Vinora Privacy Policy

This Privacy Policy explains how Digital Pulse 365 Ltd ("Vinora", "we", "us", or "our") collects, uses, stores, and shares your personal data when you use the Vinora website (vinoraai.wine), mobile application, or any associated services (collectively, the "Platform").

We are committed to protecting your privacy and handling your personal data in a transparent and lawful manner, in compliance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and all other applicable data protection legislation.

If you have any questions about this Privacy Policy or how we handle your data, please contact us at the details set out below.

1. Data Controller

The data controller responsible for your personal data is Digital Pulse 365 Ltd, a private limited company registered in England and Wales.

Address: 128 City Road, London, EC1V 2NX, United Kingdom

Email: privacy@vinoraai.wine

Support: support@vinoraai.wine

Phone: +44 20 3907 7732

Website: vinoraai.wine

Following our migration from vinorawine.com, all data processing activities are now conducted under the vinoraai.wine domain. If you previously held an account on vinorawine.com, your data has been migrated to our updated platform.

2. Personal Data We Collect

We collect personal data in the following categories, depending on how you use the Platform:

2.1 Account and Identity Data

• Full name, email address, username, and preferred language.
• Country of origin and postal address (where provided).
• Profile information and account preferences.

2.2 Wine Activity Data

• Ratings — scores assigned to wines on a scale of 1 to 5 stars.
• Reviews — written evaluations and personal commentary about wines.
• Wish lists, collections, and browsing history on the Platform.

2.3 Purchase Data

• Contact information (name, email, phone number) for order fulfilment.
• Billing and shipping addresses.
• Transaction history and payment references (note: full payment card data is processed directly by our payment providers and is not stored by Vinora).

2.4 Technical and Usage Data

• IP address, device identifiers, and browser type.
• Pages visited, features used, and time spent on the Platform.
• Device location data, where you have granted permission.
• Cookie and tracking data, as described in our Cookie Policy.

2.5 Communications Data

• Correspondence and enquiries submitted to us via email or the Platform.
• Marketing preferences and consent records.

3. How and Why We Use Your Personal Data

3.1 Account and Relationship Management

We process your personal data to create and manage your account, provide access to the Platform, and communicate with you about service updates, policy changes, and support matters.

Legal basis: Performance of a contract (UK GDPR Article 6(1)(b)).

3.2 Wine Reviews and Community Features

With your consent, we display your username and wine reviews to other users, enabling community interaction and discovery. You may withdraw this consent at any time via your profile settings, which will anonymise your username on existing reviews.

Please note that Vinora does not routinely delete the substantive content of reviews, as reviews form an integral part of the Platform's credibility and accuracy. If you request removal of a review, your username will be anonymised; however, the review text will ordinarily be retained unless there are compelling individual grounds for deletion.

Legal basis: Consent (UK GDPR Article 6(1)(a)).

3.3 Order Fulfilment

Where the Platform facilitates the purchase of wine, we process the personal data necessary to fulfil your order — whether by Vinora or a third-party merchant. Your data will be shared with the relevant merchant or logistics provider solely for this purpose.

Legal basis: Performance of a contract (UK GDPR Article 6(1)(b)).

3.4 Platform Improvement and Analytics

We analyse usage data to improve the Platform, develop new features, personalise the user experience, and assess the effectiveness of our services. This includes the use of algorithms and machine learning. Where possible, analytics are conducted on depersonalised or aggregated data.

Legal basis: Legitimate interests (UK GDPR Article 6(1)(f)) — specifically, our interest in improving and developing a high-quality platform for users.

3.5 Marketing and Personalised Communications

With your consent, we may send you personalised marketing communications by email and push notification, including updates, offers, and wine recommendations. You may withdraw consent at any time via your profile settings, by clicking "Unsubscribe" in any marketing email, or by contacting us directly.

Legal basis: Consent (UK GDPR Article 6(1)(a)).

3.6 AI-Powered Recommendations

The Platform uses artificial intelligence to generate personalised wine recommendations and curated content. This processing is based on your activity data and preferences. You have the right not to be subject to decisions based solely on automated processing where those decisions produce significant legal or similarly significant effects on you. To exercise this right, please contact us at privacy@vinoraai.wine.

Legal basis: Consent and legitimate interests (UK GDPR Articles 6(1)(a) and 6(1)(f)).

4. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

• Account and identity data: retained for the duration of your account, plus 6 months following deletion.
• Wine ratings: retained indefinitely as part of the Platform's wine database (depersonalised where possible upon account deletion).
• Wine reviews: retained in anonymised form following account deletion, unless compelling individual grounds for full deletion are established.
• Purchase data: retained for 2 years following purchase for warranty purposes, and for up to 6 years for bookkeeping and tax compliance purposes.
• Analytics data: stored in depersonalised form with no fixed retention limit.
• Marketing consent records: retained until consent is withdrawn, plus a reasonable period thereafter for compliance purposes.

5. Sharing Your Personal Data

We do not sell your personal data. We may share your data with third parties only in the following circumstances:

• Service providers and data processors: companies that support our operations (e.g., hosting, email delivery, analytics, payment processing), bound by data processing agreements in accordance with UK GDPR requirements.
• Payment providers: your payment data is processed directly by our payment providers, who act as independent data controllers under their own privacy notices.
• Third-party merchants: where you purchase wine via the Platform, relevant order data is shared with the fulfilling merchant.
• Legal obligations: where we are required to disclose data by law, regulation, or court order.
• Business transfers: in the event of a merger, acquisition, or sale of assets, your data may be transferred to the relevant successor entity, subject to equivalent privacy protections.

6. International Data Transfers

In connection with our IT infrastructure, including hosting, development, and support services, we may transfer personal data to countries outside the United Kingdom and European Economic Area (EEA). Where such transfers occur, we ensure that adequate protections are in place, including:

• Reliance on UK adequacy regulations or European Commission adequacy decisions.
• Use of International Data Transfer Agreements (IDTAs) or Standard Contractual Clauses (SCCs) approved by the UK Information Commissioner's Office (ICO) or European Commission.
• Implementation of supplementary technical and organisational safeguards where required by the laws of the destination country.

You may request further information about our international transfers by contacting us at privacy@vinoraai.wine.

7. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to operate and improve the Platform, personalise your experience, and analyse usage. Full details of the cookies we use, including their purpose and duration, are set out in our Cookie Policy, available at vinoraai.wine/cookies.

Non-essential cookies are only placed with your consent, which you may manage or withdraw at any time via the cookie settings on the Platform.

8. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These include password-protected accounts, encrypted data transmission, and access controls.

Where you access the Platform via a third-party sign-in provider (e.g., Google or Apple), your password is managed solely by that provider.

Whilst we take all reasonable steps to protect your data, no method of transmission over the internet or electronic storage is entirely secure. In the event of a data breach that poses a risk to your rights and freedoms, we will notify you and the relevant supervisory authority in accordance with our legal obligations.

9. Children's Privacy

The Platform is intended exclusively for adults of legal drinking age in their jurisdiction. We do not knowingly collect personal data from individuals below the legal drinking age. If we become aware that such data has been collected, we will delete the account and associated personal data promptly.

If you believe a minor has created an account on the Platform, please notify us at support@vinoraai.wine.

10. Your Rights

Under UK GDPR and the Data Protection Act 2018, you have the following rights in relation to your personal data:

• Right of Access: to request a copy of the personal data we hold about you.
• Right to Rectification: to request correction of inaccurate or incomplete data.
• Right to Erasure: to request deletion of your personal data, subject to certain exceptions (e.g., where we are required to retain it by law).
• Right to Restrict Processing: to request that we limit how we use your data in certain circumstances.
• Right to Object: to object to our processing of your data based on legitimate interests or for direct marketing purposes.
• Right to Data Portability: to receive your personal data in a structured, machine-readable format and transfer it to another service provider.
• Right not to be subject to Automated Decision-making: to request human review of any decision made solely by automated means that significantly affects you.
• Right to Withdraw Consent: where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at privacy@vinoraai.wine. We may ask you to verify your identity before processing your request. We will respond within one month, as required by applicable law.

If you are dissatisfied with how we handle your data or respond to your request, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

11. UK and International Users

This Privacy Policy is governed by and construed in accordance with the laws of England and Wales. If you are based in the European Union, your data may be processed on the basis of the EU GDPR in addition to UK data protection law, and you may also have recourse to your local supervisory authority.

Whilst this Policy is primarily drafted for UK and EU users, we extend equivalent privacy protections to all users of the Platform regardless of location, in the spirit of global data protection best practice.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. Material changes will be communicated via in-app notification or email at least 14 days before they take effect. The effective date at the top of this Policy will be updated accordingly.

We encourage you to review this Policy periodically. Continued use of the Platform following any update constitutes your acknowledgement of the revised Policy.