E-Label by Trusty Privacy Notice

At Trusty, we are committed to safeguarding your privacy and ensuring the protection of your personal data. This privacy notice applies specifically to our EU digital wine label solution and outlines the types of information we collect and how we use it. For further details on our digital wine label solution, please visit https://www.trusty.id/en/solutions-qr-code. Please note, this privacy notice may be updated at any time, and we encourage you to regularly check this section of our site for the most current version.

Trusty S.r.l. - Benefit Corporation

Via dei Platani, 47

65019

Pianella

Italy

The digital wine label solution is specifically designed for wine producers who must comply with EU regulations (Regulation (EU) 2021/2117 of the European Parliament and of the Council) that mandate the publication of accurate, localized information about the origin and contents of wines distributed within the EU. We offer this solution, including hosting services, to producers.

Processing of access data by Trusty

When you scan the wine label using your device, we collect information such as the date and time of the scan, your IP address, user agent (browser), device model, and operating system. This is done to help us monitor for potential abuse, as well as to track performance and ensure adequate system resources. Scan logs are anonymized and stored for a period of 5 weeks. We do not share individual scan data with the producer, only aggregated data.

Processing of location and language data

When you scan the QR code on the wine bottle, your device or browser’s language and your IP address are processed to identify your location, allowing us to display the correct wine label, including nutritional information, geographic indications, country-specific details, and local language symbols. As a data processor, we handle this data based on the instructions and for the purpose of the producer. For more details on the producer’s privacy practices, please consult their privacy notice available on the e-label.

Our e-label solution is used by producers to host and display the digital wine label to you. To ensure your privacy, after scanning the e-label, the last octet of your IP address is truncated.

Trusty is located in Italy, a country with an adequacy decision by the European Commission and which guarantees the adequate protection of personal data and the exercise of data subject rights.

Data Protection

Trusty takes data security seriously, employing both hardware and software methodologies. All connections are secured via SSL (https) and log files and databases are encrypted in transit and at rest. Access to this data is restricted to a limited number of staff based on Trusty’s access control policy.

Use of third-party providers

We rely on Amazon Web Services (AWS) to host the service. In the case of international data transfers, we ensure adequate data protection through the EU Standard Contractual Clauses or Data Privacy Framework as part of our data processing agreements. You may request a copy of these safeguards by contacting us.

No cookies or tracking

We do not use cookies or any other tracking technologies to deliver the e-label service.

Data Subject Rights

Under the GDPR, you have several rights related to your personal data:

Right of Access: You may request a copy of the personal data we hold about you in a structured, commonly used, machine-readable format.

Right to Rectification: You can request the correction of any inaccurate or incomplete data.

Right to Erasure: You may request deletion of your data in specific circumstances, such as when data is no longer necessary or processed unlawfully.

Right to Restriction: You have the right to restrict the processing of your data if you contest its accuracy, believe it is unlawful, or feel it is no longer necessary.

Right to Object: You may object to processing based on legitimate interest. Processing will cease unless we can demonstrate compelling legitimate grounds that override your rights.

Right to Lodge a Complaint: You have the right to contact a data protection authority. We encourage you to contact us first to resolve any concerns. A list of EU data protection authorities can be found here: https://edpb.europa.eu/about-edpb/about edpb/members_en

To exercise your rights, you may need to provide proof that a specific IP address was assigned to you at a particular time.

Contact Details and How to Exercise Your Rights

For any questions regarding the processing of your data or to exercise your rights, please contact us at:

Trusty S.r.l. - Benefit Corporation

By email: info@trusty.id