Effective Date: September 29, 2025

1. Introduction Selection Sommelier (“we”, “us”, or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our website sommeliersecret.com or services (collectively, the “Services”). It also outlines your rights and choices regarding your personal data. We comply with applicable data protection laws, including the EU General Data Protection Regulation (GDPR), which requires transparency about how personal data is handled. Please read this Policy carefully to understand our practices. By using our Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please discontinue use of our Services. We may update this Privacy Policy from time to time. If we make material changes, we will notify you by updating the Effective Date above and, if appropriate, through additional notification (such as a notice on our website or an email notification). We encourage you to review this Policy periodically for any updates.

2. Information We Collect We may collect several types of information from and about users of our Services, including: Personal Information You Provide: Information you voluntarily provide to us, for example:

  • Contact details: such as your name, email address, phone number, postal address, or other contact information (for instance, when you fill out a form, register an account, or contact customer support).
  • Account information: if you create an account, we may collect login credentials (like username) and other information related to your account profile.
  • Transaction information: if our website offers wine products or services for purchase, we collect information related to your orders and purchases (e.g., items purchased, order dates) and necessary information to process payments (however, credit card numbers or payment details are typically handled by secure third-party payment processors, not stored on our systems).
  • Communications: any information you provide in communications with us, such as through emails, customer support inquiries, or feedback forms.

Information We Collect Automatically: When you interact with our Services, we automatically collect certain information about your device and usage:

  • Usage data: such as IP address, browser type, device type, operating system, referring URLs, pages viewed, links clicked, and the date/time of your visit. This data helps us analyze how our Services are accessed and used, enabling us to improve performance and user experience.
  • Cookies and similar technologies: We use cookies, web beacons, and similar tracking technologies to remember your preferences and track your usage of our Services. Cookies are small text files placed on your device that help us recognize you on future visits, personalize content, and analyze site traffic. For detailed information on how we use cookies and how you can manage them, please see the Cookies and Tracking section below.

Information from Third Parties: We may receive information about you from third parties, such as:

  • Service providers: If you interact with third-party services integrated with our site (for example, a third-party login or payment gateway), they may share certain information with us as needed (e.g., confirmation of payment).
  • Analytics providers: We use analytics tools that collect information on our behalf about your interactions with our Services. This helps us understand website traffic and usage patterns.

We limit our collection of personal information to what is necessary for the purposes set out in this Privacy Policy. You may choose not to provide certain information; however, this may limit your ability to use some features of our Services.

3. How We Use Your Information We use the personal information we collect for various purposes, in accordance with applicable laws. These purposes include: Providing and Improving Services: To operate and maintain our website and Services, to process your requests, orders, or transactions, and to develop new features and enhancements. For example, we use your information to fulfill wine purchases you make and to personalize your experience on our site. Communication: To communicate with you about your account, transactions, or customer support inquiries. We may send you service-related announcements and respond to your comments, questions, and requests when you contact us. Marketing and Promotional Activities: To send you newsletters, offers, promotions or information about our wine products or services, but only if you have opted to receive such communications. You can opt-out of marketing emails at any time. Analytics and Personalization: To analyze usage of our Services and conduct research on our user base. This helps us understand user behavior and preferences, so we can improve our content and layout. Legal and Security: To enforce our Terms and Conditions and other agreements; to detect, prevent, or investigate fraudulent or illegal activities, security incidents, or misuse of our Services; and to protect the rights, property, or safety of Selection Sommelier, our users, or others. Compliance with Legal Obligations: To comply with any applicable laws and regulations, or to respond to lawful requests from authorities where we are compelled to do so.

4. Legal Bases for Processing (for EU/UK Users) If you are in the European Economic Area (EEA), United Kingdom, or another jurisdiction that requires a legal basis for processing personal data, we process your personal information under the following legal bases, as appropriate: Contractual Necessity: We process certain personal data to perform a contract with you or to take steps at your request prior to entering into a contract. For example, when you place an order on our Site, we process your contact and payment information to fulfill that purchase contract. Legitimate Interests: We process personal data as needed for our legitimate interests, provided that our interests are not overridden by your data protection rights. Our legitimate interests may include: improving and personalizing our Services; communicating with you about relevant products or services; preventing fraud or misuse; and ensuring the security of our systems. Legal Obligation: In some cases, we need to process personal data to comply with a legal obligation to which we are subject. Consent: Where required by law, we will obtain your consent before collecting or using certain personal data. If you have questions about the legal bases on which we collect and use your personal information, please contact us.

5. Cookies and Tracking Technologies We use cookies and similar tracking technologies to enhance your experience on our Site. This section explains what these technologies are and why we use them, as well as your choices for controlling them. What are Cookies? Cookies are small text files that websites place on your device when you visit. They are widely used to make websites work or to work more efficiently, as well as to provide reporting information to the site owners. Types of Cookies We Use:

  • Essential Cookies: These are necessary for the Site to function properly and are always enabled.
  • Analytics and Performance Cookies: These cookies collect information about how visitors use our Site to help us improve performance.
  • Functional Cookies: These cookies allow the Site to remember choices you make and provide enhanced, more personalized features.
  • Advertising/Targeting Cookies: We may use cookies to collect information about your browsing habits to make advertising more relevant to you.

Your Choices: Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. However, please be aware that disabling certain cookies may affect the functionality of our Site.

6. How We Share Your Information We understand the importance of keeping your personal information confidential. We will not sell or rent your personal data to third parties. However, we may share your information with certain categories of recipients in the following circumstances: Service Providers: We may disclose personal information to third-party companies that perform services on our behalf, such as website hosting, data analytics, payment processing, order fulfillment, email delivery, and customer support. Business Transfers: If Selection Sommelier is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of such a transaction. Legal Requirements and Protection: We may disclose your information if required to do so by law or to protect and defend our rights, property, or safety. With Your Consent: We will share your personal information with third parties when we have your consent to do so.

7. International Data Transfers Selection Sommelier is based in France. The personal information we collect is stored and processed primarily within the European Economic Area (EEA). However, we may use third-party service providers (such as website hosts or payment processors) that are based in other countries, including the United States. If your personal data is transferred to a country outside the EEA, we will ensure that appropriate safeguards (such as Standard Contractual Clauses) are in place to protect your information in compliance with GDPR.

8. Data Retention We will retain your personal information only for as long as necessary to fulfill the purposes for which we collected it, as described in this Privacy Policy, and for as long as we have a lawful basis for doing so.

9. Data Security We take the security of your personal information seriously. We implement a variety of technical, administrative, and physical security measures designed to protect your data from unauthorized access, disclosure, alteration, or destruction.

10. Your Rights and Choices You have certain rights regarding your personal data, particularly if you are located in the European Union, United Kingdom, or other jurisdictions with similar data protection laws. These rights may include:

  • Right of Access
  • Right of Rectification
  • Right to Erasure
  • Right to Restrict Processing
  • Right to Data Portability
  • Right to Object
  • Right to Withdraw Consent
  • Right to Lodge a Complaint

To exercise any of your rights, please contact us using the contact information provided below.

11. Children’s Privacy Our Services are not directed to children under the age of 13 (and in certain jurisdictions, under the age of 16), and we do not knowingly collect personal information from children in these age groups without verifiable parental consent.

12. Third-Party Websites and Services Our website may contain links to third-party websites that are not operated by us. This Privacy Policy does not apply to your activities on third-party websites.

13. Changes to this Privacy Policy We may modify this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors.

14. Contact Us If you have any questions, concerns, or requests regarding this Privacy Policy or our data handling practices, please contact us: Email: info@sommeliersecret.com Phone: +1 (409) 941-7254 WhatsApp: +1 (409) 941-7254 WeChat: Marco3866 French Office: Selection Sommelier 27 rue de la ronzy 38640 Claix France