Privacy Policy

Last Updated: October 1, 2025

This Privacy Notice for XL Int. & Co. Pte. Ltd. (“we,” “us,” or “our”) describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you visit our website at winespired.co or engage with us in other related ways. W’inespired is owned and managed by XL Int. & Co. Pte. Ltd.

If you do not agree with our policies and practices, please do not use our Services. If you have questions or concerns, please contact us at privacy@winespired.co.

SUMMARY OF KEY POINTS

  • We process personal information depending on how you interact with us and the Services.
  • We do not process sensitive personal information.
  • We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.
  • We rely on legal bases such as Consent, Legitimate Interests, Legal Obligations, and Vital Interests to process your data, in compliance with applicable laws like GDPR and UK GDPR.
  • We have adequate organisational and technical security measures in place to protect your personal information.

1. WHAT INFORMATION DO WE COLLECT?

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

The personal information we collect may include:

  • Names
  • Email addresses
  • Phone numbers
  • Job titles
  • Shipping and Billing address
  • Date of Birth (specifically for age verification)
  • Transaction details

Sensitive Information: We do not process sensitive information.

Accuracy: All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your personal information for a variety of reasons, including:

  • To process and fulfill orders for wine and spirits.
  • To provide, improve, and administer our Services.
  • To communicate with you and request feedback.
  • For security, age verification, and fraud prevention.
  • To comply with law.
  • To save or protect an individual’s vital interest.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

We rely on the following legal bases to process your personal information:

  • Consent: If you have given us permission (i.e. consent) to use your personal information for a specific purpose.
  • Legitimate Interests: When it is reasonably necessary to achieve our legitimate business interests (e.g., improving user experience).
  • Legal Obligations: Where processing is necessary for compliance with our legal obligations (e.g., cooperating with law enforcement).
  • Vital Interests: Where processing is necessary to protect your vital interests or the vital interests of a third party (e.g., preventing harm).

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share your personal information with specific third parties or in specific situations, including:

  • Shipping and Logistics Partners to deliver your orders.
  • Payment Processors (e.g., Stripe, PayPal) to process payments securely.
  • Business Transfers: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition.
  • Legal and Regulatory Compliance: To comply with legal obligations or protect our rights.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

Yes, we use cookies and similar tracking technologies (like web beacons and pixels) to gather information, maintain security, save your preferences, and assist with basic site functions. We also permit third parties to use these technologies for analytics and advertising. Specific information about how to refuse certain cookies is set out in our separate Cookie Notice.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your personal information for as long as necessary to fulfil the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law (e.g., tax or accounting requirements).

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

We aim to protect your personal information through a system of appropriate and reasonable technical and organisational security measures. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure.

8. AGE RESTRICTION AND MINORS

Alcohol Sales Eligibility: Due to the nature of our products (sparkling wines and spirits), by using the Services, you represent that you are at least 18 years of age or the legal minimum age for purchasing alcohol in your jurisdiction, whichever is higher.

Minors: We do not knowingly collect data from or market to children under 18 years of age. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In regions such as the European Economic Area (EEA), United Kingdom (UK), and Switzerland, you may have rights including the right:

  • To request access to and obtain a copy of your personal information.
  • To request rectification or erasure.
  • To restrict the processing of your personal information.
  • To data portability.
  • To object to the processing of your personal information.

Withdrawing your consent: If we rely on your consent to process your personal information, you have the right to withdraw your consent at any time.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

We do not currently respond to Do-Not-Track (“DNT”) browser signals or any other mechanism that automatically communicates your choice not to be tracked online, as no uniform technology standard has been finalised.

11. DO WE MAKE UPDATES TO THIS NOTICE?

Yes, we will update this Privacy Notice as necessary to stay compliant with relevant laws. The updated version will be indicated by an updated “Last Updated” date at the top.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us by email at privacy@winespired.co.

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access, correction, or deletion of your personal information. To request to review, update, or delete your personal information, please submit a data subject access request to us via the contact methods listed above.