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Privacy Policy

Learn how RareWine collects, uses and protects your personal data when you visit our websites, shop with us, join Members Club, contact support, subscribe to marketing or interact with us online.

At RareWine Trading ApS, we respect your privacy and protect your personal data. In this Privacy Policy, you can read how we collect, use, store and protect your personal data when you visit rarewine.com, use our webshop at shop.rarewine.com, visit our support and FAQ universe at support.rarewine.com, use our Members Club universe at rarewinemembersclub.com, make a purchase, create a customer account or membership profile, contact us, subscribe to our newsletter, interact with us on social media or otherwise use our services.

This Privacy Policy applies to the processing of personal data in connection with our marketing website at rarewine.com, our webshop at shop.rarewine.com, our support and FAQ universe at support.rarewine.com, our Members Club universe at rarewinemembersclub.com and other digital services operated by RareWine Trading ApS, as well as related customer service, marketing, membership, delivery, warehouse, payment, age verification and advertising processes.

This Privacy Policy is available at support.rarewine.com, but also applies to the other websites and digital services mentioned above.

1. Data Controller

The data controller responsible for the processing of your personal data is:

RareWine Trading ApS
Company registration no.: 41165979
Østre Havnepromenade 26, 5th floor
9000 Aalborg
Denmark
Email: support@rarewine.dk

If you have any questions about our processing of your personal data, or if you wish to exercise your rights, you can contact us at support@rarewine.dk.

RareWine Trading ApS is part of RareWine Group. In certain cases, we may share personal data with group-affiliated companies when this is necessary to provide our services, administer customer relationships, complete purchases, handle warehousing, delivery, investment-related services, membership benefits, support, bookkeeping, reporting or other relevant business processes.

When a group-affiliated company processes personal data on behalf of RareWine Trading ApS, this takes place under an agreement and in accordance with applicable data protection rules. If a group-affiliated company independently determines the purposes and means of a processing activity, that company is the independent data controller for such processing.

RareWine Trading ApS has not appointed a Data Protection Officer. Questions regarding data protection may be directed to the contact details above.

2. What Personal Data Do We Process?

We may process the following categories of personal data about you:

  • Contact details, including name, address, email address, telephone number and delivery address.
  • Account information, including login details, profile information, saved addresses, order history and account settings.
  • Membership information, including information about membership, membership status, membership level, membership benefits, access to Members Club, registrations, preferences, invitations, events, membership communication and any activities related to the membership.
  • Order information, including purchased products, order number, order history, delivery choices, payment status, return and complaint information.
  • Payment-related information, including payment method, payment status, transaction reference and information necessary to complete or refund payments. We do not store full card details.
  • Age verification information, including confirmation that you meet applicable age requirements when purchasing alcoholic products.
  • Customer service information, including your correspondence with us, enquiries, complaints, claims, images of damaged goods or packaging and other documentation you send to us.
  • Marketing and consent information, including newsletter sign-up, consents, withdrawals, email interactions and preferences.
  • Information for targeted advertising, including information that may be used for retargeting, custom audiences, customer match, lookalike audiences, conversion measurement and advertising statistics.
  • Information from social media, including name, username, profile information, comments, messages, reactions, shares, questions, reviews and other content you share with us or publish on our profiles.
  • Technical information, including IP address, browser, device type, operating system, time of visit, log information, cookie IDs and information about your use of our websites and digital services.
  • Business information, if you trade on behalf of a business, including company name, company registration number, billing information and contact person details.
  • Information about interests and preferences, such as which wine types, regions, producers, vintages, products, events, membership benefits or services you show interest in.
  • Documentation information, including information necessary to comply with legislation, document consents, document purchases, handle claims or protect our rights.

As a general rule, we do not process special categories of personal data about you in connection with our webshop, marketing website, support universe or Members Club.

If, in connection with an event, a customer service matter or other contact with us, you provide us with special categories of personal data, such as information about allergies or health conditions, we will only process such information if it is necessary for the specific purpose and if we have a lawful basis for the processing.

3. Purposes and Legal Basis

We process your personal data for the following purposes:

3.1 Visits to rarewine.com and Other Information Pages

When you visit rarewine.com or other information pages, we process technical information and information about your use of the website in order to operate the website, display relevant content, improve the user experience, measure traffic and marketing performance, and ensure operation and security.

This may include IP address, browser, device type, operating system, time of visit, log information, cookie IDs and information about which pages and functions you use.

The legal basis is Article 6(1)(f) of the GDPR, as we have a legitimate interest in operating, improving and protecting our websites. If the processing is based on your consent to cookies, statistics, personalisation or marketing, the legal basis is Article 6(1)(a) of the GDPR.

3.2 Completion of Purchases and Delivery

We process your contact, order, payment and delivery information in order to receive and process your order, complete payment, send order confirmations, deliver products, provide tracking information and handle any changes to the order.

The legal basis is Article 6(1)(b) of the GDPR, as the processing is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract.

If you trade on behalf of a business, the legal basis is Article 6(1)(f) of the GDPR, as we have a legitimate interest in processing information about the business’s contact persons for the purpose of completing sales, delivery and customer service.

3.3 Customer Account and Login

If you create a customer account, we process your information in order to administer your account, provide access to login, saved information, order history and any account settings.

The legal basis is Article 6(1)(b) of the GDPR when the processing is necessary to provide the account functionality to you. In certain cases, the legal basis is Article 6(1)(f) of the GDPR, as we have a legitimate interest in making it easier for customers to manage purchases, addresses and order history.

3.4 Members Club

If you sign up for or use RareWine Members Club, we process information that is necessary to administer your membership, give you access to the membership universe, provide membership benefits, invite you to relevant activities and events, communicate with you about the membership and tailor relevant content, services and offers.

This may include contact details, account and login information, membership status, membership level, membership benefits, registrations, preferences, purchase history, communication, event participation and information about your use of Members Club.

The legal basis is Article 6(1)(b) of the GDPR when the processing is necessary for the performance of the membership agreement with you or to provide the membership functionality. In certain cases, the legal basis is Article 6(1)(f) of the GDPR, as we have a legitimate interest in administering and developing Members Club, tailoring the membership experience, inviting members to relevant activities and communicating relevantly with members.

If the processing is based on consent, for example for marketing or certain forms of personalisation, the legal basis is Article 6(1)(a) of the GDPR.

3.5 Age Verification When Purchasing Alcohol

When purchasing wine and other alcoholic products, we process information necessary to verify that you meet the applicable age requirements in the country to which the goods are delivered.

For delivery to Denmark, age verification is carried out via MitID. For delivery to Sweden, age verification is carried out via BankID. The verification is carried out through our supplier Idura.

As a general rule, we only process the result of the verification, i.e. whether the age requirement has been met, and relevant technical/log information to document the check. We do not receive more information than necessary to complete the age verification.

The legal basis is Article 6(1)(c) of the GDPR if the processing is necessary to comply with a legal obligation, and Article 6(1)(f) of the GDPR, as we have a legitimate interest in ensuring that alcoholic products are not sold to persons who do not meet applicable age requirements.

3.6 Payments and Refunds

We process payment-related information in order to complete payments, handle reservations, refunds, repayments, payment errors and any payment documentation.

Payments are handled via Frisbii and the relevant payment methods, including payment cards, Vipps MobilePay and Apple Pay, depending on what is offered at checkout.

The legal basis is Article 6(1)(b) of the GDPR, as the processing is necessary to complete the purchase agreement with you. For information that must be stored for accounting purposes, the legal basis is Article 6(1)(c) of the GDPR.

3.7 Warehousing, Fulfilment, Delivery, Tracking and Returns

We process your contact, order and delivery information in order to store, pack, ship and deliver your products, provide tracking information, handle uncollected parcels, returns and any redelivery.

Warehousing and fulfilment tasks are handled by Nordic Freeport ApS, company registration no. 37999717, Industrivej 20, Vester Hassing, 9310 Vodskov, Denmark, which is a group-affiliated company in RareWine Group. Nordic Freeport receives the information necessary to store, pack, handle and ship your order and to handle returns and complaints, including name, delivery address, contact details, order number, product information and relevant delivery information.

Delivery and tracking are handled via Homerunner and relevant carriers. These recipients receive the information necessary to deliver your order, including name, address, contact details, delivery choice, tracking information and any delivery instructions.

The legal basis is Article 6(1)(b) of the GDPR, as the processing is necessary for the performance of the purchase agreement with you.

3.8 Withdrawal, Complaints and Customer Service

When you contact us, we process the information you provide to us and information about your order so that we can respond to your enquiry, handle withdrawal, returns, complaints, shipping damage, claims or other customer service matters.

If you send images of products, packaging or other documentation, we process this information in order to assess and document the matter.

Customer service is handled, among other things, via HubSpot and our support and FAQ universe at support.rarewine.com.

The legal basis is Article 6(1)(b) of the GDPR when the processing relates to a purchase or potential agreement. In other cases, the legal basis is Article 6(1)(f) of the GDPR, as we have a legitimate interest in providing customer service, documenting enquiries and handling claims.

3.9 Bookkeeping, Accounting and Documentation

We process and store relevant order, payment, invoice and accounting information in order to comply with bookkeeping, tax and duty rules.

The legal basis is Article 6(1)(c) of the GDPR, as the processing is necessary to comply with legal obligations.

3.10 Newsletter and Direct Marketing

If you subscribe to our newsletter or give consent to marketing, we process your email address, name, consent information and information about your interactions with our emails.

We use HubSpot for CRM, email marketing, segmentation and customer communication. We may use information about your purchases, interests, behaviour on our websites and digital services and interactions with our communication to tailor content, offers and recommendations when you have given consent to this, or where otherwise permitted under applicable rules.

You can unsubscribe from marketing at any time via the unsubscribe link in our emails or by contacting us at support@rarewine.dk.

The legal basis is generally Article 6(1)(a) of the GDPR when the processing is based on your consent. In certain cases, the legal basis may be Article 6(1)(f) of the GDPR if we have a legitimate interest in sending relevant communication to existing customers within the framework of applicable marketing rules.

3.11 Abandoned Cart and Personalised Communication

If you have given consent to marketing or relevant tracking, we may send you reminders about products you have added to your cart but have not purchased, as well as personalised emails and recommendations based on your interests, purchase history and behaviour on our websites and digital services.

This processing takes place via HubSpot and relevant cookie/tracking technologies.

The legal basis is generally Article 6(1)(a) of the GDPR when the processing is based on consent. Where the processing takes place without consent-required tracking and within the framework of applicable marketing rules, the legal basis may be Article 6(1)(f) of the GDPR.

3.12 Reviews via Trustpilot

After a purchase, we may invite you to review your purchase experience via Trustpilot. In this connection, we may share relevant information with Trustpilot, such as name, email address, order number and time of purchase, to the extent necessary to send the review invitation and document that the review relates to a genuine purchase.

The legal basis is Article 6(1)(f) of the GDPR, as we have a legitimate interest in collecting customer feedback, improving our service and documenting genuine customer reviews. If review invitations are sent on the basis of consent, the legal basis is Article 6(1)(a) of the GDPR.

3.13 Cookies, Statistics and Online Marketing

We use cookies and similar technologies on our websites and digital services to make the sites function, remember your choices, compile statistics, measure the effect of marketing and show relevant advertisements.

We use Cookie Information to manage cookie consents. You can change or withdraw your cookie consent at any time via our cookie settings.

We may use, among others, the following technologies and platforms:

  • Google Analytics
  • Google Tag Manager
  • Google Ads
  • Meta Pixel
  • LinkedIn Insight Tag
  • HubSpot
  • Cookie Information

We may also use audience functions from advertising platforms, including retargeting, custom audiences, customer match, lookalike audiences and similar functions, where this is permitted under applicable rules and based on relevant consent where required.

Technically necessary cookies are used to make our websites and digital services function and generally do not require consent. Cookies and similar technologies for statistics, personalisation and marketing are only used if you have given consent.

The legal basis for processing personal data in connection with consent-required cookies and similar technologies is Article 6(1)(a) of the GDPR. For technically necessary cookies and security logs, the legal basis may be Article 6(1)(f) of the GDPR, as we have a legitimate interest in operating secure and functional websites and digital services.

You can read more in our Cookie Policy and cookie settings.

3.14 Social Media

We are present on social media, including Facebook, Instagram and LinkedIn.

When you visit or interact with our profiles on social media, we may process the information you share with us or make available via the platforms. This may include your name, username, profile information, comments, messages, reactions, shares, questions, reviews and other content you send to or publish on our profiles.

We process the information in order to communicate with you, respond to enquiries, handle customer service, administer our profiles, moderate content, carry out marketing, measure the effect of our communication and obtain statistics about the use of our profiles.

The legal basis is Article 6(1)(f) of the GDPR, as we have a legitimate interest in being present on social media, communicating with customers and interested parties, marketing our business and administering our profiles. If the processing is based on consent, the legal basis is Article 6(1)(a) of the GDPR.

The social media platforms also process personal data about you as independent data controllers. In certain cases, RareWine Trading ApS and the platforms may be joint controllers for the processing of information in connection with page insights, statistics and advertising. You can read more about the platforms’ processing of personal data in their own privacy policies.

We encourage you not to share special categories of personal data, payment information, order numbers or other confidential information publicly on our social media channels. If your enquiry concerns a specific order, membership or customer service matter, we may ask you to contact us by email or another private channel.

3.15 Custom Audiences and Targeted Advertising

We may use custom audiences, customer match or similar audience functions on advertising platforms such as Meta, Google and LinkedIn.

This means that, in certain cases, we may use information such as email address, telephone number, name, country, postal code, purchase history, consent information or customer/segment information to create audiences, measure advertising performance, find similar audiences and display more relevant ads on third-party platforms.

When we upload or synchronise customer lists with advertising platforms, this is generally done in hashed or otherwise protected form, where the platform compares the information with its own user data to determine whether you have an account on the platform. The advertising platforms may also process the information as independent data controllers in accordance with their own terms and privacy policies.

We only use custom audiences and similar advertising functions where we have a lawful basis for doing so. The legal basis is generally Article 6(1)(a) of the GDPR if the processing is based on your consent to marketing and/or relevant cookies and tracking technologies. In certain cases, the legal basis may be Article 6(1)(f) of the GDPR if we have a legitimate interest in marketing our products and measuring the effect of our advertising, and the processing can take place within the framework of applicable data protection and marketing rules.

You can withdraw your consent or change your cookie settings at any time. You can also object to the processing of your information for direct marketing by contacting us at support@rarewine.dk.

3.16 Events, Invitations and Arrangements

If you register for or participate in an event, tasting, Members Club event or other activity with us, we process information necessary to administer the event, communicate with you, handle registration, participant lists, payment, access, follow-up and any documentation.

This may include name, email address, telephone number, membership status, company, number of participants, preferences, payment information, participation history and any communication about the event.

The legal basis is Article 6(1)(b) of the GDPR when the processing is necessary to complete your registration or agreement regarding participation. In other cases, the legal basis is Article 6(1)(f) of the GDPR, as we have a legitimate interest in administering and holding events, communicating with participants and documenting participation.

If you give consent to marketing in connection with an event, the legal basis is Article 6(1)(a) of the GDPR.

3.17 Group-Internal Processes and Cooperation Within RareWine Group

RareWine Trading ApS is part of RareWine Group. In certain cases, we may process and share personal data with group-affiliated companies when this is necessary for relevant business, administrative or operational purposes.

This may be in connection with warehousing, fulfilment, delivery, customer service, finance, reporting, compliance, IT operations, investment-related enquiries, Members Club, events or other services provided in cooperation with companies in RareWine Group.

The legal basis is Article 6(1)(f) of the GDPR, as we have a legitimate interest in organising and operating our business efficiently across RareWine Group, ensuring coherent customer service and providing the services you request. If the processing is necessary for the performance of a contract with you, the legal basis is Article 6(1)(b) of the GDPR. If the processing is necessary to comply with a legal obligation, the legal basis is Article 6(1)(c) of the GDPR.

3.18 Operation, Security and Prevention of Misuse

We process technical information, logs and security-related information in order to operate, maintain and protect our websites, webshop, support universe, Members Club and other digital services, prevent misuse, detect errors, prevent fraud and ensure stable operation.

Our webshop and digital solutions may be custom-developed, and our hosting/infrastructure provider is Azure/Microsoft.

The legal basis is Article 6(1)(f) of the GDPR, as we have a legitimate interest in ensuring operation, stability, security and prevention of misuse.

3.19 Automated Decision-Making and Profiling

We do not use automated decision-making that has legal effects or similarly significantly affects you.

We may use profiling to tailor marketing, recommendations, advertisements, membership communication and content based on, for example, your purchases, interests, behaviour on our websites and digital services, cookie information, membership status and interactions with our communication, if you have given relevant consent or where otherwise permitted under applicable rules.

You can withdraw your consent, change your cookie settings or object to direct marketing at any time.

4. Recipients and Suppliers

We may share your personal data with relevant recipients when this is necessary for the purposes described in this Privacy Policy.

This may include:

  • Frisbii and relevant payment partners for handling payments.
  • Idura for age verification via MitID and BankID.
  • Nordic Freeport ApS, company registration no. 37999717, Industrivej 20, Vester Hassing, 9310 Vodskov, Denmark, as a group-affiliated warehouse and fulfilment partner for storage, handling, packing, shipping, returns and complaints.
  • Homerunner and relevant carriers for delivery and tracking.
  • HubSpot for CRM, newsletter, customer service, segmentation and marketing automation.
  • Cookie Information for handling cookie consents.
  • Google, Meta and LinkedIn for statistics, advertising platforms, conversion measurement, retargeting, custom audiences/customer match, lookalike audiences and online marketing, where we have a lawful basis for the processing, including relevant consent where required.
  • Facebook, Instagram and LinkedIn in connection with our presence on social media, page insights, statistics, advertising and communication via the platforms.
  • Trustpilot for review invitations and handling customer reviews.
  • Azure/Microsoft for hosting and infrastructure.
  • Relevant system suppliers and platforms used for operation, administration, communication and access management in connection with RareWine Members Club.
  • Group-affiliated companies in RareWine Group where relevant for, for example, warehousing, fulfilment, delivery, customer service, finance, reporting, compliance, investment, membership, events, IT operations or administration.
  • Auditors, advisers, public authorities and other parties where necessary to comply with legislation, document claims or protect our rights.

When suppliers process personal data on our behalf, we enter into data processing agreements with them where required.

If we share information with other independent data controllers, such as payment providers, carriers, social media platforms or certain group-affiliated companies, these recipients process the information in accordance with their own privacy policies and applicable data protection rules.

5. Transfers to Countries Outside the EU/EEA

Some of our suppliers or their sub-suppliers may be established outside the EU/EEA or process personal data from countries outside the EU/EEA. This may, for example, be relevant for certain IT, CRM, analytics, social media and marketing platforms.

If we transfer personal data to countries outside the EU/EEA, we ensure that the transfer takes place on a lawful basis under data protection rules.

For transfers to recipients in the United States, the transfer basis may, for example, be the European Commission’s adequacy decision for the EU-U.S. Data Privacy Framework, if the recipient is certified under the framework.

If the recipient is not covered by an adequacy decision, the transfer may, for example, take place on the basis of the European Commission’s Standard Contractual Clauses, possibly supplemented by additional safeguards where necessary.

We continuously assess our suppliers, data processing agreements and transfer bases to ensure that transfers to countries outside the EU/EEA take place in accordance with applicable data protection rules.

6. Storage and Deletion

We only store your personal data for as long as necessary for the purposes for which the data was collected, or for as long as we are required to do so under legislation.

As a general rule, the following applies:

  • Order, invoice and payment information is stored for the period necessary to comply with bookkeeping, tax and duty rules.
  • Information about purchases, delivery, returns and complaints is stored for as long as necessary to handle the order, any claims, complaints and documentation needs.
  • Customer service enquiries are stored for as long as necessary to process the enquiry and document the course of events.
  • Account information is stored for as long as you have an active customer account. If you ask us to delete your account, we will delete or anonymise account information unless we are required or entitled to store certain information for a longer period.
  • Membership information is stored for as long as you have an active membership or active membership profile. If the membership ends, or if you ask us to delete your membership profile, we will delete or anonymise membership information unless we are required or entitled to store certain information for a longer period, for example for documentation, accounting, claims or applicable legislation.
  • Newsletter and marketing information is stored until you withdraw your consent or unsubscribe, unless we have a lawful basis for storing the information for a longer period, for example to document consent or withdrawal.
  • Information used for custom audiences, customer match and similar advertising functions is stored only for as long as necessary for the purpose, or until you withdraw your consent or object to direct marketing, unless we have another lawful basis for continued storage.
  • Information from social media is generally stored on the relevant platforms in accordance with the platforms’ own settings and policies. Direct enquiries, messages and customer service matters are stored for as long as necessary to handle the enquiry and document the course of events.
  • Information about arrangements, events and Members Club activities is stored for as long as necessary to administer the event, document participation, handle payment, follow up on the event or comply with legal obligations.
  • Cookie and tracking data is stored in accordance with our Cookie Policy, your cookie settings and the relevant suppliers’ deletion periods.
  • Security logs are stored for as long as necessary for operation, security, troubleshooting and prevention of misuse.

If we anonymise information so that it can no longer be linked to you, we may store and use the anonymised information for, for example, statistics, analysis and business development.

7. When It Is Necessary to Provide Information

Some personal data is necessary for us to enter into or perform a contract with you, for example when you make a purchase, create a customer account, participate in Members Club or register for an event.

If you do not provide the information necessary to complete a purchase, deliver products, complete payment, handle age verification, administer membership or provide customer service, we may not be able to complete your order or provide the requested service.

8. Your Rights

Under data protection rules, you have a number of rights. Your rights may be limited in certain cases, for example if we are required to store information under legislation, or if the information is necessary to establish, exercise or defend legal claims.

You have, among other things, the right to:

  • access the personal data we process about you
  • have inaccurate information corrected
  • have information deleted in certain cases
  • have processing restricted in certain cases
  • object to processing based on legitimate interests
  • object to direct marketing
  • receive your information in a structured, commonly used and machine-readable format if the conditions for data portability are met
  • withdraw your consent if the processing is based on consent

If you withdraw consent, this does not affect the lawfulness of processing carried out before the withdrawal.

You can exercise your rights by contacting us at support@rarewine.dk.

9. Complaint to the Danish Data Protection Agency

If you are dissatisfied with our processing of your personal data, you have the right to lodge a complaint with the Danish Data Protection Agency.

You can find the Danish Data Protection Agency’s contact information at www.datatilsynet.dk.

10. Cookies

We use cookies and similar technologies on our websites and digital services. You can read more about which cookies we use, their purposes, lifespan and suppliers in our Cookie Policy and cookie settings.

You can change or withdraw your cookie consent at any time via the cookie settings on the website.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time, for example if we change our processing activities, suppliers, technical solutions, group structure, digital services or due to changes in legislation.

The latest version will always be available on our website.