Privacy Policy

PART I. PRIVACY POLICY

1. General Provisions

This Privacy Policy governs the collection, use and protection of personal data provided by users (hereinafter, the “User”) when using the website solowine.es (hereinafter, the “Portal”), in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation, GDPR) and Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD).

By using the Portal and providing their personal data, the User confirms that they have read this Privacy Policy and agree to the processing of their data in accordance with the conditions set out below.

2. Data Controller

Data Controller: NEED FOR WINE, S.L. (trading as SOLO Wine)
Registration: Malaga Commercial Registry, dated 21/11/2023, Volume 6421, Folio 143, Page 177897, Entry 1
Registered office: Polígono Industrial La Campana, nave 80, 29660 Marbella (Málaga), Spain
Tax ID (NIF): B56638158
Email for data protection enquiries: wine@sologroup.net
Phone: +34 952 002 999

3. What Data We Collect

Depending on how the User interacts with the Portal, we may collect the following categories of data:

When registering on the website: full name, email address, and sponsor user's email address (if applicable).

When placing an order: name, telephone number, delivery address, billing address (if different from the delivery address), and message to the recipient (if applicable).

When making a payment: bank card details are processed directly by the payment provider Viva.com (Viva Wallet) and are not transferred to or stored by NEED FOR WINE, S.L.

When participating in the SOLO Wine Club: purchase history, accumulated bonuses, and loyalty programme status.

When submitting product reviews: username and review text, which may be visible to other Portal users.

When subscribing to the newsletter: email address.

Automatically when visiting the website: technical visit data (IP address, browser type, cookies) — see Part II of this document for more information.

When interacting on social networks: publicly available profile information — see the separate Social Media Policy for more information.

4. Purposes of Data Processing

— Registration and management of the User's account on the Portal.
— Processing, delivery and tracking of orders.
— Management of the SOLO Wine Club loyalty programme (crediting and redeeming bonuses).
— Responding to User enquiries, requests and complaints.
— Publication of product reviews.
— Sending news and promotional emails (only with the User's separate consent to subscribe).
— Analysis of website traffic and user behaviour for statistical purposes (Google Analytics).
— Displaying personalised advertising on social networks (Meta Pixel).
— Compliance with the company's tax, accounting and other legal obligations.

5. Legal Basis for Processing

— Performance of a contract: processing data necessary to place and deliver orders, register on the Portal and participate in the loyalty programme.
— User consent: processing data for email newsletters containing news and promotional codes, and use of analytics and advertising cookies (consent may be withdrawn at any time, for example via the unsubscribe link in each email).
— Legitimate interest: ensuring Portal security and preventing fraud.
— Compliance with legal obligations: retention of invoice-related data in accordance with Spanish tax legislation.

6. Who We Share Data With

User data may be shared with the following recipients to the extent necessary to provide the service:

— Transport and courier companies — orders are delivered by SOLO Wine's own courier service and, where necessary, by contracted partner transport companies used for certain regions and countries.
— Viva.com (Viva Wallet) — processing online bank card payments.
— Google LLC (Google Analytics) — website traffic analytics.
— Meta Platforms, Inc. (Meta Pixel) — advertising on Facebook and Instagram.
— Government authorities — where required by law (for example, tax authorities).

NEED FOR WINE, S.L. does not sell or transfer Users' personal data to third parties for commercial purposes unrelated to the provision of Portal services.

7. International Data Transfers

Some of the recipients listed above (in particular Google, Meta and Viva.com) may process data on servers located outside the European Union. Such transfers are carried out on the basis of mechanisms recognised by the European Commission as providing adequate protection for personal data (in particular, EU standard contractual clauses and/or other safeguards provided by the relevant service provider).

8. Data Retention Period

Account data is stored throughout the period during which the User uses the Portal and is deleted upon request, except where legislation requires longer retention (for example, invoice-related data is retained for the periods established by Spanish tax legislation — generally up to 6 years).

Data processed on the basis of consent (marketing communications and analytics) is retained until the User withdraws their consent.

9. User Rights

The User may exercise the following rights at any time in relation to their personal data by sending a request to wine@sologroup.net, specifying the subject of the email and attaching an identity document:

— Access — obtain information about what data is being processed.
— Rectification — correct inaccurate or incomplete data.
— Erasure (“right to be forgotten”) — request deletion of data.
— Restriction of processing — restrict processing in certain circumstances.
— Data portability — receive data in a structured, machine-readable format.
— Objection — object to processing for certain purposes, including direct marketing.
— Withdrawal of consent — withdraw previously given consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.

The User also has the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, www.aepd.es) if they believe their rights have been violated.

10. Age Restrictions

The Portal is intended exclusively for persons over 18 years of age, as the products sold are alcoholic beverages. NEED FOR WINE, S.L. does not knowingly collect data from minors. If a minor's registration is discovered, their account and associated data will be deleted.

11. Data Security

NEED FOR WINE, S.L. applies technical and organisational measures appropriate to the level of risk to protect Users' personal data from unauthorised access, alteration, disclosure or destruction.

12. Changes to the Policy

This Privacy Policy may be updated periodically. The current version is always available on the Portal. We recommend checking its contents regularly.

Last updated: [publication date]

PART II. COOKIE POLICY

A cookie is a small file stored on your device when you visit certain pages of a website. Cookies allow a website, among other things, to store and retrieve information about the behaviour of a user or their device and, depending on the information contained, may be used to recognise the user.

Cookies are an important part of how the modern internet works: they make website navigation easier and improve the user experience.

Types of Cookies

By who sets them
— First-party cookies — set by the website itself to provide the service requested by the user.
— Third-party cookies — set and processed by a third party and are not first-party website cookies.

By duration
— Session cookies — collect data while the user is on the website to provide the requested service.
— Persistent cookies — remain on the device, and the information obtained is used by the cookie owner to provide the requested service over a longer period.

By purpose
— Technical cookies — necessary for the website to function correctly.
— Personalisation cookies — allow the website to take the user's settings into account (for example, language) during navigation.
— Analytics cookies — allow analysis of user behaviour to monitor website usage, statistics on visited sections, number of visitors, etc.
— Advertising cookies — allow advertising blocks to be displayed on the website based on the website's content.
— Behavioural advertising cookies — allow advertising blocks to be displayed based on information about the user's behaviour obtained while browsing.

Managing Cookie Settings

When the User first visits the website, a cookie banner is displayed allowing them to accept all cookies, reject optional categories, or configure consent for individual categories (analytics, advertising, etc.). Settings can be changed at any time through the personal account.

In addition, the User can configure their browser to receive notifications about cookies and prevent them from being installed on the hard drive. Links to cookie settings for popular browsers:

Firefox: http://support.mozilla.org/es/kb/habilitar-y-deshabilitar-cookies-que-lossitios-we
Chrome: http://support.google.com/chrome/bin/answer.py?hl=es&answer=95647
Safari: https://support.apple.com/kb/ph17191?locale=es_ES

Cookies Used on the SOLO Wine Website

In accordance with Article 22.2 of Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI-CE), NEED FOR WINE, S.L. informs Users about the cookies used on the solowine.es website:

Google Analytics — stores cookies to generate traffic and visitor statistics. By using the website, you consent to the processing of information about you by Google. Any rights relating to this processing are exercised directly through Google. Google Analytics cookies are stored on servers located in the United States; the company undertakes not to transfer data to third parties except where necessary for the operation of the system or where required by law. According to Google, the user's IP address is not stored. More information can be found here: https://support.google.com/analytics/answer/6004245

If desired, you can use the browser add-on to disable Google Analytics: https://tools.google.com/dlpage/gaoptout

Meta Pixel (Facebook Pixel) — used to measure the effectiveness of SOLO Wine advertising on Meta social networks (Facebook and Instagram) and to display personalised advertising based on user behaviour on the website. Data processing is carried out by Meta Platforms, Inc. in accordance with its privacy policy: https://www.facebook.com/privacy/policy/

Last updated: 25.09.2026