PERSONAL DATA PROTECTION POLICY
EVOLUTION CELLARS GLOBAL S.L. is an organisation that collects personal data through the various channels available to it. This entails significant responsibility for designing and organising procedures that comply with applicable data protection legislation. Accordingly, EVOLUTION CELLARS GLOBAL S.L. shall adopt all necessary security measures to ensure the protection of the data collected.
In fulfilling these responsibilities, and with the aim of establishing the general principles governing the processing of personal data within the organisation, EVOLUTION CELLARS GLOBAL S.L. has approved this Personal Data Protection Policy, which it communicates and makes available to all its stakeholders, while complying with the following legislation:
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights (LOPD-GDD).
Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI-CE).
I. SCOPE OF APPLICATION
This Personal Data Protection Policy applies to EVOLUTION CELLARS GLOBAL S.L., its administrative and management bodies, its employees and all persons who interact with the organisation, expressly including service providers with access to personal data (“Data Processors”).
The controller responsible for the personal data collected by the organisation is EVOLUTION CELLARS GLOBAL S.L., with Tax Identification Number (NIF) B23869779, represented by DIEGO TALAVERA GABORIEAU (hereinafter, the “Data Controller”). Its contact details are as follows:
Address: PASEO CASTELLANA 280, 1ST FLOOR, 28046 MADRID, SPAIN
Contact telephone: 629677298
Contact email: diego.talavera@evolutioncellars.eu
II. INFORMATION ABOUT THE DATA CONTROLLER AND THE PROCESSING OF PERSONAL DATA AT EVOLUTION CELLARS GLOBAL S.L.
Additional information about data processing consists of more specific and detailed information that organisations must provide to data subjects regarding how their personal data is managed. This requirement derives from the transparency principle established by the General Data Protection Regulation (GDPR) and supplements the basic information initially provided, offering greater detail about the processing activities carried out.
EVOLUTION CELLARS GLOBAL S.L. provides the following additional information about its data processing activities:
Additional Data Protection Information
DATA CONTROLLER DETAILS
Identity: EVOLUTION CELLARS GLOBAL S.L.
Address: PASEO CASTELLANA 280, 1ST FLOOR, 28046 MADRID, SPAIN
Contact telephone: 629677298
Email: diego.talavera@evolutioncellars.eu
PURPOSES OF PERSONAL DATA PROCESSING
CUSTOMERS AND SUPPLIERS / BILLING AND ACCOUNTING
Purpose of processing: CUSTOMER MANAGEMENT, ACCOUNTING, TAX AND ADMINISTRATIVE MANAGEMENT.
Retention period: CUSTOMER MANAGEMENT: for the duration of the relationship and, following its termination, for the applicable statutory limitation periods relating to legal liabilities. ACCOUNTING, TAX AND ADMINISTRATIVE MANAGEMENT: 4 years.
HUMAN RESOURCES
Purpose of processing: PAYROLL MANAGEMENT, HUMAN RESOURCES.
Retention period: Payroll management: 4 years. Human resources: 4 years.
WEBSITE CONTACT FORM
Purpose of processing: PROFESSIONAL CONTACT.
Retention period: PROFESSIONAL CONTACT: for as long as the professional relationship with the legal entity is maintained and, following its termination, for the applicable limitation periods relating to potential liabilities arising from the processing (retention limited to the period necessary).
LAWFUL BASES FOR PROCESSING PERSONAL DATA
CUSTOMERS AND SUPPLIERS / BILLING AND ACCOUNTING: Performance of a commercial contract.
HUMAN RESOURCES: Performance of an employment contract.
WEBSITE CONTACT FORM: Explicit consent of the data subject.
RECIPIENTS OF PERSONAL DATA
CUSTOMERS AND SUPPLIERS / BILLING AND ACCOUNTING: ORGANISATIONS OR INDIVIDUALS DIRECTLY RELATED TO THE DATA CONTROLLER. International data transfers: No.
HUMAN RESOURCES: PUBLIC AUTHORITIES WITH JURISDICTION OVER THE MATTER, BANKING OR FINANCIAL INSTITUTIONS, ORGANISATIONS OR INDIVIDUALS DIRECTLY RELATED TO THE DATA CONTROLLER. International data transfers: No.
WEBSITE CONTACT FORM: ORGANISATIONS OR INDIVIDUALS DIRECTLY RELATED TO THE DATA CONTROLLER. International data transfers: No.
DATA SUBJECT RIGHTS AND HOW TO EXERCISE THEM
Everyone has the right to obtain confirmation as to whether EVOLUTION CELLARS GLOBAL S.L. is processing personal data concerning them.
Data subjects have the right to access their personal data and request the rectification of inaccurate information or, where appropriate, request its erasure when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
Under certain circumstances, data subjects may request the restriction of the processing of their personal data. In such cases, the data will only be retained for the establishment, exercise or defence of legal claims, as well as to comply with legally established retention periods.
Data subjects may also object to the processing of their personal data. Accordingly, EVOLUTION CELLARS GLOBAL S.L. will cease processing their data unless there are compelling legitimate grounds for doing so or the processing is necessary for the establishment, exercise or defence of legal claims.
Likewise, where certain conditions are met and it is technically feasible, data subjects have the right to have their personal data transmitted directly to another controller or processor upon request.
To exercise any of the rights described above, please contact us by submitting a written request to:
EVOLUTION CELLARS GLOBAL S.L., PASEO CASTELLANA 280, 1ST FLOOR, 28046 MADRID, SPAIN, or by email to diego.talavera@evolutioncellars.eu. We recommend enclosing a copy of your national identity document (DNI) with your request.
III. PRINCIPLES APPLICABLE TO THE PROCESSING OF PERSONAL DATA
This Personal Data Protection Policy constitutes a measure of proactive accountability intended to ensure compliance with applicable legislation and, in this regard, respect for the rights to honour and privacy in the processing of personal data belonging to all persons who interact with EVOLUTION CELLARS GLOBAL S.L.
In implementing this Policy, the organisation establishes the principles governing data processing and, consequently, the procedures and organisational and security measures that persons subject to this Policy undertake to implement within their respective areas of responsibility.
In this regard, EVOLUTION CELLARS GLOBAL S.L. shall ensure compliance with the following principles:
Lawfulness, fairness, transparency and purpose limitation. Data subjects must always be informed about the processing of their data through the established notices and procedures. Processing shall only be considered lawful where consent has been obtained (with particular attention to consent given by minors), or where another valid lawful basis exists, and where the purpose of the processing complies with applicable legislation.
Data minimisation. The data processed must be adequate, relevant and limited to what is necessary in relation to the different purposes of processing.
Accuracy. Personal data must be accurate and, where necessary, kept up to date. Appropriate measures shall be taken to ensure that personal data which is inaccurate in relation to the purposes of processing is erased or rectified without delay.
Storage limitation. Data shall be retained in a form that permits identification of data subjects for no longer than is necessary for the relevant processing purpose.
Integrity and confidentiality. Personal data shall be processed in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, through the implementation of appropriate technical or organisational measures.
Data disclosures. The purchase or acquisition of personal data originating from unlawful sources is prohibited, as is the acquisition of data collected or disclosed in breach of the law or where its lawful origin cannot be sufficiently guaranteed.
Engagement of service providers with access to data. Only service providers offering sufficient guarantees regarding the implementation of appropriate technical and security measures for data processing shall be selected. An appropriate contract shall be executed with such providers.
International data transfers. Any processing of personal data subject to European Union legislation that involves transferring data outside the European Economic Area must be carried out in strict compliance with the requirements established by applicable law.
Rights of data subjects. The organisation shall facilitate the exercise of the rights of access, rectification, erasure, restriction of processing, objection and data portability by establishing the necessary internal procedures and, in particular, the forms required or appropriate for exercising these rights, which must meet at least the applicable legal requirements in each case.
EVOLUTION CELLARS GLOBAL S.L. shall promote the consideration of the principles established in this Personal Data Protection Policy:
In the design and implementation of all working procedures.
In the products and services offered.
In all contracts and obligations entered into or assumed.
In the implementation of all systems and platforms that allow access by its employees or third parties and/or the collection or processing of personal data.
IV. PERSONAL DATA OF MINORS
In accordance with Article 8 of the GDPR and Article 7 of Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights, only persons over the age of 14 may lawfully consent to the processing of their personal data by EVOLUTION CELLARS GLOBAL S.L. Where the data subject is under 14 years of age, the consent of their parents or legal guardians shall be required, and the processing shall only be considered lawful to the extent that such consent has been granted.
V. CONFIDENTIALITY AND SECURITY OF PERSONAL DATA
EVOLUTION CELLARS GLOBAL S.L. undertakes to inform the user without undue delay when a personal data breach occurs that is likely to result in a high risk to their rights and freedoms. In accordance with Article 4 of the GDPR, a personal data breach means a breach of security leading to the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or to the unauthorised disclosure of, or access to, such data.
Personal data shall be treated as confidential by the Data Controller, who undertakes to inform and ensure, through a legal or contractual obligation, that such confidentiality is respected by its employees, associates and any other persons to whom the information is made accessible.
VI. COMMITMENT OF EVOLUTION CELLARS GLOBAL S.L. PERSONNEL
In view of the above, we declare that the employees of EVOLUTION CELLARS GLOBAL S.L. have been informed of this Policy and acknowledge that personal information is an asset of EVOLUTION CELLARS GLOBAL S.L. Accordingly, they agree to comply with this Policy and undertake to:
Complete the data protection awareness training made available by EVOLUTION CELLARS GLOBAL S.L.
Apply the user-level security measures relevant to their position, without prejudice to any responsibilities for the design and implementation of such measures that may be assigned to them according to their role within EVOLUTION CELLARS GLOBAL S.L.
Use the established forms for the exercise of rights by affected users and immediately inform EVOLUTION CELLARS GLOBAL S.L. so that an appropriate response can be provided.
Inform EVOLUTION CELLARS GLOBAL S.L., as soon as they become aware of any deviation from this Policy, particularly any “Personal Data Security Breach”, using the form established for this purpose.
VII. MONITORING AND EVALUATION
EVOLUTION CELLARS GLOBAL S.L. shall carry out an annual review, evaluation and assessment, as well as whenever significant changes occur in data processing activities, of the effectiveness of the technical and organisational measures implemented to ensure the security of processing.
EVOLUTION CELLARS GLOBAL S.L.