Privacy Policy

Our Commitment to Privacy

At Wine Cooler Online, your privacy is our priority. We only process data needed to enhance our services and treat the information we collect about you and your use of our services with utmost care. Your data will never be shared with third parties for commercial purposes.

This privacy policy applies to the use of our website and the services provided by Wine Cooler Online. The conditions are effective from 01/11/2020. Upon the release of a new version, previous versions will be invalidated. This privacy policy outlines the information we collect about you, its usage, and under what circumstances it may be shared with third parties. We also describe how we store your data, protect it from misuse, and the rights you have concerning the personal data you share with us.

For any questions about our privacy policy, please contact our privacy liaison, whose contact details can be found at the end of this policy.

Understanding Data Processing

In this section, we discuss how we process your data, where it is stored, the security measures we employ, and who has access to your data.

Web Store Software and Web Hosting

WooCommerce

Our online store is powered by WooCommerce software and a web hosting provider. The personal data you provide for our services will be shared with WooCommerce. They have access to your data to offer us (technical) support but will never use your data for any other purpose. They are contractually obligated to implement suitable security measures, including SSL encryption and a robust password policy. Regular backups are made to prevent data loss.

Web Hosting

Wine Cooler Online acquires web hosting and email services from one or more third parties. These third parties process personal data on behalf of Wine Cooler Online and do not use your data for their purposes. However, they may gather metadata about the use of the services, which is not considered personal data. All parties implement appropriate technical and organizational measures to prevent the loss or unauthorized use of your personal data, and they are bound to confidentiality by our contractual agreements.

Email and Mailing Lists

Our website employs a third party to manage email traffic from our website and distribute newsletters. All confirmation emails you receive from our website and web forms are sent through their servers. They will never use your name or email address for their purposes. An “unsubscribe” link is included at the bottom of every automated email from our website. Clicking this will prevent you from receiving future emails from our website, which may significantly reduce the website’s functionality. Your personal data is securely stored by the third party we partner with. They use cookies and other internet tools to track whether emails are opened and read. They reserve the right to use your data to improve their services and share information with third parties in this context.

Payment Partners

We use a payment partner to handle (part of) the payments in our online store. This payment partner processes your name, address, and location information, as well as payment details like your bank account or credit card number. Our partner implements appropriate technical and organizational measures to protect your personal data but reserves the right to use your data to improve their services and share (anonymized) data with third parties in this context.

All the aforementioned safeguards regarding the protection of your personal data also apply to the aspects of their services that involve third parties. Your data will not be retained longer than legally permitted.

Shipping and Logistics

When you place an order with us, we are responsible for delivering your package. We use various carriers for these deliveries, so it is necessary to share your name, address, and location information with the carrier. The carrier uses this information solely to fulfill their contractual agreement with us. If the carrier employs subcontractors, they will also share your data with these parties.

Invoicing and Accounting

Wine Cooler Online utilizes administration software and an administrative office to manage our accounting and administration.

We share your name, address, location details, and order information for the purpose of sales invoice administration. This data is transmitted and stored securely. The administrative parties we collaborate with are bound to maintain confidentiality and treat your data with discretion. They will not use your personal data for purposes other than those described above.

External Sales Channels

Marketplaces

We offer (some of) our products through other platforms. When you place an order via one of these platforms, the platform shares your order information and personal data with us. We use this information to process your order. We handle your data with confidentiality and have implemented suitable technical and organizational measures to protect your data against loss or unauthorized use.

Purpose of Data Processing

General Purpose of Processing

We only use your data to benefit our services. This means that the purpose of data processing is directly related to the actions you take. We do not use your data for (targeted) marketing. If you share information with us and we use this information to contact you later – other than at your request – we will explicitly ask for your permission. Your data will not be shared with third parties, except for fulfilling accounting and administrative obligations. All third parties are bound by confidentiality based on contractual agreements or legal obligations.

Automatically Collected Data

Information automatically collected by our website is processed to further improve our services. This data (e.g., your IP address, web browser, and operating system) is not considered personal data.

Participation in Tax and Criminal Investigations

In certain cases, Wine Cooler Online may be legally obligated to share your data in connection with government tax or criminal investigations. In these circumstances, we are required to share your data, but we will oppose this to the extent legally possible.

Retention Periods

We will retain your data as long as you remain our client. This means we will maintain your customer profile until you indicate that you no longer wish to use our services. If you communicate that you no longer wish to use our services, we will consider this as a request for deletion. Due to relevant administrative obligations, we are required to keep invoices containing your personal data; therefore, we will still retain this data as long as we are legally obliged. However, employees will no longer have access to your client profile or documents created as a result of our engagement with you.

Your Rights

Under applicable law, you have specific rights as a data subject concerning the personal data processed by us or on our behalf. We explain these rights and how you can invoke them below. In principle, we will only send statements and copies of your data to the email address we have on file to prevent fraud. If you want to receive this data at a different email address or via post, we will ask you to verify your identity. We maintain records of completed requests. In the case of a request for deletion, we administer anonymous data. You will receive all statements and copies of data in the machine-readable format that we use within our systems. You have the right to file a complaint with the Data Protection Authority at any time if you suspect we are using your personal data inappropriately.

Right of Inspection

You always have the right to access the data we process or have processed relating to your person or traceable to you. Submit such requests to our designated contact person for privacy matters. You will receive a response within 30 days. If your request is granted, we will send you a copy of all data and an overview of the processors who have this data, along with the category under which we have stored this data, to the email address known to us.

Right of Rectification

You always have the right to modify the data we process or have processed

relating to your person or traceable to you. Submit such requests to our contact person for privacy matters. You will receive a response within 30 days. If your request is granted, we will send a confirmation that the details have been amended to the email address known to us.

Right to Restriction of Processing

You always have the right to limit the data we process or have processed relating to your person or traceable to you. Submit such requests to our contact person for privacy matters. You will receive a response within 30 days. If your request is granted, we will send a confirmation that the data will no longer be processed until you remove such limitations, to the email address known to us.

Right to Data Portability

You always have the right to transfer the data we process or have processed relating to your person or traceable to you to another party. Submit such requests to our contact person for privacy matters. You will receive a response within 30 days. If your request is granted, we will send statements or copies of all data about you that we have processed or that have been processed by other processors or third parties on our behalf to the email address known to us. In all likelihood, we will no longer be able to continue our service in this case because the secure linking of data files can no longer be guaranteed.

Right to Object and Other Rights

In some cases, you have the right to object to the processing of your personal data by or on behalf of Wine Cooler Online. If you object, we will immediately stop data processing pending the settlement of your objection. If your objection is well-founded, we will make statements and/or copies of data that we process or have processed available to you and then permanently discontinue the processing. You also have the right not to be subject to automated individual decision-making or profiling. We do not process your data in such a way. If you believe that this is the case, please contact our contact person for privacy matters.

Cookies

Google Analytics

Cookies from the American company Google are placed on our website as part of the “Analytics” service. We use this service to track and receive reports on how visitors use the website. This processor may be obliged to provide access to this data in accordance with applicable laws and regulations. We collect information about your browsing behavior and share this information with Google. Google can interpret this information in conjunction with other datasets and thus track your movements on the internet. Google uses this information to offer targeted advertisements (Adwords) and other Google services and products.

Cookies from Third Parties

In the event that software solutions from third parties use cookies, this will be stated in this privacy statement.

Changes to the Privacy Policy

We reserve the right to change our privacy policy at any time. However, you will always find the most recent version on this page. If the new privacy policy has implications for the way we process previously collected data relating to you, we will notify you by email.