Privacy & Policy
Last Updated : July 2, 2025
Privacy Policy for Vinora Wine
Vinora Wine, operated by Vinora Ltd. (“Vinora Wine,” “we,” “us,” or “our”), is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you use our website, mobile applications, and related services (collectively, the “Service”). We are based in London, UK, and our data processing activities are governed by the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Important Information and Who We Are
Purpose of this Privacy Policy: This Privacy Policy aims to give you information on how Vinora Wine collects and processes your personal data through your use of this Service, including any data you may provide when you sign up for an account, use our features, or interact with us. It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and is not intended to override them.
Controller: Vinora Ltd. is the controller and responsible for your personal data. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Contact Details:
Full name of legal entity: Vinora Ltd.
Email address: cheers@vinorawine.com
Postal address: 128 City Road, London Greater, London EC1V 2NX, United Kingdom
2. The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data: Includes first name, last name, username or similar identifier, title, date of birth, and gender.
Contact Data: Includes billing address, delivery address, email address, and telephone numbers.
Financial Data: Includes payment card details (though we do not store full payment card numbers, only tokens from our payment processors).
Transaction Data: Includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data: Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Service.
Profile Data: Includes your username and password, your interests, preferences, feedback, and survey responses.
Usage Data: Includes information about how you use our Service, products, and services, such as features accessed, time spent on pages, and interactions with content.
Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Service feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. How is Your Personal Data Collected?
We use different methods to collect data from and about you, including through:
Direct interactions: You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
- Apply for our products or services
- Create an account on our Service
- Subscribe to our service or publications
- Request marketing to be sent to you
- Enter a competition, promotion, or survey or
- Give us feedback or contact us.
Automated technologies or interactions: As you interact with our Service, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers such as Google based outside the UK
- Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services based inside or outside the UK
- Identity and Contact Data from data brokers or aggregators based inside or outside the UK
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
4. How We Use Your Personal Data (Lawful Basis)
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for Which We Use Your Personal Data
We may use your personal data for the following purposes, along with the legal bases on which we rely to do so:
1. Purpose/Activity: To register you as a new customer
Type of Data:
- Identity
- Contact
Lawful Basis for Processing:
- Performance of a contract with you
2. Purpose/Activity: To process and deliver your order, including:
- Manage payments, fees and charges
- Collect and recover money owed to us
Type of Data:
- Identity
- Contact
- Financial
- Transaction
- Marketing and Communications
Lawful Basis for Processing:
- Performance of a contract with you
- Necessary for our legitimate interests (to recover debts due to us)
3. Purpose/Activity: To manage our relationship with you, which includes:
- Notifying you about changes to our terms or privacy policy
- Asking you to leave a review or take a survey
Type of Data:
- Identity
- Contact
- Profile
- Marketing and Communications
Lawful Basis for Processing:
- Performance of a contract with you
- Necessary to comply with a legal obligation
- Necessary for our legitimate interests (to keep our records updated and study how customers use our products/services)
4. Purpose/Activity: To enable you to partake in a prize draw, competition, or complete a survey
Type of Data:
- Identity
- Contact
- Profile
- Usage
- Marketing and Communications
Lawful Basis for Processing:
Performance of a contract with you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
5. Purpose/Activity: To administer and protect our business and this Service (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of Data:
- Technical
- Usage
Lawful Basis for Processing:
- Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, fraud prevention, business reorganisation)
- Necessary to comply with a legal obligation
6. Purpose/Activity: To deliver relevant website content and advertisements to you, and to measure or understand the effectiveness of our advertising
Type of Data:
- Identity
- Contact
- Profile
- Usage
- Marketing and Communications
- Technical
Lawful Basis for Processing:
- Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business, and to inform our marketing strategy)
7. Purpose/Activity: To use data analytics to improve our Service, products/services, marketing, customer relationships, and experiences
Type of Data:
- Technical
- Usage
Lawful Basis for Processing:
- Necessary for our legitimate interests (to define customer types, keep our Service updated, develop our business, and improve marketing)
5. Disclosures of Your Personal Data
We may share your personal data with the parties set out below for the purposes stated in the table in paragraph 4 above.
Internal Third Parties:
Other companies in the Vinora Ltd. group acting as joint controllers or processors and who are based in the UK and provide IT and system administration services and undertake leadership reporting.
External Third Parties:
- Service providers acting as processors who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in the UK who provide consultancy, banking, legal, insurance, and accounting services.
- HM Revenue & Customs, regulators, and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
We do not transfer your personal data outside the UK. If we do, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Information Commissioner’s Office (ICO).
- Where we use certain service providers, we may use specific contracts approved by the ICO which give personal data the same protection it has in the UK.
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
9. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
Request access: to your personal data (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction: of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure: of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing: of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
8. Contact Information
If you have any questions about these Terms, please contact us at email: cheers@vinorawine.com