Privacy Policy

a) Membership data:

• First and last name
• Email address
• Phone number (optional)
• Date of birth (for age verification)
• Postal address (optional)

b) Profile and portal data:

• Profile photos and uploaded images (up to 10 photos)
• Profile description and personal details voluntarily provided by the Member
• Messages and interactions with other Members through the portal
• Wine Vault storage data (product names, quantities, values)

c) Technical and usage data:

• IP address and browser information
• Device type and operating system
• Access timestamps and page views
• Online status ("Last seen" timestamp) to improve member interaction
• Cookie data in accordance with our cookie policy

d) Payment data:

• Payment information is processed and stored exclusively by the payment service provider Stripe, Inc.
• We only receive a transaction confirmation from Stripe, the last four digits of the card number, and the payment status – no complete credit card or bank data.

• Contract performance (Art. 6(1)(b) GDPR): Management of membership, provision of the portal, payment processing, Wine Vault management.
• Legitimate interests (Art. 6(1)(f) GDPR): Improvement of our services, platform security, fraud prevention, online status display to foster member interaction.
• Consent (Art. 6(1)(a) GDPR): Marketing communications, newsletters, non-essential cookies.
• Legal obligations (Art. 6(1)(c) GDPR): Fulfilment of tax and commercial record-keeping requirements.

We share personal data with the following categories of recipients:

• Stripe, Inc. (USA) – Payment processing. Stripe is certified under the EU-US Data Privacy Framework.
• Amazon Web Services (AWS) – Cloud hosting and file storage. Data processing within the EU (eu-west region).
• Abacus.AI – Technical platform infrastructure.
• Partners/Bodegas – Transaction-related data only (name, delivery address), as required for order fulfilment.

• Profile information and photos are visible to all registered Members.
• The online status ("Last seen") may be visible to other Members.
• ATKINSKY S.L. has no control over how other Members use shared information and therefore assumes no liability for misuse by other Members.
• Each Member is personally responsible for deciding which personal data to share on the portal.

Our website uses:

• Technically necessary cookies: Required for the functioning of the website and members portal (session management, authentication, language settings). Legal basis: Art. 6(1)(f) GDPR.
• Online status tracking: We record the timestamp of the last access ("LastSeenAt" timestamp) of logged-in Members. This serves to improve interaction in the members portal. Legal basis: Art. 6(1)(f) GDPR (legitimate interest).

• Membership data: For the duration of membership and subsequently for the legally required retention period (in Spain: 6 years under Art. 30 Código de Comercio for business records; 4 years for tax-relevant data).
• Profile photos and portal content: Until deletion by the Member or until termination of membership.
• Technical log data: Maximum 90 days.
• Payment data at Stripe: According to Stripe's retention policies and legal requirements.

Under the GDPR and LOPDGDD, you have the following rights:

• Right of access (Art. 15 GDPR): You may request information about your stored personal data.
• Right of rectification (Art. 16 GDPR): You may request the correction of inaccurate data.
• Right of erasure (Art. 17 GDPR): You may request deletion of your data, provided no legal retention obligations apply.
• Right to restriction of processing (Art. 18 GDPR): You may request restriction of processing.
• Right to data portability (Art. 20 GDPR): You may receive your data in a structured, commonly used format.
• Right to object (Art. 21 GDPR): You may object to processing based on legitimate interest.
• Withdrawal of consent: Consent given may be withdrawn at any time with effect for the future.