Privacy and Cookie Policy

Privacy and Cookie Policy

1. Introduction

1.1. This Privacy and Cookie Policy explains how Swiss Wine s.r.o. (“we”, “us”, or “our”) collects, uses, stores, and protects your personal data when you visit or use www.swisswine.uk.

1.2. We are committed to protecting your personal data in accordance with applicable data protection law, including the UK GDPR, the Data Protection Act 2018, and, where relevant, applicable EU data protection rules.

1.3. We are an independent commercial entity and are not affiliated with any governmental or state-funded wine promotion organisations.

1.4. Please read this Privacy and Cookie Policy together with our Terms and Conditions.

2. Data Controller

2.1. The data controller responsible for your personal data is:

Swiss Wine s.r.o.
Belehradska 858/23
120 00 Prague 2
Czech Republic, EU
Company No.: CZ07002106
Email: swisswine@swisswine.uk

2.2. If you have any questions about this Privacy and Cookie Policy or wish to exercise your data protection rights, please contact us at swisswine@swisswine.uk.

3. Personal Data We Collect

We may collect and process the following categories of personal data:

3.1. Identity and Contact Data

  • first name and last name;
  • billing address;
  • delivery address;
  • email address;
  • telephone number.

3.2. Order and Transaction Data

  • order details;
  • products purchased;
  • order history;
  • delivery information;
  • refund and return information.

3.3. Age Verification Data

  • date of birth, age declaration, or age-verification outcome where needed to comply with alcohol sales rules.

3.4. Payment Data

  • payment status and limited payment-related information necessary to process your order.

3.4.1. We do not generally store full card details ourselves.

3.4.2. Payments are processed by third-party payment providers, including cryptocurrency gateways and PayPal.

3.5. Technical Data

  • IP address;
  • browser type and version;
  • device type;
  • operating system;
  • time zone and language settings;
  • website usage information.

3.6. Communications Data

  • messages you send to us by email or through website forms;
  • customer service correspondence;
  • complaint and dispute records.

3.7. Marketing and Preferences Data

  • your marketing preferences;
  • consent records;
  • cookie preferences, where applicable.

4. How We Collect Your Data

We collect personal data:

4.1. Directly from you, for example when you:

  • place an order;
  • create an account, if applicable;
  • contact us;
  • sign up for marketing communications;
  • request customer support;
  • make a return or complaint.

4.2. Automatically, when you use our website, through cookies and similar technologies, including technical and usage data.

4.3. From service providers, for example:

  • payment processors;
  • delivery providers;
  • age-verification partners, if used;
  • website and hosting providers.

ICO expects organisations to tell people what information they collect, the source of the data, and the lawful basis they rely on.

5. How We Use Your Data and Our Lawful Bases

We will only use your personal data where the law allows us to do so.

5.1. Contract Performance

We use your personal data where necessary to perform our contract with you, including to:

  • process and confirm your order;
  • take payment;
  • arrange delivery;
  • communicate about your order;
  • manage cancellations, returns, and refunds;
  • provide customer support.

5.2. Legal Obligation

We use your personal data where necessary to comply with legal obligations, including to:

  • verify age where required for alcohol sales;
  • keep legally required tax, accounting, customs, and transaction records;
  • comply with applicable regulatory or enforcement requests.

Legal obligation is an appropriate basis where processing is necessary to comply with a legal requirement under UK law.

5.3. Legitimate Interests

We may process your personal data where necessary for our legitimate interests, provided your rights and freedoms do not override those interests. This may include:

  • administering and improving our website and services;
  • managing customer relationships;
  • keeping records of orders and support history;
  • preventing fraud and misuse;
  • securing our website, systems, and business operations;
  • handling complaints, disputes, and legal claims.

5.4. Consent

We rely on your consent where required, including:

  • sending marketing communications where opt-in consent is required;
  • placing non-essential cookies or similar technologies on your device.

5.4.1. You may withdraw your consent at any time.

5.4.2. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

ICO requires privacy notices to explain the lawful basis used and to reflect where consent is actually required.

6. How We Share Your Data

6.1. We do not sell your personal data.

6.2. We may share your personal data with trusted third parties where necessary for the purposes described above, including:

  • delivery partners and couriers;
  • payment processors and payment gateway providers;
  • cryptocurrency payment providers;
  • IT, hosting, website, and cloud service providers;
  • fraud prevention and security providers;
  • professional advisers, where necessary;
  • regulators, tax authorities, customs authorities, courts, or law enforcement bodies where legally required.

6.3. We require third-party processors to handle personal data only in accordance with our instructions and applicable data protection law.

7. International Transfers

7.1. We are based in the Czech Republic and serve customers in the United Kingdom. Personal data may therefore be transferred between the UK and the EU/EEA.

7.2. Where such transfers take place, we rely on applicable legal transfer mechanisms, including adequacy arrangements where available, or other lawful safeguards where required.

7.3. If we transfer personal data outside the UK or the EU/EEA in other circumstances, we will take appropriate steps to ensure your personal data remains protected.

The UK recognises adequacy mechanisms for international data transfers, and these can support transfers where the legal conditions are met.

8. Data Retention

8.1. We keep personal data only for as long as necessary for the purposes for which it was collected, including to satisfy legal, tax, accounting, dispute-resolution, and reporting requirements.

8.2. In general:

  • order, invoice, payment, customs, and accounting records are kept for as long as required by applicable financial, tax, and record-keeping laws;
  • customer service and complaint records are kept for a reasonable period to manage disputes and after-sales issues;
  • marketing data is kept until you unsubscribe or withdraw consent, or until we determine it is no longer necessary;
  • cookie consent records may be kept for as long as needed to demonstrate compliance and manage your preferences;
  • technical and analytics data is kept only for as long as reasonably necessary for security, functionality, and analytics purposes.

8.3. When we no longer need your personal data, we will delete it or anonymise it where reasonably possible.

ICO guidance expects retention periods or the criteria used to determine them to be explained in the privacy notice.

9. Your Rights

Under the UK GDPR, you may have the following rights, depending on the circumstances:

9.1. Right of access – to request a copy of the personal data we hold about you.

9.2. Right to rectification – to ask us to correct inaccurate or incomplete personal data.

9.3. Right to erasure – to ask us to delete your personal data in certain circumstances.

9.4. Right to restrict processing – to ask us to limit the way we use your data in certain circumstances.

9.5. Right to object – to object to processing based on legitimate interests, and to object to direct marketing.

9.6. Right to data portability – to request that certain personal data be provided to you or another provider in a structured, commonly used, machine-readable format.

9.7. Right to withdraw consent – where we rely on consent, you can withdraw it at any time.

9.8. Rights relating to automated decision-making – we do not currently make solely automated decisions with legal or similarly significant effects about you through this website.

9.9. To exercise your rights, please contact us at swisswine@swisswine.uk.

9.10. You also have the right to complain to the Information Commissioner’s Office (ICO) in the UK: www.ico.org.uk.

10. Marketing Communications

10.1. We may send you marketing communications only where permitted by law.

10.2. Where consent is required, we will ask for it before sending marketing emails.

10.3. You can unsubscribe from marketing communications at any time by:

  • clicking the unsubscribe link in a marketing email; or
  • contacting us at swisswine@swisswine.uk.

10.4. If you unsubscribe from marketing, we may still contact you about service-related matters such as orders, returns, legal notices, or account issues.

11. Security

11.1. We take appropriate technical and organisational measures to protect personal data against accidental loss, unauthorised access, alteration, disclosure, or destruction.

11.2. However, no internet transmission or storage system can be guaranteed to be completely secure.

12. Cookies and Similar Technologies

12.1. Our website uses cookies and similar technologies to:

  • make the website function properly;
  • remember your preferences;
  • improve website performance;
  • understand how visitors use the website;
  • support security and fraud prevention.

12.2. Cookies may be:

  • session cookies, which expire when you close your browser; or
  • persistent cookies, which remain on your device for a longer period unless deleted earlier.

ICO’s cookies guidance expects clear explanations of what cookies do, what they are used for, and the consequences of allowing them.

13. Types of Cookies We Use

13.1. Strictly Necessary Cookies

These cookies are essential for the website to function properly. They may be used for:

  • shopping basket functionality;
  • secure checkout;
  • fraud prevention and website security;
  • remembering core session information;
  • storing your cookie consent choices.

13.1.1. We may use strictly necessary cookies without asking for consent where they are genuinely essential for the website or service requested by you.

13.2. Functional Cookies

These cookies help remember your settings and preferences, such as language or interface choices.

13.2.1. Where such cookies are not strictly necessary, we will use them only where appropriate and in line with applicable consent requirements.

13.3. Analytical or Performance Cookies

These cookies help us understand how visitors use our website, for example:

  • which pages are visited most often;
  • how users move through the website;
  • whether users encounter errors.

13.3.1. We use analytical or other non-essential cookies only where you have given consent, if consent is required.

13.4. Third-Party Cookies

Some cookies may be set by third-party services we use, such as payment providers, analytics providers, or embedded services.

13.4.1. Where non-essential third-party cookies are used, we will seek consent where required by law.

Under ICO cookie guidance, valid consent for non-essential cookies must be freely given, specific, informed, and given by a clear affirmative action.

14. Managing Cookie Preferences

14.1. You can manage your cookie choices through our cookie settings tool, where available.

14.2. You can also manage or delete cookies through your browser settings.

14.3. Please note that disabling some cookies may affect the functionality of the website.

14.4. If you withdraw consent for non-essential cookies, we will stop using those cookies going forward, subject to technical limitations and browser/device settings.

15. Changes to This Policy

15.1. We may update this Privacy and Cookie Policy from time to time.

15.2. The latest version will always be published on our website.

15.3. If we make material changes, we may take additional steps to bring them to your attention where appropriate.

16. Contact Us

If you have any questions about this Privacy and Cookie Policy or about how we use your personal data, please contact:

Swiss Wine s.r.o.
Belehradska 858/23
120 00 Prague 2
Czech Republic, EU
Email: swisswine@swisswine.uk