Privacy
1. Who is responsible for the processing of data?
Sanga Interactive S.L. is responsible for the processing of your personal data for the purpose of providing the services identified in this privacy policy.Sanga Interactive S.L., is a company domiciled at Calle San German 37, 1-4 4-A, 28020 Madrid, and its tax ID number is B10829794 (hereinafter, “WineNest”).At WineNest, we are committed to the fundamental right to the protection of your personal data and this privacy policy aims to inform you about your rights under the General Data Protection Regulation (“GDPR”).
2. What information do we process?
a) The data you provide us directly:
We collect information about you when you contact us through the channels provided for this purpose, such as when you register in our application or once registered; when you decide to modify the profile associated with your account and provide us with your name and email; or as when you decide to add a picture of yourself to your user profile.When you contact us through these channels, we will ask you for some personal data such as your first and last name or your email.All fields marked with an asterisk (*) in the forms provided to you through the channels will be mandatory, so the omission of any of them could result in the inability to provide you with the requested services. You must provide truthful information, the impersonation of identity or the use of aliases or anonymous names is prohibited.You may not, when providing any data that may be requested through the channels, choose expressions that are injurious, coinciding with brands, trade names, names or pseudonyms of characters of public relevance or celebrities for whose use you are not authorized.It is essential that you safeguard at all times your reference data, passwords, and access codes that you generate. You will be the only responsible for the use of your personal account, and in this sense, you commit to making diligent use of such information, not to make it available to third parties, and to inform us, without delay, of its loss or theft.To ensure that the information provided is always up to date and does not contain errors, you must communicate to WineNest, as soon as possible, any changes to your personal data that may occur.Likewise, by clicking on the "Accept" button (or equivalent) included in the aforementioned forms, you declare that the information and data you have provided are accurate and truthful.
b) Data obtained indirectly:
When you browse, various cookies and other tracking devices can be installed on your device, as explained to you in our Cookies Policy cookies.
3. What is the source of the data?
We consider that all the data processed by WineNest have been provided freely by you.In case the personal data provided belongs to a third party, you guarantee that you have informed them of this Privacy Policy and have obtained their authorization to provide the data to WineNest for the purposes stated above. Similarly, you guarantee that the data provided are accurate and up to date, and you are responsible for any direct or indirect damage or harm that may result from the breach of such obligation.
4. For what purpose and with what legal basis do we process the data?
WineNest acts as the data controller for the following purposes and in accordance with the following legal bases:
Based on the management of the contractual or pre-contractual relationship:
a) Manage your registration as a user in our application, as well as allowing your access to the reserved area.b) Provide you with the services you have requested and attend to your information requests, as well as facilitating the exercise of your rights.
Based on compliance with legal obligations of WineNest:
a) Allow users the exercise of their rights.b) Comply with the regulations applicable to WineNest.
Based on the explicit, free, and unequivocal consent that, where appropriate, you grant us at the time of collecting your data:
a) Create profiles for statistical and/or segmentation purposes, and/or make automated decisions.
Based on the existence of a legitimate interest on the part of WineNest:
a) Carry out internal reviews and, if necessary, contact the customer in the event of detecting or having reasonable suspicions related to a possible fraud or identity theft.However, if you do not wish your data to be processed for these purposes, you can object at any time by contacting us at info@WineNest.app as indicated in the Exercise of Rights section of this Privacy Policy.
5. To whom are the data communicated?
All transfers of personal data we make are necessary for the fulfillment of the indicated purposes, or are made to comply with a legal obligation:
a) To public administrations and the administration of justice, and to law enforcement agencies in compliance with the legal obligations applicable to us.
b) IT service providers, tools or IT infrastructure on which the services that WineNest. provides are based, such as hosting providers, CRMs, email service companies, etc.In this regard, we inform you that any transfer that occurs will be carried out considering all the necessary legal safeguards. Likewise, we guarantee that we sign specific contracts with all our service providers as established by the regulations.Similarly, WineNest guarantees that in case there are providers located in countries outside the European Union or others not considered adequate according to data protection regulations, the necessary precautions are taken that guarantee that the data can be transferred securely, either because the provider offers adequate guarantees, through, among others, the signing of Standard Contractual Clauses of the European Commission, or because one of the exceptions provided in the regulations is met.
6. Exercise of your rights.
We inform you that you can exercise the following rights:
1. Right of access to your personal data to know which are being processed and the processing operations carried out with them.
2. Right to rectification of any inaccurate personal data.
3. Right to erasure of your personal data, when this is possible.
4. Right to request the limitation of the processing of your personal data when the accuracy, legality or necessity of the data processing is in doubt, in which case, we may keep the data for the exercise or defense of claims.
5. Right to object to automated decision-making, including profiling.
6. Right to opposition to the processing of your personal data when the legal basis that enables us for its processing, according to section 4 above, is the legitimate interest.
7. Right to the portability of your data, when the legal basis that enables us for its processing of those indicated in section 4 above is the existence of a contractual relationship or your consent.
8. Right to revoke the consent granted to WineNest.
You can exercise your rights at any time and for free in the following ways:
1. By sending an email to info@WineNest.app e indicating the right you wish to exercise.
2. By sending a written request to Calle San German 37, 1-4 4-A, 28020 Madrid, indicating the right you wish to exercise.
3. In addition, when you receive any communication from us, by clicking on the unsubscribe section contained in that communication, you can unsubscribe from all previously accepted commercial communication shipments.When you exercise your rights, and only in the case that we have doubts about your identity, we may request additional information to verify your identity.Furthermore, we inform you that you have the right to file a complaint with the Spanish Data Protection Agency if you believe that we have committed an infringement of the data protection legislation with respect to the processing of your personal data.Additionally, we inform you that you can sign up on the Robinson List at www.listarobinson.es: the advertising exclusion system managed by the Spanish Association of Digital Economy (ADIGITAL), where you can register in order to express your opposition to the use of your data for the purpose of sending you commercial communications.
Data retention period.
We will only keep your data for as long as necessary to offer you these services. Any of the data you provide through the channels will be blocked as soon as they are no longer necessary to manage the service and will only be available in the event of a legal obligation (arising from a request from the State Security Forces or Courts and Tribunals) as well as when you exercise your rights.
Security and confidentiality.
In order to prevent unauthorized access or unauthorized disclosure of personal data, we have taken suitable technical and physical measures, as well as management processes to safeguard and secure the information we collect from you.
Minors.
Minors under 18 years of age may not use the services offered by WineNest.
Privacy policy update.
We make our best efforts to keep our privacy policy fully up to date. If we make changes, they will be clearly identifiable in a clear and specific manner, as possible in the relationship we have established with you (for example: we may communicate changes by email).This privacy policy has been reviewed and published as of February 23, 2023.
Sanga Interactive S.L. is responsible for the processing of your personal data for the purpose of providing the services identified in this privacy policy.Sanga Interactive S.L., is a company domiciled at Calle San German 37, 1-4 4-A, 28020 Madrid, and its tax ID number is B10829794 (hereinafter, “WineNest”).At WineNest, we are committed to the fundamental right to the protection of your personal data and this privacy policy aims to inform you about your rights under the General Data Protection Regulation (“GDPR”).
2. What information do we process?
a) The data you provide us directly:
We collect information about you when you contact us through the channels provided for this purpose, such as when you register in our application or once registered; when you decide to modify the profile associated with your account and provide us with your name and email; or as when you decide to add a picture of yourself to your user profile.When you contact us through these channels, we will ask you for some personal data such as your first and last name or your email.All fields marked with an asterisk (*) in the forms provided to you through the channels will be mandatory, so the omission of any of them could result in the inability to provide you with the requested services. You must provide truthful information, the impersonation of identity or the use of aliases or anonymous names is prohibited.You may not, when providing any data that may be requested through the channels, choose expressions that are injurious, coinciding with brands, trade names, names or pseudonyms of characters of public relevance or celebrities for whose use you are not authorized.It is essential that you safeguard at all times your reference data, passwords, and access codes that you generate. You will be the only responsible for the use of your personal account, and in this sense, you commit to making diligent use of such information, not to make it available to third parties, and to inform us, without delay, of its loss or theft.To ensure that the information provided is always up to date and does not contain errors, you must communicate to WineNest, as soon as possible, any changes to your personal data that may occur.Likewise, by clicking on the "Accept" button (or equivalent) included in the aforementioned forms, you declare that the information and data you have provided are accurate and truthful.
b) Data obtained indirectly:
When you browse, various cookies and other tracking devices can be installed on your device, as explained to you in our Cookies Policy cookies.
3. What is the source of the data?
We consider that all the data processed by WineNest have been provided freely by you.In case the personal data provided belongs to a third party, you guarantee that you have informed them of this Privacy Policy and have obtained their authorization to provide the data to WineNest for the purposes stated above. Similarly, you guarantee that the data provided are accurate and up to date, and you are responsible for any direct or indirect damage or harm that may result from the breach of such obligation.
4. For what purpose and with what legal basis do we process the data?
WineNest acts as the data controller for the following purposes and in accordance with the following legal bases:
Based on the management of the contractual or pre-contractual relationship:
a) Manage your registration as a user in our application, as well as allowing your access to the reserved area.b) Provide you with the services you have requested and attend to your information requests, as well as facilitating the exercise of your rights.
Based on compliance with legal obligations of WineNest:
a) Allow users the exercise of their rights.b) Comply with the regulations applicable to WineNest.
Based on the explicit, free, and unequivocal consent that, where appropriate, you grant us at the time of collecting your data:
a) Create profiles for statistical and/or segmentation purposes, and/or make automated decisions.
Based on the existence of a legitimate interest on the part of WineNest:
a) Carry out internal reviews and, if necessary, contact the customer in the event of detecting or having reasonable suspicions related to a possible fraud or identity theft.However, if you do not wish your data to be processed for these purposes, you can object at any time by contacting us at info@WineNest.app as indicated in the Exercise of Rights section of this Privacy Policy.
5. To whom are the data communicated?
All transfers of personal data we make are necessary for the fulfillment of the indicated purposes, or are made to comply with a legal obligation:
a) To public administrations and the administration of justice, and to law enforcement agencies in compliance with the legal obligations applicable to us.
b) IT service providers, tools or IT infrastructure on which the services that WineNest. provides are based, such as hosting providers, CRMs, email service companies, etc.In this regard, we inform you that any transfer that occurs will be carried out considering all the necessary legal safeguards. Likewise, we guarantee that we sign specific contracts with all our service providers as established by the regulations.Similarly, WineNest guarantees that in case there are providers located in countries outside the European Union or others not considered adequate according to data protection regulations, the necessary precautions are taken that guarantee that the data can be transferred securely, either because the provider offers adequate guarantees, through, among others, the signing of Standard Contractual Clauses of the European Commission, or because one of the exceptions provided in the regulations is met.
6. Exercise of your rights.
We inform you that you can exercise the following rights:
1. Right of access to your personal data to know which are being processed and the processing operations carried out with them.
2. Right to rectification of any inaccurate personal data.
3. Right to erasure of your personal data, when this is possible.
4. Right to request the limitation of the processing of your personal data when the accuracy, legality or necessity of the data processing is in doubt, in which case, we may keep the data for the exercise or defense of claims.
5. Right to object to automated decision-making, including profiling.
6. Right to opposition to the processing of your personal data when the legal basis that enables us for its processing, according to section 4 above, is the legitimate interest.
7. Right to the portability of your data, when the legal basis that enables us for its processing of those indicated in section 4 above is the existence of a contractual relationship or your consent.
8. Right to revoke the consent granted to WineNest.
You can exercise your rights at any time and for free in the following ways:
1. By sending an email to info@WineNest.app e indicating the right you wish to exercise.
2. By sending a written request to Calle San German 37, 1-4 4-A, 28020 Madrid, indicating the right you wish to exercise.
3. In addition, when you receive any communication from us, by clicking on the unsubscribe section contained in that communication, you can unsubscribe from all previously accepted commercial communication shipments.When you exercise your rights, and only in the case that we have doubts about your identity, we may request additional information to verify your identity.Furthermore, we inform you that you have the right to file a complaint with the Spanish Data Protection Agency if you believe that we have committed an infringement of the data protection legislation with respect to the processing of your personal data.Additionally, we inform you that you can sign up on the Robinson List at www.listarobinson.es: the advertising exclusion system managed by the Spanish Association of Digital Economy (ADIGITAL), where you can register in order to express your opposition to the use of your data for the purpose of sending you commercial communications.
Data retention period.
We will only keep your data for as long as necessary to offer you these services. Any of the data you provide through the channels will be blocked as soon as they are no longer necessary to manage the service and will only be available in the event of a legal obligation (arising from a request from the State Security Forces or Courts and Tribunals) as well as when you exercise your rights.
Security and confidentiality.
In order to prevent unauthorized access or unauthorized disclosure of personal data, we have taken suitable technical and physical measures, as well as management processes to safeguard and secure the information we collect from you.
Minors.
Minors under 18 years of age may not use the services offered by WineNest.
Privacy policy update.
We make our best efforts to keep our privacy policy fully up to date. If we make changes, they will be clearly identifiable in a clear and specific manner, as possible in the relationship we have established with you (for example: we may communicate changes by email).This privacy policy has been reviewed and published as of February 23, 2023.