Translation of the original French version.
This privacy policy covers the services provided by EARL GILBERT RUHLMANN FILS on the website “https://vinruhlmann.fr”.
EARL GILBERT RUHLMANN FILS
EARL – French agricultural limited liability company with a share capital of €105,000.00
RC COLMAR – FRANCE – SIREN 414418442
Registered office: 31 RUE DE L ORTENBOURG 67750 SCHERWILLER, FRANCE
Email: info@vinruhlmann.fr
This privacy policy provides details of how we process personal data in accordance with our obligations under the General Data Protection Regulation (No. 2016/679) (“GDPR”), the Data Protection Act 2018 and any other law applicable to us regarding the processing of personal data (collectively referred to as “data protection laws”). In this privacy policy, “controller”, “personal data” and “process” (and its derivatives) have the meanings given to these terms in the data protection laws.
Personal data generally means information that can be used to identify an individual, and processing generally covers actions that can be performed in relation to data, such as collection, use, storage and disclosure. EARL GILBERT RUHLMANN FILS will be the controller of your personal data processed in connection with our services.
EARL GILBERT RUHLMANN FILS and the advisers operating on https://vinruhlmann.fr (“Digital Adviser”) are joint controllers with regard to all personal data.
The purpose of this privacy policy is to explain the data processing activities of EARL GILBERT RUHLMANN FILS, including how and why we process personal data. This privacy policy also describes our duties and responsibilities regarding the protection of this personal data. The way we process personal data will change over time, and we will update this policy from time to time to reflect changing practices.
Personal data we collect
We collect personal data about you when you provide it to us directly via https://vinruhlmann.fr, when third parties provide us with personal data about you, or when personal data about you is collected automatically in connection with your use of the website https://vinruhlmann.fr (the “Website”).
EARL GILBERT RUHLMANN FILS does not disclose your personal data to third parties, except as set out in this privacy policy.
In providing our services, we may collect and process the following information:
Personal data collected directly from you
We receive personal data directly from you when you provide it to us by using the website https://vinruhlmann.fr, using the features of https://vinruhlmann.fr or creating an account on https://vinruhlmann.fr, including but not limited to:
– Last name;
– First name;
– Email address;
– Name of the establishment;
– Trading name;
– Business address;
– Telephone number;
– Username;
– Information needed to take part in the https://vinruhlmann.fr programme
Personal data collected from third-party sources
Personal data collected automatically
Some personal data is collected automatically when you use a partner website or the https://vinruhlmann.fr platform, such as:
– IP address;
– device identifiers;
– browser information; and
cookie data (as explained in our cookie policy).
How we use personal data
We process personal data to operate, improve, understand and personalise our services; for example, we use personal data to:
– enrich and complete the solutions presented via the https://vinruhlmann.fr platform;
– personalise the content of https://vinruhlmann.fr according to your preferences and priorities;
– communicate with you;
– assist you through the different stages of the https://vinruhlmann.fr programme;
– protect against or deter fraudulent, illegal or harmful actions;
– respond to user requests;
– provide support and assistance via https://vinruhlmann.fr;
– comply with our legal or contractual obligations;
– enforce our terms and conditions; and
– resolve disputes where necessary.
Legal basis for processing
Purpose of processing – Legal basis under the GDPR
For administrative purposes
Such processing is necessary for the proper performance of the relationship between you and https://vinruhlmann.fr
Training, quality monitoring or evaluation of the services we provide
Such processing is necessary for the legitimate interests we pursue in monitoring and improving our services and their use, and in guaranteeing them to the internet users who use the website https://vinruhlmann.fr.
Website services, including for troubleshooting, data analysis and survey purposes.
We have a legitimate interest in operating and maintaining the website and for related purposes, including improving our services.
Statistical information that cannot be linked to individuals, to help us improve the services we offer.
We have a legitimate interest in carrying out certain analyses to ensure that the services we provide to Restaurants are effective and working properly.
Enforcing and defending our rights
We have a legitimate interest in ensuring that our services and the website https://vinruhlmann.fr are used in accordance with our terms of use and policies.
Where necessary to comply with our legal obligations.
Where necessary to establish, exercise or defend a legal claim, a potential legal claim, legal proceedings or potential legal proceedings.
Individual rights of data subjects
Data protection laws provide certain rights for data subjects (“data subject rights”).
Data subject rights include the right of a data subject to:
– receive detailed information about the processing (in accordance with the transparency obligations of controllers), which we have provided through this privacy policy;
– access personal data;
– rectify or erase personal data (i.e. the right to be forgotten);
– restrict processing;
– data portability;
– object to processing; and
– object to automated decision-making (including profiling).
You may exercise these data subject rights subject to the limitations provided for by data protection laws.
If you need more information about how https://vinruhlmann.fr processes your personal data, or if you wish to exercise any of your data subject rights in relation to the processing of your personal data by https://vinruhlmann.fr, you can contact https://vinruhlmann.fr directly at: info@vinruhlmann.fr or via the telephone details shown on the website.
With regard to the processing of your personal data by EARL GILBERT RUHLMANN FILS, you can change your privacy settings via the https://vinruhlmann.fr portal. You can also contact us or make a request to exercise any data-related right by contacting info@vinruhlmann.fr. Your request will be handled in accordance with data protection laws.
Disclosure of your information
We do not share any personally identifiable data with third parties and will not disclose your personal data to any other party, except as set out in this policy. EARL GILBERT RUHLMANN FILS may need to disclose personal data in certain scenarios, for example when you breach our terms and conditions or other policies. EARL GILBERT RUHLMANN FILS may disclose such personal data, at our sole discretion, if we consider it necessary or appropriate in connection with an investigation into fraud, intellectual property infringement, piracy or any other illegal activity. This may require the disclosure of your name, address, telephone number or email.
EARL GILBERT RUHLMANN FILS may engage other companies and individuals to perform tasks on our behalf and may need to share your information with them to provide our services to you.
In some cases, EARL GILBERT RUHLMANN FILS may buy or sell assets, which may involve the transfer of user information. EARL GILBERT RUHLMANN FILS will transfer this information if we are acquired by or merged with another company. In that case, we will inform you by email.
Without limiting the foregoing, in an effort to respect your privacy and the ability of EARL GILBERT RUHLMANN FILS to keep the community safe from bad actors, we will not otherwise disclose your personal data to law enforcement, other government officials or other third parties without a court order, law enforcement request, legal process or substantially similar legal procedure, except where we believe in good faith that the disclosure of information is necessary to protect the rights of EARL GILBERT RUHLMANN FILS or the rights of third parties, to prevent physical harm or financial loss, or to report suspected illegal activity.
Individual rights of data subjects
Data protection laws provide certain rights for data subjects (“data subject rights”).
Data subject rights include the right of a data subject to:
receive detailed information about the processing (in accordance with the transparency obligations of controllers), which we have provided through this privacy policy;
access personal data;
rectify or erase personal data (i.e. the right to be forgotten);
restrict processing;
data portability;
object to processing; and
object to automated decision-making (including profiling).
You may exercise these data subject rights subject to the limitations provided for by data protection laws.
If you need more information about how https://vinruhlmann.fr processes your personal data, or if you wish to exercise any of your data subject rights in relation to the processing of your personal data by https://vinruhlmann.fr, you can contact https://vinruhlmann.fr directly at: info@vinruhlmann.fr.
With regard to the processing of your personal data by EARL GILBERT RUHLMANN FILS, you can change your privacy settings via https://vinruhlmann.fr. You can also contact us or make a request to exercise any data-related right by contacting: info@vinruhlmann.fr. Your request will be handled in accordance with data protection laws.
Personal data obtained by https://vinruhlmann.fr
As part of the support programme process, a digital adviser may obtain from EARL GILBERT RUHLMANN FILS a username, email address, telephone number or other information. This information may only be used for communications relating to https://vinruhlmann.fr or for transactions facilitated by EARL GILBERT RUHLMANN FILS.
Where users consent to direct marketing, the user’s consent is provided directly by https://vinruhlmann.fr. EARL GILBERT RUHLMANN FILS, acting as a processor, may help https://vinruhlmann.fr manage users’ consent preferences. Users can unsubscribe from direct marketing via the unsubscribe link included in all marketing communications. EARL GILBERT RUHLMANN FILS also acts as a processor when it helps https://vinruhlmann.fr manage generic, non-individualised and non-personal data analyses.
Newsletter
If you subscribe to our newsletter (form on the website, with confirmation by email, or a tick box when placing an order), we use your email address only to send you news from the estate: new vintages, wine fairs and offers. This processing is based on your consent. We keep the date, the origin of the subscription and the IP address as proof of this consent. You can unsubscribe at any time using the link in each email or by writing to us at info@vinruhlmann.fr; your address is then removed from the mailing list. Emails may be sent by our emailing service provider (Brevo), acting on our behalf.
Data retention
We will only keep personal data for as long as keeping it is considered necessary for the purposes for which it is processed (as described in this privacy policy), unless we are required to keep your personal data for a longer period (for example in the event of legal proceedings or investigations).
Third-party links
From time to time, we include links to third parties on the website https://vinruhlmann.fr. When we provide a link, this does not mean that we have any control over the linked website or its privacy policy, or that we endorse that website’s policy on visitor privacy. You should read the privacy policy of the linked website before sending it any personal data.
Service-related announcements and changes
Any future changes to this privacy policy will be published on the website and, where appropriate, notified by email. EARL GILBERT RUHLMANN FILS may send you announcements relating to the https://vinruhlmann.fr service.
You cannot opt out of service-related communications.
Contact us
For more information about this privacy policy or the processing of your personal data by or on behalf of EARL GILBERT RUHLMANN FILS, please contact us at: info@vinruhlmann.fr.
Although you may lodge a complaint about compliance by EARL GILBERT RUHLMANN FILS with data protection laws with the data protection authority, we ask you to contact us first to give us the opportunity to address your concerns.
Last updated: 12 November 2021.
© 2022 EARL GILBERT RUHLMANN FILS. All rights reserved.