Your Legacy,
Bottled.

In compliance with current legislation, Gentlewines (hereinafter also Website) undertakes to adopt the necessary technical and organizational measures, according to the level of security appropriate to the risk of the data collected.

Laws incorporated in this policy

This privacy policy is adapted to current Spanish and European regulations regarding the protection of personal data on the internet. Specifically, it complies with the following rules:

• Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons (GDPR).
• Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights (LOPD-GDD).
• Royal Decree 1720/2007, of December 21, approving the Regulations for the development of Organic Law 15/1999 (RDLOPD).
• Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the Data Controller

The entity responsible for the processing of personal data collected at Gentlewines is: Liúber Sobrino León, with NIF: 51730567W (hereinafter, Data Controller). Their contact details are:

• Address: Calle de Luis Martínez Feduchi, 32. 28055 - Madrid, Spain.
• Phone: +34 622 405 803
• Email: info@gentlewines.com

Registration and Data Processing

In compliance with the GDPR and LOPD-GDD, we inform you that the personal data collected by Gentlewines, through the forms extended on its pages, will be incorporated and processed in our files in order to facilitate, expedite, and fulfill the commitments established between Gentlewines and the User, or to process a request or query from them.

Applicable Principles

The processing of the User's personal data will be subject to the following principles (Art. 5 GDPR):

• Lawfulness, fairness, and transparency: Prior consent and transparent information.
• Purpose limitation: Specified, explicit, and legitimate purposes.
• Data minimization: Only what is strictly necessary.
• Accuracy: Accurate and updated data.
• Storage limitation: Kept only for the necessary time.
• Integrity and confidentiality: Guarantee of security and confidentiality.
• Proactive responsibility: The Controller shall ensure compliance.

Specific Processing Information

Data categories:

Only identifying data is processed at Gentlewines. Under no circumstances are special categories of personal data processed.

Legal basis:

The legal basis for processing is express consent. The User shall have the right to withdraw their consent at any time without this affecting the general use of the Website.

Processing purposes:

To process requests, fulfill commitments, provide operational and statistical personalization, and carry out marketing actions to tailor the Content offered and improve the quality of the Website.

Retention periods:

The data will be retained for a maximum period of 18 months, or until the User requests its deletion.

Recipients:

The User's personal data will not be shared with third parties.

Minors

Only individuals over 14 years of age may grant their lawful consent. For minors under 14, the consent of parents or legal guardians is required.

Secrecy and Security

The Website features an SSL (Secure Socket Layer) certificate that ensures encrypted data transmission. In the event of a security breach posing a high risk, the Controller will communicate this to the User without undue delay.

User Rights (ARCO Rights)

The User may exercise the following rights before the Controller:

• Access: Confirmation regarding the processing of their data.
• Rectification: Modification of inaccurate data.
• Erasure (Right to be forgotten): Deletion of data when no longer necessary or consent is withdrawn.
• Restriction of processing: Limitation of data use in specific cases.
• Portability: Receiving data in a structured format for transmission to another controller.
• Objection: Cessation of processing by Gentlewines.
• Not to be subject to automated decisions: Including profiling.

To exercise these rights, the User must send a written communication to info@gentlewines.com or to our postal address, referencing "GDPR-www.gentlewines.com", attaching a copy of an ID document, reasons for the request, address for notifications, date, and signature.

Acceptance and Changes

The use of the Website implies the acceptance of this Privacy Policy. Gentlewines reserves the right to modify it according to its own criteria or due to legislative changes from the Spanish Data Protection Agency (AEPD), without explicit notification, so regular review is recommended.

If the User considers that an infringement exists, they have the right to file a claim with the AEPD (www.aepd.es).

Last updated: 01/15/2026.

I. General Information

In compliance with the duty of information set forth in Law 34/2002 on Information Society Services and Electronic Commerce (LSSI-CE) of July 11, the following general information regarding this website is provided:

The ownership of this website, www.gentlewines.com, (hereinafter, Website) is held by: Liuber Sobrino, with NIF: 51730567W, and their contact details are:

• Address: Calle de Luis Martínez Feduchi, 32. 28055 - Madrid, Spain.
• Phone: +34 622 405 803
• Email: info@gentlewines.com

II. General Terms and Conditions of Use

The object of the conditions: The Website
The purpose of these General Conditions of Use (hereinafter, Conditions) is to regulate the access and use of the Website. For the purposes of these Conditions, the Website will be understood as: the external appearance of the screen interfaces, both statically and dynamically, meaning the navigation tree; and all the elements integrated into both the screen interfaces and the navigation tree (hereinafter, Contents) and all those online services or resources that it may offer to Users (hereinafter, Services).

Gentlewines reserves the right to modify, at any time, and without prior notice, the presentation and configuration of the Website and of the Contents and Services that may be incorporated therein. The User acknowledges and accepts that at any time Gentlewines may interrupt, deactivate, and/or cancel any of these elements integrated into the Website or access to them.

The User
The access, navigation, and use of the Website confers the condition of User, for which all the Conditions established herein are accepted, from the moment navigation begins on the Website, as well as any subsequent modifications.

The Gentlewines Website provides a great diversity of information, services, and data. The User assumes responsibility for making proper use of the Website. This responsibility shall extend to:

• Using the information, Contents, and/or Services provided by Gentlewines without contravening the provisions of these Conditions, the Law, morality, or public order, or in any other way that may cause injury to the rights of third parties or to the operation of the Website itself.
• The veracity and lawfulness of the information provided by the User in the forms extended by Gentlewines for access to certain Contents or Services offered by the Website.

Gentlewines reserves the right to remove all comments and contributions that violate the law, the respect for the dignity of the person, that are discriminatory, xenophobic, racist, pornographic, spamming, that threaten youth or childhood, public order or safety, or that, in its opinion, are not suitable for publication.

The User declares to be of legal age and to have sufficient legal capacity to be bound by these Conditions. Therefore, this Gentlewines Website is not directed at minors.

III. Access and Navigation: Exclusion of Guarantees and Liability

Gentlewines does not guarantee the continuity, availability, and usefulness of the Website, nor of the Contents or Services. Gentlewines will do everything possible for the proper functioning of the Website; however, it does not assume responsibility or guarantee that access to this Website will be uninterrupted or error-free.

Gentlewines shall not be liable for damages of any kind arising from the access, navigation, and use of the Website, including, but not limited to, those caused to computer systems or those caused by the introduction of viruses.

IV. Links Policy

It is reported that the Gentlewines Website puts or may put at the disposal of Users linking means, directories, and search engines that allow Users to access websites managed by third parties.

The installation of these links is intended to facilitate Users' search for information, without it being considered a suggestion, recommendation, or invitation to visit them. Gentlewines does not offer or market the products and/or services available on such linked sites.

Gentlewines assumes no responsibility for damages that may occur due to the access, use, quality, or lawfulness of the contents of websites not managed by Gentlewines and which are linked on this Website.

V. Intellectual and Industrial Property

Gentlewines, by itself or as an assignee, is the owner of all intellectual and industrial property rights of the Website, as well as of the elements contained therein. They will be protected works as intellectual property under the Spanish legal system.

All rights reserved. The reproduction, distribution, and public communication of all or part of the contents of this webpage, for commercial purposes, on any medium and by any technical means, without the authorization of Gentlewines, are expressly prohibited.

VI. Legal Actions, Applicable Law, and Jurisdiction

Gentlewines reserves the right to present civil or criminal actions it deems necessary due to the improper use of the Website and Contents, or due to a breach of these Conditions.

The relationship between the User and Gentlewines will be governed by the current regulations applicable in Spanish territory. Should any controversy arise, the parties will submit their conflicts to ordinary jurisdiction, submitting to the corresponding judges and courts in accordance with the law.

Last updated: 01/15/2026.