Privacy Policy
Last updated: 09.12.2025
1. Who we are
This website is operated by Sustentu Wine Club (“we”, “us”, “our”).
We are committed to protecting your privacy and handling your personal data in a transparent and lawful way.
Contact details (data controller)
Sustentu Wine Club
Email: info@sustentuwineclub.com
[Company registration number, if applicable]
If you have any questions about this Privacy Policy or how we use your data, you can contact us using the details above.
2. What this policy covers
This Privacy Policy explains:
- What personal data we collect
- How we collect it
- How and why we use it
- Who we share it with
- How long do we keep it
- Your rights regarding your personal data
This policy applies when you:
- Visit our website
- Join our wine club
- Purchase products (such as wine boxes, vouchers or event tickets)
- Subscribe to our emails or marketing
Contact us by email, social media or other channels
3. Data we collect about you
3.1 Information you give us directly
When you use our website or services, you may provide:
- Identity Data:
- First name, last name
- Date of birth or confirmation that you are over 18 (for alcohol-related services)
- First name, last name
- Contact Data:
Third-Party secure it. Stripe (link para verem privacy terms)
- Email address
- Phone number
- Billing and delivery address
- Account Data:
- Login details (if you create an account)
- Preferences (e.g. wine style preferences, communication preferences)
- Login details (if you create an account)
- Purchase Data:
- Products you buy (wine boxes, vouchers, wine dinner tickets)
- Order history
- Voucher codes used
- Products you buy (wine boxes, vouchers, wine dinner tickets)
- Payment Data:
- Payment method details (processed securely by our payment provider – we do not store full card details)
- Payment method details (processed securely by our payment provider – we do not store full card details)
- Communications Data:
- Messages you send us by email, website forms or social media
- Feedback, reviews, survey responses
- Messages you send us by email, website forms or social media
3.2 Information we collect automatically
When you visit our website, we may automatically collect:
- Technical Data:
- IP address
- Browser type and version
- Device type, operating system
- Time zone setting
- IP address
- Usage Data:
- Pages visited
- Time spent on pages
- Clicks, navigation paths
- Referring websites
- Pages visited
This is usually collected through cookies and similar technologies (see Section 7 – Cookies & similar technologies).
3.3 Information from third parties
We may receive data about you from:
- Payment providers (e.g. Stripe, PayPal, etc.) – to confirm your payment and prevent fraud
- Email marketing platforms (e.g. MailerLite, Brevo) – to track email engagement (opens, clicks)
Analytics providers (e.g. Google Analytics) – to help us understand website performance
4. How and why we use your data
We will only use your personal data when we have a lawful basis to do so. This usually means one of the following:
- To perform a contract with you
- To comply with a legal obligation
- For our legitimate interests, where these are not overridden by your rights
- With your consent
4.1 To provide our services (Contract)
We process your data to:
- Process and deliver your orders (wine boxes, vouchers, event tickets)
- Manage your subscription or membership
- Issue and manage vouchers and booking changes
- Communicate with you about your order, subscription or event (confirmations, changes, cancellations)
Legal basis: Performance of a contract
4.2 To manage our relationship with you (Contract / Legitimate interests)
We may use your data to:
- Respond to your enquiries
- Notify you about changes to our terms, policies or services
- Ask for feedback, reviews or to take part in surveys
Legal basis: Performance of a contract and Legitimate interests (to keep you informed and improve our services)
4.3 To personalise your experience (Legitimate interests / Consent)
We may use your data to:
- Suggest wines or experiences based on your preferences
- Tailor our content and offers to what we think you’ll enjoy
Legal basis: Legitimate interests (to provide a better, more relevant experience) or Consent, where required.
4.4 Marketing communications (Consent / Legitimate interests)
We may use your data to:
- Send you news about Sustentu Wine Club, events, wine dinners and special offers
- Invite you to our founding circle or other membership opportunities
You can opt out of marketing emails at any time by clicking “unsubscribe” in the email or contacting us directly.
Legal basis:
- Consent, where required by law
- Legitimate interests, where we send marketing to existing customers about similar products/services, and where you have not opted out
4.5 To run and protect our business (Legitimate interests / Legal obligations)
We may use your data to:
- Monitor website usage and improve performance
- Prevent fraud and misuse of our services
- Keep appropriate business records
- Comply with legal and tax obligations related to alcohol sales and online trade
Legal basis: Legitimate interests and Legal obligation
5. Who we share your data with
We do not sell your personal data.
We may share your data with trusted third parties who help us run our business, such as:
- Payment processors (e.g. Stripe, PayPal)
- Email marketing platforms (e.g. MailerLite, MailChimp)
- Website hosting and IT providers
- Analytics providers (e.g. Google Analytics)
- Delivery and logistics companies (for shipping wine boxes or vouchers)
- Professional advisers (e.g. accountants, legal advisers)
- Regulators or law enforcement, where required by law
These providers act as “data processors” and only process your data in accordance with our instructions and applicable law.
If we are involved in a business sale, merger or restructuring, your data may be transferred as part of that process. In that case, we will ensure your rights continue to be protected.
6. International transfers
Some of our service providers may be based outside the UK or the European Economic Area (EEA), so your data may be transferred internationally.
Where we transfer your data outside the UK/EEA, we will ensure that appropriate safeguards are in place, such as:
- Transfers to countries deemed to provide an adequate level of protection by the UK or EU, or
- Standard contractual clauses approved by the UK or EU authorities
You can contact us for more information about specific transfers and safeguards.
7. Cookies & similar technologies
We use cookies and similar technologies to:
- Make our website work properly
- Remember your preferences
- Analyse how our website is used
- Improve performance
- Support marketing and personalised content
You can control cookies through your browser settings and, where applicable, through our cookie banner or settings tool.
For more details, please see our Cookie Policy [link or section, if separate].
8. How long do we keep your data
We keep your personal data only for as long as necessary to fulfil the purposes we collected it for, including:
- Orders and contracts: for the duration of the contract and then for as long as required by tax and accounting laws
- Marketing data: until you unsubscribe or object, or after a period of inactivity
- Account data: while you have an active account with us
We may retain certain information longer if necessary to:
- Comply with legal or regulatory obligations
- Resolve disputes
- Enforce our agreements
When we no longer need your data, we will delete or anonymise it
9. How we protect your data
We take appropriate technical and organisational measures to protect your personal data, including:
- Secure website connection (HTTPS)
- Restricted access to personal data
- Use of reputable, secure service providers
- Regular review of our data practices
However, no method of transmission over the internet or method of electronic storage is completely secure, so we cannot guarantee absolute security.
10. Children and age restrictions
Our services relate to alcoholic products and are strictly intended for adults aged 18 or over (or the legal drinking age in your country).
We do not knowingly collect personal data from anyone under 18. If we become aware that we have collected data from a minor, we will delete it as soon as reasonably possible.
11. Your rights
Depending on where you live (for example, in the UK or EU), you may have the following rights regarding your personal data:
- Right of access – to request a copy of the personal data we hold about you
- Right to rectification – to correct inaccurate or incomplete data
- Right to erasure – to request deletion of your data in certain circumstances
- Right to restriction – to restrict how we process your data in certain cases
- Right to data portability – to receive your data in a structured, commonly used format and transfer it to another controller
- Right to object – to object to processing based on legitimate interests, including profiling and direct marketing
- Right to withdraw consent – where processing is based on consent, you can withdraw it at any time
To exercise any of these rights, please contact us at: [contact@sustentu.com].
You also have the right to lodge a complaint with your local data protection authority.
In the UK, this is the Information Commissioner’s Office (ICO).
12. Third-party links
Our website may contain links to other websites, social networks or services that are not owned or controlled by us.
We are not responsible for the privacy practices of these third-party sites. We encourage you to read their privacy policies before providing any personal data.
13. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. When we do, we will change the “Last updated” date at the top.
We encourage you to review this page periodically to stay informed about how we protect your data.
14. How to contact us
If you have any questions about this Privacy Policy or how we use your personal data, please contact us at:
Sustentu Wine Club
Email: info@sustentuwineclub.com