|
Data |
Content and purpose |
Retention period |
|
Conversation in your browser |
A random identifier, the conversation’s messages and your reading position, created only when you open the assistant, so the conversation can resume when you change pages. Only the identifier is sent to our server. |
Until you close the tab |
|
Abuse protection |
Number of requests per IP address, held in memory only, with the address replaced by a code (hash) whose key changes every day. |
1 hour |
|
Ongoing conversation |
Recent messages, already stripped of contact details, so the assistant can keep track of the conversation’s context. |
2 hours after the last message |
|
Text of flagged conversations |
Messages and answers, without contact details, used to correct errors and improve the assistant (see 11.2). |
30 days after the last message |
11.2 - WHEN DO WE KEEP THE TEXT OF A CONVERSATION?
The text of a conversation is kept only when the conversation is flagged, which happens:
- when you mark an answer with the “thumbs down” button (this conversation didn’t help);
- when the system has to automatically correct an answer, for example a link, a price or a wine’s availability, or detects an error it cannot correct;
- when the assistant is unable to answer.
These conversations can only be read by people designated by our Data Protection Officer (DPO), from Bacalhôa’s internal network, and every access is logged. The text is not exported and is automatically deleted 30 days after the last message.
11.3 - WHAT DO WE KEEP?
Before your message is sent to the model, and without it being recorded, we automatically remove email addresses, phone numbers, tax identification numbers, IBANs, card numbers and postcodes. This removal does not reliably detect people’s names or addresses written out in full, so please do not include them.
- Health: the text of conversations about health, allergies, pregnancy, medication or driving after drinking is never kept, even if the conversation is flagged. Messages about pregnancy, breastfeeding or medication are also not sent to the model.
- Minors: if you state that you are under 18, messages in that conversation are no longer sent to the model and its text is not kept.
- Cookies and third parties: in your browser, the assistant does not create cookies and communicates only with Bacalhôa’s server. Links to the online shop identify the wine or the promotion, never the person clicking. Once you click a link and enter the online shop, the shop’s cookie policy applies.
11.4 - WHO GENERATES THE ANSWERS?
Answers are generated by Anthropic’s Claude Sonnet 5 model, which acts on our behalf as a processor, via the Claude API. The model runs in the United States, so sending messages to it constitutes an international data transfer, carried out with the safeguards provided for in the GDPR. Anthropic receives only your message, already stripped of contact details, and the conversation’s recent messages. Under Anthropic’s commercial terms, this data is not used to train its models and is deleted within 30 days. Anthropic may keep requests flagged by its safety systems for up to 2 years, as well as anything required by law.
11.5 - ON WHAT LEGAL BASIS DO WE PROCESS THIS DATA?
We process this data on the basis of our legitimate interest in providing, protecting and improving the assistant (Article 6, n.º 1 (f), GDPR). Storing the conversation in your browser is strictly necessary for the service you requested and only happens after you open the assistant.
11.6 - DOES THE ASSISTANT MAKE DECISIONS FOR YOU?
No. The assistant only provides information and suggestions. It does not make solely automated decisions that produce legal effects concerning you (Article 13, N.º 2 (f), GDPR) or that similarly significantly affect you, nor does it profile users.
11.7 - HOW CAN YOU EXERCISE YOUR RIGHTS?
You can exercise your rights of access, rectification, erasure, restriction and objection by writing to privacidade@bacalhoa.pt. As conversations are not linked to your identity, we may be unable to find them (Article 11, GDPR). In any case, the text of flagged conversations is deleted after 30 days.
We review this section whenever we change the model provider, the region where it runs or what we keep.
Last updated: 21/10/2026
PERSONAL DATA PROTECTION POLICY
BACALHÔA GROUP needs to collect and process personal data from individuals for its activity. This includes information from customers, suppliers, business contacts, employees and other people and members of organizations that you have contacted or may need to contact.
This policy describes how personal data must be collected, handled and stored in accordance with the data protection requirements of BACALHÔA and the law, regardless of its support (electronic, paper or any other).
This policy applies:
-To the headquarters of the BACALHÔA GROUP.
-All the branches of BACALHÔA GROUP.
-All employees of BACALHÔA GROUP regardless of the type of contract.
-All subcontractors, suppliers and other persons or organizations that act on behalf of BACALHÔA GROUP.
This policy ensures that BACALHÔA GROUP:
-Complies with the legislation on the protection of personal data, especially the EU Regulation 2016/679, of 27/04.
-Protects the rights of employees, customers and other partners.
-It is transparent about how it handles personal data.
-Protects yourself from the risk of personal data breaches.
The principles applicable to the protection of personal data are:
- Lawfulness, loyalty and transparency: it is necessary to identify the legal basis of each data processing and previously inform the holders in clear and accessible language about the purposes and the way in which we do it.
-Limitation of purposes: the specific purposes of the processing of personal data must be explicit, legitimate and determined when collecting personal data. Data collected for one purpose must not be used for anything other than the first.
-Suitability, relevance and minimization: only personal data necessary and adequate for the purposes to be achieved will be processed.
-Accuracy and Update: Necessary measures must be taken to ensure that inaccurate data is corrected or deleted.
-Limitation of retention: personal data will only be kept for the time necessary for the purpose for which they are intended. A deadline for erasure or destruction will be set for each set.
-Security and confidentiality: personal data will be stored in such a way as to guarantee their protection and their access will be conditioned in order to guarantee that only authorized personnel can process them.
-Privacy by design and by default: before any data processing takes place, steps will be taken to ensure that privacy is a concern from the beginning and throughout the processing process.
-Data subjects have the right of access, rectification, limitation of purposes, portability, erasure and opposition to automated decisions.
-The employee who receives contact from a holder who intends to exercise any of these rights, must verify the identity before providing any information, in accordance with the procedure for exercising rights. After that, you must forward the request to the EPD (Data Protection Officer) for processing.
-BACALHÔA GROUP may share data with public authorities without the knowledge of the holders in compliance with a legal or judicial obligation.
For any question related to the Protection of Personal Data, contact privacidade@bacalhoa.pt