Privacy policy
This policy is effective from February 1st, 2024.
This Privacy Policy describes how and when The Wine Code collects, uses and shares your personal information when you use our Services. If you have any questions or comments about this Privacy Policy, please contact our data protection officer at [email protected]
The Wine Code is an international online platform facilitator (hereinafter “The Wine Code”, “we”, “or”, “us”), providing a platform that enables registered users (hereinafter “User”) to buy, rate and review wine ratings and wine information (hereinafter the “Services”) via the website or mobile application.
Our address is 614 N. DuPont Hwy, Suite 210, Dover DE 19901 and the platform is owned by The Wine Code LLC, company registration number is 32081193. The Wine Code can be contacted at [email protected]
This privacy policy applies to all use of our websites, www.TheWine Code.com, (hereinafter “Web”), and all use of our application for mobile devices (hereinafter “App”). The Web and the App together form our service offers to you (hereinafter “Platform”).
The privacy policy may be amended from time to time by us with a fair notice to you before the new privacy policy comes into force.
Data controller
The Wine Code LLC, 614 N. DuPont Hwy, Suite 210, Dover DE 19901 is the Data controller of processing personal data concerning Users.
Purpose and legal basis
We process your personal data in order for us to manage our user relation with you, including managing your account and provide you with access to use our Platform, we collect and use information about you. The processing of your personal data is performed on the legal basis of:
Fulfillment of our contractual obligations when delivering the Platform to you.
We process your ratings of wine to provide you with the opportunity to allow other users to follow your ratings, we process your personal data the legal basis of:
your freely given consent provided when signing up to the Platform.
We process your personal data to facilitate your purchase of wine via the Platform on the legal basis of:
fulfillment of our contractual obligations to facilitate your purchase of wine.
We also process your personal data to deliver and improve the Platform, and manage our business, to improve our offerings, develop new features and updates, develop personalization services and other types of service, including but not limited to develop and implement algorithms and machine learning. This processing is on the basis of:
Our legitimate interest to improve our platform and services.
We also use your personal data to display to you personalized marketing message on our Platform, to inform you about new features and updates on the Platform, and let you know about our policies and Terms and Conditions.
The processing of personal data is performed based on:
your freely given consent to receive marketing by e-mail and push notifications provided when signing up to the Platform, which you may withdraw at any time under your Profile Settings or by clicking the “Unsubscribe” button in any marketing e-mail.
If you withdraw your consent to receive personalized marketing message, will we still display marketing message to you on the Platform, but they will be of a generic nature and therefore less relevant to you.
Categories of personal data
We mainly collect the personal data that you submit to us, including your contact information, reviews and purchase history. But we also collect information in several ways from different parts of the Platform, as further detailed below, including but not limited to the way you use the Platform and if applied tracking information about your whereabouts on the Internet and technical information about your devices and location.
When signing up:
When registering via our online Platform, you provide us with certain information, including email, password, name, country of origin, preferred language. You can manage the visibility of this information under Profile Settings.
When using the Platform:
We register the information you provide when using the Platform, including ranking wines, your wine orders, your traffic on the Platform and your communication with us.
Our App will ask for your permission to enable the collection of the location of your device/you. If you have given permission to collect your device location, we will use the location to show you certain offers available around your location as personalized marketing message. Location may also be used for analytics etc.
We use cookies to enable the Platform to work, and to provide you with a personalized experience. For further information on our use of Cookies, please see 'Cookies'.
When purchasing wine from the Platform:
When you purchase products using the Platform you buy from the wineries, not The Wine Code. Consequently, The Wine Code passes the order submitted by you to the selected wineries. Please be informed that we will share your purchase information with the wineries, for them to be able to deliver the purchased wine to you. The wineries becomes an independent controller for the personal data about you received from us. As mentioned above we will also store and process your purchase information as part of our service to you.
Cookies
A cookie is a small text file stored on your computer, tablet, mobile or similar, for the purpose of recognizing your device if you visit our website again (such as login, language, font size and other settings). This makes it possible to customize the Website to your browser. A cookie may contain text, numbers or e.g. a date, but generally there are no personal data in a cookie. It is not a program and thus cannot contain a virus.
When you visit our website, we collect information about you that allows us to identify your device. The information is used to customize and improve our content on the website and to get statistical information (not personal information), so we can provide you with the best possible experience. If you choose not to accept cookies at all you may not be able to use all the functions of our website.
You can modify your browser, so cookies are not stored on your computer, tablet, mobile etc. See instructions here: http://minecookies.org/cookiehandtering. Be aware, however, that without cookies, you may not be able to use all the functions of our website.
Besides our own cookies, we use cookies from third parties, e.g. from suppliers of advertisements and analytic tools and from suppliers of social media. These third-party cookies are used for marketing purposes and for improving the functionality of the website. We use the following third party cookies:
Alexa
Heap
Impact
Steelhouse
Outreach
Notice about Google Adsense
We use Google Adsense to display ads on our Site.
Through the use of Google Adsense, we collect a variety of data about you. This includes your IP addresses, your browsing histories, and device location.
Google Adsense enables us to serve targeted ads to you.
When we serve you targeted ads, we rely on your consent.
If you wish to opt out of personalised ads, you need to check Google’s Ad Settings.
To learn more about how Google Adsense uses your data to show you personalized ads, you should visit Google’s policy for Advertisements at:
https://policies.google.com/technologies/ads?hl=en-US
Transfer of data to third countries
The Wine Code may use suppliers located outside the EU/EEA to process data on behalf of The Wine Code according to standard data protection clauses adopted by the European Commission and to The Wine Code’s performance of the contract with you.
Sharing of data
Personal data about our users is an essential part of our business. We only share your personal data as described below apart from when we share it with a third-party vendor.
We share your reviews with other Users if you have consented to us sharing your reviews with other users.
We may share personal data regarding you if we are obligated to do so by law.
Please manage your cookie/consent choices by switching the consent toggles on or off under the Purposes listed here(link to consent preferences). These cookies will be stored based on your consent choice, but may also use the personal data they collect when we or our third party partner has a legitimate interest.
Your rights as a user
As provided by the General Data Protection Regulation, you have the right to:
Access personal data regarding you. You can always access your account to review the personal data we have collected about you. You may delete and amend the data collected. You also have the right to obtain a copy of the personal data free of charge. However, we may charge a fee corresponding to administrative costs if further copies of the information are requested, or if the request is unfounded or excessive.
Ask for rectification of incorrect or inaccurate data concerning you, or to have incomplete personal data completed. You can use your access to your account to update your personal data.
Ask for erasure of personal data regarding you (under certain circumstances).
Ask for the restriction of the processing of your data (under certain circumstances).
Object to the processing of your data for marketing purposes by withdrawing your personal consent.
You can at any time withdraw your consent by deleting your profile or delete your account in the in-app settings.
When we receive a request to access, rectify, erase or port data, we may ask you for additional information in order to confirm your identity and ensure data security. You can send a request at [email protected]
Data retention and account deletion
We store your personal data for as long as your account is active.
We may also store some of your personal data to comply with our legal obligations.
You may add or update certain information to your account. When you update information, however, we often maintain a copy of the unrevised information in systems back-ups for a period of time until our backup is updated with the latest version.
You may request deactivation of your account by following the instructions at the Platform. If you deactivate your account, we do not delete your information but holds it for you until such time as you either activates your account again or delete it.
When you delete your account, we delete the data attached to your account including your username. The username will be deleted from all reviews, and the reviews will be anonymized for future viewing.
Please note that some information may remain in our records after your account has been deleted, and that we may only be able to delete this information later when updating our backups.
Security
User accounts including personal data are protected by a password for your privacy and security. You should ensure no unauthorized access to your account and personal data by choosing and protecting your password appropriately, and by signing off when finishing accessing your account. When signing in via third-party application provider your password is solely managed by such third-party.
We do our best to ensure that user accounts are kept private. However, various instances such as unauthorized entry/use, hardware or software failure, and other factors, may compromise the security of the personal data.
This Privacy Policy only governs information collected on the Platform and through our cookies.
Children's privacy
The Platform is intended for use by adults of legal drinking age in the jurisdiction in which you reside. If we receive notice or reasonably believe that someone under the legal drinking age has provided us with personal information, we will promptly delete the account and all personal information that has been provided to us.
Changes to Privacy Policy
This Privacy Policy may be amended from time to time. You will be notified before we make changes to this policy and you will be given the opportunity to review this revised policy before you choose to continue using the Platform.
We will use only use personal data in accordance with the privacy policy under which the personal data was collected unless we specifically ask for your consent to process (reuse) your personal data to a new purpose.
Questions or concerns
If you have any feedback on this Privacy Policy, you can contact us:
By mail at 614 N. DuPont Hwy, Suite 210, Dover DE 19901
By email at [email protected] with any questions and suggestions.
We will try our best to reply to your questions and resolve your concerns.
California Residents
Under California law, California residents who have an established business relationship with The Wine Code, Inc.(“The Wine Code”) may choose to opt out of The Wine Code’s disclosure of personal information about them to third parties for direct marketing purposes. If you choose to opt out at any time after granting approval, please email [email protected]
Starting January 1, 2020, under the California Consumer Privacy Act (CCPA), California Residents have the right to request the following information from The Wine Code by emailing [email protected] and The Wine Code will provide such information to you upon verification of your request:
The categories of personal information The Wine Code collects about you
The categories of sources from which your personal information is collected
The business purpose for collecting your personal information
The categories of third parties with whom The Wine Code shares your personal information
The specific pieces of personal information The Wine Code has collected about you
In addition, you can find the following information in the corresponding The Wine Code Privacy Policy Sections located on this page.
If you elect to exercise any of your rights under CCPA, The Wine Code will not deny services, provide a different price or rate for our services, or provide a different level of service to you because you exercised such rights. Under the current definition of CCPA, The Wine Code does not sell your personal information.