Privacy Policy

Last updated: February 2025

1. Introduction

This Privacy Policy describes how ENOLOGY LAB (“Company”, “we”, “us”, or “our”) collects, uses, and protects personal data when using the Wine e-Labels platform.

The platform consists of three distinct components:

Each component is designed with different functionality and data processing behavior, as described below.

2. Public e-Label Pages (QR Code Pages)

Public e-label pages are designed to comply with EU Regulation 2021/2117.

✔ No Tracking Policy

When a consumer accesses a public e-label page:

  • No analytics tools are used
  • No user tracking is performed
  • No personal data is collected
  • No profiling or behavioral monitoring occurs
  • No marketing or advertising technologies are used

These pages are delivered through a privacy-first architecture that prevents any tracking scripts or third-party analytics from executing.

These pages are designed specifically for consumer access via QR codes on wine labels. No personally identifiable information is collected when accessing public e-label pages.

3. Technical Requests & Infrastructure

Public pages may perform strictly necessary technical requests in order to function, such as:

  • Fetching product data (e.g. ingredients, nutritional values)
  • Loading images and interface assets
  • Security protection mechanisms (e.g. bot protection, anti-abuse systems)

These processes:

  • Do not identify the user
  • Do not store personal data
  • Are strictly necessary for service delivery

4. Cookies & Browser Storage

Public e-label pages

Public e-label pages:

  • Do not use tracking cookies
  • Do not use analytics cookies
  • Do not use advertising cookies

The platform may use local browser storage (e.g. localStorage or sessionStorage) exclusively for functional purposes.

Specifically:

The platform may store a language preference locally in the user’s browser to ensure correct display of content. This does not involve tracking or identification of the user.

This information:

  • Remains entirely within the user’s browser
  • Is not transmitted to the server
  • Is not shared with third parties

5. Main Website & User Accounts (wine-elabels.eu)

When using the main website or creating an account, we may collect:

  • Name
  • Email address
  • Company details
  • Billing information

Purpose of processing:

  • Account creation and management
  • Subscription handling (via Paid Memberships Pro / payment providers)
  • Service access and usage
  • Customer support and communication

6. Application Dashboard (app.wine-elabels.eu)

The application dashboard allows users to create and manage e-labels.

Data processed:

  • User account data (via secure authentication)
  • Label content created by the user (product data, ingredients, etc.)

Important:

  • Authentication is handled securely (via SSO or equivalent mechanisms)
  • The dashboard is not publicly accessible
  • Any data processed here is under user control

We process personal data based on:

  • Contractual necessity — to provide the service
  • Legal obligation — for invoicing and regulatory compliance
  • Legitimate interest — for system security and integrity

We do not rely on consent for tracking, as no tracking is performed on public pages.

8. Data Retention

We retain personal data only for as long as necessary:

  • To provide the service
  • To comply with legal obligations (e.g. tax and accounting)
  • To resolve disputes and enforce agreements

9. Data Sharing

We may share data only with necessary service providers, such as:

  • Hosting and infrastructure providers
  • Payment processors
  • Technical service providers

We do not sell or share personal data for advertising or marketing purposes.

10. International Transfers

Data may be processed within the European Union or in jurisdictions with appropriate data protection safeguards.

11. Your Rights

Under GDPR, you have the right to:

  • Access your personal data
  • Correct inaccurate data
  • Request deletion of your data
  • Restrict processing
  • Object to processing

You may exercise your rights by contacting us at:
enologylab@gmail.com

12. Security

We implement appropriate technical and organizational measures to ensure the security of personal data and prevent unauthorized access, disclosure, or alteration.

13. Children’s Privacy

This service is not intended for individuals under the age of 18.

The service may contain links to external websites. We are not responsible for their content or privacy practices.

15. Changes to this Policy

We may update this Privacy Policy from time to time. Updates will be posted on this page with a revised “Last updated” date.

16. Contact

If you have any questions about this Privacy Policy:

📧 Email: enologylab@gmail.com
🌐 Website: https://wine-elabels.eu

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