Privacy policy

The security of personal data has become one of the top priorities for organisations, and in GRUPO BODEGAS PALACIO 1894, S.A., guaranteeing the inviolability of this information has to take top priority. In this regard, we want to be transparent and ensure that this Privacy Policy is at the disposal of all those who interact with us.

This policy applies to GRUPO BODEGAS PALACIO 1894, S.A. and all the companies in its Group, whose composition can be checked at any time at www.grupobodegaspalacio.es/el-grupo/(referred to collectively as “GRUPO BODEGAS PALACIO”). Any references in this Privacy Policy to "GRUPO BODEGAS PALACIO", "us", "we" and "our" concern the entity responsible for processing your personal information that, generally speaking, will be that which gathers and processes it.

GRUPO BODEGAS PALACIO undertakes to process the personal data in accordance with Regulation (EU) 2016/679, 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, and other legislation in force on Data Protection.

This Privacy Policy applies to all Users, understood to mean those who visit the website and any other person who suppliers their personal data for use via the different channels (“User” or “Users”). In this context, Channels refers to the different means or services that we place at your disposal so that you can interact with us, whether or not they involve registration, such as webs, applications, platforms, mailboxes, addresses or User information or assistance telephone numbers, social media profiles, forms, events, etc.

Some of our on-line Channels may contain links to other third-party websites and applications not related to GRUPO BODEGAS PALACIO. This Privacy Policy does not apply to the same. Please also revise the Privacy Policies of such third parties with a view to familiarising yourself with their practices. They may also contain third-party cookies that are not owned or controlled by GRUPO BODEGAS PALACIO. In this case, you can choose your third-party cookies configuration using our Cookies Configuration Tool, situated at the bottom of the website, where you will be able to manage your preferences and which you can access by clicking on "Cookies".

GRUPO BODEGAS PALACIO adopts the technical and organisational measures necessary to guarantee the security of personal data and avoid any alteration, loss, unauthorised processing or access, according to the state of the art, the nature of the data and the risks to which it is exposed. You can also verify the presence of the SSL certificate by checking the Page properties in your browser. A connection will be secure when the address bar of the browser displays "https://" instead of "http://" and the padlock symbol appears. You can consult further characteristics of the SSL certificate in the Legal Notice section.

 

Who is responsible for personal data processing?

Whenever personal data is gathered and processed, we will inform the User of the GRUPO BODEGAS PALACIO company responsible for processing and will supply them with the corresponding identification details.

With regard to this Privacy Policy and this website, we inform you that the data controller is:

  • Company name: GRUPO BODEGAS PALACIO 1894, S.A
  • Tax ID no.: A-28058477
  • Address: Ctra nacional Km 122 - Valladolid-Soria P.K. 325,6 Quintanilla de Onésimo 47350-Valladolid.
  • Telephone: +34 915006000
  • Email: The user will be able to contact the Data Protection Department to clear up any queries he/she may have regarding the processing of personal data at the postal address C/ Anabel Segura 11, 4ª Planta, Edificio D; CN Albatros; 28108 Alcobendas (Madrid), or at the following email protecciondatos@grupobodegaspalacio.es

 

What data can we receive via our channels?

For the purposes of this Privacy Policy, “personal data” refers to the data which identifies a person or can be used to identify them.

GRUPO BODEGAS PALACIO informs its Users that personal data, obtained via the Channels it owns or holds, will only be gathered for processing when appropriate, pertinent and not excessive in relation to the specified, explicit and legitimate ambit and purposes for which it was obtained.

We may receive the personal data provided directly by the User, through their visit to the Web, when the User contacts the Customer Service, or either by email or telephone. Also, as a result of the interaction with us, we may receive the personal data by filling in forms or surveys, when you request information, etc.

In other cases, personal data is obtained indirectly from the user in order to analyze their use of our website (See our Cookies Policy).

When, via our Channels, personal data is gathered for specific purposes, the User will be informed clearly and unequivocally in advance of i) the controller and its contact details, iii) the purposes of the specific processing and the legitimacy for it, iv) the recipients or categories of recipient, if applicable, as well as the existence of international transfers, if any, v) the storage criteria or terms, and vi) their rights as an interested party.

Among the categories of data that we can process are:

  • Identification and contact data. Name and surname, valid ID or identification document, address (shipping data), country of residence, telephone number, email, etc.
  • Financial data or related to the service provided: Billing information, Visa card, account number.

The User is also the only person responsible for the information supplied and for the veracity and lawfulness of the same.

What is the purpose and legitimacy of personal data processing by GRUPO BODEGAS PALACIO?

GRUPO BODEGAS PALACIO processes the personal data of the Users, gathered via any of our Channels, with the following purposes and legitimate grounds:

  • Manage the relationship established with us

    To provide our services, we process the data supplied by Users with the purpose of managing access credentials, manage access credentials; process adhesions to the Club Cosme Palacio and the Club Bodega Directa, as well as manage and supply orders.

    We also process the data for the purpose of catering for requests for services and information from our Users received via any of our Channels, as well as for processing any suggestions, claims or complaints.

    We also process data when a User subscribes to any of our alerts Channels, Newsletters, products and/or services news bulletins or requests the sending of commercial communications and information of the social and cultural events around the world of wine.

    We also process the data to manage and attend to reservation requests for guided tours of our wineries, access to tasting courses, harvests, activities, etc.

    We also process the data to manage the Private Customers Area, at the disposal of customers.

    Processes related to the service provided, such as management of payments made and received, invoicing, etc….

    In these cases, the legal basis for the processing is the consent given by the User, as well as the performance of the agreement and/or the legal relations established with GRUPO BODEGAS PALACIO.

  • Advertising activities and commercial communication

    We may, via any means of communication, send commercial communication, offers and other promotions based on the user profile, gifts, sales, information on participation in draws, participation in competitions, events, fairs, for guided tours of our wineries, access to tasting courses, harvests, activities, sending of commercial communications and information of the social and cultural events around the world of wine, etc.

    Sending advertising information on products and services via any means of communication, marketed by other companies in the GRUPO BODEGAS PALACIO, or marketed by third parties, including ACCIONA Group companies (listed in the report to the last consolidated annual accounts published on the www.acciona.com website), with which collaboration agreements are established.

    We may carry out automatic assessments, obtain profiles and perform follow-up tasks, based on the information available in order to personalise the relationship in line with your characteristics or needs by means of segmentation and thus be able to send you the most appropriate commercial actions.

    In these cases, the legal basis for processing is the consent provided by the User and/or the legitimate interest in receiving products and services similar to those acquired.

  • Manage contact details in the context of contractual or commercial relations

    We process contact details of potential clients; legal representatives of legal persons and bodies, whether public or private; analysts and investors; or other parties intervening, who supply their data, with a view to sending them information of interest, managing the commercial relationship between us, managing invitations or notices regarding events organised or sponsored by GRUPO BODEGAS PALACIO or in which it participates.

    The legitimacy is maintaining the contractual and/or commercial relationship between us, or where there is none, the consent stated by the User in providing contract details.

  • Compliance with the legal obligations that affect us

    Whether these legal obligations are of a commercial, tax, accounting or administrative nature; the legal basis entitling us to process data is compliance with legal obligations.

  • Fraud management

    In some of the services we provide, it is necessary to verify identity in order to offer protection, detect and prevent fraud or other unlawful activities, unauthorised transactions, claims and other kinds of responsibilities, as well as to manage the quality and risks associated with the business; and investigating where necessary, any unlawful activities and potential breaches of our policies and/or the conditions of our services.

    The legal basis is compliance with the applicable legal obligations in each case.

  • Statistics and satisfaction surveys

    We can process User data for statistical purposes, in order to analyse conduct and trends in order to improve our services. The legitimacy for this processing is the legitimate interest of GRUPO BODEGAS PALACIO in assessing our products and services.

    For this purpose, data obtained in satisfaction surveys regarding our services and experience in the process for the purchase of your property may be processed, as well as the cookies gathered from browsing websites.

    The legitimacy in this case is the consent given by the User.

  • Security and surveillance of premises

    Our premises have cameras and video-surveillance systems in order to ensure the security of assets and persons.

    The legitimacy for processing is the legitimate interest of GRUPO BODEGAS PALACIO in guaranteeing security in its premises.

  • Managing visits and third parties

    With a view to monitoring access to sites and premises by visitors, collaborators or other third parties, it is possible that identification details will be gathered at some premises.

    The legitimacy in this case is the consent given as well as GRUPO BODEGAS PALACIO’s legitimate interest in guaranteeing the security of assets and persons in its premises.

  • Information on third parties

    When the User provides data in relation to third persons, whether voluntarily or because we request it in order to comply with a legal obligation, the User consents to the processing and declares that the data is accurate. Likewise, the User declares that it has specifically informed third persons of the content of this policy and/or any other applied, and of the corresponding rights with regarding to Personal Data Protection. The above notwithstanding, GRUPO BODEGAS PALACIO will use its best endeavours to act properly in relation to processing of such third parties.

 

For how long does GRUPO BODEGAS PALACIO store the User’s personal data?

In general terms, the data will be stored (i) for the time necessary for the purpose for which it was gathered, (ii) for the applicable expiry terms, in case liabilities derived from the processing arise.

In particular:

  • Data gathered to process requests or enquiries will be stored for the time necessary to respond to the same.
  • Data gathered based on your consent will be stored unless it is withdrawn.
  • In all other cases, the User will be informed of the storage terms applicable to the specific processing.

 

To whom can GRUPO BODEGAS PALACIO disclose the User’s data?

At GRUPO BODEGAS PALACIO, we undertake not to assign or disclose the personal data of our Users except where described in this Privacy Policy or, if applicable, at the time the data is gathered.

The following data disclosures are envisaged, where necessary:

  • The Tax Authorities and other Administrations and state, regional and local public entities for the purposes of complying with all legal provisions contained in legislation and in order to make the corresponding tax declarations (taxes and levies).
  • Other Bodies with authority in the area of communications and the provision of information services or Bodies with authority in the area of consumer affairs in order to address any user complaints.
  • To financial entities and payment gateways, for the management of collections and payments, if these payment methods have been chosen.
  • Likewise, your data may be disclosed to other Entities that form part of the GRUPO BODEGAS PALACIO Group, the composition of which at any given time can be seen at the following link: www.grupobodegaspalacio.es/el-grupo/, which have the requested activity in order to attend and manage it, as well as the sending, by electronic means, of information about the services and products, through the contact email.
  • Likewise, your data may be disclosed to those Entities of the ACCIONA Group, the composition of which at any given time can be seen at the following link: www.acciona.com/shareholders-investors/financial-information/annual-accounts/; which market and provide services in different sectors of activity, for the purpose of catering to your requests and sending you via any means, including electronic means, commercial information and any other action described in the purposes already described. The consent for such communication will have been obtained in advance, in the different forms and questionnaires on the website and in those documents that have regulated the relations between users, customers and suppliers with which the Controller has any kind of link, by means of the corresponding boxes for ticking and the different forms of requesting explicit consent.
  • Aside from these cases, we will only be able to disclose your personal information (1) to courts or tribunals or administrations in the exercise of their jurisdictions and administrative powers, in the event you allow us to or if required by law or a legal process (such as a court order or summons); (2) to the police authorities or other public officials in order to comply with a legal, legitimate request; (3) when we consider it necessary to avoid physical harm or financial loss; (4) in order to establish, exercise or defend our legal rights; (5) in relation to the investigation of a suspected or proven case of fraud or unlawful activity; or (6) with the consent of the User.
  • GRUPO BODEGAS PALACIO, belongs to the ACCIONA Group, which is a global, interconnected undertaking, meaning that we may exchange personal information within the companies of the Group in the context of the centralisation of certain activities they perform. You can consult the composition of ACCIONA at any given time in the report of the last consolidated annual accounts,www.acciona.com/es/accionistas-inversores/informacion-financiera/cuentas-anuales/. Nevertheless, this transfer, disclosure and processing of personal data within the ACCIONA Group is carried out under the data protection laws in force and by means of the adoption and application of the appropriate safeguards for the purposes of ensuring the protection of the privacy and fundamental rights and freedoms of the Users.
  • We may exchange personal information with service providers which are GRUPO BODEGAS PALACIO companies or third parties, hired to provide services on our behalf. In these cases, where necessary, the corresponding processing agreements will be signed in accordance with the regulations on data protection.
  • Likewise, GRUPO BODEGAS PALACIO informs you that, in order to perform the functions mentioned, it collaborates with service providers, third parties or Group companies may be located outside of the European Economic Area in territories that do not offer a level of data protection that is comparable to that of the European Union. In such cases, we transfer User data with appropriate safeguards and always ensuring the security of the same such as the formalisation of Standard Contractual Clauses of the kind approved by the Commission, the content of which can be consulted via the following link: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_es.

 

Social media

At GRUPO BODEGAS PALACIO we use social media such as LinkedIn, Instagram or YouTube, to share our content. We act as data controller for the data we publish online, processing it always in accordance with the conditions established for each of the social media outlets.

Interaction with Users due to the use of such profiles or tools may imply an international data transfer, of an analytical and technical nature, in relation to the Website and the social media profiles, with the data supplied by Users via such profiles being processed on the servers of the social media companies.

 

Direct marketing

Generally speaking, GRUPO BODEGAS PALACIO does not use the personal data of Users for direct marketing purposes, unless consent is obtained in advance.

Users can, at any time, opt out of any direct marketing campaigns and oppose the future transfer of their personal data for such purposes, sending us an email to the address of the Data Controller using the corresponding "unsubscribe" option, included in the emails.

 

Automated decisions

At GRUPO BODEGAS PALACIO we do not carry out automated decision-making, including the preparation of profiles, except where expressly notified and the express consent of the User is requested.

 

Persons attending Events organised by GRUPO BODEGAS PALACIO

At any acts, training sessions, meetings, initiatives, etc. (“Events”), organised or promoted by GRUPO BODEGAS PALACIO, in its premises or elsewhere, we may ask the User to supply personal data in order to duly manage such Events and attendance at the same. This data may, among other things, be related to managing access, accreditation, transport and travel, accommodation, catering, delivery of related documentation, etc. This processing will be based on consent and, in certain cases, on fulfilment of a contractual relationship or legal obligation.

This data may have to be disclosed to some of the service providers or collaborator or sponsor entities, participating or intervening in the Event. As a general rule, we will only store this information for the time strictly necessary to hold the Event and, if appliable, to comply with any applicable expiry deadlines.

Image: In addition to the processing derived from the security and surveillance of our premises, as a result of User participation in Events, their image and, on occasion, their voice may be recorded and processed by GRUPO BODEGAS PALACIO in the form of photographs and/or video recordings. Whenever the Events involve this processing, we will inform the User expressly. This processing may be for internal, external and/or Event promotion purposes, meaning that the material may be used for reproduction, distribution, transformation, public communication, recording and placing at disposal in any format or medium (including, but not limited to, exploitation via analogue or digital media and via the Internet, such as websites or intranets belonging to ACCIONA Group entities) without such activities granting a right to remuneration, consideration or any other financial benefit for the User.

This processing is based on consent, whether individually and expressly granted, where possible, by the User, or due to attendance at Events in relation to which the User was informed of image processing in advance. The authorisation of the User will be worldwide in scope, transferrable (within GRUPO BODEGAS PALACIO and externally) and for the duration of the intellectual property rights. The User may revoke consent at any time, via the appropriate Channels.

The intellectual and industrial property rights of materials generated in the context of Events and activities correspond exclusively to GRUPO BODEGAS PALACIO.

 

What are the User’s rights when we process his/her data?

The User can exercise his/her rights of access, correction, erasure, data portability, and/or the limitation of or opposition to processing, before the corresponding data controller, or by writing to the Personal Data Protection Department at Anabel Segura, 11, Edificio D, 28108 Alcobendas (Madrid), or by sending an email to: protecciondatos@grupobodegaspalacio.es. If we consider it necessary in order to be able to identify you, we may ask you for a copy of an identity document.

Likewise, you may withdraw consent at any time by writing to the address indicated above, as well as by presenting a complaint to the corresponding Supervisory Authority on data protection (https://www.agpd.es/portalwebAGPD/index-ides-idphp.ph) and, in particular, to the Spanish Data Protection Agency (www.aepd.es).

Remark: During exceptional periods such as States of Alarm or Emergency, implying periods of lockdown or other external disturbances such as natural disasters, extreme climate events or wars, the rights not exercised via email and exercised by standard post will involve a longer than usual time of reply, with the times of reply being restored when the recommended lockdown period has ended.

 

Further information:

Below is a series of links where you will be able to obtain further information that may be useful in relation to other personal data processing. You can also obtain information on the website in the Legal Notice.

 

Validity

Any change to the Privacy Policy and in the information administration practices will be duly reflected and GRUPO BODEGAS PALACIO will add to, modify or replace this Policy when it considers it necessary.

 

Last update: September 24 2020.