1. INTRODUCTION
This policy details the measures that we take to preserve and safeguard your privacy when you visit our Site or use our Services. It also demonstrates how we may process data in accordance with the EU General Data Protection Regulation. We are committed to protecting the privacy of all individuals in respect of whom we hold personal information. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.
2. PERSONAL DATA WE COLLECT
We collect personal data whenever you contact us and provide us with information that we are able to identify you by. This includes information about you that you give us by filling out forms on this Site, registering or by corresponding with us by phone, email or otherwise. This information may include your full name and contact details including your email address and telephone number. We do not collect or process any special categories of personal data. We do not undertake automated decision-making or profiling on the data which are provided to us. Any information that we process, including personal data, will be stored and processed within the EEA. We will not retain your personal data for longer than is necessary for the processing. In the event your personal information is transferred, stored, or processed outside of the EEA, we will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy and applicable laws.
3. HOW WE USE YOUR DATA
We rely on the following grounds to legally collect and use your personal data:
- The data are necessary to provide our Services to you;
- We are using your personal information where it is in our legitimate interests to do so;
- We have a legal obligation to process your personal information;
- You have consented to the use of your personal information by us.
We will use your personal information to enable us to provide our Services to you, including for the following purposes:
- When you make a request for further information on the Site, either through a contact form or a similar transmission, we will use the data you provide to fulfill your request for information. We will also store this information in our database and use it to follow up with you, either by telephone or through electronic communication;
- When you make a tastings appointment, we will use the data provided to and may contact you to help you get the most out of them;
- When you subscribe to our newsletter, your email address will be stored with our third-party processor, and we will use this to fulfill your subscription request;
- Where you have provided us with your details, we may contact you to notify you of changes to our Services;
- Where you have made a purchase, we will also process data for the performance of the contract, which will involve payment or transaction details being processed and shared with our payment providers;
- When you apply for our membership, you are also given the opportunity to provide us with your consent. If you choose to do so, we will use the personal data provided with your registration to let you know about our Services which we think you will find interesting;
- When you interact with our Site, we use Google Analytics to better understand your journey and help us provide improvements, Google Analytics may record your geographical location, device, internet browser, and operating system, none of which would be classified as personal data.
4. YOUR RIGHTS
You may have the right to have access to your personal information and ask us to rectify, erase and restrict the use of your personal information. You may also have rights to object to your personal information being used, to ask for the transfer of personal information you have made available to us, and to withdraw consent to the use of your personal information. You can exercise these rights directly with us by submitting a request at hello@cluelesswines.com.
Subject to applicable law, you also have the right to restrict our use of information that constitutes your personal data for marketing purposes and lodge a complaint or direct questions to the data protection authority. If you believe that Writy has not processed your personal data in accordance with the applicable legislation, you may submit a complaint to the data protection authority through the website www.cnpd.pt.
We may also process information that constitutes your personal data for direct marketing purposes, provided that you have a right to object to our use of your personal data for this purpose. You can withdraw your consent at any time by following the ‘unsubscribe’ link that is provided in emails from us or contact us by emailing hello@cluelesswines.com.
5. AGE RESTRICTION
We do not knowingly collect any kind of information from persons under the age of 18. By using browsing the Site, you hereby represent and warrant that you are at least 18 years of age — or older — as of the date of first access to the Site. We expressly do not provide services to anyone younger than 18 years old.
4. COOKIES
We use cookies and similar technologies like web beacons, pixel tags, or local shared objects (“flash cookies”), to deliver, measure, and improve our Services in various ways. A cookie is a small text file that identifies your computer on our server. Cookies in themselves do not identify the individual user, only the computer being used. Cookies are not used to gather personal information.
We use the following cookies:
Essential cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to use online forms.
Analytical cookies. These cookies allow us to recognize and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
Marketing cookies. These are used to recognize you when you return to our Site. This enables us to personalize our content for you, greet you by name, and remember your preferences. These cookies also record your visits to our Site, the pages you have visited, and the links you have followed. We will use this information to make our Site, the advertising displayed on it and communications sent more relevant to your interests.
The user may, at any time, configure his computer to accept all cookies, be notified when a cookie is issued, and reject the reception of any cookies. The way to do this depends on the web browser being used (please consult the “Help” function of your browser). We can use the information gathered to help us develop and improve our Site. The information gathered and statistics, however, do not include details that can be used to identify you. You may choose to decline all cookies on your computer, but if you do choose to decline cookies, then you may be limited to certain areas of our Site. By continuing to use our Site, you are accepting our use of these cookies that make advertising and communications more relevant to you and your interests, and further help us to improve the Site.
5. AMENDMENTS
We may change this Privacy Policy from time to time as laws, regulations, and our business evolve. We will post the changes to this page and encourage you to review our Privacy Policy periodically to stay informed. If you have any questions about us, our Site, our Services, or this Privacy Policy, please contact us by emailing hello@cluelesswines.com.
Publication date: July 12, 2023