Privacy Policy

Effective Date: February 2, 2023

Welcome to Space Wine Lab. Protecting your privacy is very important to us. Therefore, we have developed a privacy policy that we believe protects users while allowing us to improve our services and products.

What is the content of this document?

We have created this document (“Privacy Policy”) to clarify to our users of legal age, as specified in Appendix 2 in this document (“Legal Age”), how we treat and protect their personal data, what their rights are, and how they can exercise them.

This Privacy Policy applies to any collection and processing of personal data carried out when you interact with us through digital means, including, but not limited to, the websites spacewine.io, associated and subdomains (the “Sites”), portals and mobile applications (collectively, “Space Wine Digital Platforms”); when you purchase a product or request other services from Space Wine Lab or its subsidiaries or related entities (hereinafter, “we” or “us” or “Space Wine”), either online on our Sites or through Space Wine Digital Platforms or offline in our stores, even when you contact our customer service for after-sales customer service or specific questions or requests; when we contact you as part of our marketing activities.

What happens to my personal data when I interact with Space Wine?

By accessing and using the Space Wine Digital Platforms or by providing us with your personal data, for example, when you visit our stores or when you contact our customer service, you confirm that you have read and understood the way we collect, process, use and disclose your personal data, as described in this Privacy Policy.

For specific processing activities, we need to obtain your consent to collect and process your personal data. When we need your consent, we will ask you, before submitting personal data or using the relevant sections of Space Wine Digital Platforms, to electronically confirm that you accept the processing activity in question, as described in this Privacy Policy, by checking specific boxes. Your affirmative action by checking the corresponding box and your use of these Sites signifies your acceptance of the processing activity in play as described in this Privacy Policy. Our records of your acceptance of this Privacy Policy, the date of this, and any future amendments to this Privacy Policy will be considered conclusive and written evidence of your consent.

You will also be informed about this Privacy Policy (and, when a specific processing activity requires your consent, you will be asked for your consent) when you contact our customer service or when you provide us with your personal data through interactions in stores.

We collect and process your personal data in accordance with all applicable data protection laws and regulations, including, but not limited to, the laws enacted in this area by the European Union, such as the General Data Protection Regulation (EU) 2016/679 of April 27, 2016 (“GDPR”) and the complementary national provisions, as well as the orders and guidelines issued by the competent data protection authorities, as applicable (the “Data Protection Laws”).

Who controls the processing of my personal data? Who is responsible for it?

The company Puleun Hill Lda (doing business as “Space Wine Lab”, “Space Wine” or “SWLab”) as specified in Appendix 3 of this Privacy Policy (the “Company”) is the data controller, in the respective countries; of the personal data that is collected and processed when you purchase products in our physical stores; and the data that is collected and processed for our marketing activities.

Space Wine, when required by law, asks for your consent to use your personal data, for marketing purposes.

The Company is responsible for the processing of the personal data that you provide when you interact with our customer service, and for protecting your personal data in the European Union, the United States, and the world.

To contact the company, send an email to contact@spacewine.io

What kind of personal data is processed?

Automatic Information Collection on Space Wine Digital Platforms.

The processing of your personal data when you simply visit and consult the Sites is limited to so-called navigation data, i.e., data whose transmission to the Sites is implicit in the operation of the systems responsible for managing the Sites and in the communication protocols of the Internet itself. Navigation data are, for example, the IP addresses of the devices you use to connect to the Sites and other parameters related to your device and operating system.

In principle, we collect and process browsing data, such as those specified above, and for example the number of visits and the time spent on the Sites, exclusively for statistical purposes and in an aggregated form in order to measure and improve the functioning of this. Due to the very nature of browsing data, this data can lead to the identification of users if it is associated with data held by third parties; however, we do not collect browsing data to associate it with identified users, except when such data may be used to evaluate possible liabilities in the event of information crimes committed against the Sites or through the Sites to the extent permitted by law.

Information you provide to us voluntarily.

We collect and process:

1. Personal data that you provide when you interact with us, through the Space Wine Digital Platforms, for example, when you open an account, upload user-generated content to the Sites, or fill out forms in the store or when using our mobile applications. This personal data may include:

• • • your name, email address, phone number,
    • your username and password.

2. Personal data you provide when you participate in or subscribe to our marketing activities (either through the Space Wine Digital Platforms or in our stores), for example, when you subscribe to our newsletter(s) or mailing list(s) or participate in promotions and other initiatives such as loyalty programs, contests and sweepstakes, etc. This personal data may include:

• • • your name, email address, phone number,
    • your purchase history.

3. Personal data you provide when you purchase products from us (either online or in our stores). This personal data may include:

• • • your name, email address, phone number
    • the history of products you purchase,
    • details about your transaction

4. Personal data you provide when you interact with our customer service, for example, when you contact our customer service call center and instant messaging to get help or request specific assistance or service from our customer service. This personal data may include:

• • • Your name, email address, phone number,
    • The history of products you purchase,
    • Information about the reasons why you contacted customer service,
    • Content of your communications related to your interaction with customer service.

When you have provided us with personal data about another person (for example, when you use the friend’s email function, coupons functions or other purposes), to the extent permitted by applicable laws, you hereby confirm that you have the right to communicate such personal data to us and that you have informed such person about the processing of their personal data and, where necessary, have obtained their consent for the purposes set out in this Privacy Policy.

For what purposes are my personal data processed?

We collect and process your personal data for the following purposes:

1. Space Wine, as a data controller, processes your personal data for the following purposes:

• • To operate and manage the Space Wine Digital Platforms, including:
    • to provide you with the services or functionalities you request on the Space Wine Digital Platforms;
    • to create your account and manage your subscription on the Space Wine Digital Platforms;
    • to improve your browsing experience and improve the Space Wine Digital Platforms.
  • To carry out marketing activities, including:
    • for direct marketing purposes, including;
    • to manage your subscription to our mailing list(s);
    • to allow participation in promotions and other initiatives;
    • to send you (subject to your consent, which is optional), also via email or other means of electronic communication, such as Chat Apps, SMS, MMS, etc., information and promotional material about our products;
    • to improve our products and services.

• • To manage your purchases of goods, either through the Sites or in our stores:
    • this includes all activities related to the purchase of goods, such as delivery of goods, Invoicing, replacement of goods, receipt of refunds, purchase and use of credits, and activities related to payments, including the use of vouchers and coupons.
  • For other purposes:
    • for fraud prevention purposes, through internal procedures aimed at verifying the regularity of transactions, to protect our financial integrity and protect you against data misuse and fraudulent purchases;
    • to comply with our obligations under applicable laws and regulations and to assess and defend a legal right.

2. As data controller, we process your personal data for the following purposes:

• • To provide you with our customer service, which includes:
    • to provide you with after-sales services;
    • to respond to your requests for information, questions, communications or comments;
    • For internal training purposes and to improve our customer service.

3. Additional information about our customer service:

Our customer service is managed by the Company with headquarters in the Autonomous Region of Madeira, Portugal, which interacts with you and provides you with the service. We will process your personal data when you contact our customer service and call center, which may contact you via email, chat, and phone. The call center will register your phone number for the purpose of returning your call and administrative services to provide you with the requested support and information. In some cases, for internal training, quality control, and verification purposes, the call may be recorded, and emails may be stored to the extent not prohibited by applicable law. You will always be informed in advance about the recording of the communication and will have the opportunity to object to such recording, except when necessary for verification purposes in relation to your purchase or other reasons, as permitted by applicable laws.

What are the legal bases for the processing of my personal data as described in this document?

We will collect and process your personal data for the purposes described in the Section “For what purposes is my personal data processed?” on one of the following legal bases:

The processing of your personal data is necessary for the performance of a contract with you or to take steps before entering into a contract with you at your request (Article 6, 1., (b) of the GDPR); The processing is necessary for the purposes of our legitimate interests or the legitimate interests of our affiliates or other third parties, and such interests are not overridden by your interests or fundamental rights and freedoms (Article 6, 1., (f) of the GDPR); The legitimate interests we pursue include in particular our interest in managing and maintaining the contractual relationship with you, responding to your specific requests, seeking your feedback to improve our Sites and our products, or conducting other general marketing activities. Where your specific consent is required for the processing of your personal data as described herein, your personal data will be processed based on such consent (Article 6, 1., (a) of the GDPR);

How long will my personal data be processed?

Personal data is stored only for as long as necessary to fulfill the purposes for which it was collected and to achieve the specific data processing purposes described in this document, unless there is any other reason for its maintenance, such as the need to comply with any legal, regulatory, contractual obligation, among others. allowed by law.

This may be up to 10 years after the end of the contractual relationship with you (limitation period for legal claims in most EEA countries) unless a shorter or longer retention period applies under applicable laws.

We always carry out a technical analysis to determine the appropriate retention period for each type of personal data collected, considering its nature, need for collection, and purpose for which it will be processed, as well as any retention needs to comply with obligations or protection of rights.

Is my personal data safe?

We are committed to protecting the security and confidentiality of your personal data. We take (and require any third-party service provider and/or processor that processes personal data on our behalf and on our instructions to take) appropriate technical and organizational measures to prevent the loss and destruction, even accidental, of data, unauthorized access to the data, or unfair use of the data. Furthermore, information systems and software programs are configured so that personal and identification data are used only as necessary to achieve the specific processing purpose sought from time to time.

We implement a variety of advanced security technologies and procedures to help protect personal data against the risks described above. For example, personal data provided by users is stored on secure servers located in controlled locations. In addition, encryption techniques such as the Secure Socket Layer (SSL) protocol are used to transmit some data over the Internet.

However, please note that no electronic transmission or storage of information is 100% secure. Therefore, despite the security measures we have implemented to protect your personal data, we cannot guarantee that loss, misuse, or alteration of data will never occur.

Where does my personal data go?

Personal data collected through our Sites or other Space Wine Digital Platforms, as part of the sale of products in our stores and Sites and as part of our customer service, is stored on servers provided and managed by our third-party provider. hosting and storage, DreamHost, located in California, USA. Certain personal data collected as part of the sale of products in our stores may also be stored locally in the store. All this personal data may be shared with recipients as detailed below.

Who are the recipients, where is it transferred and for what purposes?

We communicate personal data within the limits and under the circumstances specified in this Privacy Policy, subject to your specific consent when required by applicable Data Protection Laws:

1. Your personal data will be accessible within our organization by internal and external personnel who need access to them due to their functions in relation to the processing purposes specified here. We ensure that these individuals comply with appropriate security and confidentiality duties.

2. Your personal data may also be accessible through a third-party service provider that we appoint to process personal data on our behalf and on our instructions (as data processors). These data processors include:
   • • external service providers that we may use to provide functional professional, technical and organizational services for the management of the Space Wine Digital Platforms and the activities carried out on them, such as, for example, the sale of goods and related activities. , the management of the offered functionalities. for the Space Wine Digital Platforms and the initiatives and services that you may subscribe to and request through the Space Wine Digital Platforms, and for strictly functional services to achieve the other processing purposes specified herein;
     • third-party service providers we use to close purchase transactions and process payments through our e-commerce platform;
     • third-party service providers who manage and support the Space Wine Digital Platforms, the corresponding e-commerce platform and all pre-sales and post-sales activities, such as order processing, performance marketing, financial services, warehouse management and relationship management with the clients.

These data processors are subject to appropriate contractual obligations to implement appropriate security measures to protect the security and confidentiality of personal data.

3. Your personal data may also be communicated to other companies associated with Space Wine within the European Economic Area, the United Kingdom, Switzerland, the United States, and the rest of the countries of the world, processing personal data on behalf of the person responsible for the treatment. identified above. A list of these companies, indicating where they are located, is available upon request.

4. Your personal data may also be shared with institutions, authorities, public entities, banks and financial institutions, professionals, independent consultants, also in the form of associates, business partners or other legitimate recipients as permitted by applicable laws and regulations, e.g. in case of judicial proceedings, request from courts and competent authorities or other legal obligation, to protect and defend our rights and property and the Space wine Digital Platforms.

5. Finally, we may also disclose your personal data to third parties in the event of mergers, acquisitions, or transfers of any of our assets, products, websites, or operations.

Except for the above, personal data will not be shared with third parties, natural or legal persons, who are not related to or who do not perform a commercial, professional or technical function for us.

Personal data will not be communicated to third parties for their own marketing purposes.

Such transfers are made on the processing bases identified in Section 3 above.

These aforementioned recipients may be located in countries other than the country in which the personal data was originally collected, taking into account that, in principle, your personal data will be transferred within the European Economic Area or other countries recognized by the EU Commission as providing an adequate level of protection of personal data.

In the event that any of the above recipients are established in a country outside the EEA that is not covered by an adequacy decision of the European Commission and therefore does not provide the same level of protection for its staff as in the EEA , we will implement appropriate safeguards, including, but not limited to, relevant data transfer agreements based on the EU Commission’s Standard Contractual Clauses for data transfer to third countries (Article 46, 2., (c) of the GDPR) or binding corporate rules (Article 47 of the GDPR).

Am I obliged to provide my personal data?

Except in relation to browsing data (see section: ” What kind of personal data is processed?”), providing your personal data may be a necessary requirement to enter into or perform a contract, including for the performance of certain services, and functionalities offered by the Space Wine Digital Platforms, such as subscribing to the Sites, subscribing to our newsletter(s), purchasing products through the Sites or in our stores, managing the participation in loyalty programs, promotions and other initiatives communicated through the Space Wine Digital Platforms or in our stores, responding and managing requests for information, questions, communications or comments.

What are the consequences if I refuse to provide them?

In the above circumstances, refusal to provide your personal data would make it impossible for us to perform the contract or provide the requested services, products or information as specified above.

Providing your personal data for surveys, marketing and other profiling purposes, as specified above, is optional; Refusal to provide your personal data for these purposes will have no impact on the conclusion or performance of the contract. Where required by Data Protection Laws, we will obtain your prior consent before proceeding to process your personal data for these purposes.

Do Space Wine Digital Platforms contain elements controlled by third parties? Who is responsible for these elements?

The Space Wine Digital Platforms may contain links to other sites, as well as objects or elements controlled by third parties.

An example is plugins that may connect Space Wine Digital Platforms to social networks (“social plugin”) and which are generally identified with the logo of the corresponding social network. If you interact with a social plugin on any Space Wine Digital Platform, your browser may send to such social network certain data related to you, such as your user ID, information about the corresponding Space Wine Digital Platform, date and time, and others. browser data. related information. Such information will be processed by social networks, owned and operated by third parties, in accordance with their privacy policies.

We have no access to or control over elements, objects, plugins, cookies, web beacons and other elements or tracking technologies owned and operated by third parties, available on the Space Wine Digital Platforms or on the relevant third-party websites, to which that users can access. on or from the Space Wine Digital Platforms, and about the relevant methods of processing personal data through such elements or sites. We disclaim any and all liability for such items and websites. You should consult the privacy policy of such third-party websites for the conditions applicable to the processing of personal data.

What are my rights in relation to the processing of my personal data and how can I exercise them?

You have the right at any time to enforce the rights available to you under applicable data protection laws, including, but not limited to, the right of access, rectification, restriction, deletion and opposition (including objection, at any time and in any manner). free, to the processing of your personal data for direct marketing purposes), right to portability, as well as the right to withdraw your consent. You also have the right to file a complaint with the competent supervisory authority.

For a summary of what the above rights entail and how you can exercise them, please see Appendix 1 of this Privacy Policy.

For any queries or requests relating to the processing of personal data by Space Wine and to enforce the rights set out in the Data Protection Laws, you can contact us at contact@spacewine.io

Can we make changes to this Privacy Policy?

We reserve the right to update and modify this Privacy Policy in whole or in part, at any time, to the maximum extent permitted by applicable law. The version published on the Sites, and on any other relevant Space Wine Digital Platform, is the version actually in force. If we change this Privacy Policy, we will notify you of such changes through the applicable Space Wine Digital Platform and/or by direct email notification.

The date at the top of this Privacy Policy indicates when it was last updated.

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Appendix 1 – Data Subject’s Rights

As an individual whose personal data is processed as described in this Privacy Policy, you have a number of rights which are summarized below. Please note that the exercise of these rights is subject to certain requirements and conditions established in applicable law.

1. Right of access: Subject to applicable law, you have the right to obtain confirmation from us as to whether or not personal data concerning you is processed and, if so, to request access to such personal data, including, but not limited to, the categories of personal data in issue, the purposes of the processing and the recipients or categories of recipients. However, we do have to consider the rights and freedoms of others, so this is not an absolute right. If you request one or more copies of the personal data being processed, we may charge you a reasonable fee based on administrative costs.
2. Right to rectification: You have the right to request from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you also have the right to request the completion of incomplete personal data, including by submitting a supplementary declaration.
3. Right to erasure (“right to be forgotten”): You have the right to request that we delete personal data concerning you in certain circumstances, as defined by applicable law. Where your request falls within one of those circumstances, we will delete your personal data without undue delay. If, for technical and organizational reasons, we were unable to delete your personal data, we will ensure that it is completely and irreversibly anonymized so that we no longer retain such personal data about you.
4. Right to restriction of processing: In certain circumstances, as defined in applicable law, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, and you may have the right to transmit those data to another data controller or that such personal data be transmitted directly from us to another data controller, where technically feasible.
5. Right to data portability: In certain circumstances as defined under applicable law, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that data to another data controller or to have such personal data transmitted directly from us to another data controller, where technically feasible.
6. Right to object: In certain circumstances, as defined by applicable law, you have the right to object, on grounds relating to your particular situation, at any time to our processing of your personal data and we may be required to stop processing your data. personal data unless you demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. This applies in particular to the processing of your personal data based on our legitimate interests or for statistical purposes.
7. Right to object to direct marketing: Where your personal data is processed for direct marketing purposes, you have the right to object at any time to processing for such direct marketing (including profiling related to such direct marketing).
8. Right not to be subject to a decision based solely on automated processing: Subject to certain restrictions, you have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects on you and significantly affects you.
9. Right to withdraw consent: If you have declared your consent to any personal data processing activities as described in this Privacy Policy, you may withdraw this consent at any time with future effect. Such withdrawal will not affect the legality of the processing prior to the withdrawal of consent.

If you have declared your consent for any personal data processing activities as described in this Privacy Policy, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to withdrawal of the consent.

If you wish to access such personal data or exercise any of the rights listed above, you must request it in writing, providing evidence of your identity, by sending us a message through our direct contact: contact@spacewine.io

Any communications from us in relation to your rights as detailed above will be provided. We may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the requested action; or refuse to act on the request.

In the event that you have a complaint about the processing of your personal data, you have the right to lodge a complaint with a competent supervisory authority.

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Appendix 2 – Legal Age

The services offered by the Space Wine Digital Platforms are not directed to persons who are younger than the legal age to consume or purchase alcoholic beverages in their jurisdiction (“Minors”). Therefore, we do not knowingly collect or solicit information from Minors in our operations. Minor users should not attempt to register to access our services or send us any information. If we become aware that we have collected information from a Minor, we will terminate any account used and delete related personal data.

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Appendix 3 – The Company

Puleun Hill Lda. – Parque das Nações, Lisboa, Portugal, EU. 1990-079

Space Wine Lab (SWLab) – R. do Carmo, Funchal, Autonomous Region of Madeira, Portugal. 9050-019

Space Wine (Online Shop) – spacewine.io

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