Privacy Policy

DATA PROTECTION AND SECURITY – PRINCIPLE AND SCOPE OF APPLICATION

Spirit of Wine SA, Anna and Nikita Ehrbar, Via al Mulino 6, 6943 Vezia – Ticino attaches great importance to your privacy and takes the protection of your personal data very seriously.


Personal data relating to an identified or identifiable natural person (hereinafter referred to as “personal data”) is collected, processed and used by Spirit of Wine SA within the scope of these data protection provisions (hereinafter referred to as “provisions”) in compliance with the provisions of applicable data protection law.


This information, therefore, applies to the processing of data in connection with a visit to the website www.luganowineboat.ch, insofar as no specific provisions for data protection are integrated into them. We process your personal data (hereinafter also referred to as “data”) insofar as this is necessary for the use of our website and the associated online services or online applications (hereinafter together referred to as “services”). www.luganowineboat.ch may contain links to the websites of other suppliers who are not subject to this privacy policy.


Personal data is data that you have distributed to an identified or identifiable natural person. Personal data worthy of particular protection are personal data that are protected by law because they are sensitive, e.g. health data. Processing refers to any form of data operation, in particular collection, storage, use, disclosure, storage or deletion. In this regard, we comply with the Federal Data Protection Act (DPA), the Implementing Ordinance (GDPR) and other data protection laws applicable in the specific case (e.g. the EU General Data Protection Regulation European Union, GDPR).

The personal data collected will be stored in a form that allows the identification of the interested parties for a period of time not exceeding the achievement of the purposes for which the personal data are processed.


Below we tell you which data we collect, for what purpose they are used and what your rights are in this regard. If we transmit data relating to third parties to us, we assume that you are authorized to do so and that this data is correct. We therefore invite you to inform third parties about our processing of their data and to provide them with a copy of this data protection information or relevant product information.

USE OF PERSONAL DATA AND RESPONSIBLE OFFICES – CONTACT

What personal data we process: Spirit of Wine SA collects and processes personal data provided by you or generated through the use of our Online Store, applications and bonus programs or as part of other contacts with us, such as:

  1. a) Personal data
  • Name and surname
  • Address (delivery and billing address)
  • Telephone number(s).
  • Email address(es).
  • Date of birth and age
  • Language preferences
  1. b) Order and payment information
  • Credit card and account information
  • Shopping cart information (including order date, order time, type, quantity and value of goods ordered, shopping cart, cancelled cart, order history, etc.)
  • Payment information (payment methods used, paying agent, invoicing date, payment behavior, information on any reminder and collection procedures, etc.)
  • Information about newsletters, advertising, etc. to which you have subscribed.
  • Customer account information (an overview of the customer account information can be found under “My account” in the online shops).
  • Customer service information (contacts, support requests, complaints, returns, etc.)
    c) Specific information regarding use
  • Internet protocols (“IP address”) of your technical devices
  • Specific information about the bonus program (if available)
  • Usage data generated by the use of the Spirit of Wine SA online store and applications (such as frequency and duration of visits, time and date of visit, preferred default settings, search terms and results, etc.)
  • Other data necessary for managing the commercial transaction or responding to a request.

Payment management services allow this Application to process payments via credit card, bank transfer or other instruments. The data used for payment are acquired directly by the manager of the requested payment service without being processed in any way by this Application. Some of these services may also allow the scheduled sending of messages to the User, such as emails containing invoices or payment notifications.

The data collection owner and the Office responsible for data protection for the forms of processing described here is the following:

Spirit of Wine SA – Data Protection Service
Spirit of Wine SA, Anna and Nikita Ehrbar, Via al Mulino 6, 6943 Vezia +41 79 511 20 54
The Data Protection Office is available to answer any questions or concerns about our data protection practices. You can contact him at the address indicated above or at the email address: info@luganowineboat.ch

We advise that personal data has been collected from you (as part of the ordering process):
Name, surname, date of birth, address, email address, telephone number, purchasing behaviour and the data collected by the above-described applications and processors/service providers.

Purposes of processing personal data:

  • Processing of online purchases, evaluation of customer clicks and purchasing
  • Recipients or categories of recipients of personal data:
  • Employees in charge of sales, logistics and marketing, as well as processors and service providers commissioned in this context.
  • Duration of storage of personal data or, alternatively, criteria for determining this duration:
  • Until the conclusion of the respective purchase contract and beyond (in anonymous and blocked form), for the entire legal retention period of the transactions carried out;
  • Regarding the sending of newsletters, for as long as the recipient’s consent exists.
    Rights of interested parties involved in the processing of personal data
    You have the right to be informed by the data protection officer (Art. 15 GDPR) and to have the processing rectified (Art. 16 GDPR) or erased (Art. 17 GDPR) or to have the processing restricted (Art. 18 GDPR) or to have your personal data transferred (art. 20 GDPR) and to object to the processing of your personal data (art. 21 GDPR). Please direct your inquiries to the aforementioned data protection officer.
  • If the data processing is based exclusively on art. 6 para. 1 a) GDPR, i.e. if you have given your consent to the collection and processing of data, you have the right to withdraw your consent at any time, but without affecting the legitimacy of the processing carried out on the basis of your consent until the revocation.
  • and (personalised) marketing as detailed above;
  • Analysis of purchasing and clicking behaviour, email tracking and personalized marketing: we will evaluate your purchasing history on products you have already purchased to offer you suggestions for other similar products. Additionally, we will evaluate the information you left behind during previous visits to our online stores. In this way, we would like to better understand and analyze your purchasing needs. The tools used for this purpose are described in more detail above.

Legal basis of processing:


Art. 6 paragraph 1 GDPR: “Processing is only lawful if at least one of the following conditions is met:
a) The interested party has given his consent to the processing of his personal data for one or more specific purposes;
b) Processing is necessary for the execution of the contract of which the interested party is a party or for the execution of pre-contractual measures adopted at the request of the interested party;
f) Processing is necessary to safeguard the legitimate interests of the controller or a third party, except where the interests or fundamental rights and freedoms of the data subject, which require protection of personal data, are overriding, in particular when the data subject is a minor”.

Recipients or categories of recipients of personal data:
Employees in charge of sales, logistics and marketing, as well as processors and service providers commissioned in this context.

Duration of storage of personal data or, alternatively, criteria for determining this duration:

  • Until the conclusion of the respective purchase contract and beyond (in anonymous and blocked form), for the entire legal retention period of the transactions carried out;
  • Regarding the sending of newsletters, for as long as the recipient’s consent exists.
    Rights of interested parties involved in the processing of personal data
    You have the right to be informed by the data protection officer (Art. 15 GDPR) and to have the processing rectified (Art. 16 GDPR) or erased (Art. 17 GDPR) or to have the processing restricted (Art. 18 GDPR) or to have your personal data transferred (art. 20 GDPR) and to object to the processing of your personal data (art. 21 GDPR). Please direct your inquiries to the aforementioned data protection officer.

If the data processing is based exclusively on art. 6 para. 1 a) GDPR, i.e. if you have given your consent to the collection and processing of data, you have the right to withdraw your consent at any time, but without affecting the legitimacy of the processing carried out on the basis of your consent until the revocation.

Cookies

At www.luganowineboat.ch we use so-called “cookies”. Cookies are small text files that can be stored by your browser on your computer’s hard drive and are used to access our online shop. We use cookies to better understand how www.luganowineboat.ch is used and to improve navigation.

Cookies help, for example, to determine whether you have already visited the online store or whether you are a new visitor. Cookies contain a unique combination of letters and numbers that identifies the browser you are using. Cookies are stored temporarily on your computer and are only transmitted to our system when you visit www.luganowineboat.ch. The cookies we use do not store personal data or personally identifiable information.


We use session cookies and temporary and permanent cookies. So-called session cookies are automatically deleted from your computer or mobile device at the end of a browser session. Temporary or permanent cookies remain stored on your computer or mobile device for a longer or indefinite period of time after the end of a browser session and, among other things, allow you to be recognized again during a future visit to our online stores and adopt your preferred settings.


You can view and delete cookies stored on your computer and control and prevent the setting of cookies through your Internet browser settings. For further information, please contact the manufacturer or the help function of your Internet browser. Please note that some features of our online store may be limited or unavailable if you do not accept cookies.


The cookies used in www.luganowineboat.ch may also come from third parties. These cookies are used for marketing purposes to present advertising and offers tailored to your needs. Furthermore, cookies used by third parties can be used for customer and market analysis as well as for the analysis of user behavior.

RESTRICTED USE BY THIRD PARTIES

Your data is processed by us only for the purposes that we indicate at the time of collection of the same, if we are required or authorized by law to process it and for further purposes in accordance with what is mentioned:

Klaviyo (Klaviyo, Inc. Email marketing Boston (Global HQ), 125 Summer St Floor 6, Boston, MA 02111, United States)

Google Analytics (Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA)

Facebook Plugins (Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA)

Instagram (Instagram LLC, 1601 Willow Road, Menlo Park CA 94025, USA)

LinkedIn (LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland)

TikTok Inc., 5800 Bristol Parkway, Suite 100, Culver City, CA 90230, USA

Youtube (YouTube LLC, 901 Cherry Ave. San Bruno, CA 94066, USA)

All personal data exchanged in this context are used exclusively to be able to offer the notification technologies in a permanent, secure and reliable manner.

/ Mailchimp /
Mailchimp technology company that provides an electronic email marketing automation tool focused on e-commerce. Purpose: communications with customers for business purposes. Personal data collected: Email, Name, Surname, Usage data, Postcode, Date of birth, City, Language, Telephone number.
By registering on the mailing list or newsletter, the User’s email address is automatically added to a contact list to which email messages containing information, including commercial and promotional information, relating to this Application may be sent. Your email address may also be added to this list as a result of registering on this Application or after making a purchase.

In the UK: Bird & Bird GDPR Representative Services UK (contact details can be found in the section below).

In the EEA: Bird & Bird GDPR Representative Services Ireland (contact details can be found in the section below).

United Kingdom and EEA contact information

Intuit Limited Attention: Intuit Data Protection Administration,Cardinal Place, 80 Victoria Street, London,United Kingdom, SW1E 5JL
Place of processing: United Kingdom – Privacy Policy

/ Google Ads (conversion tracking) and Google Marketing Platform /
We use Google Ads on our websites in connection with Google Conversion Tracking. This service is offered by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, a subsidiary of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (hereinafter referred to as “Google”).
In conversion tracking, Google Ads sets a cookie on access devices if one of our websites was accessed from a Google ad. If you visit certain pages of our websites and the cookie has not yet expired, both Google and us can recognize that you have reached that page by clicking on the advert. Each AdWords customer – including us – receives a different cookie. Cookie tracking cannot therefore take place via the websites of AdWords customers. The cookie is not used to identify a specific person.
The information collected with the help of the conversion cookie is used to create conversion statistics for AdWords customers and to ascertain their surfing behaviour for marketing purposes. This way we can adapt advertising offers to your interests. However, we do not receive information that would allow us to trace the user’s identity.
Further information on conversion tracking and general information on Google Ads and the Google Marketing Platform can be accessed via the links provided.
Conversion Tracking – Google Ads – Google Marketing

/ Facebook Business (Facebook Pixel, Facebook Retargeting, Facebook Conversion API) /
We use the Facebook Business Facebook Pixel Facebook Retargeting and Facebook Conversion API services on our website. These professional services are offered by Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (hereinafter referred to as “Facebook”), a subsidiary of Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA (hereinafter referred to as “Facebook”).
Facebook Pixel is a tracking cookie that is used on all pages of our websites. It allows us to track user behavior when you visit one of our websites. Furthermore, interest-based advertisements can be displayed and user profiles (profiling) or target groups (Facebook Retargeting) created. If you do not want Facebook Retargeting to use your personal data and you have a Facebook user account, you can deactivate the function here.
When you visit our websites, a direct connection is created between your browser and the Facebook server with the remarketing tags. This tells the Facebook server which of our websites you have visited. Facebook assigns this information to your personal Facebook user account. You can find more information about Facebook’s collection and use of data, your rights and options for protecting your privacy in Facebook’s data protection notices. If you do not want Facebook to directly assign the information collected to your Facebook user account, you can deactivate the “Custom Audiences” retargeting function here. To do this you must log in to Facebook.
Through Facebook Event it is possible for us to reconstruct the operations you carry out on our websites (the so-called Customer Journey). In this case, Facebook Pixel is activated and the operation is recorded as an event. No information is collected that results when you interact with Facebook via the Facebook login, social plug-ins or in any other way (for example by marking a Facebook contribution with “Like”). Facebook is commissioned by us to process the event information collected for the creation of campaign reports, analyses and custom audiences to enable us to clearly reconstruct the effect of advertising campaigns and gain an idea of the use of our websites.
The legal basis for the processing of your personal data by Facebook Pixel is your consent. Consent can be revoked at any time with the “Show details” button in our Cookie Policy. Any further processing of personal data contained in the Facebook Pixel that does not serve the aforementioned purposes is the responsibility of Facebook separately. Relevant information from Facebook and information on how Facebook processes your data, including the legal basis on which Facebook is based and the options for safeguarding your rights against Facebook, can be found here.
Further information on this can be found in Facebook’s data protection declaration at facebook.com/about/privacy/.

Facebook Conversion API is a data interface through which we transmit data about your behaviour on our website to Facebook for evaluation purposes. This allows us to show you advertisements in line with your behaviour on our site.? Regarding the Conversion API tool we use the following data:

  • IP address
  • User Agent
  • Site Activity

/ Instagram /
Instagram Authentication is a registration and authentication service provided by Instagram, Inc. and connected to the Instagram social network.
Personal data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.

/ LinkedIn /
On our website we use the Linkedin Business services Linkedin Pixel and Linkedin Retargeting. These professional services are offered by LinkedIn Ireland Unlimited Company, Wilton Place Dublin 2, Ireland.
LinkedIn Pixel is a tracking cookie that is used on all pages of our websites. It allows us to track user behavior when you visit one of our websites. Furthermore, interest-based advertisements can be displayed and user profiles (profiling) or target groups (LinkedIn Retargeting) created.
When you visit our websites, Insight tags create a direct connection between your browser and the LinkedIn server. LinkedIn thus receives the information that you have visited our website with the corresponding IP address. LinkedIn can thus associate the visit to our websites with your user account. We may use the information obtained in this way to measure the effectiveness of ads and to display advertising for LinkedIn. If you do not wish LinkedIn to record this data, you can deactivate this function here.
For further information on this, see LinkedIn’s data protection declaration at linkedin.com/legal/privacy-policy.

/ TikTok /
The Pixel of the TikTok social network is integrated into www.luganowineboat.ch (TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland, and TikTok Information Technologies UK Limited, WeWork, 125 Kingsway, London, WC2B 6NH, Great Britain) . The TikTok Pixel is JavaScript code that helps us understand and track the activities users perform on our websites. The information obtained in this way may be used by us for the display of TikTok Ads and for other targeting measures. Further information on this can be found in TikTok’s data protection declaration.

CONTACT FORM, TELEPHONE, ELECTRONIC MAIL (E-MAIL), LIVE CHAT

If you communicate with us by telephone or email, we will retain the information exchanged and your contact details. We may also process data relating to your behaviour or preferences. If necessary, we will ask for your consent in advance. Contact details are collected for processing the request and in case of subsequent questions. You can revoke your consent at any time with effect for the future. To this end, contact the managers indicated above.

Inputs in the case of contact via Live Chat are processed to respond to your request. The content and purpose of the communication are defined based on the content of the message sent or your request.
We also send you information by e-mail to the extent that you provide us with your e-mail address for the purpose of responding to your questions and queries or if you have contacted us directly by e-mail. The processing of your data takes place on the basis of our legitimate interest and serves only for the purpose of responding to the contact. If the aim of the email contact is the conclusion of a contract, the legal basis of the reaction is the initiation of this contractual relationship.

NEWSLETTER

At www.luganowineboat.ch you have the possibility to subscribe to a newsletter. This way you can receive regular information about our offers. When you register for the newsletter, your contact data (e-mail address) is transmitted to us from the input mask. To ensure data security we use the so-called “double opt-in” procedure. This means that after entering your email address and subscribing to the newsletter, an email with a confirmation link will be sent to the specified email address. Only after clicking on this link will you receive the newsletter in the future. Subscription to the newsletter requires your consent, which is given to us when ordering the newsletter. On this occasion, you also confirm that you have read our data protection information.
You can revoke your consent at any time with effect for the future by clicking on the corresponding link at the end of each newsletter sent.

MARKETING

We may also use your data to occasionally send you information about new products or services or other services from us and our partners that may be of interest to you.
If you do not wish your data to be processed for marketing purposes, you can inform us or deny or withdraw consent to contact for advertising purposes.

SECURITY

Spirit of Wine SA takes appropriate technical and organizational measures to protect your personal data from unauthorized processing and to ensure the confidentiality, availability and integrity of your personal data. These measures are intended to protect personal data in Spirit of Wine SA systems, in particular against the following risks: unauthorized or accidental destruction, accidental loss, technical errors, falsification, theft, illicit use, as well as modification, copying, access or other unauthorized processing. When communicating your personal data to affiliated companies or service providers in Switzerland and abroad, Spirit of Wine SA also guarantees that the personal data is adequately protected and protected.
In particular, Spirit of Wine SA uses SSL (Secure Socket Layer) encryption as a standard security measure. If you order goods in one of our online shops, your personal data will be transmitted to us. The SSL procedure is used to protect the data that a customer sends over the Internet to a company’s server. SSL provides the following triple protection:

  • The items to be transmitted are encrypted;
  • Ensures that the form is only returned to the server that sent it
  • The system checks whether the data reaches the respective recipient completely and unchanged.
    Areas protected by SSL can be recognized by the padlock symbol in the browser. Secure connections are usually identified by their address, which begins with “https://”. By double-clicking the padlock icon, you can get more information about the security certificate.

YOUR RIGHTS

In accordance with applicable data protection law and if the conditions are met, you have the following rights:

  • you can request that we inform you whether we process your personal data and, if so, what data it involves;
  • you can request that we correct incorrect data or complete incomplete data or, at least for part of them, correct or integrate them directly and at any time in the insured portal;
  • you can request the deletion of your data except in the case in which we are obliged or authorized by current laws and regulations to retain them;
  • you can request that the data you have made available be sent or transmitted in a commonly used electronic format to another controller, insofar as the processing takes place in the form of automated processing, you have given your consent to the processing or your data is treaties for the conclusion and processing of the social security relationship;
  • where data processing is based on your consent, you have the right to withdraw such consent at any time. The revocation of consent does not affect the lawfulness of the data processing carried out on the basis of consent before the revocation;
  • you may have the right to object to the processing of your data, in particular for purposes of direct marketing, profiling carried out for direct marketing and other legitimate interests in processing;
  • you have the right to express your opinion in case of automated individual decisions and to request that the decision be verified by a natural person;
  • you also have the right to complain to our data protection service or to a competent data protection authority if you do not agree with our management of your rights. The Swiss supervisory authority can be contacted at edoeb.admin.ch and that of the Principality of Liechtenstein at datenschutzstelle.li.
    Please remember that these rights are subject to legal requirements, and exceptions and limitations apply. In particular, we may need to further process your personal data and store it to fulfill a contract with you, to protect our legitimate interests such as asserting, exercising or defending legal claims, or to comply with legal obligations. To the extent permitted by law, in particular to protect the rights and freedoms of other data subjects and to safeguard legitimate interests, we must therefore completely or partially reject a request from data subjects (for example by obscuring certain content relating to third parties or our trade secrets). We must identify you (e.g. with a copy of your identity document, if identification is not possible in any other way) in order to be able to exclude misuse.

    You also have the right to appeal to the competent supervisory authority:
  • Federal Data Protection and Information Commissioner (FDPIC)
  • Feldeggweg 1, CH-3003 Bern
  • Tel: +41 58 462 43 95
  • https://www.edoeb.admin.ch/edoeb/it/home/datenschutz/internet_technologie.html
  • https://www.fedlex.admin.ch/eli/cc/2022/491/it

AMENDMENT OF THIS DATA PROTECTION POLICY – THIRD-PARTY USE

If you purchase goods in our online shop (conclusion of contract), you must provide your personal data (art. 6 para. 1 lit. b GDPR). Accordingly, you are obliged to provide the responsible person with the necessary personal data. If this data is not available, it is not possible to make purchases in our online store.

There is no automated decision-making process regarding the evaluation of your personal data.

These provisions may be modified or updated by Spirit of Wine SA from time to time without notice. Whenever you visit our website or online store and our mobile applications, you should check the terms of our provisions. By using our websites, online stores and mobile applications (collectively referred to as “online stores”), you accept the current version of our provisions, applicable at the time of your visit.

References in these provisions to the processing of your data by third parties during your visit to our online shops reflect the state of knowledge of Spirit of Wine SA at the time of drafting these provisions. We have no influence on any changes to the practices of these third parties. Although these provisions are updated periodically, you should check the current provisions of these third parties before using our online shops or preventing the processing of data by these third parties (see instructions in this regard in the relevant chapters of these provisions).

Spirit of Wine SA complies with the legal provisions of Swiss data protection law, in particular the provisions of the Federal Data Protection Act (LPD), the Ordinance on the Federal Data Protection Act (OLPD) and the Telecommunications Act ( LTC). As part of order processing, your data will be processed by third parties, for whom the provisions in Europe of the General Data Protection Regulation (GDPR) also apply (see section 11 of these provisions).

Last update: February 2024