Privacy Notice

1. What is this Privacy Notice about?
2. Who is the controller for processing your data?
3. What data do we process?
4. For what purposes do we process your data?
5. On what basis do we process your data?
6. With whom do we share your data?
7. Is your personal data disclosed abroad?
8. How long do we process your data?
9. How do we protect your data?
10. What are your rights?
11. Do we use online tracking and online advertising technology?
12. What data do we process on our social network pages?
13. Can this Privacy Notice be updated?

1.What is this Privacy Notice about?

Midi Vins SA; Château Laquirou (also “we”, “us”) collects and processes personal data
that concern you but also other individuals (“third parties”). We use the word “data”
here interchangeably with “personal data”.

In this Privacy Notice, we describe what we do with your data when you use (“website”), obtain services or products from us, interact
with us in relation to a contract, communicate with us or otherwise deal with us.

appropriate, we will provide a just-in-time notice to cover any additional processing
activities not mentioned in this Privacy Notice.
If you disclose data to us or share data with us about other individuals, such as family
members, co-workers, etc., we assume that you are authorised to do so, and that the
relevant data is accurate. When you share data about others with us, you confirm that.

Please make sure that these individuals have been informed about this Privacy Notice.
This Privacy Notice is aligned with the EU General Data Protection Regulation (“GDPR”),
the Swiss Data Protection Act (“DPA”) and the revised Swiss Data Protection (“revDPA”).

However, the application of these laws depends on each individual case.

2. Who is the controller for processing your data?

Midi Vins SA, Zürich is the controller for Midi Vins SA & GFA Château Laquirou
processing under this Privacy Notice, unless we tell you otherwise in an individual case,
for example, in additional privacy notices, on a form or in a contract.

You may contact us for data protection concerns and to exercise your rights under
Section 11 as follows:

Midi Vins SA
Limmatquai 28
CH-8001 Zürich

3. What data do we process?

We process various categories of data about you. The main categories of data are the

 Technical data: When you use our website or other online services (e.g., free Wi-
Fi), we collect the IP address of your terminal device and other technical data to
ensure the functionality and security of these services. This data includes logs with
records of the use of our systems. We generally keep technical data for 12
months. To ensure the functionality of these services, we may also assign an
individual code to you or your terminal device (e.g., as a cookie – see Section 11).

Technical data, as such, does not permit us to draw conclusions about your
identity. However, technical data may be linked with other categories of data (and
potentially with your person) in relation to user accounts, registrations, access
controls or the performance of a contract.

Registration data: Certain products and services (e.g., the login areas of our
website, newsletters, free Wi-Fi access, etc.) can only be used with a user account
or registration, which can happen directly with us or through our third-party login
service providers. In this regard, you must provide us with certain data, and we
collect data about the use of the product or service. Registration data may be
required in relation to access control to certain facilities. We generally keep
registration data for 12 months from the date the use of the service ceases or the
user account is closed.

 Communication data: When you contact us via the contact form, by e-mail,
telephone, letter or other means of communication, we collect the data
exchanged between you and us, including your contact details and the metadata
of the communication. If we have to determine your identity, for example, in
relation to you checking in to one of our rental apartments, we collect data to
identify you (e.g., a copy of your passport). We generally keep this data for 24
months from the last exchange between us. This period may be longer where
required for evidentiary purposes, to comply with legal or contractual
requirements, or for technical reasons. E-mails in personal mailboxes and written
correspondence are generally kept for at least 5 years.

Master data: By master data, we mean the basic data that we need, in addition to
contract data (see below), for the performance of our contractual and other
business relationships or for marketing and promotional purposes, such as name
and contact details, and information about, for example, your bank details, your
date of birth, customer history and address. We process your master data if you
are a customer of ours or we wish to address you for our own purposes or for the
purposes of a contractual partner (for example, as part of marketing and
advertising, with invitations to events, with vouchers, with newsletters, etc.). We
receive master data from you (for example, when you make a purchase or as part
of a registration). We generally keep master data for 10 years from the last
exchange between us or the end of the contract. This period may be longer if
required for evidentiary purposes, to comply with legal or contractual
requirements, or for technical reasons. In the case of contact solely for marketing
and advertising purposes, the retention period is shorter and usually no more than
5 years from the last contact.

Contract data: This means data that is collected in relation to the conclusion or
performance of a contract, for example, information about the contracts and the
services provided or to be provided. We collect this data from you. We generally
keep this data for 10 years from the last contract activity or the end of the
contract. This period may be longer where necessary for evidentiary purposes, to
comply with legal or contractual requirements, or for technical reasons.
 Behavioural and preference data: Depending on our relationship with you, we try
to get to know you better and tailor our products, services and offers to you. For
this purpose, we collect and process data about your behaviour and preferences.
We do this by evaluating information about your behaviour in our domain, and we
may also supplement this information with third-party information, including from
public sources. Based on this data, we can, for example, determine the likelihood
that you will use certain services or behave in a certain way. The data processed
for this purpose is already known to us (e.g., where and when you use our
services), or we collect it by recording your behaviour (e.g., how you navigate our
website). We anonymise or delete this data when it is no longer relevant for the
purposes pursued, which may be – depending on the nature of the data –
between 2-3 weeks and 24 months (for product and service preferences). This
period may be longer where necessary for evidentiary purposes, to comply with
legal or contractual requirements, or for technical reasons. We describe how
tracking works on our website in Section 11 .

Much of the data set out in this Section 3 is provided to us by you (e.g., through forms,
when you communicate with us, in relation to contracts, when you use the website, etc.).
You are not obliged or required to disclose data to us except in certain cases, for example,
within the framework of binding protection plans (legal obligations). If you wish to enter
into contracts with us or use our services, you must also provide us with certain data, in
particular master data, contract data and registration data, as part of your contractual

obligation under the relevant contract. When using our website, the processing of
technical data cannot be avoided. If you wish to gain access to certain systems or
buildings, you must also provide us with registration data. However, in the case of
behavioural and preference data, you generally have the option of objecting or not giving
As far as it is not unlawful, we also collect data from public sources (e.g., the internet,
including social media) or receive data from public authorities and other third parties
(e.g., credit agencies, contractual partners, internet analytics services, etc.).

4. For what purposes do we process your data?

We process your data for the purposes explained below. Further information for online
services is set out in Sections 11 and 12 .

These purposes and their objectives represent
the interests of us and potentially of third parties. You can find further information on the
legal basis of our processing in Section 5 .

We process your data for purposes related to communication with you, in particular in
relation to responding to enquiries and the exercise of your rights (Section 1 0) and to
enable us to contact you in case of queries. For this purpose, we use, in particular,
communication data and master data, and registration data in relation to offers and
services that you use. We keep this data to document our communication with you for
training purposes, for quality assurance and for follow-up inquiries.
We process data for the conclusion, administration and performance of contractual

We process data for marketing purposes and relationship management, for example, to
send our customers and other contractual partners personalised advertising for products
and services from us and from third parties. This may take the form of newsletters and
other regular contact (electronically, by e-mail or by telephone), through other channels
for which we have contact information from you, but also as part of individual marketing
campaigns (e.g., events, special offers, last-minute deals, etc.) and may also include free
services (e.g., invitations, vouchers, etc.). You can object to such contact at any time (see
the end of this Section 4 ) or refuse or withdraw consent to be contacted for marketing
purposes. With your consent, we can target our online advertising on the internet more
specifically to you (see Section 1 1).
We also process your data for market research, to improve our services and operations,
and for product development.
We may also process your data for security and access control purposes.

We process personal data to comply with laws, directives and recommendations from
authorities and internal regulations (“compliance”).
We may process your data for other purposes, such as part of our internal processes and

5. On what basis do we process your data?

Where we ask for your consent for certain processing activities (e.g., for the processing of
sensitive personal data, for marketing mailings, for advertising management and
behaviour analysis on the website), we will inform you separately about the relevant
processing purposes. You may withdraw your consent at any time with effect for the
future by providing us with written notice (by post) or, unless otherwise noted or agreed,
by sending an e-mail to us; see our contact details in Section 2 . For withdrawing consent
for online tracking, see Section 1 1. Where you have a user account, you may also
withdraw consent or contact us through the relevant website or other service, as
applicable. Once we have received notification of withdrawal of consent, we will no
longer process your information for the purpose(s) you consented to unless we have
another legal basis to do so. Withdrawal of consent does not, however, affect the
lawfulness of processing based on your consent prior to withdrawal.

Where we do not ask for consent for processing, the processing of your personal data
relies on the requirement of the processing for initiating or performing a contract with
you (or the entity you represent) or a third-party legitimate interest, in particular in
pursuing the purposes and objectives set out in Section 4 and in implementing related
measures. Our legitimate interests also include compliance with legal regulations insofar
as this is not already recognised as a legal basis by applicable data protection law (e.g., in
the case of the GDPR, the laws in the EEA and, in the case of the DPA, Swiss law). This also
includes the marketing of our products and services, the interest in better understanding
our markets and in managing and further developing our company, including its
operations, safely and efficiently.

6. With whom do we share your data?

In relation to our contracts, the website, our services and products, our legal obligations
or otherwise with protecting our legitimate interests and the other purposes set out in
Section 4 , we may disclose your personal data to third parties, in particular to the
following categories of recipients:

 Service providers: We work with service providers in Switzerland and abroad who
process your data on our behalf or as joint controllers with us or who receive data
about you from us as separate controllers (e.g., IT providers, the City of Narbonne
(registration forms, tourism tax for apartment bookings), shipping companies). For
the website service providers, see Section 1 1. Our key IT service providers are
Microsoft, Swisscom and Hostpoint.

 Contractual partners including customers: This refers to customers (e.g., service
recipients) and our other contractual partners, as this data disclosure results from
these contracts. If you work for one of these contractual partners, we may also
disclose data about you to that partner in this regard. These recipients also include
contractual partners with whom we cooperate.

 Authorities: We may disclose personal data to agencies, courts and other
authorities in Switzerland and abroad if we are legally obliged or entitled to make
such disclosures or if it appears necessary to protect our interests. These
authorities are responsible for processing data about you that they receive from
All these categories of recipients may involve third parties so that your data may also be
disclosed to them. We can restrict the processing by certain third parties (e.g., IT
providers) but not by others (e.g., authorities, banks, etc.).

7. Is your personal data disclosed abroad?

As explained in Section 6, we disclose data to other parties. These are not all located in
Switzerland. Therefore, your data may be processed in Europe and, in exceptional cases,
in any country in the world.

If a recipient is located in a country without adequate statutory data protection, we
require the recipient to undertake to comply with data protection (for this purpose, we
use the revised European Commission’s standard contractual clauses, which can be
accessed at, unless the recipient is
subject to a legally accepted set of rules to ensure data protection and unless we cannot
rely on an exception. An exception may apply, for example, in case of legal proceedings
abroad, but also in cases of overriding public interest or if the performance of a contract
requires disclosure, if you have consented or if data has been made available generally by
you and you have not objected to the processing.

8. How long do we process your data?

We process your data for as long as our processing purposes, the legal retention periods
and our legitimate interests in documentation and keeping evidence require it or storage
is a technical requirement. You will find further information on the respective storage and
processing periods for the individual data categories in Section 3 and for cookies in
Section 1 1. If there are no contrary legal or contractual obligations, we will delete or
anonymise your data once the storage or processing period has expired as part of our
usual processes.

9. How do we protect your data?

We take appropriate security measures to maintain the required security of your personal
data and ensure its confidentiality, integrity and availability, and protect it against
unauthorised or unlawful processing, and mitigate the risk of loss, accidental alteration,
unauthorised disclosure or access.

10. What are your rights?

You have certain rights in connection with our data processing. In accordance with
applicable law, you may, in particular, request information about the processing of your
personal data, have incorrect personal data corrected, request the deletion of personal
data, object to data processing, request the release of certain personal data in a standard
electronic format or its transfer to other persons responsible, or revoke consent with
effect for the future, insofar as our processing is based on your consent.
If you wish to exercise the above-mentioned rights in relation to us, please contact us in
writing, at our premises or, unless otherwise specified or agreed, by e-mail; you will find
our contact details in Section 2 . For us to be able to prevent misuse, we need to identify
you (e.g., by means of a copy of your passport if identification is not possible otherwise).
You also have these rights in relation to other parties that cooperate with us as separate
controllers – please contact them directly if you wish to exercise your rights in relation to
their processing. You will find information on our key partners and service providers in
Section 6 and additional information in Section 11 .
Please note that conditions, exceptions or restrictions apply to these rights under
applicable data protection law (e.g., to protect third parties or trade secrets). We will
inform you accordingly, where applicable.

11. Do we use online tracking and online advertising technology?

We use various techniques on our website that allow us and third parties engaged by us
to recognise you when you use our website and possibly to track you across several visits.
This Section covers this.

In essence, we wish to distinguish access by you (through your system) from access by
other users, so that we can ensure the functionality of the website and carry out analysis
and personalisation. We do not intend to determine your identity, even if that is possible
where we or third parties engaged by us can identify you by combination with
registration data. However, even without registration data, the technologies we use are
designed in such a way that you are recognised as an individual visitor each time you
access the website, for example, by our server (or third-party servers) that assign a specific identification number to you or by your browser (“cookie”).

We use these technologies on our website and may allow certain third parties to do so as
well. You can also set your browser to block or deceive certain types of cookies or
alternative technologies or to delete existing cookies. You can also add software to your
browser that blocks certain third-party tracking. You can find more information on the
help pages of your browser (usually under “Privacy”) or the websites of the third parties
listed below.

We distinguish between the following categories of “cookies” (including other
technologies such as fingerprinting):

– Necessary cookies: Some cookies are necessary for the functioning of the website
or for certain features. For example, they ensure you can move between pages
without losing information entered in a form. They also ensure that you stay logged
in. These cookies exist temporarily only (“session cookies”). If you block them, the

website may not work correctly. Other cookies are necessary for the server to store
options or information (which you have entered) beyond a session (i.e., a visit to the
website) if you use this function (e.g., language settings, consent, automatic login
functionality, etc.). These cookies have an expiration date of up to 24 months.

– Performance cookies: To optimise our website and related offers and better adapt
them to the needs of users, we use cookies to record and analyse the use of our
website, potentially beyond one session. We use third-party analytics services for
this purpose. These are listed below. Performance cookies also have an expiration
date of up to 24 months. Details can be found on the websites of the third-party

– In addition, we sometimes use social media plug-ins, which are small pieces of
software that create a connection between your visit to our website and a third-
party provider. The social media plug-in tells the third-party provider that you have
visited our website and may send the third-party provider cookies that they have
previously placed on your web browser. For more information on how these third-
party providers use your personal data collected through their social media plug-ins,
please refer to their respective privacy statements.
We currently use services following providers and advertising partners (where they use
data from you or the cookies set on your computer for advertising purposes):
– Google Analytics:
Provider: Google Ireland Ltd., Ireland
Data protection advice:

– MailChimp:
Provider: MailChimp, USA
Data protection advice:

– WooCommerce :
Provider: WooCommerce, San Francisco, CA, California
Data protection advice:

– Instagram
Provider: Meta Platforms Ireland Ltd., Ireland
Data protection advice:

– Facebook
Provider: Meta Platforms Ireland Ltd., Ireland
Data protection advice:

– LinkedIn
– Provider: LinkedIn Ireland Unlimited Company, Ireland

Data protection advice:

12. What data do we process on our social network pages?rken?

We may operate pages and other online presences (“fan pages”, “channels”, “profiles”,
etc.) on social networks and other platforms operated by third parties and collect the
data about you described in Section 3 and below. We receive this data from you and from
the platforms when you interact with us through our online presence (e.g., when you
communicate with us, comment on our content or visit us online). At the same time, the
platforms analyse your use of our online presence and combine this data with other data
they have about you (e.g., about your behaviour and preferences). They also process this
data for their own purposes, particularly for marketing and market research purposes
(e.g., to personalise advertising) and to manage their platforms (e.g., what content they
show you).

We process this data for the purposes set out in Section 4 , in particular for
communication, for marketing purposes (including advertising on these platforms – see
Section 11 ) and for market research. You will find information about the applicable legal
basis in Section 5 . For example, we may disseminate content published by you (e.g.,
comments on an announcement) as part of our advertising on the platform or elsewhere.

We or the operators of the platforms may also delete or restrict content from or about
you in accordance with their terms of use (e.g., inappropriate comments).

For further information on the processing of the platform operators, please refer to the
privacy information of the relevant platforms. There, you can also find out about the
countries where they process your data, your rights of access and erasure of data and
other data subjects’ rights and how you can exercise them or obtain further information.

13. Can this Privacy Notice be updated?

This Privacy Notice is not part of a contract with you. We can change this Privacy Notice at
any time. The version published on this website is the current version.

Last updated: 27 September 2023