Privacy Policy ofVinové

Vinové collects some Personal Data from its Users.


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Data Controller

Punch Srl- Via Martiri Della Liberazione 38, 16043 Chiavari GE

Data Protection Officer (DPO or RDP):
Punch Srl- Via Martiri Della Liberazione 38, 16043 Chiavari GE

Owner contact email:[email protected]


Types of data collected

Among the Personal Data collected by Vinové, either independently or through third parties, there are: email; Tracking Tool; Usage data; unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example); Data communicated while using the service; first name; last name; geographic location; sex; telephone number; address; password; VAT number; country; city; various types of data.

Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using Vinové.
Unless otherwise specified, all the Data requested by Vinové are mandatory. If the User refuses to communicate them, it may be impossible for Vinové to provide the Service. In cases where Vinové indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation.
Users who have doubts about which data are mandatory are encouraged to contact the owner.
Any use of Cookies - or of other tracking tools - by Vinové or by the owners of third-party services used by Vinové serves the purpose of providing the Service requested by the User, in addition to any other purposes described. in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through Vinové and guarantees to have the right to communicate or disseminate them, freeing the Owner from any liability to third parties.


Method and place of processing of the collected data

Processing methods

The Data Controller adopts the appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
The processing is carried out using IT and / or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organization of Vinové (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers, hosting) may have access to the Data. providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller.


Legal basis of the processing

The Data Controller processes Personal Data relating to the User if one of the following conditions exists:


·      the User has given consent for one or more specific purposes; Note: in some jurisdictions the Data Controller may be authorized to process Personal Data without the User's consent or another of the legal bases specified below, as long as the User does not object ("opt-out") to such treatment. However, this is not applicable if the processing of Personal Data is governed by European legislation on the protection of Personal Data;

·      the processing is necessary for the execution of a contract with the User and / or for the execution of pre-contractual measures;

·      the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;

·      the processing is necessary for the execution of a task of public interest or for the exercise of public authority vested in the Data Controller;

·      the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.


However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.



The Data is processed at the Data Controller's operating offices and in any other place where the parties involved in the processing are located. For more information, contact the owner.
The User's Personal Data may be transferred to a country other than that in which the User is located. To obtain further information on the place of processing, the User can refer to the section relating to the details on the processing of Personal Data.

The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization governed by public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.

The User can check if one of the transfers described above takes place by examining the section of this document relating to the details on the processing of Personal Data or request information from the Data Controller by contacting him at the details indicated at the beginning.


Retention period

The Data are processed and stored for the time required by the purposes for which they were collected.


·      Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.

·      Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until this interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.



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Purpose of processing the collected data

The User Data is collected to allow the Owner to provide the Service, comply with legal obligations, respond to requests or executive actions, protect their rights and interests (or those of Users or third parties), identify any malicious activities. or fraudulent, as well as for the following purposes: Contacting the User, Remarketing and behavioral targeting, Statistics, Advertising, Registration and authentication, Displaying content from external platforms, Access to accounts on third party services, Tag management, Content performance tests and features (A / B testing), Heat mapping and session recording, Infrastructure monitoring, Content commenting, Interaction with live chat platforms, Data collection and online survey management, Payment management, Support request management and Contact, Productivity Activity Management, Platform and Hosting Services, Registration and Authentication for nite directly from Vinové and Transfer of Data outside the EU.

To obtain detailed information on the purposes of the processing and on the Personal Data processed for each purpose, the User can refer to the "Details on the processing of Personal Data" section.


Facebook permissions requested by Vinové

Vinové may ask for some Facebook permissions that allow it to perform actions with the User's Facebook account and to collect information, including Personal Data, from it. This service allows Vinové to connect with the User's account on the Facebook social network, provided by Facebook Inc.

For more information on the permissions that follow, please refer todocumentation of Facebook permissionsand toFacebook privacy policy.

The required permissions are as follows:


Basic information

The basic information of the User registered on Facebook which normally includes the following Data: id, name, image, gender and localization language and, in some cases, the "Friends" of Facebook. If the User has made further Data publicly available, they will be available.


Access to private data

Allows access to the User's and friends' private data.


Custom user actions

Allows the application to retrieve published actions from another application, as specified by the 'app namespace'.


Birthday date

Provides access to the birthday date.



Provides access to the User's primary email address.


On me

Provides access to the 'About me' section of the profile.


Details on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

·      Access to accounts on third party services

·      Comment on the contents

·      Contact the user

·      Payment management

·      Tag management

·      Management of data collection and online surveys

·      Management of activities related to productivity

·      Management of support and contact requests

·      Heat mapping and session recording

·      Interaction with live chat platforms

·      Infrastructure monitoring

·      Advertising

·      Registration and authentication

·      Registration and authentication provided directly by Vinové

·      Remarketing and behavioral targeting

·      Platform and hosting services

·      Statistics

·      Content and functionality performance tests (A / B testing)

·      Transfer of data outside the EU

·      Viewing content from external platforms


Information on how to opt out of interest-based advertising

In addition to any opt-out function provided by any of the services listed in this document, Users can read more on how to disable interest-based advertisements in the appropriate section of the Cookie Policy.


Further information on the processing of Personal Data

·      Analysis of User Data and forecasts ("profiling")

·      Consent cookies

·      Automated decision-making processes


Rights of the User

Users can exercise certain rights with reference to the Data processed by the Data Controller.

In particular, the User has the right to:


·      withdraw consent at any time.The User can revoke the consent to the processing of their Personal Data previously expressed.

·      oppose the processing of their data.The User can object to the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are indicated in the section below.

·      access their data.The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.

·      verify and request rectification.The User can verify the correctness of his / her Data and request its updating or correction.

·      obtain the limitation of the treatment.When certain conditions are met, the User may request the limitation of the processing of their Data. In this case the Data Controller will not process the Data for any other purpose than their conservation.

·      obtain the cancellation or removal of their Personal Data.When certain conditions are met, the User can request the cancellation of their Data by the Owner.

·      receive their data or have them transferred to another owner.The User has the right to receive his / her Data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain its unhindered transfer to another owner. This provision is applicable when the Data is processed with automated tools and the processing is based on the User's consent, on a contract to which the User is a party or on contractual measures connected to it.

·      propose a complaint.The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.


Details on the right to object

When Personal Data is processed in the public interest, in the exercise of public authority vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to oppose the processing for reasons connected to their particular situation.

Users are reminded that, if their Data are processed for direct marketing purposes, they can oppose the processing without providing any reasons. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.


How to exercise your rights

To exercise the User's rights, Users can direct a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within one month.

Cookie Policy

Vinové makes use of Tracking Tools. To find out more, the User can consult the Cookie Policy.


Further information on the treatment

Defense in court

The User's Personal Data may be used by the Owner in court or in the preparatory stages for its eventual establishment for the defense against abuse in the use of Vinové or related Services by the User.
The User declares to be aware that the Owner may be obliged to disclose the Data by order of the public authorities.


Specific information

At the request of the User, in addition to the information contained in this privacy policy, Vinové may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.


System log and maintenance

For needs related to operation and maintenance, Vinové and any third party services used by it may collect system logs, i.e. files that record the interactions and which may also contain Personal Data, such as the User IP address.


Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.


Response to "Do Not Track" requests

Vinov√© does not support ‚ÄúDo Not Track‚ÄĚ requests.
To find out if any third-party services used support them, the User is invited to consult the respective privacy policies.


Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on Vinové as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details. of which it is in possession. Please therefore consult this page frequently, referring to the date of the last modification indicated at the bottom.

If the changes concern treatments whose legal basis is consent, the Data Controller will collect the User's consent again, if necessary.

Definitions and legal references

Personal Data (or Data)

Any information that, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable constitutes personal data.


Usage Data

This is the information collected automatically through Vinové (also from third-party applications integrated into Vinové), including: the IP addresses or domain names of the computers used by the User connecting with Vinové, the addresses in URI (Uniform Resource Identifier ), the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.) the country of origin , the characteristics of the browser and the operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details relating to the itinerary followed within the Application, with particular reference to the sequence of the pages consulted, the parameters relating to the operating system and the IT environment of the User.



The individual using Vinové who, unless otherwise specified, coincides with the Data Subject.



The natural person to whom the Personal Data refers.


Data Processor (or Manager)

The natural person, legal person, public administration and any other body that processes personal data on behalf of the Data Controller, as set out in this privacy policy.


Data Controller (or Owner)

The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures relating to the operation and fruition of Vinové. The Data Controller, unless otherwise specified, is the owner of Vinové.


Vinové (or this Application)

The hardware or software tool through which the Personal Data of Users are collected and processed.



The service provided by Vinové as described in the relative terms (if available) and on this site / application.


European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document is intended to be extended to all current member states of the European Union and the European Economic Area.



Cookies are Tracking Tools which consist of small pieces of data stored in the User's browser.


Tracking Tool

By Tracking Tool we mean any technology - eg. Cookies, unique identifiers, web beacons, integrated scripts, e-tags and fingerprinting - which allow users to be traced, for example by collecting or saving information on the User's device.

Legal references

This privacy statement is drawn up on the basis of multiple legislative systems, including articles. 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy statement only concerns Vinové.