Privacy Policy

1. Who is responsible

LENwine is the controller for the personal data described in this policy.

Privacy contact: info@lenwine.com.

2. Data we process

When the website is delivered

The website and its hosting infrastructure may process limited technical data needed to deliver and protect the service, such as IP address, request time, requested page, browser and device information, and security logs.

Privacy and display preferences

We store your cookie choice locally in your browser for six months so the site can respect your decision. This record is not used to identify you and is not sent to our analytics providers unless you separately allow analytics.

Analytics — only with your consent

If you accept analytics, Google Analytics and Microsoft Clarity may process pseudonymous identifiers, approximate location, browser and device characteristics, referring page, pages viewed, clicks, scrolling, interaction events, performance and diagnostic information. Clarity may reconstruct on-page interactions as session recordings; this website contains no data-entry forms other than links that open your own email application.

When you contact us

If you email us, we process the information you choose to include, your email address and related correspondence so that we can reply and manage the relationship.

3. Why we use personal data

• Website delivery and security: to provide the pages you request, diagnose failures and protect the service. The legal basis is our legitimate interest in operating a secure, reliable website.
• Analytics and experience improvement: to understand how people use the site and improve its content and performance. The legal basis is your consent. Analytics remains off until you choose to allow it.
• Communications: to respond when you contact us and to take steps you request before entering into a relationship. The legal basis is your request, possible pre-contractual steps and our legitimate interest in managing correspondence.
• Legal obligations: where processing is required by applicable law or to establish, exercise or defend legal claims.

You may withdraw analytics consent at any time without affecting processing that took place before withdrawal.

4. Service providers

We disclose data only where needed for the purposes above. Depending on your choices, recipients may include:

• the provider that hosts and secures this website;
• the provider used to receive and manage email;
• Google, which provides Google Analytics 4;
• Microsoft, which provides Microsoft Clarity.

These providers may act as processors or, for some activities described in their own notices, independent controllers. Their processing is also governed by their terms and privacy information: Google Privacy Policy and Microsoft Privacy Statement.

5. International transfers

Google and Microsoft operate internationally. Where personal data is transferred outside the European Economic Area, the recipient must rely on an available legal transfer mechanism, such as an adequacy decision or approved standard contractual clauses, together with any additional safeguards required by law.

Consent to analytics controls whether the optional services load; it does not replace the safeguards required for international transfers.

6. How long data is kept

• Your local privacy choice is kept for six months.
• Google Analytics user-level and event-level data is configured to be retained for no more than 14 months. Standard aggregated reports may be available for longer under Google's service rules.
• Microsoft Clarity playback data is retained for 30 days. Click data, heatmaps, labelled or favourited sessions and a limited sample of recordings may be retained for up to nine months.
• Technical security logs and correspondence are kept only as long as reasonably needed for security, support, legal obligations or claims.

Cookie-level lifetimes are listed in the Cookie Policy.

7. Your rights

Subject to applicable law, you may ask for access to your personal data, correction, deletion, restriction, portability, or object to processing based on legitimate interests. Where processing relies on consent, you may withdraw it at any time.

We may need enough information to verify your identity before completing a request. You also have the right to complain to the data protection authority in the EU or EEA country where you live, work, or believe an infringement occurred. A list of authorities is available from the European Data Protection Board.

8. Contact and updates

For privacy questions or rights requests, email info@lenwine.com.

We may update this policy when the website, vendors or legal requirements change. A material change to analytics purposes or providers will also trigger a new consent request.