Privacy Policy

Introduction – Protecting Your Privacy

At Ta’ Betta, we understand the importance of personal data and strongly value everyone’s right to privacy. We are thus committed to do our utmost to keep your personal data as safe as possible. This privacy policy describes our practices relating to the processing (collection, usage and storage) of personal data of our customers, visitors of our website tabetta.com and users of our online facilities, as well as the purpose for that processing.

Information We Collect

Most of the personal information which we may collect about you through this website is given to us only if you choose to give it to us. Such personal information may be requested from you when you fill in a field (e.g. sign up for our newsletter or fill in an online form). If you send us an email, then the personal data we process will depend on what you send us in that email.

The information we collect from you normally includes the following:

• Name and surname
• Contact details
  • Email address
  • Home address
  • Telephone number
• Date of birth
• Payment information
• Communication history
• Purchase history and saved items
• Information from accounts you link with us
• Your responses to our surveys and competitions
• Information about your device (phone or laptop) with which you access our online services
• Information given to us through the use of website cookies.

How and Why We Use Information Collected

The following tables provide detail on how we may use information collected from you and why.

Name and contact details

Date of birth

Payment information

Communication history

What you have said to us, for example, over email or contact forms.

Purchase history and saved items

What you have bought in the past and what you have stored in your basket for another time.

Information from accounts you link to us

Information from third-party accounts, such as Google, Facebook, and Twitter accounts amongst others, that you link to us.

Your responses to surveys, competitions and promotions

Information about your device (phone or laptop) with which you access our online services

Information you give us when you browse our website or online services, including your IP address, device type and, if you choose to share it with us, your location data.

Information given to us through the use of website cookies.

Choice not to Provide Personal Information

You do not have to give us any of the personal information described in this policy but, if you do not, you may not necessarily be able to use all of our online services and you are unlikely to receive an optimal customer experience.

Anonymised and Aggregated Personal Information

We may also anonymise and aggregate personal information (so that it does not identify you) and use it for purposes such as testing of our IT systems, research, data analysis, improving our website and online services as well as developing new products and services. We may also share this anonymised information with third parties but in a way that these third parties cannot identify you.

The Legal Basis for Processing

For some of the uses of your personal data (as described in this policy), there is a legal basis under applicable data protection laws for us to use such personal data without having obtained your consent. This includes, for example, where it is necessary for us to use the information to perform a contract with you or take steps at your request prior to entering into a contract with you, such as to process your order, provide customer care and support services to you.

It also includes circumstances where we have a legitimate interest to use your data, provided that proper care is taken in relation to your rights and interests, to:

• ensure that you know about any changes to the website or the terms of this Privacy Policy
• ensure that we organise our databases efficiently and understand how our customers may make purchases
• carry out research and analysis (including purchase information) as this helps us understand better our clients better and how they interact with us
• improve and ensure the security of the website and online services

Retention Periods

We will store your information for no longer than is necessary keeping in mind the purpose/s (or compatible purposes) for which we collected the data in the first place. We may also store some of your information if it becomes necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.

As a guide:

• We will keep personal data while your account with us is active (if you have an account) or until such time as you ask us to stop communications with you, unless we need to keep the data for longer.
• We may keep certain categories of personal data for longer in order to meet any legal or regulatory requirements or to resolve a legal dispute.
• We may keep different types of personal data for different lengths of time if required by law (for instance, we may need to keep certain personal data relating to purchases for at least 10 years in order to comply with tax/VAT reporting requirements).

Children Under 18

If you are aged 18 or under, you need to get your parent/guardian’s permission before you provide any personal information to us. We will need to process personal data relating to parents or guardians in that case and we may also need to request for verification documentation to ensure that consent is given or authorised by the holder of parental responsibility. This notwithstanding, some of our products and services may not be sold to children under 18 years of age or to parent/guardian’s on the children’s behalf, according to applicable legal and regulatory requirements.

Sharing of Your Personal Information

We do not, and will not, sell any of your personal data to any third party. It is not our business to do so and we want to earn your trust and confidence.

However, we may share your data with the following categories of companies as an essential part of being able to provide our products and services to you:

• Professional service providers, such as marketing agencies, advertising partners and website hosts who service us in order to operate our business.
• Companies that are involved in the process of getting your purchases from us to you, such as payment service providers, warehouses, order packers, and delivery companies.
• Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud.
• Other companies that you may approve as part of your interaction with us, such as social media sites.

In most circumstances, we will not disclose personal data without consent. However there may be occasions where we might have, such as, for example, in response to a court order, to comply with legal requirements or satisfy a legal request, for the proper administration of justice, to protect your vital interests, to fulfil your requests, to safeguard the integrity of the relevant websites and online services operated by us or by such related entities or subsidiaries, or in the event of a corporate sale, merger, reorganisation, dissolution or similar event involving us and/or our subsidiaries and related entities.

When we do share data, we do so on an understanding with the other entities that the data is to be used only for the purposes for which we originally intended. If we have to share data with entities that are outside of the EEA, we will be sure to do so in a manner that complies with the requirements established by the GDPR.

Marketing Messages

We would normally communicate to you about products or services in which you have shown interest. We understand that you would be interested in receiving this information as it is of use with the product or service. However, you can ask us to stop receiving marketing messages from us at any time through one of the following methods:

• By updating your account settings in your online profile
• By clicking on the link to unsubscribe in emails we send you
• By contacting our Customer Care team through the contact points provided in this policy

Once you do this, we will update your profile to ensure that you don’t receive further marketing messages. Please note that it might take a few days for all our systems to be updated, so you might get messages from us while we process your request.

If you ask us to stop marketing messages this will not stop service communications (such as order updates). This may be necessary for us to communicate with you in order to fulfil our contract with you.

Cookies

What are Cookies?

A cookie is a small text file (typically numbers and letters) that is downloaded onto ‘terminal equipment’ (e.g. your computer or smartphone) when you (or someone else) access a website using that device. Cookies are then sent back to the originating website on each subsequent visit. Cookies are useful because they allow a website to recognize a user’s device and store some information about your preferences or past actions.

Some cookies are needed for the sole purpose of carrying out the transmission of a communication over an electronic communications network. Others may be necessary for the provision of a service over the Internet. The use of such cookies is a necessity for the delivery of the online service. Other cookies may be optional but desirable to improve your experience, in which case we will ask you for your consent to use them.

How do you change your cookie settings?

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

Other passive information which we collect

Apart from the information you provide us with when using our website and online services, other information may be passively collected from you (without you actively furnishing such information) when you navigate through the website and online services. We use various technologies and navigational data collection methods to gather such passive information for various reasons, for example, to track how many visitors access our website, the date and time of their visit, the length of their stay and which pages they view. The passive information also aids us to determine which web browsers our visitors use and the address from which they accessed our website.

Such passively collected information may be used and combined to improve our services to website visitors, customise the website based on your preferences, compile and analyse statistics and trends of our visitors and their use of the sites operated by us and our related entities or subsidiaries. Together with our related entities or subsidiaries we may use this information and share it with third parties to improve the content, functionality and administration of our websites, to better understand our customers and markets, and to improve our products and services.

Unless you have consented, such passive information shall not be combined with personally identifiable information collected elsewhere by our website or respective sites operated by our related entities or subsidiaries.

Your Rights

You enjoy several rights relating to your personal information as explained in the following sections.

The right to be informed about how your personal information is being used

We need to be clear with you about how we process your personal data. We do this through this Privacy Policy, which we will keep as up to date as possible.

The right to access the personal information we hold about you

You can access the personal data we hold on you by contacting us through the contact points provided in this policy. To process your request, we will ask you to send us proof of identity so that we can be sure we are releasing your personal data to the right person. We will carry out our best efforts to process your request within one month or, if the request is particularly complex, two months. We can provide you with a copy of your personal data in electronic format or hard copy. If we consider the frequency of your requests as being unreasonable, we may refuse to comply with your request. In those circumstances, if you disagree, you can complain to the data protection authority – in Malta, the Information and Data Protection Commissioner.

The right to request the correction of inaccurate personal information we hold about you

We appreciate feedback from you to ensure our records are accurate and up to date. If you think that the information we hold about you is inaccurate or incomplete please ask us to correct it by contacting us through the contact points provided in this policy.

The right to request that we delete your data, or stop processing it or collecting it

You can ask us to delete your personal data. However, this is not an absolute right. In spite of a request for erasure, we may be justified to keep personal data in some instances such as, for example, to comply with a legal obligation (such as retaining personal data for VAT reporting purposes) or in relation to the exercise or defence of any legal claims. When you ask us to delete your personal data, we assume that you do not want to hear from us again. Other than as described above, we will always comply with your request and do so promptly.

The right to stop direct marketing messages

The right to object to certain processing based on legitimate interest

You have a right to object to our use of your personal information including where we use it for our legitimate interests or where we use your personal information to carry out profiling using automated means.

The right to request human intervention if automated processing without human intervention is used to make decisions having legal or similar effects on you

The right to withdraw consent for other consent-based processing at any time

The right to request that we transfer or port elements of your data either to you or another service provider

You have the right to move, copy or transfer your personal data from one organisation to another. If you do wish to transfer your personal data we would be happy to help. If you ask for a data transfer, we will give you a copy of your personal data in a structured, commonly used and machine-readable form (e.g. a CSV file format). We can provide the personal data to you directly or, if you request, to another organisation. Please note that we are not required to adopt processing systems that are compatible with another organisation, so it may be that the recipient organisation cannot automatically use the personal data we provide. When making a transfer request, it would be helpful if you can identify exactly what personal data you wish us to transfer.

The right to complain to your data protection regulator — in Malta – the Information and Data Protection Commissioner (IDPC)

If you want to exercise your rights, have a complaint, or just have questions, please contact us here through the contact points provided in this policy.

Please appreciate that some limitation may apply to the exercise of these rights must be exercised. For example, for any request you make we can only provide you with information that relates to you and not what relates to other persons. When we receive requests, we may also request that you identify yourself and provide documentation or information for verification as we would not want to disclose information to the wrong person. Unreasonable requests may be subjected to a reasonable fee or refusal to respond.

Security of your Personal Data

Security of your personal data is very important to us. Where it’s appropriate, our website uses HTTPS to help keep information about you secure. However, no data transmission over the Internet can be guaranteed to be totally secure.

You may complete a registration process when you sign up to use parts of the websites. This may include the creation of a username, password and/or other identification information. Any such details should be kept confidential by you and should not be disclosed to or shared with anyone. Where you do disclose any of these details, you are solely responsible for all activities undertaken where they are used.

Whenever you create a password, you should choose a strong one, meaning it should be lengthy and include a mixture of upper-case and lower-case letters, numbers and non-alphanumeric symbols. We do our best to keep the information you disclose to us secure. However, we can’t guarantee or warrant the security of any information which you send to us. Security measures which have implemented to secure information transmitted over our website or stored on our systems include the following:

• Use of secure servers
• Use of firewalls
• Use of encryption
• Physical access controls at data centres
• Information access controls
• Use of back-up systems

Please understand, however, that no system is perfect or can guarantee that unauthorised access or theft will not occur.

Changes to How We Protect Your Privacy

Our website is continually under review – new functions and features are periodically added and improved to the interface, thus changes to our privacy policy may be required from time to time. We, therefore, encourage you to check our privacy policy on a frequent basis.

Links to Other Websites

This privacy notice does not cover the links within our website and online services linking to other websites which are not controlled by us. We are not responsible for the collection or use of your personal information from these third-party websites. Therefore, we encourage you to read the privacy statements on other such websites you may visit.

How to Contact Us

We are always happy to hear from you, whether to make a request or provide a suggestion on how we can do better. If you have any queries or require clarifications about this Privacy Policy, or if you wish to raise a request or make a complaint in relation to our handling of your personal information, please contact us at:

Ta Betta’ Wine Estates Ltd.
31,
Triq l-Imsida
Birkirkara BKR 2012
Malta, Europe

Website: tabetta.com

Email: [email protected]

Mobile: +356 7977 4477

Last update: 09-Jun-2019