Argenwine | Privacy Policy

In accordance with Regulation (EU) 2016/679, the General Data Protection Regulation, and Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights, ARGENWINE, S.L.U informs users of its website about the processing of personal data that they may provide through the website, the contact form, requests for information and pre-registration processes for workshops, activities, residential gatherings and camps.

1. IDENTITY OF THE DATA CONTROLLER

Data Controller: ARGENWINE, S.L.U
Tax Identification Number (CIF): B70588728
Registered office: Calle de la Alameda 22, 28004 Madrid, Spain
Email address: nicolas.trejo@argenwine.es
Contact telephone: 670 240 567
Registration details: Company incorporated in A Coruña on 6 May 2019 by means of a public deed authorised by Notary Víctor José Peón Rama, under Protocol No. 860, and registered with the Madrid Commercial Registry. IRUS: 1000079561061. EUID: ES28065.082311346.

2. PERSONAL DATA THAT MAY BE COLLECTED

Through the website and its associated contact channels, ARGENWINE, S.L.U may collect identification and contact details, such as first and last name, email address, telephone number and any other information voluntarily provided by the data subject in their message or request.

As a general rule, the website form shall be used for contact purposes, requests for information and pre-registration. The collection of health data through the website is not envisaged. If it becomes necessary to process information regarding allergies, intolerances, medication or other particularly sensitive data for a specific activity, such data shall be collected through specific and separate documentation and on the corresponding legal basis.

3. PURPOSES OF PROCESSING

Personal data may be processed for the following purposes:

To respond to enquiries, requests for information and communications submitted through the website, by email, telephone or other channels made available by the organisation.
To manage pre-registrations and applications to participate in workshops, activities, residential gatherings, retreats, camps and other initiatives promoted by ARGENWINE, S.L.U.
To carry out the organisational, coordination and follow-up actions necessary to respond to the data subject’s request.
To send information related to the activities, workshops or services of ARGENWINE, S.L.U, only where express consent has been given or there is another sufficient legal basis under applicable legislation.
To manage operational communications by telephone, email or WhatsApp where necessary to handle the enquiry, pre-registration or requested activity.
Where applicable and subject to specific authorisation, to manage the publication of images or videos on the organisation’s website, social media profiles or promotional materials. The processing of images, particularly those involving minors, shall be documented separately and specifically.

4. LEGAL BASIS FOR PROCESSING

The legal basis for processing personal data shall depend on the specific purpose pursued:

Article 6(1)(b) of the GDPR: taking steps at the request of the data subject prior to entering into a contract or the performance of a contractual relationship, where processing is necessary to manage a request for information, pre-registration or participation in an activity.
Article 6(1)(a) of the GDPR: the consent of the data subject or their legal representative, where required to send future information, use images or carry out any other processing that is not strictly necessary to manage the request or activity.
Article 6(1)(c) of the GDPR: compliance with legal obligations, where applicable in relation to administrative, tax, accounting and security matters or responding to requests from the competent authorities.
Article 6(1)(f) of the GDPR: the legitimate interests of the data controller in defending its rights, properly managing communications and protecting the security of its systems and services, always within the limits established by law.

5. MINORS

The activities of ARGENWINE, S.L.U may be aimed at families and minors. Where participation involves children under the age of fourteen, their data must be provided and authorised by those exercising parental responsibility or legal guardianship. In all cases, the organisation may request the documentation necessary to verify legal representation where appropriate.

The formal registration of minors and authorisations relating to stays, outings, medical emergencies, administration of medication and the use of images shall be managed through specific documentation separate from the general website form.

6. RECIPIENTS OF THE DATA

As a general rule, personal data shall not be disclosed to third parties unless required by law or where necessary for the proper management of the request, pre-registration or contracted or requested activity.

However, service providers supplying auxiliary services to ARGENWINE, S.L.U may have access to the data in their capacity as data processors. These may include web hosting, IT maintenance, email, technical support, communication and organisational service providers, always subject to the corresponding contractual safeguards.

Furthermore, depending on the specific activity and where necessary, data may be disclosed to insurance companies, healthcare professionals, emergency services or competent public authorities, solely to the extent strictly necessary and on a sufficient legal basis.

7. DATA RETENTION

Data processed to respond to enquiries or requests for information shall be retained for the time necessary to handle the request and subsequently for the periods required by law or, failing that, for a maximum of one year, unless the enquiry results in a subsequent relationship.

Data processed to manage pre-registrations or activities shall be retained for the time necessary to organise, carry out and document the activity, as well as for the applicable statutory periods.

Data processed on the basis of consent for sending future information shall be retained until the data subject withdraws their consent or requests to unsubscribe.

Authorisations for the use of images and documentation relating to minors shall be retained for as long as they remain valid, have not been revoked or are necessary to demonstrate that consent was given and that legal obligations were complied with.

8. SOURCE OF THE DATA

As a general rule, personal data shall be provided by the data subjects themselves. In the case of minors, data may be provided by their parents, guardians or legal representatives.

9. RIGHTS OF DATA SUBJECTS

Everyone has the right to obtain confirmation as to whether ARGENWINE, S.L.U is processing personal data concerning them. Where applicable, data subjects may also exercise the following rights:

Access to their personal data.
Rectification of inaccurate or incomplete data.
Erasure of their data where, among other reasons, it is no longer necessary for the purposes for which it was collected.
Objection to the processing of their data in certain circumstances.
Restriction of processing in the circumstances established by law.
Data portability, where applicable.
Withdrawal of consent, without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise these rights, the data subject may submit a written request, accompanied by a copy of their identification document, to the data controller’s postal address or by email to nicolas.trejo@argenwine.es.

Likewise, if the data subject believes that their rights have not been properly addressed, they may lodge a complaint with the Spanish Data Protection Agency through its electronic office or any of the channels made available by that supervisory authority.

10. ACCURACY AND UPDATING OF DATA

Users guarantee that the data provided is true, accurate and up to date and undertake to report any changes that may be necessary. Where users provide data relating to third parties, they declare that they have sufficient legal authority to do so and undertake to provide those third parties with the information contained in this Privacy Policy where legally required.

11. INFORMATION SECURITY

ARGENWINE, S.L.U adopts reasonable and appropriate technical and organisational measures to protect personal data against loss, alteration, unauthorised access or unlawful processing, taking into account the current state of technology, the nature of the data processed and the existing risks.

12. CHANGES TO THE PRIVACY POLICY

This Privacy Policy may be updated where necessary to reflect legislative, case law, organisational or technical changes. In the event of a substantial amendment, the new version shall be published on the website with due notice or from the date on which it becomes legally required.