Privacy Policy

Asiavino is operated by Eurasia Trading Sarl, Switzerland ("we", "us", "our", the "Company"). This document applies to asiavino.com and to every country-level extension of it (the "Site", the "Platform", the "Service").

This Privacy Policy explains what personal data we collect when you visit or use Asiavino, why we collect it, who we share it with and what you can ask us to do about it.

What we collect

We collect information you give us. Depending on what you do on the Platform this may include:

• your name and email address, when you create an account, write to us, subscribe to the newsletter or ask to be told when a wine becomes available in your market
• a delivery address and a telephone number, when you submit an order request
• your date of birth, when an age check is required before a wine order request
• the company details of a producer, brand owner or distributor, when a partner account is opened
• the content of messages you send us

We also collect information automatically when you use the Site: the pages you view, your IP address, your browser and device type, the country resolved from the network you are connecting from, and the language and market you are browsing in. We use it to serve the right version of the Site, to keep the Platform working, to measure how the Site is used and to detect abuse.

Every time you submit a form on the Site, we record, alongside what you typed, the IP address you submitted it from, your browser's user agent string, the country resolved from your connection, the market and language of the page the form was on, and the moment of the submission. This applies to every form: an enquiry about a wine, a request for a sales kit, a newsletter or availability-alert sign-up, a partner application and the contact form.

We record it because it is part of the submission: it is how we can show what was sent, from where and when, how we tell a genuine enquiry from an automated one, and what evidences a consent given at the same moment. Submitting a form on the Site means accepting that we record it, and the Terms and Conditions say so. You may ask us in writing to delete it.

Analytics and advertising

We measure how the Site is used, and we advertise.

We use Google Tag Manager to load the tools below. Google Tag Manager is a container; it measures nothing of its own.

• Google Analytics 4, to understand how the Site is used: which pages are read, which wines are looked at, which carts are filled, which forms are completed.
• Google Ads, to measure which advertising led to those actions, and to show you advertising for Asiavino on Google's services and on sites in its network.
• Meta, for the same two purposes on Facebook and Instagram.

These tools set identifiers in your browser and receive the pages you visit, what you do on them, your IP address and your browser and device type. Google and Meta may combine what they receive with data they already hold about you, including through an account you hold with them. This is interest-based advertising and it includes remarketing: you may see advertising for Asiavino after visiting the Site.

When you complete a form or submit an order request, we may also send Google and Meta a one-way cryptographic hash of your email address and, where you gave one, of your telephone number, so that a conversion can be matched to the advertising that led to it. The hash is computed in your browser before anything is sent. Your address itself is never sent to them, and a hash cannot be turned back into it.

Your choice about analytics and advertising

Where the law where you are requires your consent before any of this, we ask for it on the Site, before those tools store anything. Until you answer, they run in a restricted mode in which no analytics or advertising cookie is set and no identifier is stored on your device. You may change your answer at any time from the cookie link in the footer of every page.

This is the European Economic Area, the United Kingdom, Switzerland, and the countries whose own laws require being asked first, which across the markets this Site serves includes mainland China, Japan, South Korea, Taiwan, Thailand, Vietnam, Malaysia, Indonesia and the Philippines. Where we cannot tell where you are, we ask.

Elsewhere, including Hong Kong, Macao, Singapore, Australia and New Zealand, the law asks us to tell you rather than to ask you. This policy is how we tell you, and it names every tool, everything it receives and everything we send it. If you would prefer we did not, write to us and we will stop.

Refusing costs you nothing anywhere: every part of the Site works exactly as it does with consent given, and nothing about your order request, your account or your enquiry depends on it.

We do not sell your personal data, and we do not share it with data brokers.

We do not take card details on asiavino.com. Where a payment is taken, it is taken on Stripe's own hosted page and your card number never reaches our servers.

Cookies

The Platform sets cookies of two kinds, and they are treated differently.

Necessary cookies make the Site work. They are set whatever you decide about the others, because without them there is no Site to decide about.

• a session cookie, so you stay signed in
• a cart cookie, so a cart started before you signed in is not lost
• an age check cookie, so you are not asked the same question on every page
• a short-lived cookie during sign-in with Google, which is deleted as soon as the sign-in finishes
• your answer to the analytics and advertising question, which is kept by your browser on your own device and is never sent to us
• for partners and staff, a cookie recording which brand you are working on, and a cookie used by the content preview

Analytics and advertising cookies are set by the tools named in the previous section, by Google and by Meta. Where your consent is required they are set only once you have given it. They let those tools recognise a browser between pages and between visits, which is what makes a visit measurable and an advertisement attributable. None of them is necessary for the Site to work.

Your browser can block or delete cookies. If you block the necessary ones, parts of the Platform will not work: you will not be able to stay signed in or to keep a cart.

Why we may use your data

• To do what you asked: to transmit an order request to a Seller, to send a document you ordered, to answer an enquiry, to deliver a ticket you bought.
• To keep an account you opened, and to let you sign in to it.
• To send the newsletter or a market availability alert, where you asked for one. Both require you to confirm by email before we send anything, and both can be stopped from any message we send.
• To meet legal obligations, including those that apply to the sale of alcohol, such as verifying that you are of legal drinking age.
• To keep the Platform safe and to detect and prevent abuse and fraud.
• To measure how the Site is used, so that we can improve it.
• To advertise Asiavino, and to measure whether that advertising worked.
• To keep a record of what you submitted through a form, from where and when.

The lawful bases we rely on are:

• performing a contract with you, for an order request, an account and anything you asked us to send you
• complying with a legal obligation, including the ones that apply to alcohol
• your consent, which is what we rely on for analytics and advertising, and which you may withdraw at any time without giving a reason and without losing anything
• our legitimate interest in operating, measuring and protecting the Platform, which is what we rely on for the record we keep of a form submission and for detecting abuse

Who we share it with

We share your order request with the Seller that will fulfil it. That Seller becomes an independent controller of what it receives, and its own privacy policy applies to what it does with it. We give the Seller what it needs to accept and deliver the order and nothing more.

We use the following service providers to run the Platform. They act on our instructions and only for the purposes below.

• Vultr, which hosts the application and the database. The servers are in Singapore.
• Cloudflare, which serves the Site, protects it, and stores uploaded images and documents.
• Stripe, which processes payment for the items Asiavino sells itself and for partner subscriptions. Stripe receives the payment details you enter on its own page. We receive a confirmation and never the card number.
• Resend, which sends the emails the Platform sends you.
• Google, for Tag Manager, Analytics and Ads where you have consented to them, and for sign-in if you choose a Google account.
• Meta, for advertising and conversion measurement on Facebook and Instagram, where you have consented to it.

Google and Meta are not only acting on our instructions. For the advertising described above they are independent controllers of what they receive, they decide things about it that we do not control, and their own privacy policies apply to it. This is the reason your consent is asked for before anything reaches them.

We may also disclose personal data where the law requires it, in response to a lawful request, or to establish or defend a legal claim.

Where your data goes

The Company is established in Switzerland and the Platform is hosted in Singapore. If you are in the European Economic Area, the United Kingdom or Switzerland, this means your personal data is transferred outside your own country. Where such a transfer needs a safeguard, we rely on the standard contractual clauses or on an adequacy decision covering the country concerned.

Sellers are established in the markets they serve, across Asia-Pacific and elsewhere. An order request transmitted to a Seller is transferred to that Seller's country.

Google, Meta, Stripe, Resend and Cloudflare process data in the United States and in other countries. Where you have consented to analytics and advertising, what those tools collect is transferred to the United States. We rely on the standard contractual clauses and on the adequacy decisions covering the EU-US and Swiss-US Data Privacy Frameworks where they apply.

How long we keep it

• Account data: for as long as the account exists, and until you ask us to delete it.
• Order requests and orders: for as long as we need them for accounting, tax and legal purposes.
• Newsletter and alert subscriptions: until you unsubscribe.
• Enquiries and messages: for as long as we need them to deal with the matter and to keep a record of it.
• Age check records: we keep the result of the check, the age it computed and when it happened. We do not copy your date of birth into that record.
• The record of a form submission, including the IP address and the user agent: for as long as we need it for the purposes described above.
• Analytics and advertising data held by Google and by Meta: under their own retention policies, which their own privacy notices describe.

You may ask us in writing to delete personal data we hold about you, and we will.

Your rights

You may ask us to give you a copy of the personal data we hold about you, to correct it, to delete it, to restrict or object to how we use it, and to receive it in a portable form. You may withdraw a consent you gave at any time, which does not affect what was done before you withdrew it.

Where we asked for your consent to analytics and advertising, you may withdraw it on the Site itself, at any time, from the cookie link in the footer, without writing to us. Nothing about the Site changes when you do.

For anything else, including deletion, write to us through the contact form or at [email protected]. We answer within one month.

Legal drinking age, and people below it

The Platform is intended only for people of legal drinking age where they are. We do not knowingly collect personal data from anybody below that age. If we learn that we hold data belonging to somebody below it, we delete it.

Security

We take reasonable technical and organisational measures to protect personal data, including encryption in transit, access control on the administrative interface, and passwords stored so that they cannot be read back. No system is completely secure, and we cannot guarantee absolute security.

Email is not a secure medium. Please do not send us anything confidential by email.

Changes

We may update this Privacy Policy. The version and the date in effect are shown at the top of this page.

Contact

Eurasia Trading Sarl, Rue du Collège 16, 1325 Vaulion, Switzerland. Company registration CHE-148.614.767. Telephone +41 76 231 44 62. Email [email protected].