Policy for the protection of your personal data

Download the policy for the protection of your personal data.

Policy for the protection of personal data

Website https://u.wine and « U’WINE » Application

Data controller : U’WINE SAS — RCS Bordeaux n°522 015 692 — 13 allées de Chartres, 33000 Bordeaux — contact@uwine.fr — +33 (0)5 35 54 61 39

Data Protection Officer (DPO) : Appointed in accordance with article 37 of the GDPR. Contact : admin@uwine.fr or letter to the attention of the U’Wine IT Department, 13 allées de Chartres, 33000 Bordeaux.

U’WINE SAS is an intermediary in miscellaneous assets (art. L. 550-1 I of the French Monetary and Financial Code). Its information documents are registered with the AMF under nos. D-17-01 and D-23-01. The processing of your data in the context of the Cave INVEST and Cave CONSO offers is carried out in strict compliance with the GDPR and the French Data Protection Act.

1. Definitions

2. Personal data collected

We collect only the data necessary for each of our purposes, in accordance with the principle of minimisation (art. 5 GDPR) :

2.1 Data common to all Users

•     Identity data : title, birth name, name in use, first name, date of birth, nationality, marital status, address of tax residence, telephone, email, internal identifier.
•     Browsing data : IP address, browsing history and origin, browser, operating system, time of requests.
•     Transaction data (online shop) : products purchased, amounts, payment methods, billing and delivery addresses, transaction number.
•     Preference data : wine preferences (type, regions, vintages, packaging), favourites, quiz, delivery thresholds.
•     Wine stock and consumption data (via the NFC tag and the App).

2.2 Data specific to the Cave INVEST and Cave CONSO offers

•     Customer knowledge questionnaire : knowledge and experience of wine, investment objectives (Pure Investor, Investor-Consumer, Consumer-Investor), risk tolerance, investment horizon, share of the investment in the estate.
•     Financial data : annual commitment amounts, schedule of calls for funds, portfolio profile (Rising Stars, Famous Seconds, Legends), total investment amount.
•     SEPA direct debit mandate data : IBAN, BIC code, unique mandate reference (UMR), number of the underlying contract.
•     Identity document (photocopy) : in the context of the Cave INVEST mandate, the exercise of rights and the obligations to combat money laundering and the financing of terrorism.
•     Data relating to co-subscribers and beneficial owners : contact details, share of the joint ownership, contact details of the joint ownership manager.
•     Portfolio data : composition, B2B and B2C valuations, gross and net performance, status of the bottles (in barrel, in stock, on sale, sold, delivered), annual management reports, investor account.
•     Data relating to the warehouse keeper : storage and inventory information communicated to the company Dartess (Blanquefort) and insurance data.
•     Opt-in consent to commercial communications (Events, Shop, News).
•     Information on the business introducer or the referrer, where applicable.

Principle of minimisation : We collect only the data strictly necessary for each purpose. You will be informed of the mandatory or optional nature of the information requested.

3. Purposes and legal bases of the processing

3.1 Processing common to all activities

3.2 Processing specific to the Cave INVEST and Cave CONSO offers

Profiling (art. 22 GDPR) : U’WINE may use recommendation algorithms to personalise your experience (wine selection, cellar profile suggestions). This processing is based on your consent and has no significant legal effect. You may object to it via your personal area or by contacting the DPO.

4. Times of collection

We collect your data during the following interactions :

•     Visit to the Site or the Application (cookies, trackers).
•     Creation of a user account.
•     Any contact by email or telephone.
•     Purchase in the online shop.
•     Completion of the customer knowledge questionnaire (Caves U’WINE).
•     Online appointment booking to discover the investment offers.
•     Subscription to a Cave INVEST and/or Cave CONSO mandate (particular conditions, annexes, joint ownership agreement where applicable).
•     Signature of the SEPA direct debit mandate.
•     Receipt of the annual management reports, sale transactions or delivery of bottles.
•     Participation in an event, competition or survey organised by U’WINE.

5. Retention periods

At the end of these periods, your data are deleted or irreversibly anonymised, save for a legal obligation, legal action or ongoing dispute.

6. Recipients of the data

Your data are processed internally by authorised persons. They may also be transmitted to :

6.1 Common recipients

•     Technical processors (hosting, CRM, authentication, payment, emailing) — bound by a contract compliant with art. 28 GDPR.
•     Social network partners (Meta, LinkedIn, YouTube) for advertising campaigns and sharing buttons — on the basis of your consent.
•     Legal and judicial authorities where the law so requires.

6.2 Recipients specific to the Cave INVEST and Cave CONSO offers

•     Company Dartess (warehouse keeper) — 53 rue du Déhez, 33290 Blanquefort : Cave INVEST and Cave CONSO Investors enter directly into a storage contract with Dartess. The data necessary for the individualisation of the bottles and for the annual inventories are transmitted to it.
•     Other warehouse keeper of U’Wine.
•     In certain cases, distribution partners for offering the bottles for sale on the Investor’s mandate.
•     Autorité des Marchés Financiers (AMF) and financial supervisory authorities in the context of regulatory obligations.
•     Independent expert (Mr Aymeric de Clouet, wine expert with the Paris Court of Appeal) for the audit of the portfolios.
•     Accountants (We Doo Accounting, Angers) and Statutory Auditor (Exco Ecaf, Mérignac) for the certification of the annual inventories.
•     Insurers : AXA Agency – Clauzel et Clauzel (civil liability) and TOKIO MARINE EUROPE S.A. (goods stored outside Dartess).
•     Authorised business introducers and referrers, solely for the data strictly necessary to their assignment.
•     Subsidiaries and affiliated companies (e.g. U’Wine Grands Crus SCA) — subject to your consent where required.
  

Important : We never sell your data to third parties. Every processor is bound by a contract compliant with article 28 of the GDPR.

7. Transfers outside the European Union

Certain providers or partners are established outside the EU. Transfers are governed as follows :

EU-US Data Privacy Framework : Transfers to Google LLC (Google Analytics) and Algolia Inc. are covered by the adequacy decision of the European Commission of 10 July 2023.

For wines stored at the Geneva Freeports (Cave INVEST option) or distributed through international partners (e.g. Wine World in China), transfers to countries without an adequacy decision are governed by Standard Contractual Clauses (SCC) in accordance with article 46 of the GDPR. You will be informed of any new significant transfer.

8. Cookies and trackers

When browsing our Site, cookies and trackers may be placed on your device.

Cookies subject to prior consent :

•     Social network cookies (Facebook, LinkedIn, YouTube, Instagram)
•     Audience measurement trackers (Google Analytics, Algolia)
•     Personalisation and recommendation cookies

Cookies exempt from consent :

•     Storage of cookie preferences, authentication, shopping basket, load balancing.

On your first connection, a banner allows you to accept or refuse non-essential cookies. Your choice is kept for 6 months and can be changed at any time via the button at the bottom right of the Site.

9. Technical security of the data

U’WINE implements measures appropriate to the sensitivity of the data processed, in particular in the context of the investment mandates :

•     TLS/SSL encryption (HTTPS) of all communications.
•     Secure access to the Investor’s personal area for consulting the portfolio, the valuations and the management reports.
•     Strict control of internal access : only authorised persons process the financial and contractual data.
•     Segregation of client funds : sums paid by investors are collected in a dedicated bank account, separate from U’WINE SAS’s own assets.
•     Regular security audits and controls of processors.
•     Notification of breaches (art. 33-34 GDPR) : notification to the CNIL within 72 hours and information of the data subjects where the risk is high.

10. Your rights

In accordance with the GDPR and the French Data Protection Act, you have the following rights :

Processing times : 1 month (simple request), 3 months (complex request). Proof of identity required. Requests are free of charge, save in the event of manifest abuse.

Exercising your rights

• By email : admin@uwine.fr 
• By post : 13 allées de Chartres, 33000 Bordeaux — « For the attention of the DPO »
• By telephone : +33 (0)5 35 54 61 39 (Mon–Fri, 9 a.m.–6 p.m.)
• Complaint to the CNIL (if dissatisfied) : cnil.fr — 3 place de Fontenoy, 75007 Paris

11. Protection of minors

The Site, the Application and the Cave INVEST and Cave CONSO offers are reserved exclusively for persons of full age (18 years or over). The sale of alcohol to minors is prohibited (art. L.3342-1 and L.3353-3 of the French Public Health Code). Proof of majority is required for any online purchase and upon subscription to an investment mandate.
U’WINE does not knowingly collect any data relating to a minor. In the event of unintentional collection, the data will be deleted upon notification.

12. Update of this policy

U’WINE reserves the right to amend this policy in order to keep it up to date in the light of developments in its activities (including the Cave INVEST and Cave CONSO offers), of data protection regulation and of the AMF’s requirements. Any substantial amendment will be notified by email and/or via a banner on the Site.

Date of this version : Avril 2026