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Politique de Confidentialité

Politique de Confidentialité

Privacy Policy

Version - 0.1 / DigitalWiMCommunication | Dated: 25 May 2018

    1. Scope
    2. Glossary of Terms
    3. What information do we collect about you and how?
    4. Why we process personal data and on what basis?
    5. How do we use cookies, analysis, tracking tools and social media registrations
    6. Why and who do we share your personal data with?
    7. Transferring your information outside of Europe
    8. How do we protect your data?
    9. Profiling
    10. How long will we hold your data for?
    11. Access to your information, correction, portability and deletion
    12. Other websites
    13. Complaints
    14. Changes to our Privacy Policy
    15. How to contact us


1. Scope

In this document, “we” and “our” refers to Wine in Moderation – Art de Vivre AISBL (hereafter called WiM), an international NGO registered under Belgian Law (n° BCE 0841.650.885) and located Avenue des Arts, 43, 1040 Brussels; Belgium.

Wine in Moderation–Art de Vivre is an international programme of the wine sector to inspire healthy lifestyles and well-being, and to contribute to the reduction of alcohol related harm. The WiM Association is the international association, founded by wine sector associations and leading wine companies, that centrally coordinates the Wine in Moderation Programme and expands its reach and impact throughout the world.

This Privacy Policy sets out how we collect, handle, process and store certain information we collect about you when you use this web­site and our wider services. WiM is committed to handle personal data in compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR - EU Regulation 2016/679).

In this privacy policy, we describe what personal data we collect and process, for what purposes, on what legal grounds, with whom such data is shared, how long such data is retained, whether we transfer it to third parties inside or outside the European Economic Area (EEA) and what your rights are as data subjects.


2. Glossary of terms

What is personal data?

Personal data relates to any information about a natural person that makes you identifiable. This may include (but is not limited to):

  • Names and contact information i.e. emails and telephone numbers
  • E-mail addresses
  • Company details & Job title

What is sensitive personal data?

Some data is more sensitive than other and needs to be protected more carefully. For example:

  • Medical conditions;
  • Religious or philosophical beliefs and political opinions;
  • Racial or ethnic origin;
  • Criminal convictions;
  • Biometric data (e.g. photo in an electronic passport);
  • Genetic data.

What is a Data Controller?

For general data protection regulation purposes, the “data controller” refers to the person or organisation which decides the purposes for which and the way in which any personal data is processed.

The data controller is WiM, that can be reached by contacting [email protected].

What is a Data Processor?

A “data processor” is a person or organisation which processes personal data for and on behalf of the controller.

What is Data Processing?

Data processing is any operation or set of operations performed upon personal data, or sets of it, be it by au­tomated systems or not. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organising, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by trans­mission, disseminating or making available, aligning or combining, restricting, erasure or destruction.

What is an IP address?

An Internet Protocol, (“IP”) address, is a unique numerical address assigned to a computer as it logs on to the internet. We use your IP address to diagnose problems with our servers and/or software, to administer our services, and to gather demographic information.


3. What personal data do we collect?

WiM may collect certain personal data to the extent necessary to achieve the purposes outlined in this policy. In most instances, we collect personal data from the data subjects directly, as follows:

A. Information when you browse through our website

When you visit our website, we may process information such as the region you are visiting us from, your operating system and browser, your user behaviour on our site during the current session, and whether you have visited us before. For this, we use cookies.

B. When you register to our newsletter

When you wish to receive our latest news, you have to subscribe online where we will request certain personal information such as name and surname, email, type of economic activity and country.

C. When you become a WiM Supporter

When registering or reporting on their Wine in Moderation activities, WiM Supporters may be asked for the personal data of the contact person / legal representative. This personal data includes your name, email address and telephone number.

D. When you contact us through our “Contact” webpage

If you contact us, we will store your data in connection with this particular inquiry, such as contact details, information on your request, and log data. In some cases, we may ask you to provide us with additional information to handle your inquiry.


4. Why we process personal data and on what basis?

At WiM we take your privacy seriously and we process your data for one or more of the following purposes:

  • To improve the performance and impact of the Wine in Moderation programme
  • To establish and carry out a cooperation in the framework of the Wine in Moderation programme (e.g. WiM Supporters)
  • To inform about the latest news and activities of Wine in Moderation;
  • To invite you to events and actions;
  • To respond to specific requests for information;
  • To participate to surveys, reports, etc.;
  • To incorporate users’ personal data into one or more automated digital tools to provide solutions such as newsletters, polls, events, etc. (Mailchimp, Survey Monkey, Eventbrite, SendGrid, etc.);
  • To analyse, adapt and improve the content of the website;
  • For administrative purposes;

5. How do we use cookies, analysis, tracking tools and social media registrations

When you use our tools, cookies are uploaded to your browser. Cookies may be used to identify your browser so that our website is displayed correctly. We also use cookies at various points on our website to analyse the use of our website and thereby optimise it, such as your language preferences.

In addition to our own systems, we also use the following third-party tools for communication purposes and to make your experience with the Wine in Moderation programme more user-friendly.


Cookies are text files put on your computer to collect standard internet log information and visitor behaviour information. This information is then used to track visitor use of the website and to create statistical reports on website activity.

WiM uses cookies to improve your browsing experience (language preferences, social media, google analytics, etc.). Cookies are stored on your browser memory, locally on your computer.

When a user accepts WiM cookies, this consent will be valid for 90 days, after which the cookie files are automatically deleted, and the system will ask for your consent again.

The site includes a cookie policy and requests user consent.

You can set your browser not to accept cookies, please refer to your browser’s information to learn more about cookies deletion or see hereunder.

You can disable Cookies in your web browser. However, this may disable all cookies used by your browser, including those from other websites, which may cause certain settings or information to be altered or lost. Disabling cookies may change your browsing experience on the Site, or may make navigating around the Site more difficult.

You can disable cookies in your web browser as follows:

Microsoft Internet Explorer 8.0 and above:

  1. Select Tools > Internet Options.
  2. Click on the General tab and then the Delete... button.
  3. Make sure to uncheck Preserve Favorites website data and check both Temporary Internet Files and Cookies then click Delete.


  1. In the browser bar, enter: chrome://settings/clearBrowserData
  2. At the top of the "Clear browsing data" window, click “Advanced”.
  3. Select the following:
    1. Browsing history.
    2. Download history.
    3. Cookies and other site data.
    4. Cached images and files
      From the "Time range" drop-down menu, you can choose the period of time for which you want to clear cached information. To clear your entire cache, select All time.
    5. Click “CLEAR DATA”.
    6. Exit/quit all browser windows and re-open the browser


  1. From the History menu, select Clear Recent History.
  2. If the menu bar is hidden, press Alt to make it visible.
  3. From the Time range to clear: drop-down menu, select the desired range; to clear your entire cache, select Everything.
  4. Next to "Details", click the down arrow to choose which elements of the history to clear; to clear your entire cache, select all items.
  5. Click Clear Now.
  6. Exit/quit all browser windows and re-open the browser.

Microsoft Egde:

  1. In the top right, click the Hub icon (looks like star with three horizontal lines).
  2. Click the History icon (looks like a clock), and then select Clear all history.
  3. Select Browsing history, then Cookies and saved website data, and then Cached data and files. Click Clear.
  4. After the "All Clear!" message appears, exit/quit all browser windows and re-open the browser.

Safari 8 and later:

  1. From the Safari menu, select Clear History... or Clear History and Website Data....
  2. Select the desired time range, and then click Clear History.
  3. Go to Safari > Quit Safari or press Command-Q to exit the browser completely.
  • Language cookies

The user’s consent to the language cookie will live for 30 days. If the user comes back during these 30 days, the cookie will be extended for another 30 days and so on. This cookie is used for user redirection to a different language than the default English.

  • Google Analytics

Google Analytics is a third-party information storage system that records information about the pages you visit, the length of time you were on specific pages and the website in general, how you arrived on the site and what you clicked on when you were there.

We therefore use Google Analytics to track visitor use of the website and to create statistical reports on website activity.

For these purposes, Google collects information related to web traffic and the number of visitors. The Data (Page URL address, IP address & device information) is kept locally on the memory of the user's browser and may be transferred to Google's servers.

These cookies do not store any personal information about you e.g. name, address, etc. and we do not share the data with any third party. You can view Google’s privacy policy: http://www.google.com/intl/en/policies/privacy/

  • Social media buttons

We use LinkedIn, Facebook, Twitter and Google Plus social media buttons to help you share our content on these social media. The icons are simple redirect links, and do not carry any tracking code. We do not store and process any personal data.


6. Why and who do we share your personal data with?

We share and transmit your personal data for successfully delivering Wine in Moderation services based on your consent, legitimate interest or contractual agreement.

Where this is the case we will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as outlined in this policy.

We may share your data with 3rd parties such as:

  • Employees and technical experts (internal and external): for the performance of the services;
  • Subcontractors and service providers (including IT, software, logistics, etc.): We use IT infrastructure including cloud-based servers, networks, and software solutions of national and international companies to provide our services, such as:
      • McArnolds: McArnolds is the data processor responsible for the development of the Wine in Moderation website. As such, McArnolds has access to personal data processed through the website (contact log, newsletter subscription, WiM Supporters’ registration, etc.).
      • Mailchimp: we use this platform to send invitations to events, and general communications.
      • SurveyMonkey: we use this platform to conduct surveys and gather information on the Wine in Moderation Programme.
      • SendGrid: when submitting forms on our website we use this third-party software provider for automated data collection and processing purposes (press releases, newsletters, contact us forms, registrations procedures for WiM Supporters, etc.)
      • Eventbrite: we use this platform to manage events organisations, etc.
      • Wine in Moderation Actors: The sharing of data between WiM and other actors of the Wine in Moderation programme (e.g. national coordinators, ambassador companies, associated partners, observers, supporters) is necessary for the successful execution of the Wine in Moderation programme.


7. Transferring your information outside of Europe

As part of the services offered to you through this website and the Wine in Moderation programme development and functioning, the information which you give to us may be transferred to countries outside the European Economic Area (“EEA”). For example, some of our members, data processors and sub-contractors may be located outside of the EEA.

Where this is the case we will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as outlined in this policy.

8. How do we protect your data?

When you give us personal information, we take steps to make sure that it’s treated securely.

Non-sensitive details (your email address etc.) are sent normally over the Internet, and this can never be gua­ranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot gua­rantee the security of any information you transmit to us, and you do so at your own risk.

Once we receive your information, we make our best effort to ensure its security on our systems. Such measures include anti-virus protection, secure data transfer between our online communication tools, our applications and backends, via SSL (Secure Socket Layer) encryption procedure.

Where we have given (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

9. Profiling

We do not analyse your personal information to create a profile of your interests and preferences.

You have a right at any time to stop us from contacting you.

To opt out please email: privacy@wineinmodera­tion.com.


10. How long will we hold your data for?

WiM will only keep your personal data for the time that is strictly necessary to achieve the purpose(s) for which they were collected, unless applicable law requires us to hold on to the data for an extra period of time after the end of said contract or project.

You may request us to delete your personal data at any time (see your rights under 11). However, this might prevent us from keeping you informed about WiM activities.

Your data will be kept according to the following principles:


  • External Communication (newsletters, press releases, etc.): We will hold your data for a period of 10 years with a review every 5 year. You will have the opportunity to opt out, update or delete data at any point. The procedure to follow is set out in this policy.
  • “Contact us” pageShould you contact us through the “Contact us” webpage, we will make sure to get back to you as soon as possible. Your data will be deleted after 30 days. If we think that we should need to keep your contact details for future cooperation, we will inform you by email and ask you for your consent to keep your contact information. If you refuse, your contact details will be deleted immediately.
  • Events: The data requested for the good organisation of an event will be kept during and for no more than 3 months after the end of the event. Only Users who have given consent to receive further information will continue to receive communications from WiM.
  • WiM Supporters: Your information will be kept for as long as you are part of the programme and for an additional period of 1 year after the end of your participation to the programme. In case you have not finalised your application to join the Wine in Moderation programme as a WiM Supporter, your data will be kept for 10 days and then permanently deleted. Should you then decide to register again, you will have to submit a new application form.

11. Access to your information, correction, portability and deletion

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all your personal information, please email: [email protected]. We will respond to your request within one month of receipt of the request.

We want to make sure your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate by sending an e-mail to [email protected].

Objections to processing of personal data

It is your right to lodge an objection to the processing of your personal data.

Your Right to be Forgotten

Should you wish for us to completely delete all information that we hold about you, please email: [email protected].


12. Other websites

Please note that this privacy policy only applies to our website, should you link to other websites, their own privacy policies apply.


13. Complaints

If you feel that your personal data has been processed in a way that does not meet the GDPR, you have a specific right to lodge a complaint with the relevant supervisory authority. The supervisory authority will then tell you of the progress and outcome of your complaint. The supervisory authority in Belgium is the Commission for the protection of privacy.

14. Changes to our Privacy Policy

We keep our privacy policy under regular review and we will place any updates on this web page. This privacy policy was last updated on 25 May 2018 and the Version number is 0.1 in line with the new GDPR guidelines.

15. How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you:

  • By email: [email protected]
  • Or write us at: Wine in Moderation, Avenue des Arts, 43, 1040 Brussels, Belgium