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Privacy Policy

1. Introduction

Depot Noir B.V. (“Depot Noir”, “we”, “our”, “us”) is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, and share your personal data when you use our website, subscription services, and related offerings (“Services”).

We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Dutch GDPR Implementation Act (UAVG).

By using our Services, you acknowledge that you have read and understood this Privacy Policy.

 

2. Personal Data We Collect

When you use our Services, we may collect the following categories of personal data:

2.1. Information you provide directly

  • Name and contact details (name, email address, phone number, billing/shipping address)

  • Account details (username, password)

  • Payment details (processed securely by third-party payment providers – we do not store full card details)

2.2. Information collected automatically

  • Device and browser information (IP address, browser type, device type, operating system)

  • Usage data (pages visited, time spent on our website, interactions with our Services)

  • Cookies and tracking data (see Section 6)

 

3. Purposes of Processing

We process personal data for the following purposes:

  • To create and manage your account and subscription

  • To process orders, payments, and deliveries

  • To provide customer service and respond to inquiries

  • To send you transactional and service-related communications

  • To send promotional communications, only if you have explicitly opted in (e.g. newsletter sign-up)

  • To comply with legal and regulatory obligations (e.g. tax, bookkeeping, age verification)

  • To improve our website, products, and services

 

4. Legal Basis for Processing

We process your personal data on the following legal bases under the GDPR:

  • Performance of a contract (Article 6(1)(b)): to deliver Services, manage subscriptions, and process payments.

  • Legal obligation (Article 6(1)(c)): to comply with Dutch and EU laws (e.g. tax, consumer protection, alcohol regulations).

  • Legitimate interests (Article 6(1)(f)): to improve our Services, prevent fraud, ensure security.

  • Consent (Article 6(1)(a)): for marketing communications and non-essential cookies. You may withdraw consent at any time.

5. Sharing of Data

We do not sell or rent your personal data. We only share data with:

  • Service providers (IT hosting, payment processors, logistics partners, marketing tools) under strict data processing agreements.

  • Legal authorities if required by law or necessary to protect our rights.

  • Depot operators for the purpose of storing and managing your wines.

All third parties are contractually bound to handle your data securely and in compliance with the GDPR.

6. Cookies and Tracking

We use cookies and similar technologies to:

  • enable website functionality,

  • analyze website traffic,

  • personalize your experience,

  • and (with your consent) deliver targeted marketing.

You can manage or disable cookies through your browser settings. 

 

7. Data Retention

We retain personal data only as long as necessary to fulfil the purposes outlined in this Policy:

  • Account and transaction data: retained for up to 7 years in line with Dutch tax law.

  • Marketing data: retained until you withdraw consent or unsubscribe.

  • Other data: deleted or anonymised once no longer necessary.

8. Your Rights (EU/EEA Residents)

You have the following rights under the GDPR:

  • Access: request a copy of your personal data.

  • Rectification: correct inaccuracies.

  • Erasure (“right to be forgotten”): request deletion where legally possible.

  • Restriction: limit processing in certain cases.

  • Portability: receive your data in a machine-readable format.

  • Objection: object to processing based on legitimate interests or direct marketing.

  • Withdraw consent: where processing is based on consent (e.g. marketing).

You can exercise these rights by contacting us (see Section 10). We will respond within 30 days.

You also have the right to lodge a complaint with the Autoriteit Persoonsgegevens (Dutch Data Protection Authority).

9. Data Security

We implement appropriate technical and organisational measures to protect your personal data, including encryption, secure servers, and access controls. However, no method of transmission or storage is 100% secure.

10. Contact

If you have questions or wish to exercise your rights, contact us:

Depot Noir B.V.
Zandhoek 10h

1013 KT Amsterdam
The Netherlands
Email: info@depotnoir.com

 

11. Changes to This Policy

We may update this Privacy Policy from time to time. If we make significant changes, we will notify you via email or another durable medium at least 14 days before they take effect. Continued use of our Services after changes take effect means you accept the updated Policy.

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