Your privacy is important to us. This website, www.luxaviation-finewines.com (the "Site"), is owned and operated by Luxaviation Management Company S.A., having its registered address at 35A avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg trade and companies register under number B185225 (“Luxaviation” or “we”) which is considered as the “data controller”. Luxaviation is a member of the Luxaviation group of companies (the “Luxaviation Group”). This Privacy Policy ("Privacy Policy") describes how we collect, use and disclose information that we may obtain about you ("You") (the "Personal Information") through the Site and the mobile application [Luxaviation Fine Wines App] (the “App”). When you provide Personal Information to us via our Site or the App, we protect it according to this Privacy Policy. By using this Site and/or the App, You acknowledge that you have reviewed, and agree to, the terms of this Privacy Policy and you give us your consent to process your Personal Information for the purposes mentioned herein. If you do not agree to this Privacy Policy, do not use this Site or the App. Luxaviation complies with the requirements of the EU General Data Protection Regulation n° 2016/679 (the “GDPR”). To the extent we collect Personal Information online, our purpose is to better serve our customers.
THE PERSONAL INFORMATION WE COLLECT
We may collect the following types of information when you browse this Site, any other website, or any affiliate site or use the App:
• Personal Information You provide directly when You register on the Site and/or the App, inquire about our services via any e-mail messages You send us, including personally identifiable information such as Your name, contact information (phone, fax, address, and email address), weight, passport number (or similar ID document), and your birth year and month, as well as payment method such as credit card.
• Passively collected information, including through the use of "cookies" described below, such as IP addresses, web browser and operating system information, date and time of visits, and the web pages Your Internet browser visits when browsing this Site, any other Luxaviation Group website or any affiliate site; click-through information related to Luxaviation Group emails and related marketing activities; and aggregate, non-personally identifiable information, such as the number of hits per week or per web page.
COOKIES
Cookies are small text files that store information about your interactions with a particular website, either temporarily (known as a "temporary" or "session" cookie, and deleted once You close Your browser window) or more permanently on the hard drive of your computer (known as a "permanent" or "persistent cookie"). Cookies can make it easier to use a website by allowing servers to access certain information quickly. Luxaviation also uses performance cookies to obtain information about visitors' use of the Site in order to improve the content of the Site and make it user-friendlier. For instance, we use Google Analytics cookies that, inter alia, count the number of visitors or keep track of the most popular pages. You can refuse the installation of cookies via your browser settings. You can also remove cookies already installed on your computer or mobile device at any time. Certain parts of the site may no longer work as well once the cookies have been deactivated.
WEB BEACONS
Luxaviation may use "web beacon" technology to gather metrics from anonymous web users and email recipients for the purpose of operating and improving websites and email communications. A web beacon is an electronic image that is embedded in a web page or email which allows to track web page views/hits or the opening of an email containing a beacon. Luxaviation may use web beacon in conjunction with cookies to track web site activity on the Site and associated websites. Web beacon tracking by Luxaviation does not identify the name or email address of the web user or mail recipient.
THE WAY WE USE PERSONAL INFORMATION
Luxaviation uses Personal Information You have provided directly or information we collect indirectly online about you for marketing purposes in the following ways: For Personal Information You provide directly online (through the Site and/or the App), or through email messages, relating to inquiries about our services, we use the information to engage in and process transactions with You, to respond to Your inquiries and requests, to provide information on our services, to provide you with services through the App, to provide information on Luxaviation’ partners offerings and to provide customer support activities. Before we use Your Personal Information, we will give you the opportunity to choose whether or not you allow Luxaviation to use Your Personal Information in such ways described in this Privacy Policy. You may at any time choose to stop receiving Luxaviation or Luxaviation Group members’ emails relating to marketing materials by following the unsubscribing instructions contained in the emails, which are sent to your attention. You can also unsubscribe through the App or by sending an email to unsubscribe@luxaviation-finewines.com and requesting the removal of your name from our marketing lists. Third parties may advertise some of Luxaviation services of Luxaviation Group member services. We will only share Your Personal Information if you have agreed to allow us to share your information with third parties, including Luxaviation Group members. You have the opportunity to choose to not receive such marketing materials from third parties by updating your subscription preferences by clicking here. Luxaviation informs You that when You agree for Your information to be shared and used by Wine Source Group Holding, a company having its registered address located at 71 avenue Franklin Roosevelt, 75008 Paris, France, that will perform the services and/or provide the products that You have ordered via the Site or App, then Wine Source Group Holding is responsible for handling Your Personal Information. Therefore, we recommend that you familiarise yourself with Wine Source Group Holding’s privacy policies available online so you understand how our partner will use, collect and handle your information. For Personal Information You provide online, including actions or clicks from hyperlinks and subscriptions, we may use the information to customise future communications and web pages in accordance with communication preferences you have established with us. For Personal Information you provide through the App, we use this information to provide you with requested services and to send you marketing communications. For Personal Information about web pages visited, page hits per week, and the like, we use this information internally to improve the design of our web pages.
WHEN WE SHARE YOUR PERSONAL INFORMATION
As a member of a worldwide group, Luxaviation shares Personal Information for business and/or marketing purposes only on a need-to-know basis and only with: (a) Luxaviation Group’s employees, contingent workers, and worldwide offices, (b) Luxaviation Group ‘s subcontractors, consultants, and third-party service-provider companies. Such third parties have agreed, through written agreements entered into with us, to safeguard the Personal Information in a manner that complies with the terms of this Privacy Policy and the requirements of the GDPR. We will also share your Personal Information with Wine Source Group Holding in order to provide You with the products and services that You have requested through the Site or the App. Please note that if You do not allow us to share Your Personal Information with Wine Source Group Holding, We will not have the possibility to provide you with certain products or services that you with to order. Luxaviation may disclose Your Personal Information to protect our rights or property, to enforce our terms of use and legal notices, as required or permitted by law, or at the request of government regulators or other law enforcement officials and the courts. We shall have no duty to notify you of such compliance with local law. Luxaviation will not use or share Your Personal Information in ways unrelated to those described above without first notifying you and offering you a choice as to whether or not we may use Your Personal Information in a different manner. Subject to your prior consent, Luxaviation will share Your Personal Information with other members of the Luxaviation Group for marketing purpose. Luxaviation does not share non-public personally identifiable information with third-party marketers.
OUR COMMITMENT TO DATA INTEGRITY AND SECURITY
Luxaviation is committed to protecting your privacy. Luxaviation processes Your Personal Information only in ways compatible with the purpose for which it was collected. To the extent necessary for such purposes, we take reasonable steps to make sure that the information is accurate, complete, current and otherwise reliable with regard to its intended use. Luxaviation expects that you will update Your Personal Information with Luxaviation as necessary. Luxaviation takes reasonable and appropriate measures to maintain the confidentiality and integrity, and prevent the unauthorized use or disclosure, of information. This includes maintaining a system of appropriate administrative, physical and technical safeguards to secure such information.
LINKS TO UNAFFILIATED THIRD-PARTY WEBSITES
This Site may contain links to affiliated and unaffiliated third party websites. If you link to or otherwise visit any other websites managed by third parties, Luxaviation encourages you to review the privacy policies that may be available on these websites. You understand that Luxaviation has no control over those websites and is not responsible or liable for the policies and practices followed by such third parties.
YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
If you have created an online profile with us you can update your profile by logging on and following the prompts to update Your Personal Information. You can also request access to your personally identifiable information that we collect online and maintain, and update or correct that information, through e-mailing Luxaviation. You also have the right to request from us the erasure of Your Personal Information or restriction of processing or to object to the processing as well as the right to data portability. Users may request to be removed from our e-mail list, by following the "unsubscribe" instructions on e-mails from Luxaviation or by sending a request to us. You may send any request related to the processing of Your Personal Information to the following address privacy@luxaviation-finewines.com. To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making corrections. We may keep information in an off-line form for as long as we need it for the purpose it is being processed to or as otherwise required by law. Please note that if your information is removed from our databases, you may no longer be able to access certain areas of our website requiring registration or a subscription. You may lodge a complaint with the data protection supervisory authority of your European Union country of residence.
REVISIONS AND CONTACT INFORMATION
We periodically update the features of our Site to better serve you and all our customers. We reserve the right to change this Privacy Policy without advance notice and any modifications are effective when they are posted here. The date of the newest version will be posted below. Please check back frequently, especially before you submit any personally identifiable information at this Site, to see if the Privacy Policy has changed. By using our website, you indicate your understanding and acceptance of the terms of the Privacy Policy posted at the time of your use. If you have any questions, please contact us by sending an e-mail message to privacy@luxaviation-finewines.com.