Privacy Policy

https://www.hlelaroyalwines.com/

https://www.hlelaroyalwines.nl/

About our privacy policy 

Hlela Royal Wines cares greatly about your privacy. We exclusively process data that we need for (improving) our services, and carefully handle all information gathered about you and your usage of our services. Your data is not shared with third parties for commercial goals. This privacy policy applies to the use of the website and the services provided by Hlela Royal Wines. The starting date for the validity of these terms and conditions is 03/05/2023, with the publication of a new version the validity of all previous versions is canceled. This privacy policy describes what information about you is collected by us, what this data is used for, and with whom and under what conditions this data could be shared with third parties. We also explain to you how we store your data, how we protect your data against misuse, and what rights you have regarding the personal data you provide us. 

If you have any questions about our privacy policy, please contact our privacy contact person, you will find the contact details at the end of our privacy policy. 

About our data processing 

Below you can read how we process your data, where we save it, what security techniques we use, and to whom the data is visible. 

Webshop software 

MijnWebwinkel 

Our webshop has been developed using MijnWebwinkel a.k.a. MyOnlineStore software. Personal data gathered with the use of our website and services is shared with MyOnlineStore. MyOnlineStore requires access to these details to offer (technical) support. They will not use this data for any other purposes. MyOnlineStore has an obligation, based on the agreement we have with them, to take necessary precautions and security measures when it comes to your personal data. MyOnlineStore uses cookies to gather technical information about the use of the software. No personal data is gathered and/or stored. MyOnlineStore maintains the right to internally share the gathered data to improve its own services. 

Webhosting 

Mijnwebwinkel 

We use the webhosting- and email services of MijnWebwinkel a.k.a. MyOnlineStore. MijnWebwinkel processes personal data on our behalf of us and will not use this data for their own purposes. This party can however collect meta-data about the use of their services. This is not personal data, however. MijnWebwinkel has taken necessary precautions and security measures, both technical and organizational, to prevent the loss, abuse, and misuse of your personal data. MijnWebwinkel is obligated to a confidentiality duty based on our agreement with them. 

E-mail and mailing lists 

TransIP & Mijnwebwinkel 

Our website uses TransIP & Mijnwebwinkel, which handles our e-mail traffic and newsletter distribution. Any confirmation e-mail or web forms you receive from our website are sent to you via the TransIP & Mijnwebwinkel servers. TransIP & Mijnwebwinkel will not use your name and email address for their own commercial purposes. At the bottom of each automated email sent from our website, you will find an ‘unsubscribe” link. When you click on the ''unsubscribe'' link at the bottom of our emails, you will no longer receive automated emails from our website. However, please note that this has a substantial effect on the functionality of our website. Your personal data will be securely sent, stored, and unlocked by TransIP & Mijnwebwinkel. TransIP & Mijnwebwinkel uses cookies and other internet technologies to track if emails are read. Additionally, TransIP & Mijnwebwinkel gathers information about you as a receiver and about the subjects of these emails, with the purpose of improving the quality of their service. TransIP & Mijnwebwinkel retains the right to use your personal information to further improve its services and, within this context, share it with third party's mailboxes and we treat our email traffic confidentially. 

Reviews

WebwinkelKeur

We collect reviews through the platform of WebwinkelKeur. If you leave a review via WebwinkelKeur, you are required to provide your name and e-mail address. WebwinkelKeur shares this information with us so we can link the review to your order. WebwinkelKeur also publishes your name on its own website. In some cases, WebwinkelKeur may contact you to comment on your review. In case we invite you to leave a review, we share your name and e-mail address with WebwinkelKeur. They only use this data for the purpose of inviting you to leave a review. WebwinkelKeur has taken appropriate technical and organisational measures to protect your personal data. WebwinkelKeur reserves the right to use third parties for the provision of services, for which we have given WebwinkelKeur permission. All of the above guarantees regarding the protection of your personal data also apply to those parts of the service for which WebwinkelKeur engages third parties.

Payment processors

Mollie 

For concluding and processing (part of) our payments in our webshop we use the payment provider Mollie. Mollie processes your name, address, and residence information. They also process payment information such as your bank account number or credit card number. Mollie has implemented fitting technical and organizational measures to protect your personal data. Mollie retains the right to use your personal (anonymized) information to further improve their services and, within this context, share it with third parties. All the aforementioned guarantees in regard to the protection of your personal data are also applicable to any services by Mollie that uses third parties. Mollie does not store your data any longer than the installments permitted by the appropriate legal grounds. 

Transport and logistics 

MyParcel 

If you place an order with us it is our responsibility to have your order successfully delivered to you. For the delivery, we use the services of MyParcel. For a successful delivery, it is important that we share your name, address, and residential details with MyParcel. MyParcel uses this information with the sole purpose to carry out the agreement of delivery. In the case of MyParcel hiring subcontractors, they will share said information with these parties. 

Accounting and Bookkeeping 

Rompslomp 

For our accounting, administration, and bookkeeping we use the services of Rompslomp. We share your name, address, residential details, and general details concerning your order/purchase. This data is used for the administration of sales invoices. Your personal data is securely sent and stored, Rompslomp has implemented fitting technical and organizational measures to protect your personal data against loss or unauthorized use. Rompslomp is obligated to a duty of confidentiality and will treat your data accordingly. Rompslomp does not use your personal data for any other purposes other than those previously described above. 

External sales channels 

Meta 

Part of our sales is done through the platform of Meta. When you place an order at Meta, Meta will share your order- and personal information with us. We use this information to further handle and conclude your order. We go about your data in a confidential manner and have implemented fitting technical and organizational measures to protect your personal data against loss or unauthorized use. 

Purpose of data processing 

The general purpose of data processing 

We use your data with the sole purpose of providing you with our services. This means that the goal of processing this data stands in direct relation to the assignment or task that you offer us. We do not use this data for (addressed) marketing purposes. If you share information with us and we use this information to - not based on a request – contact you at a later time, we will first ask for explicit consent. Your data is not shared with third parties, for any other purpose than to fulfill accountancy and administrative obligations. These third parties are all obligated to a duty of confidentiality based on the agreement we have with them, an oath, or legal obligation. 

Automatically collected data 

Information automatically gathered by our website is processed with the sole purpose of providing you with and/or to further improve our services. This information (for instance your IP address (anonymized), web browser, and operating system) is not personal information. 

Cooperation in tax and criminal investigation 

In some cases, we may be obligated by the government to a lawful duty of sharing your information with the purpose of assisting in a fiscal or criminal investigation. In such cases, we are forced to comply and assist, but will, based on lawful possibilities, offer objection. 

Retention periods 

We store your data for as long as you are a client with us. This means that we maintain and keep your client profile until you make it known to us that you no longer desire to use our services. Such a message also functions as a request to be forgotten. This also means we will maintain your data for no more than two years following your last contact or transaction unless there is a legal justification for doing so. We are required to keep invoices with your (personal) information due to relevant administrative obligations, this information is safely stored for as long as the relevant term for these obligations has not yet passed. Personnel no longer has access to your client profile and any documents made because of your assignment or task. 

Your rights 

Based on valid Dutch and European law you, as a concerned party, have certain rights when it comes to personal data that is processed by or on behalf of us. Below you may find an explanation of these rights and how you, as a concerned party, can invoke these rights. In principle to prevent abuse we only send invoices and copies of your data to e-mail addresses that you have made known to us. Should you wish to receive this data at another e-mail address or for instance via mail we will ask you to identify yourself accordingly. We maintain an administration of concluded requests, in case of a request is forgotten we will maintain an administration of anonymized data. You receive all invoices and copies of data in files that are structured in a machine-readable format Based on data classifications that we use within our system. At all times you maintain the right to lodge a complaint with Autoriteit Persoonsgegevens if you suspect that we mistreat or misuse your personal data. 

Right of inspection 

At all times you maintain the right to view the data we process that has a relation or may be reducible to your person. You may request such viewing to our contact in charge of privacy matters. You will receive a response to your request within 30 days. If your request is approved we will send you, via the e-mail address known to us, a copy of all data with an added overview of processors managing this data while also mentioning the categories under which we store this data. 

Right to rectification 

At all times you maintain the right to have the data we process that has a relation or may be reducible to your person be adjusted. You may request such an adjustment to our contact in charge of privacy matters. You will receive a response to your request within 30 days. If your request is approved we will send you, via the e-mail address known to us, a confirmation that the data has been adjusted. 

Right to restriction of processing 

At all times you maintain the right to limit the data we process that has a relation or may be reducible to your person. You may request such limits to our contact in charge of privacy matters. You will receive a response to your request within 30 days. If your request is approved we will send you, via the e-mail address known to us, a confirmation that the processing of your data is limited until you chose to cancel said limitation. 

Right of transferability 

At all times you maintain the right to request for the data we process that has a relation or may be reducible to your person be processed by a third party of choice. You may send in such a request to our contact in charge of privacy matters. You will receive a response to your request within 30 days. If your request is approved we will send you, via the e-mail address known to us, your (personal) invoices or copies of data that we, or third parties on behalf of us, have processed. It is highly likely that in such a case we can no longer offer our services to you for we can no longer guarantee the previous data safety. 

Right of objection and other rights 

At all times you maintain the right to object to the processing done by us, or on behalf of us by third parties, of your personal data. In case of such an objection, we will immediately cease all processing of your data while your objection is being investigated and handled. In case of a justified objection, we will return all invoices and/or copies of personal data that we, or third parties on behalf of us, have processed up until that point and cease processing thereafter. You also maintain the right to not be subject to automated decision-making processes or profiling. We process your data in such a way that this right does not apply. Should you believe this right applies, we ask you to contact our contact in charge of privacy matters. 

Privacy policy changes 

At all times we maintain the right to alter our privacy policy. This page however always displays the most recent version of our privacy policy. Should a new privacy policy affect how we process recently gathered data regarding your person, we will notify you via e-mail. 

Company details 

Hlela Royal Wines 

Fascinatio Boulevard 708 2909 VA Capelle aan den IJssel Nederland T (085) 203-1333 E info@hlelaroyalwines.com 

Contact privacy officer 

Igor Milovanovic