Privacy Policy

1. Introduction

WinepackOS is operated by Delivering Happiness Limited, a company registered in England and Wales under company number 10490062, whose registered office is at Donald Reid Group Limited, 1010 Eskdale Road, Winnersh Triangle, Wokingham RG41 5TS, United Kingdom, trading as WinepackOS. In this Privacy Policy "we", "us" and "our" mean Delivering Happiness Limited.

This policy explains what personal information we collect through the WinepackOS platform at winepackos.com, why we collect it, who we share it with and what rights you have over it. It applies to visitors to the website, people who request or are granted access to the configurator, and business contacts at customers, suppliers, manufacturers and fillers.

We are the controller of the personal information described in this policy for the purposes of the UK General Data Protection Regulation and the Data Protection Act 2018.

WinepackOS is a business-to-business platform. The information we handle is mostly business contact information and details of packaging projects, rather than information about people in a personal capacity. It is still personal information when it identifies an individual, and we treat it accordingly.

We may update this policy from time to time, in particular to reflect changes in the platform or in applicable law. The date shown on the page tells you when it was last revised. Where a change materially affects your rights and we hold your email address, we will tell you.

If you do not agree with this policy, please do not submit personal information to us.

2. The information we collect

By personal information we mean information that identifies you or can be used to identify you, such as your name, business email address, telephone number, job title, employer and IP address.

Access requests and sign-in

Access to the configurator is by invitation. When you request or are granted access we collect your name, business email address, company name and any other details you provide in the request, together with the access code issued to you and a record of when access was requested, approved or declined. A functional cookie keeps you signed in.

Business and contact information

When you contact us, request a call or submit an enquiry we collect your name, business email address, telephone number, employer, job title and the content of your message. If you subscribe to updates we collect the details you give on the sign-up form.

Configurations, quotations and project requirements

When you use the configurator we record the selections you make and the specification they produce, including destination market, order volume, bottle format, shape, capacity, colour, recycled content, shelf life and barrier, closure, labels, cases and filling location, along with the indicative pricing generated and any quotation you download, order you place or call you request. Where you submit a bespoke enquiry we collect the brief, volumes and timings you describe.

This project information is mostly commercial rather than personal, but it is linked to the person and company who submitted it, so we treat the combined record as personal information.

Technical information and website usage

Our servers keep standard access logs, including your IP address, browser type and the pages you request. With your consent we also use Google Analytics cookies to understand how visitors move through the site, which pages they spend time on and where they leave the configurator. These load only after you accept them on the banner shown on your first visit. Section 11 explains how to change that choice.

Information from other sources

We may receive your information from a colleague at your organisation who refers you to the platform, from a supplier, manufacturer or filler who is working with you on a project, or from publicly available business sources such as a company website or professional network.

3. How and why we use your information

We use your personal information to:

• review and decide on access requests, issue access codes and keep you signed in;
• operate the configurator, save your selections and generate indicative pricing and quotations;
• prepare and send quotations, respond to enquiries and arrange calls you request;
• arrange the manufacture and filling of your order through our supply network;
• progress an order you place and the supply arrangements that follow from it;
• provide customer support and keep a record of our correspondence with you;
• understand how the platform is used so we can improve it, with your consent where that relies on analytics cookies;
• send you updates and marketing where you have asked for them or where we are otherwise entitled to (see section 9);
• keep our own business records and comply with our legal and regulatory obligations.

We do not sell your personal information.

Pricing and payment. The prices shown in the configurator are indicative and are generated from the selections you make. Any contract for supply, and any payment, is handled outside the platform and is governed by our terms of use. We do not collect card or bank details through the website and we do not process payments on it.

4. Our lawful bases for using your information

We only use your personal information where the law allows.

We rely on your consent for analytics cookies, and for marketing emails where you have subscribed.

We rely on the performance of a contract with you, or on steps taken at your request before entering into one, to grant access, produce quotations, and progress an order and the supply arrangements that follow.

We rely on legal obligation to keep accounting and tax records, and to respond to lawful requests from authorities.

We rely on our legitimate interests for the following purposes: operating and securing the platform; understanding and improving how it works; sourcing and managing the supply of your order; marketing our products and services to business contacts; keeping records of enquiries and projects; and handling any sale, restructuring or financing of our business. We balance those interests against your rights and only proceed where ours are not overridden.

You can ask us at any time to explain the basis we are relying on for a particular use, or object to a use based on legitimate interests (see section 10).

5. Who we share your information with

We share your personal information with:

• Manufacturers, fillers and other suppliers, so that they can price, produce or fill your order. We share what they need for that, which will usually include the specification, the volume, the destination market and the timings, together with any contact details needed to arrange delivery or resolve a production issue.
• Our service providers, who help us run the platform and act on our instructions under appropriate confidentiality and data protection terms. These include SMTP2GO, which sends the emails the platform generates, Google Analytics, which provides website analytics where you have consented to it, and our hosting provider. Each receives only the information it needs for its service.
• Our professional advisers, such as accountants, auditors, insurers and lawyers, where they need the information to advise us.
• Other companies in our group, where they are involved in supplying your project or supporting the platform.
• Acquirers or investors, in connection with any merger, acquisition, restructuring, financing or sale of all or part of our business, subject to appropriate confidentiality.
• Authorities and third parties, where we are required to disclose information by law or where disclosure is necessary to establish, exercise or defend legal claims, or to protect the rights, property or safety of any person.

We do not sell your personal information and we do not share it with third parties for their own marketing.

We may also publish or share aggregated statistics about how the platform is used. These do not identify you.

6. International transfers

WinepackOS is operated from the United Kingdom, but our users, suppliers, manufacturers and fillers are international. Our current supply and filling network spans the United Kingdom, Belgium, France, Australia and South Africa, so your information may be transferred to and processed in those countries, and in any country where a service provider we use is based.

Where we transfer personal information outside the United Kingdom, we take steps to see that it is protected to the standard required by UK data protection law. Depending on the recipient and the country, that may mean relying on UK adequacy regulations, which currently cover the EEA countries and others on the UK adequacy list, or putting approved contractual safeguards in place, such as the UK International Data Transfer Agreement or the UK Addendum to the European Commission’s Standard Contractual Clauses.

You can ask us about the arrangements that apply to a particular transfer using the contact details in section 12.

7. Security

We take appropriate technical and organisational measures to protect your personal information against unauthorised or unlawful processing and against accidental loss, destruction or damage. These include access controls so that only staff who need your information can see it, encrypted connections to the website, authenticated access to the configurator, and regular backups.

No website or system can be guaranteed secure. If a breach occurs that is likely to result in a risk to your rights, we will act to contain it and will notify you and the Information Commissioner’s Office where the law requires us to.

If you think your access code has been shared or misused, please tell us so that we can reset it. Your obligations in relation to access codes are set out in our terms of use.

8. How long we keep your information

We keep personal information only for as long as we need it for the purpose we collected it, and then delete it or anonymise it so that it no longer identifies you.

Access requests are anonymised 24 months after they are created, or sooner on request. Enquiries, including quotation requests and the configurations behind them, are anonymised on the same basis.

For orders, the commercial record is anonymised 24 months after it is created, or sooner on request. The invoice and ledger entries that the law requires us to keep are retained separately, for as long as the law requires, currently six years from the end of the relevant financial year.

Marketing subscriptions are kept until you unsubscribe, after which we keep a suppression record so that we do not contact you again. Website access logs and analytics data are kept for the retention periods set by our hosting and analytics providers.

Where we need to keep a record for longer to establish, exercise or defend a legal claim, or to meet another legal obligation, we will keep only what is necessary for that purpose.

9. Marketing

We may send you information about our products, services and new supply locations by email where you have subscribed to receive it, or where you have enquired about or bought from us and the information is about similar products and services. Every marketing email includes an unsubscribe link.

You can also ask us to stop at any time by emailing privacy@winepackos.com. If you do, we will keep your name and email address on a suppression list so that we do not contact you again by mistake. We will still contact you about an enquiry, quotation or order you have in progress, and about changes to this policy, because those are not marketing.

We do not use your information for automated decision-making or profiling that produces legal or similarly significant effects for you.

10. Your rights

Under UK data protection law you have the right to:

• be informed about how we use your information, which is what this policy is for;
• access a copy of the personal information we hold about you;
• rectification of information that is inaccurate or incomplete;
• erasure of your information where we no longer have a reason to keep it;
• restrict our use of your information in certain circumstances, for example while a dispute about its accuracy is resolved;
• data portability, meaning a copy of information you gave us in a commonly used machine-readable format, where we process it by automated means on the basis of consent or a contract;
• object to our use of your information where we rely on legitimate interests, and to direct marketing at any time;
• withdraw consent at any time where we rely on it, without affecting anything we did before you withdrew it.

To exercise any of these rights, email privacy@winepackos.com. We will respond within one month, which we may extend by up to two further months for complex requests, and we will tell you if we do. We may need to confirm your identity before we act.

Exercising these rights is free. We may charge a reasonable fee, or refuse to act, if a request is manifestly unfounded or excessive, and we will explain our reasons if we do.

If you are outside the United Kingdom you may have equivalent or additional rights under your local law, and we will honour those where they apply.

11. Cookies and your choices

We use two kinds of cookie.

Strictly necessary cookies keep you signed in to the configurator and let the site work. These do not need your consent and cannot be switched off without preventing access to the platform.

Analytics cookies are set by Google Analytics and tell us how visitors use the site, for example which pages they view, how long they spend on each step of the configurator and where they leave it. We use this only to improve the platform. These cookies load only if you accept them on the banner shown on your first visit.

You can accept or reject analytics on that banner, and you can change your mind at any time using the cookie settings link in the footer of any page. Rejecting analytics does not affect your access to the platform or the prices you are shown.

We do not use advertising cookies and we do not allow third parties to use cookies on our site for their own advertising.

12. Contacting us, and complaints

For anything to do with this policy or with how we handle your personal information, including a request to exercise your rights, email privacy@winepackos.com or write to the Data Protection Contact, Delivering Happiness Limited, 1010 Eskdale Road, Winnersh Triangle, Wokingham RG41 5TS, United Kingdom.

For general enquiries about the platform, email hello@winepackos.com or call +44 (0)330 223 4123 during UK office hours.

If you are unhappy with how we have handled your information, please tell us first so we can put it right. You also have the right to complain to the Information Commissioner’s Office, the UK supervisory authority, at ico.org.uk or on 0303 123 1113. If you are based outside the United Kingdom you may instead complain to the supervisory authority in your own country.

13. Changes to this policy

We may update this Privacy Policy from time to time, for example when we add supply locations, change the platform or use a new service provider. The revision date at the top of the page shows when it was last changed, and the current version is always published at winepackos.com/privacy.

Where a change materially affects your rights and we hold your email address, we will notify you. Otherwise, please check this page from time to time.

Your use of the platform itself is governed by our terms of use, published at winepackos.com/terms.