Draft · needs legal review

Privacy notice

This notice explains how Swirl Wine Academy ("we") processes personal information under the Protection of Personal Information Act 4 of 2013 (POPIA). It is a working draft for the pre-launch site and will be finalised before general launch.

1. Responsible party & Information Officer

Swirl Wine Academy / Coflex (details to be confirmed for final notice). Contact: hello@swirl.wine. Early-access and enquiry forms also go to martin@coflex.wine.

2. What we collect

Early-access / waitlist details (name, email, phone if given, audience type, optional message), trade and sponsor enquiry details, and an age-confirmation flag stored on your device (localStorage).

3. Why & lawful basis

To answer requests and send launch news (consent), and to keep the site secure and age-gated (legitimate interest).

4. Operators & cross-border transfers

Forms are delivered via FormSubmit. Hosting will be on Porkbun static hosting for swirl.wine. Analytics (Google Analytics 4) will only load once a Measurement ID is configured and after any required consent steps. Some providers may store data outside South Africa under adequate safeguards.

5. Retention

Waitlist and enquiry data until launch plus a reasonable period (target: 12 months) or until you ask us to delete it / unsubscribe.

6. Your rights

Access, correction, deletion, objection and withdrawal of consent. You can also complain to the Information Regulator (inforegulator.org.za).

7. Cookies & local storage

Essential: age-gate answer on this device. Analytics: Google Analytics 4 will load only after a Measurement ID is set in site.js (placeholder until then). Marketing cookies are not used on this pre-launch site.

Last updated: 27 October 2026 (Africa/Johannesburg).