Privacy Policy

Who is responsible for this website?

Identity of the person responsible: TMP LOGISTICS S.L.
Trade name: TMP LOGISTICS
NIF/CIF: B60948114
Address: Carrer de Craywinckel, 7, Sarrià-Sant Gervasi, 08022 Barcelona.
Mail: consultas@juantrigo.com
Activity: Export and consulting
Contact details of the data controller or representative, and of the data protection officer if applicable: Carrer de Craywinckel, 7, Sarrià-Sant Gervasi, 08022 Barcelona.
Registered in the Barcelona Mercantile Register: Volume ??? Folio ??, Page ???.

What personal data is collected on this website?

For the purposes established in this Privacy Policy, TMP LOGISTICS collects and processes the Personal Data detailed
below, which will depend on the different products or services requested in this Web:

– Identification data: name, surname, first name,
– Contact details: postal address, e-mail address, mobile phone number.
– Contractual data: data on contractual transactions, DNI, products and services purchased, financial transactions,
payment data.
– Browsing data: IP address, type and identification of the device, type of browser, domain through which you access the
Website, browsing data, activity on the Website.

On what legal basis are these data processed?

We process your personal data on the following legal bases:

The user’s consent in relation to contact, subscription to content and the sending of commercial communications, via
email, cookies or messaging systems.

The legitimate interest of the data controller to protect the users of the TMP LOGISTICS website from abuse and fraud in
the use of our services.

For what purposes will we process your data?

On this website, there are different forms, in each of them, the information collected will be used in the following
way:

Sales form: data to manage the purchase of different wines, including the management of the order, payment and all
operations related to the contracting of the chosen service or product. This includes sending follow-up emails, replies,
invoices, receipts, etc.

Retention period of personal data

Client Data:

The period of retention of personal data will vary depending on the service contracted by the customer. In any case, it
shall be the minimum necessary and may be maintained up to:

-4 years: Law on Offences and Penalties in the Social Order (obligations regarding affiliation, registration,
deregistration, contribution, payment of salaries, etc.); Arts. 66 et seq. General Tax Law (accounting books…).

-5 years: Art. 1964 of the Civil Code (personal actions without special time limit).

-6 years: Art. 30 of the Commercial Code (accounting books, invoices, etc.).

-10 years: Art. 25 of the Law on the Prevention of Money Laundering and Terrorist Financing.

Subscriber data: From the time the user subscribes until the user unsubscribes.

Data of potential customers: the data will be kept in any case for the duration of the commercial relationship
established and, once it has ended, for two years, unless the user requests its deletion beforehand.

What are your rights regarding the use of your data?

Any person has the right to obtain confirmation from MORE THAN WINE whether or not we are processing personal data
concerning him/her.

Interested persons have the right to:
● Request access to personal data relating to the data subject.
● Request its rectification or erasure.
● Request its cancellation.
● Request the restriction of their processing.
Opposing treatment.
● Request data portability.

If you have given your consent for a specific purpose, you have the right to withdraw your consent at any time, without
affecting the lawfulness of the processing based on your consent prior to its withdrawal.

In case you feel that your rights concerning the protection of your personal data have been violated, especially when
you have not obtained satisfaction in the exercise of your rights, you can lodge a complaint with the competent Data
Protection Supervisory Authority via its website: www.agpd.es.

To exercise these rights, please write to consultas@juantrigo.com.

There is a form for exercising your rights, you can request it by email or, if you prefer, you can use the forms
prepared by the Spanish Data Protection Agency or third parties.

These forms must be electronically signed or be accompanied by a photocopy of the ID card.

If you are represented by someone, you must attach a copy of your ID card, or it must be signed with your electronic
signature.

Forms can be submitted in person, by letter or by mail to the address of the person responsible at the beginning of this
document.

Facebook Ads

Facebook Ads can be used in this shop:
Facebook Ads allows you to segment the audience to target an ad.

Thanks to Facebook’s Custom Audiences feature, you can create an audience from Facebook user and subscriber data, such
as email addresses and phone numbers. To do this, databases need to be shared with Facebook to then create customised
audiences by targeting ads to people with similar profiles.

No sensitive personal information is used for ad targeting in accordance with Facebook’s Policies and is not shared with
third parties or other advertisers, and will be deleted by Facebook upon completion of the ad targeting process. In
addition, Facebook will ensure confidentiality.
Facebook’s ad system allows you to display relevant and useful ads without revealing your identity to advertisers, and
can reach groups of people with specific profiles.

At any time as a user, you can revoke your consent via https://www.facebook.com/settings?tab=ads, where you can
configure the receipt of advertisements. You can also indicate that you do not want interest-based ads from Facebook, or
other companies, through the European Interactive Digital Advertising Alliance (EDAA) of Your On Line Choices
(http://www.youronlinechoices.com/es/) or in the settings of your computer or mobile device.

To use the custom audiences feature, this website uses Facebook’s Website Custom Audience tool, which makes use of the
Facebook pixel that tags the visitor to this website in an anonymised form. If you wish to object to Facebook’s use of
Website Custom Audiences, you can do so at: https://www.facebook.com/ads/website_custom_audiences/.

For more information on the scope and purpose of data collection by Facebook and its subsequent processing, as well as
to configure your privacy, you should go to the following links: https://www.facebook.com/privacy/explanation.

Facebook Conversion Tracking Pixel

For the optimisation of advertising campaigns for ads served on Facebook, and for statistical purposes, we use the
conversion tracking pixel of Facebook Inc., 1601 s. California Ave, Palo Alto, CA 94304, which tracks users’ actions
after clicking on an ad.

The data obtained through this pixel are anonymous and do not refer to identified natural persons, nor are they stored
or profiled with their personal data.

This data may be stored and processed by Facebook, and Facebook may link this data to your Facebook account and also use
it for its own advertising purposes in accordance with Facebook’s data usage policy, which you will find at
https://www.facebook.com/about/privacy/, recently updated at https://www.facebook.com/about/privacy/update.

You can enable Facebook and its partners to place advertisements on and off Facebook, and a cookie may be stored on your
computer for this purpose.

Security Notification and Gap Statement

At MORE THAN WINE we take security measures appropriate to the level of risk to protect personal information against
loss, misuse and unauthorised access, disclosure, alteration and destruction, taking into account the risks involved in
the processing and the nature of personal information; however, if MORE THAN WINE determines that your service data has
been misappropriated (including by an employee of MORE THAN WINE, exposed by a security breach or improperly acquired by
a third party, MORE THAN WINE will promptly inform you of such security breach, misappropriation or misacquisition.

To which recipients will your data be communicated?

Many tools used on this website to manage data are contracted by third parties. In order to provide services strictly
necessary for the development of the activity, MORE THAN WINE shares data with the following providers under their
corresponding privacy conditions:

External service providers (e.g. payment processing services, order processing, analytics, marketing campaign
management, website management, and email distribution and other similar service providers) in order for them to perform
business functions on behalf of MORE THAN WINE.

This website may be accessed occasionally by the web development and maintenance company, or by the hosting company.
They have signed a contract for the provision of services that obliges them to maintain the same level of privacy that
applies to the processing carried out on this website.

Any international transfer of data derived from the use of tools or service providers will be subject to the Privacy
Shield agreement, which guarantees that American software companies comply with European data protection policies on
privacy, secrecy and data security.

Specifically, this website uses the following tools:

Email marketing tools, Shopify billing
Google and Facebook analytics tools

Segmentation and profiling

The registration of personal data provided at the time of subscription, contact, interaction with the website and any
other data provided during browsing, including the information provided by cookies in relation to browsing habits, will
be used to be segmented or categorised in order to apply them to the activity related to the management of general
administration, information, marketing of advertising space, analysis of proposals requested by users/customers,
statistical study of the services and content used, tastes and preferences, and surveys or forms.

Profiling, by analysing your automated individual choices, is the use of your Personal Data to evaluate certain personal
aspects, such as analysing and predicting your financial situation, personal preferences, interests, behaviour,
location, movements and attitudes. The logic applied to obtain these profiles is the use of statistical procedures and
the consequences of this processing of your data by means of profiling are the sending of personalised communications of
interest to you with content related to the wines sold in this shop.

The legal basis for the processing of your data for the above-mentioned purposes and the automated individual profiling
is the consent given by ticking the above-mentioned box.

The data we use in profiling and show to advertisers is not user-identifiable data, but only shows in a graph the type
of audience we have, their age, country, gender, etc.

Secrecy and data security

Bodegas TMP LOGISTICS undertakes to use and process the user’s personal data, respecting their confidentiality, in
accordance with their purpose; as well as to comply with its obligation to store them and adapt all measures to prevent
alteration, loss, unauthorised processing or access, in accordance with the provisions of current data protection
legislation.

[This website includes an SSL certificate. This is a security protocol that makes your data travel in an integral and
secure way; that is to say, the transmission of data between a server and the web user, and in feedback is totally
encrypted].

Bodegas TMP LOGISTICS cannot guarantee the absolute impregnability of the Internet, nor, therefore, the violation of
data through fraudulent access to them by third parties.

With respect to the confidentiality of the processing, TMP LOGISTICS will ensure that any person who is authorised by
TMP LOGISTICS to process the customer’s data (including its staff, collaborators and service providers), will be under
the appropriate obligation of confidentiality (whether it is a contractual or legal duty).

When a Security Incident occurs, upon becoming aware of it, MORE THAN WINE shall notify the Customer without undue delay
and shall provide timely information related to the Security Incident as it becomes known, or when reasonably requested
by the Customer.

Accuracy and veracity of the data

As a user, you are solely responsible for the veracity and accuracy of the data you submit to Bodegas TMP LOGISTICS,
exonerating TMP LOGISTICS from any liability in this regard. Users guarantee and are responsible, in any case, for the
accuracy, validity and authenticity of the personal data provided, and undertake to keep them duly updated. The user
agrees to provide complete and correct information in the contact or subscription form.

Revocability

The consent given, both for the processing and for the transfer of the data of the interested parties, may be revoked at
any time by communicating it to TMP LOGISTICS in the terms established in this Policy for the exercise of the ARCO
rights. Such revocation shall in no case be retroactive.

Changes to the privacy policy

TMP LOGISTICS Global S.L. reserves the right to modify this policy to adapt it to new legislation or jurisprudence, as
well as to industry practices. In such cases, it shall announce on this page the changes introduced reasonably in
advance of their implementation.