The wines Private member

PRIVACY POLICY – COS D’ESTOURNEL APPLICATION

Concerned about respecting your privacy and protecting the personal data you provide to us, we are committed to complying with current legislation on privacy and personal data protection, particularly the General Data Protection Regulation (GDPR) of 27 April 2016.

We have created this privacy policy to inform users of the ‘COS D’ESTOURNEL’ application (hereinafter referred to as the ‘Application’) about:

–       How their personal data is collected (personal data being any information that can be used to identify a user);
–       Their rights concerning this data;
–       The identity of the person responsible for processing the personal data collected and processed;
–       The recipients of the personal data;
–       The Application’s cookie policy.”

This policy supplements the legal notice and the General Terms and Conditions of Use in the “Legal information” section of the Application.

The Application is not intended for minors. Only users aged 18 or over may browse the Application and create a user account (hereinafter referred to as a “User Account”).

1.              Who are we?

Your personal data is processed by DOMAINES REYBIER, a public limited company with capital of 121,000 euros, registered in the Bordeaux Trade and Companies Register under number 331 321 109, with its registered office at Château Cos d’Estournel, 33180 SAINT-ESTEPHE.

2.              When do we collect personal data?

When you visit and use the Application, you may be asked to provide a certain amount of personal data about yourself, i.e. information that directly or indirectly enables you to be identified.

You will be asked to provide personal data in order to:
–        Create your User Account and log in to it,
–        Correspond with us via the messaging system on the Application, by email or by any other means,
–        Access your virtual cellar and any other services offered on the Application,
–        Receive newsletters,
–        Benefit from privileged contacts and offers at partner hotels,
–        To improve and personalize your user experience on the Application.

Some of the personal data you may be asked to provide is compulsory. The mandatory nature of the data collected is indicated by an asterisk; other data is optional. Failure to provide mandatory personal data will result in the impossibility of creating a User Account and accessing all the functions offered by the Application.

3.              What types of data do we collect?

The personal data collected through the Application is as follows:

Les données personnelles collectées par le biais de l’Application sont les suivantes :

User profile data
o   Civility,
o   Name,
o   First name,
o   E-mail address,

Connection data
o   IP address,
o   Operating system,
o   Information about the devices from which the user accesses the Application.

4.              For what purposes do we collect this personal data? How long do we keep your data?

This data is collected and processed for specific purposes, as detailed below:

Purposes of Processing:

  1. Create a user account
    • Legal basis for processing: Contract
    • Personal data processed: User profile data
    • Shelf life: During the registration period
  2. Use of the Application services
    • Legal basis for processing: Contract
    • Personal data processed: Connection data
    • Shelf life: During the registration period
  3. Communicate with you
    • Legal basis for processing: Consent
    • Personal data processed: User profile data
    • Shelf life: For the duration of the registration or until consent is withdrawn
  4. Provide the user with the latest information regarding the Application
    • Legal basis for processing: Consent
    • Personal data processed: User profile data
    • Shelf life: For the duration of the registration or until consent is withdrawn
  5. Send newsletters
    • Legal basis for processing: Consent
    • Personal data processed: User profile data
    • Shelf life: For the duration of the registration or until consent is withdrawn
  6. To improve the services offered, develop our services, ensure the technical operation and the Application
    • Legal basis for processing: Legitimate interests
    • Personal data processed: User profile data, connection data
    • Shelf life: During the registration period
  7. Ensure the security of the Application
    • Legal basis for processing: Legitimate interests in guaranteeing the security and proper operation of its services and infrastructures
    • Personal data processed: User profile data, connection data
    • Shelf life: 6 months
  8. Respond to requests for assistance, complaints, and questions sent by users via the Application’s messaging system
    • Legal basis for processing: DOMAINES REYBIER’s legitimate interest in responding to users’ requests and complaints
    • Personal data processed: User profile data, content, and nature of the request
    • Shelf life: 5 years from the date the request was processed
  9. Monitoring and analysis of usage data for audience measurement and personalized recommendations purposes
    • Legal basis for processing: User consent regarding the deposit of cookies
    • Personal data processed: Connection data
    • Shelf life: 25 months from the date of acceptance of the cookies by the user
  10. Respond to users’ requests to exercise their rights
    • Legal basis for processing: Legal and regulatory obligations
    • Personal data processed: User profile data
    • Shelf life: 5 years from the date the request is processed
      • 6 years for requests to exercise the right to object

At the end of the retention periods mentioned above, and once the purposes for which your personal data was collected have been fulfilled, DOMAINES REYBIER will proceed with their deletion or anonymization for statistical purposes. The retention period of your personal data may be extended if they are required for the establishment, defense, or exercise of DOMAINES REYBIER’s legal rights.

5.              To whom are my personal details sent?

The information collected by DOMAINES REYBIER is not sold to third parties.

We may share personal data collected with other entities, namely:
–        Authorized members of DOMAINES REYBIER as part of carrying out the tasks resulting from the purposes identified above;
–        Service providers and subcontractors who perform certain support functions on our behalf (IT services), including the company SERUM and Co, the company Itransition, and the company 2gezer;
–        Our legal advisors, legal officers, bailiffs, administrative authorities, courts, and regulatory bodies when necessary for the establishment, exercise, or defense of a legal claim.
We reserve the right to disclose your personal data to other parties when required or permitted by law, regulation, a court order or a regulation, or where such disclosure is necessary as part of an investigation or proceeding, whether domestic or international.

As part of our tasks and the purposes described above, we may engage any subcontractor of our choice and ensure that the subcontractor complies with its obligations under applicable regulations, particularly regarding personal data protection. DOMAINES REYBIER commits to signing a written contract with all its subcontractors, requiring them to adhere to the same data protection obligations as those of DOMAINES REYBIER. In particular, DOMAINES REYBIER undertakes to impose contractual security guarantees on its subcontractors through technical measures to protect the data and appropriate human resources. Additionally, DOMAINES REYBIER reserves the right to conduct an audit of these subcontractors to ensure compliance with the applicable regulations.

We may also share your data with third parties where you consent to or request such sharing.

6.              Is my personal data transferred outside the European Union?

As a general rule, the personal data collected is not intended to be transferred outside the European Union. This personal data is hosted on a server located within the European Union.

However, if data concerning you is transferred, for the purposes mentioned above, to companies located in countries outside the European Union, DOMAINES REYBIER will take, prior to such transfer, all necessary measures and guarantees to secure such transfers and undertakes to ensure that this transfer is covered by either:
–       An adequacy decision from the European Commission in accordance with Article 45 of the European Data Protection Regulation,
–       Standard contractual clauses issued by the European Commission or a Supervisory Authority in accordance with Article 46 of the European Data Protection Regulation,
–       Binding corporate rules approved by a competent supervisory authority pursuant to Article 47 of the European Data Protection Regulation.

If a data transfer is envisaged to countries not recognized by the European Commission as having an adequate level of protection, DOMAINES REYBIER will inform you.

7.              How are my personal details protected?

DOMAINES REYBIER is committed to ensuring the security of the data you transmit. To prevent any unauthorized access, use, modification, destruction, loss, damage or disclosure, appropriate technical and organizational measures have been taken to protect the data collected. In particular, the security of your data is ensured by limiting access to your data to authorized persons only (only members of DOMAINES REYBIER or their employees who need access for the purposes indicated above will have access).

The transmission of information via the Internet is not completely secure. Although DOMAINES REYBIER undertakes to do everything possible to protect your personal data, DOMAINES REYBIER cannot fully guarantee the security of the data you transmit.

In the event of a breach of your personal data presenting a risk to the rights and freedoms of the persons concerned, please be aware that DOMAINES REYBIER is obliged to notify the competent supervisory authority and to inform you, as soon as possible, of any breach of personal data likely to give rise to a high risk to your rights and freedoms, to enable you to take the appropriate measures.

8.              What about cookies?

When you visit the Application, a “cookie” may be placed on your computer, tablet or smartphone. Cookies record information relating to your browsing on the Application (pages viewed, date and time of viewing, etc.) and enable us to identify your preferences and respond better to your expectations and needs.

You have the option of becoming aware of the purposes for which cookies are used, as well as the option of expressing your refusal or acceptance to the use of cookies subject to the requirement of prior consent at any time by consulting the banner provided for this purpose and/or this confidentiality policy.

Type of cookies :

Cookies of functional : These cookies are essential to enable you to navigate the Application and use its functions safely.

Cookies of performance / analytics : The purpose of these cookies is to measure statistics and analyses relating to visits, browsing and interaction with the Application.

Cookies of Marketing : The purpose of these cookies is to offer you relevant and interesting content, including adverstising.

We draw your attention to the fact that the deposit of a cookie may be necessary to access certain functions of the Application.

Cookies have a maximum lifetime of 12 months. The information collected via cookies is kept for a maximum of 25 months.

9.              What are my rights?

You have the right to access your personal data, modify it, erase it, be forgotten by DOMAINES REYBIER, restrict the processing of your data, and receive the personal data you provided to DOMAINES REYBIER in a structured, commonly used, and machine-readable format.
When processing is based on your consent, you also have the right to withdraw it.
You also have the right to object, on grounds relating to your particular situation, to the processing of your data and to request the restriction of the processing concerning you.
You also have the right to lodge a complaint with the CNIL or a data protection authority of a member state of the European Union and to define post-mortem directives.

To exercise your rights, please write to DOMAINES REYBIER, Château Cos d’Estournel, 33180 SAINT-ESTEPHE, France, or send an e-mail to marketing@estournel.com.

To enable DOMAINES REYBIER to respond quickly, please provide your surname, first name and email address. If you are making this request on behalf of the person concerned, please provide us with your identity, that of the principal and the purpose of the mandate entrusted to you by the latter. A reply will then be sent to you, except in special cases, within one month (1) of receipt of the request.

10.               Conditions for amending the privacy policy

DOMAINES REYBIER reserves the right to modify this Policy at any time to ensure that users of the Application comply with current legislation.

Such changes will take effect as soon as they are published. To keep abreast of changes, please check this page regularly.

This policy, published on [26/07/2023], was updated on [03/09/2024].

11.              Contact DOMAINES REYBIER

If you have any comments or questions about this document, please write to us at:
marketing@estournel.com
Telephone number: 05.56.73.15.50
Email: marketing@estournel.com
Postal address: Château Cos d’Estournel, 33180 Saint-Estèphe, France.

For more general information on the protection of personal data, please consult the CNIL website (www.cnil.fr).