Data Privacy Policy

Processing of personal data

The processing of personal data is done in accordance with the requirements of the General Data Protection Regulation (GDPR). WannaWhisky handles personal data carefully and processes it only for predetermined purposes.

Personal data that is processed

WannaWhisky processes personal data of users of the platform, visitors to the website and people who contact us in other ways. This data is obtained directly from the user, for example when creating an account, placing an advertisement, or contacting us via the contact form or by email. Data is also processed when users communicate with each other through the private messaging system on the platform.

Depending on the user’s role on the platform and their verification status, we collect:

• First and last name
• Username and email address
• Address details, including the delivery address given for a sale and any billing address
• Details returned by Stripe after a completed verification, such as name and address, which are used to pre-fill the user’s Trade Preferences
• Invoice numbers and transaction data
• The contents of advertisements, including uploaded photographs
• The contents of private messages between users
• Photographs submitted as evidence in a dispute
• Reports made by or about a user, and the decisions taken on them
• Any other data a user actively provides, for example when contacting us

We do not store bank account details. Where Buyer Protection is used, payment details are processed directly by Stripe and are not visible to us. Where buyer and seller settle a payment between themselves, they exchange any account details directly; if those are sent in a private message on the platform, they are held in the encrypted contents of that message and are deleted together with it.

Date of birth is requested at registration to confirm that the user is 18 or older. It is used for that check only and is not stored; we record only the moment the user confirmed being 18 or older. In the same way, we record the moment the user declared that they use WannaWhisky as a private individual and not as a business (for an account created earlier: at its next sign-in). The country of residence is asked at registration only to check that the user lives in a country the platform serves; the answer is not stored. We do not ask for or store a telephone number.

Private messages between users

The platform includes a private messaging system that buyers and sellers use to negotiate a sale and to arrange the handover of a bottle. Messages are processed as follows.

• Storage. Message contents are stored on our own servers, encrypted at rest, and decrypted only in order to display a conversation to the people taking part in it or, as described below, to our staff handling a report about it. Messages are not sent to any third party, and no third party analyses them.
• Who can read a conversation. The two people taking part in it. Our staff can open a conversation only to handle a report about that negotiation or order, made by one of the two participants or raised by the automated check described below. Every time a conversation is opened, we record who opened it and when. There is no other route through the website into a private conversation.
• Automated check. Each message a user sends is automatically compared against a fixed list of terms associated with payment methods that fall outside the protection the platform offers, such as gift cards or money transfer services. The comparison is a simple text match. It does not block, alter, delay or withhold any message: the message is delivered in full, and neither sender nor recipient is notified that the check has run.
• What a match records. Where a message matches, we record on the relevant negotiation or order that a match occurred and which terms from the list were matched, and a report is opened so that a person reviews it (see Reports and moderation). We do not record the message, nor the words surrounding a matched term. Our moderation team is notified by email; that notification contains the reference of the negotiation or order, the matched terms and the sender’s account number, and does not contain the message. The record on the negotiation or order is deleted together with the conversation; the report follows the retention period for reports.
• Why. We carry out this check on the basis of our legitimate interest in protecting users against fraud and in keeping transactions on the platform, where the protections described in our Terms and Conditions apply.
• Limits on sending. Separately from the check above, an account that is less than 24 hours old cannot send messages, and no more than 20 messages per hour can be sent to the same recipient. Both limits are applied before a message is stored, and the sender is told when a limit applies.

Reports and moderation

An advertisement, a user, or, by a party to it, a negotiation or order can be reported, through the report function on the platform or by email, as described in Article 6a of our Terms and Conditions. A report is stored as a record. It holds who made it, who or what it is about, the reason chosen, any explanation given and, once a person has dealt with it, the decision and its reasoning. The explanation is stored encrypted, and the notification our staff receive about a new report does not contain it.

The user a report is about is never told who made it. The person who made it is told the outcome, without the other user’s details. Where a measure is taken, the user concerned receives a statement of reasons, as set out in the Terms and Conditions.

We process reports on the basis of our legitimate interest in keeping the platform safe, and of our legal obligation under the EU Digital Services Act to handle reports and to give reasons for measures. How long reports are kept is described under How long data is kept.

Automated analysis of listing photographs

When a seller creates an advertisement, they can choose to have a photograph analysed automatically to pre-fill the details of the listing, such as the distillery, bottling and volume shown on the label. This is one of three ways to start a listing, alongside finding the bottle in our catalogue and filling in the details by hand.

The analysis takes place only with the seller’s consent. The first time a seller chooses it, we ask; the answer applies to the whole account and can be changed at any time in the account settings, under Photo suggestions. Without consent, no photograph is sent. Withdrawing consent does not affect analyses carried out before.

For this purpose the photograph is sent to Mistral AI, a model provider established in the European Union, and is processed within the EU. We chose this provider so that photographs uploaded to the platform do not leave the EU. Before a photograph is sent, location data and other metadata embedded in the file are removed.

The analysis produces a suggestion only. The seller reviews every field and can change it before the advertisement is published, and no decision about any person is taken on the basis of this analysis. Sellers are asked to photograph the bottle and its packaging; photographs should not show people, identity documents or other personal information.

Identity verification and special categories of personal data

WannaWhisky does not itself process special categories of personal data.

An account can be created, and advertisements can be placed, once an email address has been confirmed. Verifying an identity is optional. A user who does not verify can buy and sell on the platform, but buyers cannot choose Buyer Protection on their advertisements. Once a seller is verified, Buyer Protection is available on all of their advertisements.

Verification is carried out by Stripe. A user who chooses to verify follows a link to Stripe’s own environment, and we pass on only details we already hold, such as the email address and country. Where the details provided cannot be verified against the documentation supplied, Stripe may ask the user to photograph an identity document and to take a photograph of their own face, and compares the two. That comparison involves biometric data, which is a special category of personal data. It takes place entirely at Stripe, under Stripe’s own privacy policy and with the consent the user gives there. We do not receive the photographs or the identity document.

What we receive is an account reference and, once verification has succeeded, a limited set of details such as name and address. These are used to pre-fill the user’s Trade Preferences, so that an address does not have to be typed again during a negotiation. Trade Preferences are private by default and the user can change or remove them at any time. We deliberately take no more from Stripe than this: the less we hold, the less there is to lose, and the fewer places the same detail can fall out of step.

Personal data of persons under 18 years of age

WannaWhisky is not directed at persons under 18 years of age and does not intend to collect data from minors. If there is reason to suspect that personal data of a minor has been collected without parental or guardian consent, this can be reported to info@wannawhisky.com, so that this data can be removed.

The purpose and basis for collecting personal data

WannaWhisky processes personal data only for clear and legitimate purposes, and only to the extent necessary to perform our services properly and to comply with legal obligations.

The main purposes are:

• Communication and contact: to answer questions, send notifications and provide support.
• Performance of agreements: to manage accounts, carry out verification, and enable users to negotiate, agree and complete a sale.
• Financial processing: to process payments made with Buyer Protection via Stripe, to settle commission, and to comply with accounting obligations.
• Safety of the platform: to prevent fraud and abuse, to handle disputes, and to protect the site against automated abuse.
• Newsletter and updates: with consent, to send updates by email. Unsubscribing is possible at any time.
• Improvement of our services: based on user feedback and statistics about how the website is used.
• Advertising: with consent, to measure how well our advertisements work and to show advertisements for WannaWhisky on other websites.

We process personal data on the following legal grounds from the GDPR:

• Performance of an agreement: for example to enable a sale via the platform.
• Legal obligation: for example to keep payment records for our accounts.
• Consent: for example for newsletters, non-essential cookies, advertising and the analysis of listing photographs.
• Legitimate interest: for example to prevent abuse, to settle disputes, and to improve the platform.

We never process more personal data than is necessary for these purposes, and do not keep it longer than necessary.

Automated decision-making

WannaWhisky does not take decisions that have legal consequences, or that otherwise significantly affect users, by automated means alone. Automated checks do exist — the limits on sending messages, and the check for off-platform payment lures described above — but a match leads only to review by a person, never automatically to a measure against an account. Users have the right to object to automated decision-making and to human review of any decision.

Withdrawal of consent

Consent for the processing of personal data may be withdrawn at any time, by contacting us at info@wannawhisky.com. Withdrawal does not affect the lawfulness of processing carried out before it. After receiving such a request we delete the relevant data as soon as possible, unless a legal retention obligation applies, for example to invoices.

Who receives personal data

WannaWhisky shares personal data with third parties only where necessary to perform the agreement, to operate the platform, or to comply with a legal obligation, and shares only what is strictly necessary for that purpose.

• Stripe (payment services, United States): processing payments made with Buyer Protection, identity verification of sellers, and payouts;
• Mistral AI (model provider, European Union): automated analysis of listing photographs, only where the seller has consented, as described above;
• Brevo (email delivery, European Union): sending notifications and transactional emails generated by the platform;
• Proton (email hosting, Switzerland): the mailboxes through which we correspond with users;
• Google (United States): Google Tag Manager, Google Analytics and Google Ads, for statistics about the use of the website and for measuring and targeting our advertising. These are loaded only after consent has been given, and are configured to collect and share as little as the services allow;
• Our hosting provider: technical management, storage and security of the platform environment.

We have concluded processing agreements with the parties that act as processors. These stipulate that they take appropriate technical and organisational measures to protect personal data and process it only on our instructions.

Personal data is not sold to third parties. Most of the parties above are established in the European Union. Proton is established in Switzerland, which the European Commission has recognised as offering an adequate level of data protection. Stripe and Google are established in the United States; transfers to them take place under the EU-U.S. Data Privacy Framework or standard contractual clauses.

How long data is kept

We distinguish between showing data and keeping it. Data often stops being visible to the people involved well before it is deleted, because it may still be needed to settle a payment dispute.

Negotiations that do not lead to a sale

If a negotiation expires, is withdrawn, is declined or is cancelled, the delivery address given for it is deleted immediately. Both parties can still read the conversation for seven days, so that nothing is lost mid-exchange. After those seven days the negotiation, the whole message thread and the related notifications are deleted permanently.

Orders

When a negotiation leads to a sale, its conversation moves to the resulting order and remains available while the order is being completed. For a sale with Buyer Protection, the delivery address is passed to the seller only once the payment is being held; for a sale paid between the two users directly, it is passed on when the order is created.

As soon as an order reaches a final state — completed, cancelled or refunded — the delivery address, the conversation and any agreed meeting place stop being shown to either party from that moment.

Six months (180 days) later, the delivery address, the meeting place, the conversation and its messages, the reasons given for a cancellation, a dispute or an appeal, WannaWhisky’s written reasoning for a dispute decision, the related notifications and any photographs submitted as evidence are deleted together.

We keep this material for those six months because a card payment can be reversed up to roughly four months after it was made, and it is the evidence with which such a reversal is contested. Deleting it sooner would leave both the buyer and the seller unable to demonstrate what was agreed and what was sent.

While a dispute is open, no deletion period runs, because the dispute is decided on this material. The period begins when the dispute ends and the order reaches a final state.

The order record itself is not deleted. What remains is what was sold, when, and for how much — the details we need for our accounts and are required to keep for seven years.

Photographs submitted in a dispute

Photographs submitted as evidence are stored outside the public part of the website and cannot be reached by a web address. They can be viewed only while the dispute is open, and only by the two parties and by us. Once the dispute closes, nobody can view them, including us, and they are deleted with the rest of the order’s personal data.

Reports

A report is kept while it is open. Once it has been decided, it is deleted twelve months later, so that repeated behaviour can be recognised for a year. A report about an order is instead deleted together with the order’s personal data, as described above. The record of who opened a conversation is kept on the report and is deleted with it. If the person who made a report deletes their account, their name is removed from the reports they made; reports about a user who deletes their account follow their own periods.

Account deletion

An account cannot be deleted while an order is still running. Any open negotiations are closed first and then follow the seven-day route described above. On deletion, the account’s personal details are removed, the email address is replaced with a placeholder and the display name becomes “Deleted user”. Completed orders are not deleted: the personal data in them follows its own six-month period, and the accounting record is kept for seven years. We also keep the reference numbers of the associated Stripe account, because Stripe holds records we must be able to match.

Everything else

Personal data required for administrative and fiscal obligations, such as invoices, is kept for seven years after the agreement has been completed. All other personal data is deleted no later than two years after our relationship with the user ends, unless a longer period is legally required or justified.

Cookies

A cookie is a small file that a website places on a device when it is visited. Cookies are used, among other things, to make the website function properly, to keep it secure and to understand how it is used.

Which cookies this website places, what each one is for and how long it remains active is set out in full in our cookie policy. That overview is generated from an automatic scan of the website itself, so it reflects what the site actually sets. Consent for non-essential cookies is requested via a cookie notice on the first visit and can be changed at any time via the consent manager on that page.

Viewing, modifying or deleting data

Under the law, users have various rights regarding their personal data. These rights help users keep control over their data and check that WannaWhisky complies with the applicable rules.

Users have the right to, among other things:

• Access and inspection: to know which personal data WannaWhisky processes.
• Correction and rectification: to have personal data supplemented or changed where it is incorrect or incomplete.
• Restriction of processing: where the data may be incorrect, the processing may be unlawful, the data is no longer needed, or an objection has been made.
• Deletion: to have personal data deleted, though this is not always possible.
• Data portability: to receive data in a structured, commonly used and machine-readable format. This covers digital data provided with consent or necessary for the performance of the agreement.
• Objection: to object to processing because of a particular personal situation, or to processing for direct marketing.
• Automated decision-making: to object to being subject to it, and to human review of a decision.

These rights can be exercised by writing to info@wannawhisky.com. We answer as soon as possible and no later than within four (4) weeks.

So that we do not disclose someone’s data to the wrong person, we may ask for additional information to confirm that a request comes from the person it concerns. We ask only for what is needed for that purpose. If we ask for a copy of an identity document, the passport photograph, the machine readable zone (the strip of characters at the bottom), the document number and the citizen service number (BSN) may be blacked out on it.

How personal data is secured

WannaWhisky takes the protection of personal data seriously and takes appropriate technical and organisational measures to prevent abuse, loss, unauthorised access, unwanted disclosure and unauthorised modification.

• Encrypted connections (TLS/SSL);
• Encrypted storage of particularly sensitive data, including the contents of private messages and delivery address details;
• Storage of dispute photographs outside the public part of the website, unreachable by a web address;
• Access restrictions based on authorisation; staff can open a private conversation only to handle a report about it, and every opening is logged;
• Strong passwords and two-factor authentication where possible;
• Regular software updates and system maintenance;
• Periodic backups to prevent data loss and corruption.

Protection against automated abuse. Some forms, and some actions by users who have signed in, ask the browser to solve a small computational puzzle before the request is accepted. The puzzle runs in the browser, usually without the user noticing. It collects nothing about the person or the device, sends nothing to a third party, and stores nothing: it exists only to make automated mass requests expensive. We chose this method deliberately over services such as reCAPTCHA, which work by profiling the visitor.

Any indication that something has gone wrong with the security of personal data, or any suspicion of abuse, should be reported to us immediately at info@wannawhisky.com.

Complaints

Complaints about the processing of personal data by WannaWhisky can first be raised with us at info@wannawhisky.com. If the matter cannot be resolved together, a complaint may be filed with the Dutch Data Protection Authority (autoriteitpersoonsgegevens.nl).

Changes to this privacy policy

If this privacy policy changes, the updated version is posted on the website and takes effect when it is posted. The date at the top of this page shows when it was last changed. Where a change is significant, we announce it separately or ask users to agree to it.

We keep earlier versions of this policy. If a question arises about a period in the past, we can establish which version applied at the time; a copy can be requested at info@wannawhisky.com.

Questions

Questions about this privacy policy can be sent to info@wannawhisky.com and are answered as soon as possible.

Third Party Policy Documents

WannaWhisky works with external parties that provide functionality on the WannaWhisky platform. They have their own policy documents, which are linked below for information.

Stripe

WannaWhisky collaborates with Stripe for identity verification and payment functionality. Read more about Stripe’s:

• Terms and conditions
• Cookie policy
• Privacy policy