Privacy and Cookie Policy

Your privacy is important to us. We respect your privacy and are committed to us. We respect yout privacy are committed to protecting you. To best protect your privacy, we present this notice explaining our privacy practices and the available for how your information is collected and used.

 

1 - WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT ?
We may requesr personally identifiable information when you request to an inquiry, participate in a contest, exchange correspondence with us or participate in certain other activities. You decide whether you wish to pursue any activity that solicits personal information. However, if you do not want to provide the requested personal information, you may not be able to complete the transaction. Similarly, when you visit our Websites, we will collect information known as "clickstreams" (IP address, domain name, etc.). This information combined with the data you provide, allows us to custumize your visits better.

 

2 - HOW DO WE USE THE INFORMATION WE COLLECT ?
We use personal infromation in the following ways: 1. To provide you with information about product updates, new products, services, newsletters, informational emails and research on ideas for future products or improvements; 2. To help us create relevant content for you; 3. To offer you special offers that may be of interest you; 4. To help us create better products and services that meet your needs; 5. To allow you to download documents, gain access to services or participate in other activities you selct; 6. To help you quickly find aoftware, services, or infromation about products important to you.

 

3 - WHO HAS ACCESS TO YOUR PERSONAL INFORMATION AND TO WHAT EXTENT ?
To ensure the security of your information, we have established a series of security measures and protections. Your personal information is stored on secure networks that can only be accessed by a limited number of people who have special access rights and undertake to respect and maintain the confidential nature of such information. Notwithstanding these measures, when you provide personal information on the Internet there is always a risk that may be intercepted and used by third parties outside our control. While we make every effort to procect your personal information and your privacy, we can not guarantee the security of the information you make available through the Internet.

 

 

4 - WHO HAS ACCESS TO YOUR PERSONAL INFORMATION AND TO WHAT EXTENT ?
In assition to the companies in our group and for the purposes described above, we do not sell, exchange or tranfer to third parties your personal information in any form. Your personal information may be transferred to third party subcontractors to provide us with certain services. We require these suppliers to use personal information anly on behalf of Maisis - Information Systems Lda. You may at time choose not to allow the sharing of your personal information with third parties. Such a request can be mede through our website in the contact section or simply by emailing us.

 

5 - LINKS
In order to improve the services offered, we may provide links to third party websites. Maisis - Information Systems, Lda is not responsible for the privacy practices of such Websites.We recommended that you read as their respective statements, as we are different. Maisis - Information Systems, Lda can not be responsible, for the content and activities of such websites.

 

6 - COOKIES
Maisis - Information Systems, Lda, websites may use technology widely known is the industry as “cookies”. Cookie is a unique text file that a website sends to your browser software.Cookies allow a website to customize the information presented to you, based on your browsing preferences. We may use cookies to personalize your pages or to "remeber" you when registering products or services. If you do not want us to install cookies in your browser, you can set cookies to reject cookies. Rejecting cookies may effect your ability to use some of the servicfes on our website. Maisis - Information Systems, Lda also uses cookies to track visits to our websites. The information collected in this way hels us to optimize the content of websites, navigation on them and their performance.

 

7 - OPTIONS AND CANCELLATION
There are several ways you can reviw, change or delete your personal information, or request that we do not send you additional information, or request that we do not send you a additional information. We may at the same time make these options available to you when you provide us with personal information. You may also reviw, update or delete your account by editing your profile and account settings in the registration area where and as applicable. To protect your privacy and securty, we will take reasonable steps to verify your identify before granting access or making corrections. If you have difficulty changing or delecting your personal information, you can contact us for assistance.

 

8 - CHAGES TO THE PRIVACY POLICY
In the future, we may choose to modify or update this policy either because of changes in legislation or in order to cover new developments in the Internet. Accordingly, we reserve the right to make any changes in this regard and request that you visit this page on a regular basis, as such changes may affect you as a visitor to our website.

 

9 - CONTACT US
For any questions regarding this privacy policy and privacy aspects of our products and services, or to make a complaint, please contact:
Estrada Nacional 10,
Vila Nogueira de Azeitão
2925-901 Azeitão
Portugal
T. +351 21 219 80 60
F. +351 21 219 80 66
E. info@bacalhoa.pt

 

10 - WHO MANAGES PERSONAL INFORMATION?
Our Websites and the information collected are managed and controlled by Maisis - Information Systems, Lda. We provide sufficient guarantees regarding the protection of your personal information being administered in accordance with the current legislation on the protection of personal information, as well as this information privacy policy.

 

11 - WHO MANAGES PERSONAL INFORMATION?
The wine assistant on bacalhoa.pt is an automated artificial intelligence system: you are not talking to a person. It answers questions about our wines and food pairings and was designed to use as little personal data as possible: it does not ask for your name or contact details, does not require registration and does not use cookies.

Answers are generated automatically, may contain errors and do not replace official confirmation of prices, availability or terms.

This section applies only to the assistant. For everything else, the rest of the website’s Privacy Policy applies.

11.1 - WHAT DATA DO WE KEEP AND FOR HOW LONG?

We keep only the data listed below, all of which is deleted automatically, either on Bacalhôa’s servers in Portugal or in your browser.

 

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