1. <u>WHO WE ARE</u>
1.1 <u>Data Controller</u>. UK Vineyard Guide Ltd (Company No. 16832285), registered at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, is the data controller responsible for your personal data.
1.2 <u>Regulatory Compliance</u>. We process personal data in accordance with: (a) The UK General Data Protection Regulation (UK GDPR); and (b) The Data (Use and Access) Act.
1.3 <u>Contact Information</u>. For any questions regarding this policy or to exercise your legal rights, please contact us at hello@ukvineyardguide.co.uk.
2. <u>PERSONAL DATA COLLECTION</u>
2.1 <u>Categories of Data</u>. We may collect, use, and store the following types of personal data : (a) Identity and Contact: Name, email address, phone number, and billing details; (b) Account and Transaction: Login credentials, saved itineraries, subscription status, and payment details (processed securely via Stripe) ; (c) Technical and Location: IP address, device type, usage analytics, and approximate or precise location data to provide interactive map features ; and (d) Notification Data: Device identifiers and tokens required to deliver push notifications.
2.2 <u>Age Restrictions</u>. The Platform is not intended for individuals under 18 years of age: (i) We do not knowingly collect personal data from children; and (ii) If minor data is inadvertently collected, it will be deleted immediately upon discovery.
3. <u>HOW WE USE YOUR DATA</u>
3.1 <u>Purposes of Processing</u>. Your data is utilized to : (a) Operate and maintain the Platform functionality; (b) Process subscription payments and manage vineyard listings ; (c) Deliver marketing communications via Klaviyo or Mailchimp (subject to your consent); and (d) Provide personalized recommendations based on saved itineraries and usage data.
3.2 <u>Lawful Bases</u>. Processing is conducted under the bases of: Contractual Performance, Consent, Legitimate Interests, and Compliance with legal obligations.
4. <u>DATA SHARING AND TRANSFERS</u>
4.1 <u>Third-Party Disclosure</u>. We do not sell personal data. We share data only with trusted service providers, including: (a) Payment and IT: Stripe (Payments), GoDaddy (Hosting), and IT system administrators; (b) Marketing and Analytics: Klaviyo, Mailchimp, and Google Analytics ; and (c) Professional Advisers: Legal, accounting, and regulatory authorities where required .
4.2 <u>International Transfers</u>. Where data is processed outside the UK, we ensure appropriate safeguards are implemented in accordance with UK GDPR.
5. <u>SECURITY AND RETENTION</u>
5.1 <u>Security Measures</u>. We implement technical and organisational measures to prevent unauthorised access. Access is restricted to personnel with a genuine business need.
5.2 <u>Retention Periods</u>. Data is retained only for as long as necessary : (a) Account Data: Retained while the account remains active; (b) Transaction Data: Retained for six years per UK tax law; and (c) Marketing Data: Retained until consent is withdrawn or you unsubscribe.
6. <u>USER RIGHTS AND ACCOUNT DELETION</u>
6.1 <u>Legal Rights</u>. Under UK law, you have the right to access, correct, or request the deletion of your personal data, as well as the right to object to or restrict processing.
6.2 <u>Mandatory Account Deletion Path</u>. To satisfy 2026 App Store requirements, users may: (a) In-App Deletion: Navigate to Profile > Privacy & Security > Delete Account to remove all associated data directly; or (b) Email Request: Submit a request to hello@ukvineyardguide.co.uk, which will be processed within 30 days.
6.3 <u>Complaints</u>. You have the right to lodge a complaint with the Information Commissioner's Office (ICO) at www.ico.org.uk.