Privacy policy
I. GENERAL INFORMATION
1. JSC "Vinportas" (hereinafter – the Company or us) is the website and the online store www. grapeescape. Lt , or www . grapeescape . eu , or “GRAPEESCAPE” (hereinafter referred to as the website) manager. With this privacy policy, the Company establishes the conditions for the processing of personal data of website visitors, which apply every time visitors use the Company's website and the services provided therein.
2. The controller of your processed personal data is JSC “Vinportas” (legal entity code 305361064, registered office address Medelyno g. 27, Noriškiai, Plungės raj. Lithuania data is collected and processed by state-owned company Register center Register of Legal Entities, e-mail address info@grapeescape.eu, telephone number +370 612 00 445).
3. We confirm that your data will be collected in accordance with the requirements of the applicable European Union and Republic of Lithuania legislation and the instructions of the controlling authorities, and that all reasonable technical and administrative measures will be applied to protect the data collected by us about the visitors of the website against loss, unauthorised use and/or alteration. The Company's employees are under a written obligation not to disclose or distribute to third parties any information obtained in the workplace, including information about visitors to the website/social network accounts.
4. This policy applies when visiting the website, using the e-shop, registering, viewing and ordering the products offered, subscribing to newsletters, participating in games, promotions, contacting the telephone or e-communication channels, visiting the collection point. These rules do not apply when you browse other companies' websites or use third party services.
5. The Company may use other persons to process the personal data of visitors to the website and to transfer information about individuals to other legal entities for this purpose, subject to the conditions set out in the Privacy Policy.
6. This Privacy Policy applies regardless of the device used to access the website.
7. By registering or placing an order without registering on the “GRAPEESCAPE” website, you entrust the Company with your personal data and grant us the right to process them within the scope, in the manner and for the purposes set out in this Privacy Policy and the Rules for the Purchase and Sale of Goods in the “GRAPEESCAPE” Online Store ("the Rules") and in the physical stores.
8. A Customer who does not wish to become a member of the “GRAPEESCAPE” Club is entitled to make purchases without registering in the e-shop, provided that he/she meets the requirements set out in the “GRAPEESCAPE” Rules, including the minimum age requirement.
9. The Customer who wishes to use the e-shop more conveniently and to purchase the goods offered therein shall have the right to register in the e-shop system by filling in the registration form and creating a “GRAPEESCAPE” club member account. By registering in the e-shop and creating an account, the Customer becomes a member of the “GRAPEESCAPE” Club.
10. Disagreement with the Rules, this Policy or any of their individual terms and conditions shall preclude the use of all or any of the services provided by the Company, as well as the enjoyment of the benefits of the “GRAPEESCAPE” Club membership (hereinafter referred to as "Services").
II. BASIC CONCEPTS
11. Personal data shall mean any information relating to a natural person (data subject) whose identity is known or can be established, directly or indirectly, by reference to data such as name, surname, personal identification number, one or more factors specific to him or her, whether of a physical, physiological, psychological, economic, cultural or social nature.
12. Processing of personal data shall mean any operation or set of operations which is performed upon personal data, such as collection, recording, accumulation, storage, classification, grouping, aggregation, alteration, communication, disclosure, use, logical and/or arithmetical operations, retrieval, dissemination, destruction, or any other operation or set of operations.
13. Data subject means a natural person who uses the website, as well as a natural person whose data is processed on the website for other purposes as defined in this privacy policy.
III. DATA COLLECTION AND PROCESSING
14. By registering and agreeing to the Policy and the Terms and Conditions, you provide us with the data provided in the form. By registering, you confirm that the data you have provided is accurate and correct and that you are at least 20 years old. If the personal data provided is incorrect, you must correct it immediately. Submission of the data is required and if you do not provide it, you will not be able to use the Services. We accept no liability for inaccurate, incomplete or erroneous data.
15. Registration in the e-shop and ___ Club
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Personal data categories |
The data contained in the questionnaire shall include: name, surname, date of birth, email address, telephone number, address, city, postcode, account login details, account activity, including technical browsing data (user's IP address, registration date and time) |
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Legal basis |
Consent of the data subject |
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Time limit for the storage of personal data |
For the entire period of membership of the “GRAPEESCAPE” Club. If the customer has not made any purchases at “GRAPEESCAPE” physical stores or e-shops within 2 years from the date of consent, the account will be cancelled. The consent given is kept for 1 year after the expiry of the consent period |
Based on the data you provide when registering for “GRAPEESCAPE” Club membership, we will create a unique profile that will identify you as a registered member of “GRAPEESCAPE” Club, both in the e-shop and in the “GRAPEESCAPE” physical stores, or whenever you wish to update or modify your data, and ensure that the benefits of “GRAPEESCAPE” Club membership and information are provided to you.
We also use the contact details (email, telephone number) provided in your form for the purposes of communicating with you (delivery of purchases, answering queries, etc.).
It is your responsibility to ensure that the data you provide is accurate and correct. The Company is not and will not be held liable for the provision of inaccurate and/or incorrect data and the resulting consequences. The Company will assume, upon acceptance of your registration form, that your data is accurate and correct, and that all your consents have been given freely by you, having read this Policy and the Terms and Conditions in detail.
In the event of a change in the details you have provided, you must immediately change the relevant details, except for your email address, in your "“ GRAPEESCAPE”" account under Settings.
16. Placing and fulfilling an order in the “GRAPEESCAPE” e-shop without registration
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Personal data categories |
Name, surname, date of birth, phone number, email address, address, city, postcode, order payment method, account activity. In cases where the recipient of the order is another person, we will process the name, surname, telephone number and address of the person to whom the order is addressed. |
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Legal basis |
Execution of the Treaty |
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Time limit for the storage of personal data |
1 year from the date of the last order |
To place an order in the e-shop, you do not need to create an account, but you must provide the personal data necessary to complete the order.
Such personal data will not be stored in the customer database and will only be stored and processed together with the order and the documents related to that order. The contact details you provide (e-mail, telephone number) will be used for the purpose of communicating with you.
Where you specify another person as the recipient of your order, we will additionally process the name, surname, telephone number and address of the other person to whom your order is addressed. When you provide the data of another person, you undertake to ensure that the other person does not object to such processing of personal data.
By placing an order in the e-shop without registration, you agree to the Policy and the Terms and Conditions; you confirm that the data provided is accurate and correct and that you are at least 20 years old. If the personal data provided is incorrect, you must correct it immediately. Submission of the data is required and you will not be able to use the Services if you do not provide it. The Company accepts no liability for inaccurate, incomplete or erroneous data.
17. Processing of Purchase Data for the purpose of properly providing the Services
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Personal data categories |
Name, surname, year of birth, email address, telephone number, delivery and residential addresses, date and time of purchase and delivery, point of sale, product names, quantities, prices, discounts given (only for products outside the alcoholic beverages category), IP address, method of payment for purchases and payment status. Where the recipient of the order is another person, his/her name, surname, telephone number and address will be processed. |
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Legal basis |
Execution of the Treaty |
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Time limit for the storage of personal data |
Accounting and tax records are kept for the periods laid down by law. Other purchase data shall be kept for 2 years from the date of the last purchase transaction. The document indicating the age of the person receiving the goods shall be kept for 1 year from the date of receipt. |
Where you indicate a person other than yourself as the recipient of your order, the Company will process the personal data of that person. When providing the personal data of another person, the submitter undertakes to make sure that the other person does not object to such processing of personal data.
18. Data profiling in the context of personalised offers
If you have expressed your wish to receive personalised offers by completing the questionnaire and have given your consent for this purpose, the Company will not only process your questionnaire data, but will also analyse and use the history of your purchase data in order to provide you with the best possible personalised offers.
For the purpose of providing personal offers, personal data is processed:
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Personal data categories |
Your name, city, email address and phone number, details of your purchases (including date and time of purchase, names of goods, quantities, total price of purchases, frequency of purchases). History of personal offers made to you and information on how you have used them |
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Legal basis |
Consent of the data subject |
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Time limit for the storage of personal data |
As long as your consent is valid, but no longer than 2 years from the date of your consent. The Company will keep the consent for 1 year after the expiry of the consent period |
By providing your consent to personalised offers relevant to the profiling of your personal data, the Company may get to know you, tailor personalised offers to your perceived needs and provide you with other tailored benefits. For these purposes, the Company may use automated data analysis and decision-making, including profiling. The Company may aggregate and analyse your profile and/or purchase data and provide you with relevant, interesting and useful offers and other information based on your shopping habits and/or other attributes.
If you do not want your data to be profiled for the purpose of providing you with personalised offers, you can refuse to give your consent to the Company or withdraw your consent at any time. In this case, you will continue to be able to use the Services, but the Company will no longer be able to provide you with personalised offers and information.
Please note that the Company's data analysis and profiling activities do not have any legal or similarly significant effect on you.
19. Conducting surveys on the quality of services and service
In order to ensure that the quality of the Company's services and service meets the needs of our customers, we process data that allows us to contact you to ask for your opinion on the quality of services and service.
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Personal data categories |
Your email address, place of residence, purchase details (including place, date and time of purchase, product names, quantities, price and total purchase price) |
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Legal basis |
Consent of the data subject |
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Time limit for the storage of personal data |
For as long as the consent is valid, but no longer than 2 years from the date of consent. We will keep the consent given for 1 year after the consent period has expired |
20. Handling customer queries, complaints, requests and feedback
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Personal data categories |
Contact information: name, surname, telephone number, email address, residential address, date of birth. Content of the enquiry: the event for which the enquiry is made, the circumstances, date, place, the purchasing document, the request, requirement or feedback, the product, other information contained in the enquiry. Other documents and/or data submitted with the Enquiry: e. g. details of the purchase receipt or e-shop account, photographs |
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Legal basis |
The Company's legal obligation to investigate and respond to User Inquiries, as well as the Company's legitimate interest in evaluating feedback from its customers in order to improve the quality of the Company's operations and the quality of the services provided |
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Time limit for the storage of personal data |
1 year from the date of the resolution of the response to the Inquiry |
The Company uses your data only for the purpose of properly and objectively examining the Enquiry, providing the necessary information, answering questions, resolving requests and/or requirements. The data may be analysed in order to improve the quality of the Company's operations and services, taking into account the opinions and suggestions of customers.
After the expiry of the data processing and storage period set out in this Policy, your data will be destroyed or reliably and irreversibly depersonalized by the Company as soon as possible within a reasonable and prudent period of time for such action.
21. We also process your personal data for the following purposes:
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Purpose of processing personal data |
Personal data categories |
Legal basis |
Time limit for the storage of personal data |
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Gathering customer feedback on goods, services and service quality |
Name, city, email address, details of the “GRAPEESCAPE” goods purchased, the time of purchase and the store (physical or e-store) where you purchased the goods using your “GRAPEESCAPE” e-store account and club membership |
Consent of the data subject |
For the duration of the consent, but no longer than 2 (two) years from the date of consent |
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Organisation of games |
Name, surname, contact details |
Consent and legal obligation to deliver the prize |
Until the winner is announced and the prize is awarded. Accounting and tax documents are kept for the periods provided for by law |
As the consent period draws to a close, the Company reserves the right to send you a reminder of the expiry of the consent period and the possibility to extend it.
IV. Data retention period
22. The Company shall keep personal data for no longer than required by the purposes of the processing or provided for by law. Upon expiry of the period of processing and retention of your data set out in this Policy, the Company shall destroy your data or, in the cases specified in the Policy, reliably and irreversibly depersonalize your data as soon as possible within a reasonable and prudent period of time for such action.
23. The retention of your personal data for a longer period than specifically provided for in this Policy may only be carried out where:
- necessary for us to defend ourselves against claims, demands or actions and to enforce our rights;
- there are reasonable grounds to suspect an illegal act that is the subject of an investigation;
- Your data is necessary for the proper resolution of a dispute or complaint;
- for backup purposes and other similar purposes;
- other grounds provided for by law.
V. Sources of collection of personal data
24. The Company receives your personal data only from you. You provide the Company with survey data directly, e. g. by completing the e-shop Account Registration and Club Member forms, and purchase data by completing the Purchase Order form and using the Services, or when you submit an Enquiry by any of the methods you have chosen: by emailing us, by submitting a written request to us, by calling us.
VI. Disclosure of Personal Information
25. The Company has the right to outsource the processing of your personal data to third parties who assist in the operation and administration of the Services and provide services related to the administration of Customer Requests. Such persons may include database software providers, database administration service providers, hosting and cloud service providers, direct marketing service providers, market research or business analytics service providers, such as companies providing advertising and event services, companies providing newsletter services, companies administering IT and other facilities, etc. In each case, we only provide the data processor with the amount of data that is necessary to carry out a specific order or provide a specific service. The data processors engaged by the Company may only process your personal data on our instructions and may not use it for other purposes or transfer it to other persons without the Company's consent. They must also ensure the security of your data in accordance with applicable law and written agreements with us.
26. The Company will forward Your Enquiry specifying the insured event that may be recognised and the details to the insurance company(-ies) with which the Company's liability and property is insured or which provides the Company with other insurance cover in relation to the event identified in Your Enquiry. The insurance companies act as independent data controllers and process your data in accordance with the terms and conditions and rules set by the insurance company.
27. Data may also be provided to competent authorities or law enforcement agencies, such as the police or supervisory authorities, but only upon their request and only when required by applicable law or in the cases and procedures provided for by law, in order to safeguard the Company's rights, the safety of the Company's customers, employees and resources, and to assert, bring, submit and defend legal claims.
28. If the Company uses a website analytics service (e.g. Google Analytics) which is used to determine how you use the information provided in the e-shop, we may share your personalised data with third parties who rely on this information to evaluate the use of the website or mobile application, to compile reports for the website operators on the performance of the website or the mobile application, and to provide other services relating to the use of the website, the internet and the mobile application.
29. All information you provide to the Company via social media (including messages, use of the "Like" and "Follow" boxes, and other communications) is controlled by the social network manager. The Website provides links to the Company's social media accounts.
30. The following accounts are available:
(a) Facebook, whose privacy notice can be found at https://www.facebook.com/privacy/explanation;
(b) Linkedin, whose privacy notice can be found at https://www.linkedin.com/legal/privacy-policy;
(c) Instagram, whose privacy notice is available at https://privacycenter.instagram.com/policy/?entry_point=ig_help_center_data_policy_redirect.
We recommend that you read the privacy notices of third parties and contact the service providers directly if you have any questions about how they use your personal data.
VII. Territories and jurisdictions where the Company processes your personal data
31. The Company processes your personal data only within the territory of the European Union. Personal data is not transferred to third countries.
VIII. Rights under personal data protection legislation
32. The right to have access to your personal data processed by the Company.
You have the right to obtain confirmation from the Company as to whether or not the Company processes your personal data; the right to have access to your personal data processed by the Company and to information about the purposes of the processing, the categories of data processed, the categories of recipients of the data, the duration of the processing, the sources of the data, automated decision-making, including profiling, and its implications for you.
33. Right to rectification of personal data.
If the data you have provided to us in your registration form has changed, or if you believe that the information we are processing is inaccurate or incorrect, you have the right to request that the information be amended by logging into your account under Settings and, if this fails, you have the right to rectify the data by notifying the Company by email to info@grapeescape.eu .
34. Right to withdraw consent.
Where the Company processes your data on the basis of your consent, you have the right to withdraw your consent at any time and the processing based on your consent will cease. In certain cases, we may not be able to provide you with continued access to the Company's Services. You can adjust your consent (revoke or re-grant it) by changing your consent settings in the Settings section of your account. You can withdraw your consent to the processing of your personal data for direct marketing purposes at any time by clicking on the unsubscribe link in the newsletter or newsletter, i. e. by clicking on the "Unsubscribe" button. Unsubscribing from the newsletter service also withdraws the data subject's consent (to receive future newsletters) to the processing of personal data for direct marketing purposes.
35. Right to lodge a complaint.
If you believe that we are processing your data in violation of the requirements of personal data protection legislation, please always contact the Company directly in the first instance. If you are not satisfied with the proposed solution, you have the right to lodge a complaint with the supervisory authority, which in the Republic of Lithuania is the State Data Protection Inspectorate.
36. The right to object to processing where the processing is based on legitimate interests.
You have the right to object to the processing of personal data where the processing is based on the legitimate interests of the Company. Taking into account the purposes of the provision of the Services and the balance between the legitimate interests of both parties, your objection may mean that your continued use of the Services will be prevented if the Company's processing of your personal data based on its legitimate interest ceases. To exercise the right set out in this section, please submit a written request to the Company's Data Protection Officer.
37. Right to erasure (right to be forgotten).
In certain circumstances listed in the data processing legislation (where personal data are processed unlawfully, the basis for processing has ceased to exist, etc.), you have the right to request that we delete your personal data. To exercise this right, you must submit a written request to the Company's Data Protection Officer.
38. Right to restrict processing.
In certain circumstances listed in the data processing legislation (where personal data is processed unlawfully, you have objected to the processing on the basis of our legitimate interest, etc.), you have the right to restrict the processing of your data. As a result of the restriction of processing and during the period of such restriction, we will not be able to provide the Services to you. To exercise the right set out in this section, please submit a written request to us at info@grapeescape.eu .
39. Right to data portability.
You have the right to receive or transfer your personal data to another controller (right to data portability). This right only applies to data that have been provided to the Company on the basis of your consent or pursuant to a contract and where the data are processed by automated means. To exercise this right, please submit your request in writing to the Company.
IX. Procedure for dealing with applications
40. In order to protect the data of all customers from unauthorised disclosure, the Company will be obliged to identify you upon receipt of your request for data or to exercise your other rights. For this purpose, the Company may ask you to provide the relevant profile data (e. g. name, surname, email address or telephone number) provided in your registration form/purchase order form, and we will compare whether the data you have provided matches the relevant profile data.
41. Upon receipt of your request for the exercise of any of your rights and upon successful completion of the verification procedure referred to above, the Company undertakes to provide you, no later than one month after receipt of the request and completion of the verification procedure, with information on the action taken in response to the request. The period for examining the request may be extended for a maximum of two additional months.
42. Requests shall be received and answered only by electronic means. Requests on the same subject matter, in the same circumstances, shall not be examined and no reply shall be made.
X. Cookies
43. The Company uses cookies (a small file of information sent to your computer or other device (for example, a mobile phone) when you visit a website and stored in your browser. A cookie is sent to your computer or other device to store data so that the Company can recognise you as a user of the Services when you visit the website. Cookies also allow the Company to link your purchase history and other data collected when you use the Services to your browsing on the Internet. The information collected by cookies enables us to provide you with a more user-friendly browsing experience, to provide you with attractive offers and to learn more about website user behaviour, to analyse trends and to improve both the website and our service to you.
44. The website also uses third party cookies. These cookies are used to create a browsing history for each visitor so that we can show you tailored advertising and provide you with the best experience when browsing the website. If your browser allows third-party cookies, the partner chosen by the Company has the option of placing its own cookies in your browser.
45. For more information on cookies, their use and refusal, please refer to the Cookie Policy.
XI. Validity and amendments to the Policy.
46. The Policy may be amended, supplemented and updated. The Company shall have the right to amend the Policy in part or in full at any time. If we change this Policy, we will post an updated version on this website.
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