What happens to your data when you land here

There's no sign-up here, no basket, no comments and no working form. We don't ask you for anything and we don't keep a database of your details. That said, loading any web page leaves a trail, and there are third parties collecting data while you read. This page says which ones, what they get and what you can do about it.

Who's responsible

The data controller is the Clandestine Tasting Club (Club Clandestino de Cata), an editorial wine project published from Spain. For anything to do with privacy, or to exercise your rights, write tohola@clandestinodecata.club.

If you need the full identifying details of the person behind it (name and tax ID), for instance to file a formal complaint, ask at that same address and we'll give them to you.

What we collect ourselves

Nothing, directly. No user accounts, no working forms, no first-party cookies. Everything that gets collected is collected by the providers that keep the site running, which are the ones below.

Hosting: Cloudflare

The site is hosted on Cloudflare Pages. Its servers log the minimum needed to serve the page and protect it from attacks: IP address, browser type, page requested and time. Cloudflare acts as our processor and may handle that data outside the European Economic Area, covered by the European Commission's standard contractual clauses.

Legal basis: legitimate interest in keeping the site up and secure (GDPR art. 6(1)(f)).

Analytics: Cloudflare Web Analytics

To know what gets read and what doesn't, we use Cloudflare Web Analytics. It sets no cookies, does no browser fingerprinting and doesn't follow you from site to site. What we see is aggregate numbers: page views, where people arrive from, country and device type. We can't identify you from that, and we don't want to.

Legal basis: legitimate interest in understanding how the site is used (GDPR art. 6(1)(f)).

Advertising: Google AdSense

These pages carry ads served by Google AdSense. Google acts here as an independent controller: it uses cookies and identifiers to choose ads, cap how often you see the same one and measure whether they work. Depending on your settings, those ads may be personalised based on your browsing history.

Straight talk: this site does not currently show a cookie consent banner, and for personalised advertising the correct legal basis is your prior consent. We're working on that mechanism. Until it lands, these controls work today and don't depend on us:

• Turn off Google's personalised ads atMy Ad Center.
• Manage third-party behavioural advertising atYour Online Choices.
• Block third-party cookies in your browser settings.

The detail of what Google does with that data: how it uses cookies in advertising and its privacy policy.

Typefaces: Google Fonts

The site's fonts load from Google Fonts servers, so Google receives your IP address and browser when they're requested. We're looking at serving them from our own domain to save you that hop.

Links to shops

Some buying links are affiliate links and pass through the TradeTracker network, which drops a cookie to credit the Club if you end up buying. From the click onwards, that network's policy and the shop's policy apply, not ours. All we see are aggregate reports: how many sales, how much commission. We never know who bought or what they bought.

How all of that works is in theaffiliate disclosure.

Instagram and outbound links

There are no Instagram widgets or iframes: the images you see are hosted here, so Instagram isn't watching you while you browse this site. Clicking a link and heading off to Instagram or a shop is another matter, and their policy takes over there.

Newsletter

There is no newsletter right now. The form isn't live on any page and we don't collect or store any email address. When we do launch one, we'll say so here, naming the provider, before we ask you for anything.

Cookies, in short

• First-party: none.
• Google AdSense: advertising and measurement, on every page.
• TradeTracker: only if you click a buying link, to credit the order for 30 days.
• Cloudflare Web Analytics: uses no cookies.

You can delete or block them any time from your browser settings (Chrome, Firefox, Safari,Edge). The site reads just as well without them.

How long it's kept

On our side, nothing: we don't store personal data about you anywhere. Server logs are kept by Cloudflare for a limited period under its own policy, and third-party cookies expire on whatever schedule each one sets.

Your rights

You can request access to your data, have it corrected or deleted, object to processing, restrict it or ask for it to be ported. Write tohola@clandestinodecata.club and we'll reply.

Since we keep no user database, the odds are we hold nothing about you. If that's the case we'll say so plainly and point you to whoever does (Google or Cloudflare, depending on the case). If you think we've handled it badly, you can complain to the Spanish Data Protection Agency: aepd.es.

Minors

This site is about wine and is for ages 18 and over only. We don't aim any content at minors and we don't knowingly process their data.

Changes

When something substantial changes (the consent banner, the newsletter, a new affiliate network) we update this page and move the date at the top. No odd notices, no hidden versions.