1. Data controller
- Company name: Wine Up Consulting, S.L.
- Tax ID (CIF): B13645908
- Address: Calle Churruca, 5 — 13700 Tomelloso (Ciudad Real), Spain
- Website: www.wineup.info
- Email: hola@wineup.es
Wine Up Consulting, S.L. acts as controller of the personal data collected through the website www.wineup.info, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR), and Organic Law 3/2018 of 5 December on Personal Data Protection and guarantee of digital rights (LOPDGDD).
2. Nature of the platform and scope of this policy
www.wineup.info is a platform with a dual nature: on the one hand, it operates as a marketplace connecting users with wineries and third-party sellers; on the other, it offers proprietary training, consultancy and tasting services, as well as an informative documentary archive of tastings since 2008.
This Privacy Policy applies exclusively to processing of personal data carried out by Wine Up Consulting, S.L. as controller. Wine Up Consulting, S.L. is not responsible for processing carried out independently by wineries, producers or third-party sellers on the platform, who act as separate controllers for GDPR purposes.
3. Personal data we process
Wine Up Consulting, S.L. processes only personal data that users voluntarily provide through the channels enabled on the Website (contact forms, user registration, service contracting, newsletter subscription, etc.). In general, such data may include:
- Identification data: first and last name, email, contact telephone.
- Access data: username and password (stored in encrypted form).
- Commercial and contracting data: history of contracted services, communication preferences.
- Browsing data: IP address, browser type, pages visited (processed in anonymised form through analytics cookies, in accordance with the Cookie Policy).
Wine Up Consulting, S.L. does not collect or process special categories of personal data (health, beliefs, racial origin, etc.) through this Website.
The user warrants that the data provided are truthful, accurate and up to date, and undertakes to notify any changes affecting them. Wine Up Consulting, S.L. accepts no liability for damage arising from inaccurate data provided by the user.
4. Purposes of processing, legal bases and retention periods
The following describes the processing activities carried out by Wine Up Consulting, S.L., the legal basis for each and the retention period:
| Purpose | Legal basis | Retention | Recipients |
|---|---|---|---|
| Management of the contractual relationship (proprietary training, tasting and consultancy services) | Performance of a contract (Art. 6(1)(b) GDPR) | Duration of the contract + applicable statutory periods | Not disclosed to third parties except where legally required |
| Handling enquiries and information requests | Consent of the data subject (Art. 6(1)(a) GDPR) | Until the enquiry is resolved | Not disclosed to third parties |
| Sending commercial communications and newsletters | Express consent or legitimate interest where there is a prior relationship (Art. 6(1)(a) and (f) GDPR) | Until consent is withdrawn or objection is made | Not disclosed to third parties except email delivery platforms acting as processors |
| Management of users registered on the marketplace platform | Performance of a contract / Consent (Art. 6(1)(a) and (b) GDPR) | While the account remains active + statutory periods | Not disclosed to third parties except where legally required |
| Compliance with legal obligations (tax, accounting, LSSI) | Legal obligation (Art. 6(1)(c) GDPR) | As required by applicable law (typically 5–10 years) | Public authorities and courts where applicable |
Data will be kept for the periods indicated and, in any case, for as long as necessary to comply with applicable legal obligations (tax, commercial, civil liability, etc.), after which they will be erased or securely anonymised.
5. Recipients of the data
Wine Up Consulting, S.L. does not sell or disclose users’ personal data to third parties outside the company, except in the following cases:
- Where there is a legal obligation to disclose them to competent public authorities (tax agency, law enforcement, courts, etc.).
- To processors providing ancillary services to Wine Up Consulting, S.L. (hosting providers, email platforms, payment gateways), who act under a data processing agreement and with the safeguards required by the GDPR.
- On the marketplace platform, data strictly necessary to manage contact between the user and a third-party seller/winery may be shared with that third party to the extent indispensable for the requested service. The user accepts such disclosure by using contact features with third parties on the Portal.
Wine Up Consulting, S.L. does not carry out international transfers outside the European Economic Area (EEA), except where digital service providers operate internationally (such as Google LLC in the context of Google Analytics), in which case appropriate safeguards under the GDPR apply, including European Commission adequacy decisions or standard contractual clauses.
6. Rights of data subjects
Under the GDPR and LOPDGDD, users may exercise the following rights at any time in relation to their personal data:
- Access: obtain confirmation of what data Wine Up Consulting, S.L. processes about them.
- Rectification: correct inaccurate or incomplete data.
- Erasure: request deletion when data are no longer necessary for the purposes for which they were collected.
- Objection: object to processing, in particular for direct marketing.
- Restriction: request restriction of processing in certain circumstances.
- Portability: receive their data in a structured, commonly used, machine-readable format.
- Withdrawal of consent: where processing is based on consent, withdraw it at any time without affecting the lawfulness of processing before withdrawal.
These rights may be exercised by written request to Wine Up Consulting, S.L., accompanied by a copy of identification, through:
Email: hola@wineup.es
Postal address: Calle Churruca, 5 — 13700 Tomelloso (Ciudad Real), Spain
Wine Up Consulting, S.L. will respond to requests within one (1) month of receipt, extendable by two further months in complex cases, with prior notice to the data subject.
If the user considers that processing does not comply with applicable law, they have the right to lodge a complaint with the Spanish Data Protection Agency (www.aepd.es), the supervisory authority in Spain.
7. Commercial communications
Wine Up Consulting, S.L. will send commercial or promotional communications by electronic means only where the user has given prior express consent, or where there is a prior contractual relationship and the communications concern services similar to those contracted, in accordance with Article 21 of Law 34/2002 on Information Society Services and Electronic Commerce (LSSI).
Users may unsubscribe from commercial communications at any time, free of charge, by email to hola@wineup.es or via the unsubscribe link in each message. Objection to commercial communications will not affect the provision of other contracted services.
8. Security measures
Wine Up Consulting, S.L. has implemented appropriate technical and organisational measures to ensure the security, integrity and confidentiality of personal data, and to prevent unauthorised alteration, loss, processing or access, in line with the state of the art, the nature of the data and the risks involved.
In particular, payment data are transmitted using SSL/TLS encryption. Access passwords are stored in encrypted form and are not available in plain text to any employee or contractor of Wine Up Consulting, S.L.
Wine Up Consulting, S.L. performs periodic backups of data on its systems but does not guarantee full recovery of data deleted by the user or due to causes attributable to the user.
9. Retention of traffic data — LSSI
In accordance with Article 12 of Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI), Wine Up Consulting, S.L. retains for a maximum of twelve (12) months the traffic data necessary to identify the origin of stored data and the start of provision of the service.
Such data may be used only in the context of a criminal investigation or to safeguard public security, and will be made available to courts, tribunals or competent authorities that so require. This retention does not affect the confidentiality of communications.
10. Intellectual and industrial property
Wine Up Consulting, S.L. holds all intellectual and industrial property rights in the content of the website www.wineup.info, including texts, images, designs, databases, software and other proprietary elements. Reproduction, distribution, modification or public communication without prior written authorisation is expressly prohibited.
The user undertakes to respect the intellectual property rights of Wine Up Consulting, S.L. and third parties, and not to use Website content for purposes other than strictly private ones. In particular, the following is prohibited:
- Publishing or transmitting violent, unlawful, defamatory, obscene, xenophobic content or content that infringes third-party rights.
- Collecting or using other users’ personal data without their express consent.
- Using corporate domain email to send unsolicited bulk communications (spam).
- Unauthorized access to, modification or viewing of systems, configurations or files on Wine Up Consulting, S.L.’s servers.
The user will bear any civil or criminal liability arising from breach of the above, and shall indemnify Wine Up Consulting, S.L. for all damage, costs and expenses —including legal defence fees— resulting from third-party claims attributable to their conduct.
11. Changes to this privacy policy
Wine Up Consulting, S.L. reserves the right to modify this Privacy Policy at any time, in particular when required by applicable data protection law. Any material change will be communicated to users via the Website before it takes effect. Users are encouraged to review this document periodically.
