Privacy Policy UK

Your data and our website

How does it work?

Transparency first of all!

We will only use your data to allow you to use our website.

On this page you will find all the information relating to the processing of your personal data: where, when, how and why we process your data, as well as the list of your rights.

Your data will not be sold or transferred to third parties

Your data (that is, the data you entrust to us) will only be used by xtraWine UK Ltd.

We undertake never to sell or transfer your data.

Where in some cases we use external providers, please be aware that they will only act on our behalf and in accordance with our instructions.

How to contact us

The Data Controller is xtraWine UK Ltd, with registered office in 16 Albemarle St., London, United Kingdom, W1S 4HW.

You can contact us at any time by writing to the address privacy@xtrawine.com.

Website Privacy Policy

Full Privacy Notice

Last updated: 12/10/2026

Why this Privacy Notice?

This privacy notice informs you, in compliance with the UK GDPR and the Data Protection Act 2018, about how we collect, use, share and store the personal data provided and/or collected through the Website www.xtrawine.com/uk, as described below.

This is a privacy notice provided by xtraWine UK Ltd as Data Controller.

What information do we collect, for what purposes, on what legal bases, and for how long do we retain your data?

Purpose of registration to the site and management of purchases
The data collected pursuant to this paragraph will be collected and processed in order to allow a person to register on the Site by creating an account on the same, as well as, following registration, to allow you to access your private area on the Site and to purchase online the products offered by xtraWine UK Ltd.
Types of data processed
  • first name, surname;
  • telephone number;
  • e-mail address;
  • address for dispatch;
  • payment methods and details;
  • billing address;
  • billing data.
Lawful basis for processing
  • the processing is necessary to perform a contract between the data subject and the Controller.
Retention period
  • The registration data will be kept until the account is deleted by the person to whom it relates.
  • Data relating to purchases made will be kept for a maximum of 10 years from the date of purchase. This storage period may be extended where necessary to comply with a legal obligation to which xtraWine UK Ltd is subject, or to protect a right before a competent authority.
Purchase of “Xperience” Vouchers – wine tourism experiences

Through the Site it is possible to purchase Vouchers entitling the holder to enjoy wine tourism experiences (e.g. tastings, winery visits) organised and provided by partner wineries (“Partner Wineries”). The data collected pursuant to this paragraph will be processed in order to manage the order, issue and send the Voucher with its unique code and the booking instructions, handle any exercise of the right of withdrawal and prevent fraud.

For the issue and management of the Voucher, xtraWine UK Ltd communicates to the Partner Winery only the order number, the order date and the Voucher code, without any data allowing the purchaser to be directly identified. The Partner Winery only informs xtraWine UK Ltd that the Voucher has been used. The Partner Wineries may be established in Italy or in other countries of the European Economic Area, which are covered by UK adequacy regulations under section 17A of the Data Protection Act 2018.

Booking and enjoyment of the experience take place directly with the Partner Winery, which processes any personal data collected at that stage (e.g. participants’ data, any food allergies or intolerances) as an independent data controller, providing its own privacy notice. xtraWine UK Ltd does not receive such data.

The Voucher may be transferred to third parties outside the Site: xtraWine UK Ltd does not collect the beneficiary’s data. The page of the Site that allows the instructions to be viewed by entering the Voucher code does not require any personal data to be entered.

Types of data processed
  • first name, surname;
  • e-mail address;
  • telephone number;
  • billing address and billing data;
  • payment methods and details;
  • order number and date, Voucher code and its usage status;
  • declaration of legal age.
Lawful basis for processing
  • the processing is necessary to perform a contract between the data subject and the Controller (Article 6(1)(b) UK GDPR), for the management of the order and the issue of the Voucher;
  • the processing is necessary to comply with a legal obligation to which the Controller is subject (Article 6(1)(c) UK GDPR), e.g. tax and accounting obligations under UK law;
  • the legitimate interests of the Controller (Article 6(1)(f) UK GDPR) in preventing fraud and protecting its legal rights.
Retention period
  • Data relating to Voucher purchases will be kept for a maximum of 10 years from the date of purchase. This storage period may be extended where necessary to comply with a legal obligation to which xtraWine UK Ltd is subject, or to protect a right before a competent authority.
Customer Care
The personal data provided by the data subject through the sending of e-mails, filling in forms on the site, or contact via chat will be processed for the sole purpose of providing a response to requests sent to xtraWine UK Ltd.
Types of data processed
  • Personal data provided voluntarily;
  • first name, surname;
  • contact details;
  • telephone number;
  • e-mail address;
  • address.
Lawful basis for processing
  • The data subject has given consent to the processing of his or her personal data for one or more specific purposes.

In particular, the fact that the data subject decides to contact us by submitting a request will be considered an unequivocal positive action equivalent to written consent.

Retention period The data processed pursuant to this paragraph will be kept for the period strictly necessary to provide a response to the requests of the data subjects. This period may be extended where necessary to comply with legal obligations, or to protect a right before a competent authority.
Newsletter
The data collected pursuant to this paragraph will be processed in order to send marketing communications relating to products, services and offers.
Types of data processed e-mail address, telephone number and postal details provided at the time of signing up to the Newsletter or when purchasing a product or service.
Lawful basis for processing
  • the legitimate interest of the Controller, in the case of communications to customers regarding products or services similar to those already purchased, in accordance with the soft opt-in exemption under Regulation 22(3) of the Privacy and Electronic Communications Regulations 2003 (PECR), provided a simple means of opting out is offered with each communication; or
  • the consent of the data subject (Article 6(1)(a) UK GDPR), expressed by means of a dedicated checkbox at the time of sign-up.
Retention period
  • The data is retained until consent is withdrawn, which can be exercised through the opt-out option provided at the bottom of each communication sent.
  • In the event of continuous inactivity for 90 days (no opening of, or interaction with, communications), the data subject is automatically excluded from further mailings, without prejudice to the possibility of reactivation in the event of a new purchase or new consent.
Profiling for marketing purposes
Subject to consent, the data collected may also be processed for profiling purposes, in order to personalise marketing communications and to analyse the purchasing habits and interests of the user.
Types of data processed
  • personal identification data;
  • purchase frequency and behaviour;
  • product preferences;
  • data relating to the Newsletter sign-up.
Purpose of processing
  • personalisation of Newsletter content;
  • internal commercial analysis;
  • customer care assistance.
Lawful basis for processing
  • Specific consent of the data subject (Article 6(1)(a) UK GDPR), expressed by means of a dedicated checkbox at the time of sign-up.
Automated decision-making This profiling activity does not amount to a significant decision based solely on automated processing within the meaning of Articles 22A-22D UK GDPR (as introduced by the Data (Use and Access) Act 2025, in force since 5 February 2026), as it does not produce a legal or similarly significant adverse effect on the data subject.
Retention period
  • The data is retained until consent is withdrawn, which can be exercised through the opt-out option provided at the bottom of each communication sent.
  • In the event of continuous inactivity for 90 days (no opening of, or interaction with, communications), the data subject is automatically excluded from further mailings, without prejudice to the possibility of reactivation in the event of a new purchase or new consent.
Chatbot – Sommelier & Help

Where data subjects use the “Sommelier & Help” chatbot – a tool based on Artificial Intelligence – the personal data provided in the chat may be processed in order to:

  • verify the status of an order, where the user spontaneously provides their e-mail address and order number in the chat;
  • put the user in contact with a customer care operator, upon explicit request or when necessary;
  • answer frequently asked questions (FAQs) relating to the website and the services offered;
  • provide wine-related suggestions and food-pairing advice;
  • share general information about the products and services offered by the Controller.

The chatbot replies automatically, without human intervention; a customer care operator monitors the conversations and intervenes, in particular when the user explicitly requests human support.

Where an operator is not available, the request is forwarded to the general mailbox info@xtrawine.com.

Types of data processed
  • identification data voluntarily provided by the user (e.g. name, e-mail address, order number)
  • free-text content typed in the chat window, which may contain personal data or references to orders
  • contact details (e.g. e-mail)
  • order-related data
  • information relating to wine preferences
  • essential technical data (e.g. date and time of the interaction, referring URL)
Lawful basis for processing
  • performance of a contract, where the request is functional to the management of an order;
  • implicit consent, where the user interacts with the chatbot to obtain general information or voluntary support.
Retention period
  • Chats are retained for a period of 3 years, for the purpose of responding to user requests.
  • Technical logs relating to the operation of the system (e.g. times, interactions, errors) may be retained for a period of 4 weeks, for security, auditing and monitoring purposes.

 

Purpose of navigation on the site

The computer systems and software procedures used to operate this site acquire, in the course of their normal operation, some personal data whose transmission is implied by the use of Internet communication protocols.

These data, necessary for the use of web services, are also processed for the purpose of:

  • obtaining statistical information on the use of services (most visited pages, number of visitors per time or day, geographical areas of origin, etc.);
  • checking the proper functioning of the services offered.
Types of data processed
  • IP addresses or domain names of the computers and terminals used by users;
  • the addresses in URI/URL (Uniform Resource Identifier/Locator) notation of the resources requested;
  • the time of the request;
  • the method used to submit the request to the server;
  • the size of the file obtained in response;
  • the numerical code indicating the status of the response given by the server (successful, error, etc.);
  • other parameters relating to the user’s operating system and computer environment.
Lawful basis for processing
  • the processing is necessary to fulfil a legal obligation to which the Controller is subject;
  • the processing is necessary to pursue the legitimate interest of the Controller in ensuring the security and usability of the website.
Retention period The navigation data does not persist for more than seven days (save for any need to establish offences by the judicial authority).

 

Cookie

The Cookie Policy of the site is accessible here.

Social button

Our website features social buttons.

Social buttons are digital buttons, i.e. direct links to the platforms of the Social Networks configured in each individual “button”.

By clicking on these links, you will be able to interact directly with our accounts (social pages).

The operators of the Social Networks to which the buttons refer are autonomous data controllers. More information on the individual privacy policies of the Social Network platforms, and on how to manage and disable the related cookies, can be found on the Social Network platforms themselves.

Payment card details

To make a payment, the user enters the confidential payment card data directly on a page that communicates via a secure encryption protocol with the payment service provider – which acts as an autonomous data controller – without passing through the servers of xtraWine UK Ltd, which therefore does not process such data in any way. The data is collected in encrypted format.

With regard to the processing of payment card data, please note that this is necessary to allow the conclusion of the online purchase contract with xtraWine UK Ltd. Failure to provide this data will therefore prevent users from completing the online purchase process.

Data processing methods

Personal data will be processed mainly by electronic or otherwise automated means, using methods and tools suitable to guarantee the security and confidentiality of the data, in compliance with the UK GDPR and the Data Protection Act 2018 (Article 5(1)(f) and Article 32 UK GDPR). In particular, all technical, IT, organisational, logistical and procedural security measures necessary to ensure the adequate level of data protection required by the applicable privacy legislation will be adopted, allowing access only to authorised personnel.

The information collected and the processing methods will be relevant and not excessive in relation to the type of services provided. The data will also be managed and protected in environments whose access is subject to constant control.

With whom do we share personal data?

Without prejudice to any communications made in fulfilment of legal or contractual obligations, the personal data collected and processed may be shared exclusively for the purposes set out in this Privacy Notice, by way of example with:

  • legal or natural persons acting as data processors, carrying out outsourced activities (e.g. management and maintenance of the website), formally appointed by us pursuant to Article 28 UK GDPR;
  • banking institutions and companies managing the national or international payment circuits through which online payments for products purchased via the Site are made; couriers and freight forwarders who manage logistics on behalf of the Controller;
  • partner wineries providing the experiences purchased through Vouchers, acting as independent data controllers, limited to the order number, the order date and the Voucher code (Partner Wineries may be established in the European Economic Area, covered by UK adequacy regulations under section 17A of the Data Protection Act 2018);
  • employees and/or collaborators (including system administrators) who, operating under our direct authority, are authorised to process personal data;
  • employees and/or collaborators of external data processors (including system administrators) who, operating under the direct authority of the external data processors, are authorised to process personal data;
  • any public and/or private parties, natural and/or legal persons, where sharing is necessary or functional to the proper operation of the website, as well as to comply with obligations arising from the law.

Data relating to data subjects will not be disclosed, except in anonymous and aggregate form, for statistical or research purposes.

Identity and contact details of the data processors

The complete list of data processors is available on request by contacting privacy@xtrawine.com.

Transfer of data

We use Google Analytics to measure and analyse traffic on our website. This involves the transfer of certain data to servers located in the United States. Such a transfer is permissible where the recipient is certified under the UK-US Data Bridge (the UK extension to the EU-U.S. Data Privacy Framework, in force since 12 October 2023) or where other appropriate safeguards under Article 46 UK GDPR (e.g. the UK Addendum to the EU Standard Contractual Clauses, or an International Data Transfer Agreement) are in place. You can express your consent to the use of Google Analytics on your first visit to our website and review this choice at any time thereafter. For more information, please refer to our Cookie Policy.

In accordance with Article 44 et seq. UK GDPR, xtraWine UK Ltd uses only certified and secure service providers that are established in the UK, in a country covered by UK adequacy regulations under section 17A of the Data Protection Act 2018, or in the European Union, and that process personal data in the UK or in the European Union. Communications of personal data to countries that do not ensure adequate protection are excluded, except where appropriate safeguards under Article 46 UK GDPR are in place, or under one of the derogations of Article 49 UK GDPR (e.g. the data subject's prior and express consent, their explicit instruction, or performance of a contract).

Your rights and how to contact us

As a data subject, in accordance with the UK GDPR and the Data Protection Act 2018, you may exercise in particular the following rights:

  • the right of access (Article 15 UK GDPR), i.e. to obtain confirmation as to whether your personal data is being processed, and to access it together with information on the purposes, categories of data, recipients, retention period and source;
  • the right to rectification of inaccurate personal data and completion of incomplete data (Article 16 UK GDPR);
  • the right to erasure or restriction of processing, in the cases provided for by the UK GDPR (Articles 17 and 18 UK GDPR);
  • the right to data portability (Article 20 UK GDPR) and the right to object to processing, including for direct marketing purposes (Article 21 UK GDPR).

Requests should be sent to privacy@xtrawine.com.

Right to lodge a complaint

If you believe that the processing of your data violates the UK GDPR or the Data Protection Act 2018, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at www.ico.org.uk, without prejudice to your right to seek an effective judicial remedy or to claim compensation before the competent courts (Articles 78-82 UK GDPR).

Privacy policy modification

xtraWine UK Ltd reserves the right to make changes to this notice at any time, giving appropriate notice to data subjects and in any case guaranteeing an adequate and equivalent level of protection of personal data. To review any changes, you are invited to consult this notice regularly, or to contact us at the following e-mail address: privacy@xtrawine.com.