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Business Contact Privacy Notice

Version 2026-08-18-UK2 · Last updated 18 August 2026

This notice explains how Greg Bowe trading as MyNextWine, an Irish sole trader and the controller, uses business-contact information when introducing the My Next Wine Wine Finder to selected wine retailers in Ireland and the United Kingdom.

1. Information and source

We may record a store's name, public website/domain, country, ecommerce platform, public business email address, the contact role where apparent, the particular public source and date obtained, subscriber/corporate-status assessment and evidence, marketing-permission assessment, contact dates, responses, consent evidence and do-not-contact status. The first live email states the recorded source. We do not infer that a business is a company merely because it has a website or a business-looking email address.

2. Purpose and lawful basis

We use this limited information to select relevant wine retailers, send a personalised introduction and at most one follow-up, answer enquiries, record any consent, and prevent further contact after an objection. For personal data used in proportionate business outreach and suppression, we rely on legitimate interests in introducing and administering a relevant B2B service and respecting objections. Where consent is required or chosen, we record and rely on that consent. We do not rely on the mere fact that information is public as a lawful basis.

3. Electronic-marketing rules

For a UK recipient, unsolicited electronic mail is sent only after we have recorded evidence that the recipient is a corporate subscriber, or that valid consent or every condition of the soft opt-in applies. Limited companies, limited liability partnerships and Scottish partnerships can be corporate subscribers. Sole traders, ordinary partnerships and recipients of unknown status are treated as individual subscribers and are not emailed without a qualifying permission.

For Irish recipients we apply the Irish ePrivacy rules, including the applicable consent requirement and the recipient's right to object. In every market, each live message identifies us, contains a working opt-out, and does not use a tracking pixel. Opt-outs and objections are honoured promptly; the right to object to direct marketing is absolute.

4. Recipients and international transfers

Access is limited to the controller and providers needed for secure hosting, database administration and email delivery. The current provider list is at mynextwine.com/subprocessors. We do not sell business-contact data. Where a restricted transfer needs safeguards, the applicable adequacy decision, EU Standard Contractual Clauses and, for a UK transfer where appropriate, the UK International Data Transfer Addendum or another lawful mechanism must be in place before the transfer.

5. Retention

Uncontacted lead information is reviewed and erased when it is no longer accurate, relevant or needed for the targeted business outreach. Contact history and permission evidence are kept only for the outreach, response and reasonably necessary legal-claims period. If you object or opt out, we erase unnecessary contact details but may keep an email/domain hash and minimal suppression evidence for as long as reasonably needed to ensure you are not contacted again. Suppression records are not used for another purpose.

6. Your rights and complaints

Depending on applicable law, you may request access, correction, deletion, restriction or portability, or object to processing based on legitimate interests. You may object to direct marketing at any time by replying to the email, using its secure opt-out link or contacting the privacy address above. We will not ask you to justify a direct-marketing objection.

To make a data-protection complaint, email the privacy contact with the subject “Data protection complaint” and describe what happened and the outcome you want. You may also write to the business address or, if a UK representative is listed above, contact them. We will help you make the complaint, acknowledge it within 30 days, investigate and keep you informed, and communicate the outcome without undue delay.

You may also complain directly to the Irish Data Protection Commission or, where UK law applies, the UK Information Commissioner's Office (ICO), or another competent supervisory authority. You do not have to complain to us first.

7. Changes

We may update this notice when our limited outreach, providers or applicable law changes. The current version and date will remain published here.