Wines Curated Privacy Policy
1. General
1.1 The following terms (the “Privacy Policy”) govern the use and processing of users/visitors’ data collected by www.winescurated.com (the “Website”).
1.2 Any capitalized terms in this Privacy Policy that are not explicitly defined shall carry the meanings assigned to them in the Terms and Conditions as periodically updated on the Website.
1.3 The terms “user” or “visitor” designate any person who engages with, navigates, or uses the Website and/or its Services (as defined below).
1.4 By accessing the Website users/visitors accept to be bound by the terms of this Privacy Policy. Non-agreement with the terms of this Privacy Policy necessitates immediate discontinuation of the Website and the usage of its services.
1.5 Wines Curated (as defined below) reserves the right to modify or update this Privacy Policy at its discretion. Any changes will take effect immediately upon being posted on the Website users/visitors’ continued access to the Website or use of its Services implies their acceptance of the revised Privacy Policy. It is the duty of the users/visitors to periodically revise this Privacy Policy.
1.6 For the avoidance of doubt, “Services” in this Privacy Policy shall have the same meaning as ascribed to in the terms and conditions posted on the Website and available here.
1.7 Words importing the singular include the plural and vice versa, and words importing gender include all genders.
2. Data Controller
2.1 United Growth Holding Limited a company incorporated in Malta with registered address at Block I, Belmonte Heights, St. Ignatius Street, Sliema SLM 2030, Malta (hereinafter referred to as “Wines Curated”, “we”, “our”, or “us”) is responsible for safeguarding users/visitors’ data (hereinafter also referred to as the “Data Controller”). As Data Controller, Wines Curated determines the means and purposes of processing users/visitors’ personal data.
3. Data Collection and Processing
3.1 “Personal Data” encompasses any information collected by Wines Curated, whether through the Website or offline, that pertains to a user or visitor and can be used to identify them.
3.2 Wines Curated may collect, process, use, store, transfer, or otherwise share Personal Data as follows:
3.2.1 “Identity Data” includes data that identifies a user/visitor, including their first, middle, and last names;
3.2.2 “Profile Data” includes the visitors/users’ username, in some cases, the password (encrypted), IP address, log-in and log-out times;
3.2.3 “Contact Data” includes the contacts a user/visitor has submitted, such as email address, phone number, social media contacts and/or any other data through which a user/visitor can be contacted;
3.2.4 “Technical Data” includes users/visitors’ IP (Internet Protocol) address, address, device details, operating system and platform, browser type and version, browser plugin types and versions, login data, time zone settings, Internet Service Provider (ISP), geographic location, and other online identifiers;
3.2.5 “Marketing and Communication Data” encompasses users/visitors’ preferences regarding marketing communications from Wines Curated and third parties, their communication settings, and any related correspondence. For clarity, this category may further include User Content (as defined in the terms and conditions set out on the Website), as well as opinions, complaints, and chat interactions between users/visitors and Wines Curated;
3.2.6 “Usage Data” includes information about how users/visitors use our website, including complete URL and interaction details. We also collect, use, and share Aggregated Data (as defined below), for any purpose.
3.3 Wines Curated employs various methods to collect Personal Data, including:
3.3.1 Direct engagement with users/visitors who may provide identity details, contacts, and profile data when they register on the Website; or contact Wines Curated; or subscribe to the newsletter; or submit User Content;
3.3.2 Automatic collected data through cookies, server logs, and similar technologies. This automated information is gathered when users and visitors access the Website and includes Technical Data related to their devices, browsing behavior, and usage patterns. Most web browsers accept cookies by default; however, users and visitors who wish to disable them can do so by adjusting their browser settings. For further details, please refer to our Cookie Policy ;
3.3.3 Information obtained from public sources or by third parties for marketing and business purposes, such as data collected from Google Analytics.
4. Purpose
4.1 Wines Curated uses Personal Data only for the purposes for which it collects them.
4.2 Wines Curated collects and uses Personal Data for the following purposes:
4.2.1 Permit users/visitors’ to access to the Website and the Services;
4.2.2 Users/visitors’ explicit request or consent to such use
4.2.3 Manage users/visitors’ accounts (if applicable);
4.2.4 Register new users/visitors (if applicable);
4.2.5 Promote and advertise the Website and the Services;
4.2.6 Customize online content and user experiences based on individual preferences and browsing behavior;
4.2.7 Share services, products, promotions, or other relevant information we believe may interest the users/visitors;
4.2.8 Provide updates relating to the Website and the Services;
4.2.9 Detect and address security breaches, protect against fraudulent, deceptive, malicious, or unlawful activities, and take appropriate measures against individuals or entities engaged in such conduct.;
4.2.10 Fulfil a contract we have with users/visitors or third parties; and
4.2.11 Wines Curated’s legitimate interests (or of a third party);
4.2.12 Ensure compliance with legal or regulatory obligations.
4.3 Users/visitors’ Personal Data may be collected without their knowledge in cases permitted or required by law.
5. Duration
5.1 Wines Curated will retain Personal Data for a duration that is deemed reasonably necessary to fulfill the purposes set out in this Privacy Policy.
5.2 If Wines Curated determines that Personal Data is no longer necessary for the purposes set out in this Privacy Policy, we will ensure that such data is anonymized or destroyed.
5.3 Wines Curated may anonymize user/visitors Personal Data (so it can no longer be linked to a specific user/visitor) for research or statistical purposes, in which case Wines Curated may use this information indefinitely without further notice.
5.4 Wines Curated may be obligated to retain Personal Data for specific periods of time to comply with tax, accounting, or legal obligations.
6. Data Sharing and Third-Party Categories
6.1 Wines Curated does not sell, share, transfer, or disclose Personal Data except as outlined in this Privacy Policy or as required by applicable laws, regulations, or directives.
6.2 Wines Curated collaborates with third parties to deliver the services on the Website. As a result, we may share users’ and visitors’ Personal Data with these third parties for the following purposes:
6.2.1 Third party service providers (including but not limited to wine shops, online wine stores, wine makers, accessories resellers, any other third party service provider);
6.2.2 Website development;
6.2.3 Website hosting services;
6.2.4 Data storage and data analyses services
6.2.5 Payment providers;
6.2.6 Marketing and advertising; and
6.2.7 Products and services’ promotions and sales.
6.3 We request all third parties to respect the security of users/visitors’ Personal Data and to treat them in compliance with all applicable laws. Wines Curated does not permit any third-party service providers to use Personal Data for their own purposes and only authorizes them to process Personal Data for specific purposes, and in accordance with Wines Curated’s instructions.
6.4 We may share users/visitors’ Personal Data with other entities or individuals when required by law. This includes compliance with legal obligations, cooperation with law enforcement authorities, and participation in legal proceedings.
6.5 Wines Curated could disclose Personal Data to establish or exercise its legal rights or to defend against any legal claims/disputes.
6.6Wines Curated may disclose Personal Data to affiliated or related companies for legitimate business purposes.
7. Third-Party Websites
7.1 Wines Curated does not have control over third-party websites. When users or visitors leave the Website or are redirected to an external site—such as by clicking on an advertisement or a third-party brand banner displayed on the Website—the terms, privacy policies, and data handling practices of that third party will govern their interactions. From that point forward, the terms and conditions of the Website, including this Privacy Policy, will no longer apply to the user/visitor or any activity they engage in on the third-party website.
7.2 Wines Curated makes no guarantees regarding handling or use of users/visitors’ data by third-party websites that are linked to or originate from the Website. Users and visitors should review such third-party privacy policies and terms independently.
8. Aggregated Data
8.1 Wines Curated may generate, analyze, and utilize de-identified, anonymized, or aggregated data derived from users/visitors’ Personal Data. However, such data does not directly or indirectly identify any individual. Wines Curated employs this data, for example, to assess trends, compile statistical reports, determine the percentage of users accessing specific services or features, and ensure compliance with applicable laws (“Aggregated Data”). Aggregated Data will be processed and used solely in an anonymized and de-identified form, with no attempts to re-identify individuals unless expressly permitted by applicable law.
8.2 We may disclose Aggregated Data to third parties without consent from users/visitors or prior notice; Wines Curated may utilize, use, and disclose such data without any restrictions.
8.3 Wines Curated does not collect information about race or ethnicity, religious or philosophical beliefs, sexual life, sexual orientation, political opinions, union membership, health, genetic, or biometric data; it is prohibited for users/visitors to share or otherwise send such data.
9. Account and Changes to Personal Data
9.1 Registering and opening an account on the Website is not mandatory to access/use the Website and/or the Services. The Website and/or the Services are accessible free of charge by any user/visitor that is not a Minor (as defined in Section 12 below). Using the Website and/or its Services by Minors is strictly prohibited.
9.2 If users/visitors choose to open an account, such an account is subject to the terms and conditions published on the Website and to this Privacy Policy.
9.3 If an account was created, users/visitors may request its deactivation or deletion at any time; after deactivation or deletion, Wines Curated may retain some information as set out in Section 5 above.
9.4 At any time, users/visitors may contact Wines Curated at [email protected] to:
9.4.1 Correct any inaccuracy in Personal Data;
9.4.2 Receive a copy of Personal Data for the purpose of transferring it to another entity;
9.4.3 Opt-out of the use of Personal Data for targeted advertising; or
9.4.4 Request deletion of Personal Data except where Wines Curated is legally required to retain it.
10. Security
10.1 Wines Curated utilizes appropriate electronic, physical, and personnel measures to safeguard Personal Data. However, absolute security against unauthorized access or breaches resulting in loss, theft, alteration, or misuse cannot be guaranteed. Users/visitors are responsible for maintaining the confidentiality of their login information and should promptly change their passwords and notify Wines Curated if they suspect any unauthorized access to their account.
11. Do Not Track (DNT)
11.1 The Website does not recognize or respond to browser Do Not Track (hereinafter referred to as “DNT”) signals or similar mechanisms.
12. Under Age Users / Children
12.1 The Website offers information on alcohol related products (amongst others) and, as such, none of its marketing content, products, services, or promotions are intended for or suitable for children or individuals under the age of 18 (outside US) or 21 (within US), depending on the applicable laws in the country of residence (or the equivalent minimum age in the relevant jurisdiction) (“Minor(s)”).
12.2 Wines Curated and the Website do not knowingly solicit or collect personal data from Minors. If we become aware that we have accidentally collected personal data from a Minor, we will remove such personal data from our records as soon as reasonably possible.
12.3 We decline any responsibility for actions taken by Minors based on the content available on the Website, its subdomains, or any of its pages, as well as for any of our outbound marketing campaigns, including but not limited to newsletters.
13. Users/Visitors from California
13.1 Under California Civil Code Section 1798.83, user/visitors residing in California have the right to request, once per calendar year and at no cost, a notice disclosing any Personal Data that Wines Curated may have shared with third parties for direct marketing purposes in the preceding year. This notice will include the categories of Personal Data shared and the names and addresses of all third parties that received such information. California residents who wish to make this request should submit a written inquiry to [email protected].
14. Changes in Business—Bankruptcy
14.1 In the event of a merger, acquisition, reorganization, bankruptcy, or sale of the Website or other company assets, Wines Curated may sell or transfer Personal Data to third parties. Additionally, users’ and visitors’ Personal Data may be shared and/or transferred in connection with potential transactions related to these circumstances. Wines Curated will notify users and visitors if their Personal Data becomes subject to a different privacy policy.
15. Assignment
15.1 Wines Curated reserves the right to transfer, or assign this Privacy Policy or of its rights and/or obligations to entities within the same corporate group as Wines Curated or to third parties in the event of corporate transactions.
16. Contacts
16.1 For any matter pertaining or connected to this Privacy Policy or for privacy queries users/visitors may contact [email protected]; or write to United Growth Holding Limited, Block I, Belmonte Heights, St. Ignatius Street, Sliema SLM 2030, Malta.