Privacy Policy

How we collect, use, and protect your personal data

Last updated: October 3, 2026

This Privacy Policy describes how WineFlow CRM ("we", "us", or "our") collects, uses, and shares your personal information when you use our website and services (collectively, the "Service"). We are committed to protecting your privacy and complying with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

Data Controller

WineFlow CRM

Email: [email protected]

Website: https://wineflow.app

1. Information We Collect

1.1 Information You Provide

We collect information you provide directly to us, including:

1.2 Information We Collect Automatically

When you access or use our Service, we automatically collect:

2. How We Use Your Information

We use the information we collect to:

3. Legal Basis for Processing (GDPR)

Under the GDPR, we process your personal data based on the following legal grounds:

4. Data Sharing and Disclosure

We may share your information in the following circumstances:

4.1 Third-Party Services

We use the following third-party services that may process your data:

4.2 Data We Process on Behalf of Our Customers

For the customer, prospect, supplier and email-recipient data that our customers store in or send through the Service, the customer company is the data controller and WineFlow acts as its processor under Article 28 GDPR, processing that data only on the customer's instructions. If you are a customer, prospect or email recipient of a company that uses WineFlow, please address requests about your data to that company; we will assist it in responding.

5. Data Retention

We retain your personal data for as long as necessary to:

Specifically:

When you delete your account, we will delete or anonymize your personal data within 30 days, unless retention is required by law.

6. Your Rights Under GDPR

If you are a resident of the European Economic Area (EEA), you have the following rights:

To exercise these rights, please contact us at [email protected]. We will respond within 30 days.

If your data was entered into WineFlow by a company that uses our Service (for example because you are its customer, a prospect or a recipient of its emails), that company is responsible for your data: please send your request to it. WineFlow provides it with tools to find, export and anonymise your data and will assist it in responding.

7. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

8. International Data Transfers

Our own servers are in the European Union, but some of the providers listed in Section 4.1 — Cloudflare, Stripe, OpenRouter and the AI model providers it routes to, Perplexity, SerpAPI and, if you connect it, Monday.com — are based in or may process data in the United States or other countries outside the EEA. For these transfers we rely on:

9. Children's Privacy

Our Service is not directed to children under 16. We do not knowingly collect personal data from children. If you believe we have collected data from a child, please contact us immediately.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new policy on this page and updating the "Last updated" date. For significant changes, we will provide additional notice via email.

11. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:

Privacy Inquiries

Email: [email protected]

General: [email protected]

12. Supervisory Authority

If you are in the EEA and believe we have not adequately addressed your concerns, you have the right to lodge a complaint with your local data protection supervisory authority.

For Italy: Garante per la protezione dei dati personali - www.garanteprivacy.it