Privacy Policy

General provisions

E. & J. Gallo Winery Europe Ltd, owner of the brand Barefoot Wine, 4th Floor, Harman House, 1 George Street, Uxbridge, Middlesex UB8 1QQ, (hereinafter referred to as GALLO) has commissioned CMC W. Grün, Josefshöhe 1, 87452 Altusried, Germany (hereinafter referred to as CMC) to operate the website www.barefoot-win.eu on behalf of GALLO. CMC would therefore like to inform you in the following privacy policy about the extent to which data iscollected when you use our website and the purpose for which this data is used.

The personal data of users processed within the scope of this website includesgeneral data (e.g. names and addresses of customers), contract data (e.g. servicesused), usage data (e.g. web pages visited on our website) and content data (e.g. contact by e-mail).

“User” covers all categories of data subjects affected by data processing.

If you have any unanswered questions, please contact our data protection officerat service@barefoot-win.eu with the subject “Data protection”.

Specific provisions

We guarantee that we will only collect, process, store and use your data in connection with the processing of your participation in the raffle, enquiries or for internal purposes or in order to provide services requested by you or to makecontent available.

Principles of data processing

We process users’ personal data only in compliance with the relevant dataprotection regulations. Users’ data is only processed if legal permission has beengiven on one of the following grounds:

- in order to provide our contractual services and online services
- if you have given your consent
- on the basis of our legitimate interests (i.e. interest in analysis, in particular in measuring reach, collection of access data and use of third-party services).

We would like to show you where the above legal bases are regulated in the GDPR:

Consent

Art. 6(1) a) and Art. 7 GDPR

Processing for the fulfilment of our services and implementation of contractualmeasures: Art. 6(1) b) GDPR.
Processing to comply with our legal obligations: Art. 6(1) c) GDPR.
Processing to protect our legitimate interests: Art. 6(1) f) GDPR.

The following personal data is collected for the following purposes:

The first name, surname and e-mail address of all participants will be collected in order to be able to communicate with the participants of the promotion. In orderto be able to transfer the prizes in the event of a win, the following data will also be requested: shipping address (street, house number, postcode, city and country) and telephone number.

Furthermore, the date of birth of the participants is collected in order to be able to assess whether the participation condition “participation from 18 years of age” has been met.

Data transmission to third parties

In order to send the raffle prizes, data will be passed on to third parties within the framework of the promotion.

If we use subcontractors to provide our services, we will take appropriate legal precautions and corresponding technical and organisational measures to ensurethe protection of personal data in accordance with the relevant statutoryprovisions.

An agreement was made with Weblizards GmbH, Germaringen, Germany, asthey are responsible for programming and hosting the promotion.

The raffle prizes will be shipped through local parcel delivery services.

Data transfer to a third country or an international organisation

Third countries are countries in which the GDPR is not directly applicable law. This basically includes all countries outside the EU or the European EconomicArea.

No data is transferred to a third country or an international organisation.

Storage period of your personal data

We comply with the principles of data economy and data avoidance. We collect, process and use your personal data exclusively for the purpose of carrying out this promotion. After the winners have been drawn (05/08/2022 CET) and the raffle prizes have been sent out, your data will be deleted immediately, providedthat there are no legal or contractual provisions to the contrary. Server log fileswill be deleted 3 months after the promotion ends.

Contact

If you contact us by online form or e-mail, you agree to electronic communication. Personal data is collected when you contact us. The informationyou provide will exclusively be used by us to process your participation orenquiry and saved for future reference in case you have follow-up questions.

We would like to provide you with the legal basis for this:

Processing for the fulfilment of our services and implementation of contractualmeasures

Art. 6(1) b) GDPR.

Processing to protect our legitimate interests

Art. 6(1) f) GDPR.

We would like to point out that e-mails can be read or changed duringtransmission without authorisation and without this being noticed. Furthermore, we would like to point out that we use software to filter unsolicited e-mails (spamfilter). The spam filter can reject e-mails if they have been falsely identified asspam by certain characteristics.

What rights do you have?

Right of access

You have the right to obtain information about your stored data free of charge. Upon request, we will inform you in writing, in accordance with applicable law, which of your personal data we have stored. This also includes the origin and recipients of your data as well as the purpose of the data processing.

Right of rectification

You have the right to have your data stored with us corrected if it is incorrect. Here you can request a restriction of processing, e.g. if you dispute the accuracyof personal data.

Right to blocking

Furthermore, you can have your data blocked. For blocking of data to be able to be considered at any time, this data must be held in a blocking file for monitoringpurposes.

Right to erasure

You can also request the erasure of your personal data, provided there are nolegal retention obligations. If there is such an obligation, we shall block your dataon request. If the relevant legal requirements are met, we will delete yourpersonal data even without a corresponding request from you.

Right to data portability

You have the right to request that we provide the personal data you haveprovided to us in a format that allows it to be transferred to another entity.

Right to lodge a complaint with a supervisory authority

In the event of breaches of data protection law, the data subject has a right of appeal to the competent supervisory authority. The competent supervisoryauthority for data protection issues is the data protection officer of the federalstate in which our company is based. A list of data protection commissioners and their contact information is available at the following link: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html

Right to object

You have the option of revoking your participation in the promotion at any time. All you need to do is send an e-mail to service@barefoot-win.eu. After revokingparticipation in the promotion, your collected and stored personal data shall bedeleted immediately. You thereby withdraw from participation in the promotion.

Protection of personal data

We apply contractual, organisational and technical security measures in accordance with the latest technological standards to ensure that the provisions of the data protection laws are complied with and to thereby protect the dataprocessed by us from accidental or intentional manipulation, loss, destruction orfrom access by unauthorised persons.

The security measures include in particular the encrypted transmission of databetween your browser and our server. A 256-bit SSL encryption technique isused for this purpose.

Your personal data will be protected within the scope of the following points(excerpt):

Maintaining the confidentiality of personal data

To maintain the confidentiality of your personal data stored with us, we havetaken various measures to control access.

Maintaining the integrity of your personal data

To maintain the integrity of your personal data stored with us, we have takenvarious measures to control disclosure and input.

Safeguarding the availability of personal data

To maintain the availability of your personal data stored with us, we have takenvarious measures to control order and availability.

The security measures in use are being continuously improved in line withtechnological developments. Despite these precautions, due to the insecurenature of the Internet, we cannot guarantee the security of your data transmissionto our website. As a result, any data transmission from you to our website is at your own risk.

Protection of minors

Personal information may only be provided to us by persons who have not yetreached the age of 18 if the express consent of their parent/guardian has beenobtained. This data will be processed in accordance with this privacy policy.

Server log files

The provider of the web pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. This is information about the:

- browser type and browser version
- operating system used
- referrer URL
- host name of the accessing computer
- time of the server request
- IP address

This data is not combined with other data sources.

The basis for data processing is Art. 6 (1) f) GDPR, which allows data processingto protect our legitimate interests and/or Art. 6 (1) b) GDPR, which allows dataprocessing to fulfil a contract or pre-contractual measures.

We use cookies. Cookies are small text files that are stored locally in your web browser cache. Cookies allow your web browser to be recognised when youreturn to the site. The files are used to help the browser navigate through the website and to be able to use all functions to the full extent.

Our website uses: browser cookies.

Monitoring of cookies by the user

Browser cookies: You can set all browsers to accept cookies only on request. Also, you can configure your settings to accept only cookies whose pages arecurrently being visited. All browsers offer functions that allow the selectivedeletion of cookies. The acceptance of cookies can also be generally deactivated, however, restrictions in the user-friendliness of this website may then have to beaccepted.

Life span of the cookies used

Cookies are managed by the web server of our website. This websiteuses: transient cookies/session cookies (one-time use)
Life span: until this website is closed

Disable or remove cookies (opt out)

Every web browser offers options to restrict and delete cookies. For moreinformation, please visit the following websites:

• Internet Explorer: https://support.microsoft.com/de-de/help/17442/windows-internet-explorer-delete-manage-cookies

• Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer?redirectlocale=en-US&redirectslug=Cookies

• Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

• Safari: https://support.apple.com/de-de/HT201265

Matomo advertising analysis service

We use the web analytics software Matomo (https://matomo.org/), a service provided by InnoCraft Ltd, 150 Willis Street, 6011 Wellington, New Zealand, (“Matomo”) to collect and store data for marketing and optimisation purposes. From this data, user profiles are created under a pseudonym; cookies are used for this purpose. The data collected using Matomo technology (including youranonymised IP address) is only transmitted to our server and stored for usageanalysis purposes, which serves to optimise our website.

The information produced by the cookie in the pseudonymised user profile arenot used to identify you personally and are not combined with personal detailsabout the individual to whom the pseudonym relates. If you do not agree with the storage and evaluation of this data from your visit to our website and would like to object for the future, you can prevent the use of cookies and thus participationin tracking.

For this purpose, you can customise your browser in such a way that you areinformed of the placement of cookies and can decide separately on theiracceptance or to block the acceptance of cookies for certain cases or generally. Not accepting cookies may limit the functionality of our website.

If you do not consent to data concerning your visit to the website being storedand evaluated, you can object to such storage and use at any time by mouse click. An opt-out cookie will then be placed in your browser which will then preventMatomo collecting any session data. Please note that if you delete all yourcookies, you will also delete the opt-out cookie which you will therefore have to activate once again.

Amendments to our privacy policy

We reserve the right to amend our privacy policy to ensure conformity at all times to the latest legal requirements, or to incorporate changes to our servicesinto the privacy policy. This could, for example, concern the introduction of newservices. The new privacy policy is then effective the next time you visit ourwebsite.

Status: April 2022