S.A., Regiões Unidas – promoção de produtos regionais, Lda., Quinta de Cabriz – Vinhos e Turismo, Lda, 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. (jointly referred to hereinafter as “Global Wines”) will process your data for the following purposes. Global Wines is responsible for processing your personal data.