Privacy Policy
Updated
Cellarcoin is a wine custody house: it keeps physical bottles in climate-controlled cellars, its own or those of accredited custodians, and issues a transferable title over each lot. This page explains what personal data that work involves, why it is held and how to have it deleted.
1.What this policy covers
It covers the Cellarcoin website, the account area, the custody register, the marketplace where titles change hands, the redemption of a title for the physical bottle, and the booking of tastings and cellar visits.
It does not cover the sites of the wineries, carriers or payment providers we work with. When you follow a link out of Cellarcoin, the policy of whoever runs that site applies instead.
2.Who is responsible for your data
The company that operates Cellarcoin is the controller of the personal data described here, and decides what is collected and why.
Pending business decision
The registered name, address and tax identification of the operating company, and whether a data protection officer has been appointed, are not published on this site. They have to be taken from the company's own records before this policy is signed off — inventing them here would be worse than leaving the gap visible.
3.What data we hold
We ask for what the custody work needs and little else. Grouped by the reason it reaches us:
- Account: your name, email address, password (stored hashed) and language preference.
- Custody and lots: which lots are registered to you, when you acquired or transferred them, and the entries attached to those lots in the cellar log.
- Redemption and delivery: the delivery address, the phone number the carrier needs, and the shipping status of your bottle.
- Experience bookings: your name, your contact details, the number of places, and any note you leave for the host.
- Payment and verification: the record of each payment and, above certain amounts, the identity documents that know-your-customer and anti-money-laundering rules require.
- Wallet and chain: if you connect a wallet, its public address and the transactions relating to your titles.
- Use of the site: the pages you visit and basic technical data such as browser and the approximate location derived from your IP address.
We do not ask for health data. The only sensitive information we ever see is what you choose to write in a booking note — an allergy, for instance — so please keep those notes to what the host needs to know.
4.Why we use it, and on what basis
Each use has a reason that justifies it in law:
- Running your account and keeping the custody register accurate — necessary to perform the contract between us.
- Moving a bottle: preparing it, insuring it, handing it to the carrier and tracking the delivery — the same contract.
- Holding your place at a tasting or a cellar visit and giving the host the attendee list — the same contract.
- Meeting identity, anti-money-laundering, tax and alcohol-sale obligations — legal obligation.
- Keeping the platform secure, preventing fraud and diagnosing faults — our legitimate interest in running a service that can be trusted.
- Sending the newsletter or other commercial messages — your consent, which you can withdraw at any time without losing access to anything else.
5.The on-chain record
A title is anchored on a public blockchain so that it can change hands without the bottle moving. Whatever is written there — the address holding a title, the history of its transfers — is public and permanent by design. We cannot edit it or delete it, and neither can anyone else.
A wallet address is not your name, but it can be linked to you if you publish it elsewhere. Worth considering before you connect a wallet you use publicly. Your name, your address and your documents are never written on chain: they stay in our own systems, which we can correct and erase.
7.How long we keep it
The custody register is long-lived on purpose: the whole point of a lot number is that the history of a bottle outlives changes of owner. Accounting and anti-money-laundering records have retention periods set by law rather than by us.
Pending business decision
The specific period for each category — account data after an account is closed, booking notes, identity documents, delivery records — has not been set. It has to be agreed against the applicable accounting and anti-money-laundering rules and then stated here as a number of years.
8.Where it is processed
Some of the suppliers described above may process data outside the country where the bottles are stored.
Pending business decision
The list of processors, where each one operates, and the safeguard relied on for any transfer outside the European Economic Area are not fixed for this demonstration. They must be listed here once the production suppliers are chosen.
9.Your rights
You can ask us to:
- give you a copy of the data we hold about you;
- correct anything that is wrong or out of date;
- delete data we no longer have a reason to keep;
- restrict a particular use, or object to it;
- hand your data over in a portable format;
- withdraw a consent you gave, without that affecting what was done before you withdrew it.
Two limits are worth stating plainly rather than burying: we cannot erase what is already on the public blockchain, and we cannot delete a record the law obliges us to keep.
Write to the address in the last section and we will answer. If you think we have handled your data badly, you can also complain to the data protection authority where you live.
10.How we protect it
Passwords are stored hashed, traffic is encrypted in transit, and access to the custody register is limited to the people who need it to do their job. We will never ask you for your password or for the seed phrase of a wallet — not by email, not by phone, not by any other means. Anyone who does is not us.
No system is beyond reach. If a breach affects your data and puts you at risk, we will tell you and the competent authority, in the terms the law requires.
11.Age
Cellarcoin sells and ships wine, so the service is for adults: you must be at least 18, or older where local law sets a higher age for alcohol. We do not knowingly collect data from minors, and we delete it if we find it.
13.Changes to this policy
When this policy changes, the date at the top of the page changes with it. If a change materially affects how we use your data, we will tell account holders before it takes effect rather than leaving them to notice.
14.How to reach us
Write to info@cellarcoin.com, or use the contact page, and say that it is about your data so that it reaches the right person.
Pending business decision
Whether there will be a dedicated privacy mailbox, and a named data protection officer behind it, is still to be decided. Until then, requests go to the general address.