1. WHO IS THE DATA CONTROLLER?

MIGUEL TORRES, S.A. (from now on, TORRES), with registered office at calle Miquel Torres i Carbó, 6, 08720 Vilafranca del Penedès (Barcelona) and Tax Identification Number A-08933251.

2. FOR WHAT PURPOSE DO WE PROCESS YOUR DATA, WHAT ARE THE LEGAL GROUNDS FOR PROCESSING? HOW LONG WILL WE KEEP YOUR DATA?

Your data will be processed in accordance with:

Processing/Purpose	Legal Grounds	Duration
Sending our newsletter: if you give us your consent and provide us with your contact details, we will use them to send you our newsletter which may contain information about our products, as well as discounts, promotions, invitations to events or opinion polls.	Consent	We will process your data until you unsubscribe or revoke your consent.
Participation in competitions, promotions and prize draws: if you participate in contests, promotions and sweepstakes, your data will be processed to manage your participation in them, and to comply with the provisions of the legal grounds.   If you win a prize, we may process your data to manage the communication and delivery of the prize, and to comply with any legal obligation derived from delivering it.	Contractual relationship and legal obligation	We will retain your data for 10 years after the end of the competition, promotion and/or prize draw.
Attendance at our events, tastings and experiences: if you register or book one of our events, tastings and experiences, your data will be processed to manage your registration, payment if necessary, and attendance that may involve, among other things, making access cards, and similar.   We may also manage the transfer of image rights if you authorise us to do so in accordance with the pertinent clause. If you have attended our events or experiences, we may send you information and invitations to our upcoming events, if you have indicated your interest by ticking the appropriate box. TORRES informs you that if you attend as an influencer, public person or promoter of the event, we will process your data to manage the contractual relationship that binds us, the attendance to the event and the transfer of image rights if you authorise us to use them.	Consent and/or contractual relationship	We will retain your data for 2 years after the end of the event, tasting or experience unless longer periods are set forth in the image rights release documents.   In connection with receiving information about our events and tastings, your data will be processed until you unsubscribe or revoke your consent.
Clients and off-line services: if you interact with us and purchase our products or services offline, we will process your data to manage the purchase or service requested, payments and collections made, ship the product, manage any contract between the two parties that may be necessary, and resolve any questions or queries you may have.   Because you are a customer, we may also process your data to send you commercial information that may be of interest to you if you have indicated your interest by ticking the appropriate box.	Contractual relationship	We will retain your data for the duration of the business relationship and/or existing contract and for up to 15 years after your relationship with TORRES has terminated.     Regarding the sending of commercial information, your data will be kept until you inform us by any means that you do not wish to receive this type of information.
Suppliers and distributors: if you are one of our suppliers and/or distributors, we may process your data to manage the relationship between both parties, make the corresponding payments and manage the contracts that bind us. Also, as a supplier and/or distributor, we may process your data to send you commercial information that may be of interest to you.	Contractual or pre-contractual relationship	We will retain your data for the duration of the business relationship and/or existing contract and for up to 15 years after your relationship with TORRES has terminated.
Collaborations: we may also process your data as an influencer, public person, or promoter of an event, tasting and/or experience, competitions, promotions and/or prize draws, for which your data will be processed to contact you and, where appropriate, to manage your attendance at the event, where applicable, and the transfer of image rights if you authorise us to use them.	Legitimate interest, contractual relationship and consent.	We will retain your data for 2 years after the end of the collaboration, unless longer periods are set forth in the image rights release documents.

 

3. TO WHOM WILL WE DISCLOSE YOUR DATA?

If you make a purchase and on the basis of the existing contractual relationship, TORRES may communicate your data to third parties who will act as data controllers, and who will therefore determine the purposes and means for which the data will be used. These parties may be logistics companies that deliver goods to the address indicated.

Except for data communication described in the previous paragraph, your data will not be transferred, sold, rented or made available in any other way to third parties, except for the service providers who perform certain activities for us (database management, and the like) but who will in no case process the data for their own purposes.

Some of these providers may be located outside the European Union or the European Economic Area as indicated in the following section.

4. DO WE TRANSFER DATA INTERNATIONALLY?

If the third parties assisting us in the provision of services process your personal data outside the European Union or the European Economic Area, TORRES will ensure that your data is always protected with the necessary safeguards, which may include:

1. EU-approved standard clauses
2. Third-Party Certifications

You may at any time request further information about the guarantees taken in each case by contacting our Data Protection Officer at dataprotect@torres.es

5. WHAT INFORMATION DO WE COLLECT THROUGH COOKIES?

Through cookies, we can process and store information about how you use the website,  and we can see the sections you visit, make influence maps, track behavioural patterns, and when you leave the website.

We obtain this information mainly through Cookies, so your processing will depend on the Cookies you have accepted.

Remember that you can manage cookies from our configuration option and change your preferences at any time. For more information, including the types of Cookies used and how to configure the Cookies installed on our website, please see our Cookies Policy.

6. WHEN AND HOW DO WE SEND COMMERCIAL COMMUNICATIONS AND INFORMATIVE NEWSLETTERS?

If you have given your consent, we will process your data and send you commercial communications as well as our informative newsletter which may contain information about our products, discounts, promotions, invitations to events or opinion polls.

As a user, you should bear in mind that all our communications and newsletters may be personalised according to the interests shown, based on the products you have purchased, or the data we can obtain from the browsing behaviour shown on our website by our cookies.

This personalisation is partially automated.

We remind you that you may withdraw your consent at any time, and that all our newsletters have a link so users can unsubscribe from this information.

7. WHY CAN WE CARRY OUT PROCESSING ON GROUNDS OF LEGITIMATE INTEREST?

Under the second section of this privacy policy, TORRES processes your data on legitimate interest grounds. To assess the legitimate interest, we have assessed the legitimate interest and analysed our own benefits as data controllers and the benefits of third parties, and in which we conclude that our legitimate interest in processing prevails over the interests, rights and freedoms of users.

You may request further information about the assessment of legitimate interests by contacting our Data Protection Officer at the address stated in section 13 of this privacy policy. We would like to remind you that you may object to processing on the grounds of legitimate interest.

8. HOW LONG WILL WE KEEP YOUR PERSONAL DATA?

All data provided will be retained for the period indicated in the second section of this privacy policy.

Notwithstanding these time limits, your data may be retained in anonymised form for statistical or market research purposes, where possible, or appropriately blocked when necessary to comply with our legal obligations which may require us to retain certain data for a specified period.

9. HOW CAN I EXERCISE MY RIGHTS?

You may exercise your rights of access, rectification, deletion, opposition, limitation of processing and portability of your data by writing to calle Miquel Torres i Carbó, 6, 08720 Vilafranca del Penedès (Barcelona), or by e-mail to the following address dataprotect@torres.es, including the reference “Personal data” and in both cases providing a photocopy of your ID card or passport whenever necessary.

You may also withdraw your consent to processing operations based on consent and/or object to other processing operations where this is possible in accordance with the regulations in force. Notwithstanding the foregoing, revocation/opposition to any processing may mean that we are unable to provide you with our services.

10. HOW CAN I CONTACT THE DATA PROTECTION OFFICER (DPO)?

If you have any doubts, questions, queries or complaints about the way in which we process your personal data, you can contact our Corporate Data Protection Officer at dataprotect@torres.es or by writing to the following address: calle Miquel Torres i Carbó, 6, 08720 Vilafranca del Penedès (Barcelona) with the reference “DPO”.

We inform you that if you do not receive a response within a reasonable period, you may lodge a complaint with the Spanish Data Protection Authority.

11. HOW WILL WE PROCEED IF WE CHANGE OUR PRIVACY POLICY?

Please note that we will inform you, where possible by email and/or information on our website, of any significant changes to our privacy policy so that you are informed of the changes made to the processing of your data and, if you consider it appropriate, exercise your rights on your personal data.