Privacy Policy.

Last updated: 29 September 2026

1. Who we are

1.1 This Privacy Policy explains how VIN DE GARDE PTE. LTD. (UEN 202616134D) ("Garde", "we", "us") collects, uses, discloses and protects personal data in connection with our website, applications, wine storage services and marketplace (the "Services").

1.2 We comply with the Personal Data Protection Act 2012 of Singapore ("PDPA"). Terms not defined here have the meaning given in our Terms and Conditions.

2. Personal data we collect

2.1 Depending on how you use the Services, we may collect:

• Identity and contact data: name, date of birth or confirmation of age, email address, telephone number, residential or delivery address, and, for corporate Clients, details of authorised representatives.
• Verification data: information and documents needed to verify your identity, age, source of Wine or funds, or tax status, where required (see clause 3).
• Account and transaction data: log-in details, listings, offers, purchases, sales, storage and delivery records, fees and correspondence.
• Inventory data: details of Wine you deposit, buy or sell, including photographs, condition reports and provenance information you provide.
• Payment and settlement data: payment method details (processed by our payment service provider), and bank account details for remittance of sale proceeds.
• Tax data: GST registration status and number, where relevant.
• Technical data: IP address, device and browser information, log data and cookie data (see clause 9).
• Facility data: CCTV footage and visitor records at our Storage Facilities and premises.
• Community data: your username, profile details and any posts, comments or images you publish on the Garde community forum.
• Marketing preferences.

2.2 We collect personal data directly from you, from your use of the Services, and from third parties such as payment providers, logistics providers, identity-verification providers and persons you authorise to act for you.

3. NRIC and identification numbers

3.1 We will only collect, use or disclose your NRIC number, FIN, passport number or copies of identity documents where required by law, or where necessary to establish or verify your identity to a high degree of fidelity (for example, before releasing high-value Wine, remitting sale proceeds, or where we are required to carry out checks). Where it is sufficient, we will verify your age or identity without retaining the full number or a copy of the document.

4. How we use personal data

4.1 We use personal data for the following purposes:

(a) opening, verifying and administering your Account;

(b) receiving, storing, recording, insuring and releasing Wine, and arranging delivery;

(c) operating the marketplace, including publishing Listings (without identifying the Seller to other Clients unless necessary), processing offers and purchases, and transferring Wine between Accounts;

(d) processing payments, collecting fees and remitting sale proceeds;

(e) verifying age and identity, preventing and detecting fraud, counterfeit wine and other unlawful activity, and managing risk;

(f) complying with legal and regulatory obligations, licence conditions, and requests or directions from competent authorities;

(g) resolving disputes and enforcing our Terms;

(h) communicating with you about the Services, including service notices and changes to our terms;

(i) improving the Services and carrying out analytics; and

(j) with your consent, sending you marketing about our Services, events and wine offers.

4.2 Community forum. If you join our community forum at la.garde.sg, your username, profile details and anything you post are visible to other members and may be publicly accessible. Do not post personal data, yours or anyone else’s, that you do not wish to be seen. You can edit or delete your own posts, but we may retain copies for moderation, security, dispute-resolution and legal purposes, and content that others have quoted or shared may remain. The forum is also subject to the community rules published on the forum.

5. Consent and withdrawal

5.1 By using the Services and providing personal data, you consent to our collection, use and disclosure of your personal data for the purposes in clause 4, and for any other purposes we notify to you at the time of collection. We may also rely on exceptions to consent permitted by the PDPA, including legitimate interests and business improvement.

5.2 You may withdraw consent at any time by contacting our Data Protection Officer. We will inform you of the likely consequences; for example, if the personal data is needed to store or release your Wine or to settle a sale, we may not be able to continue providing the Services. Withdrawal does not affect our right to retain and use personal data where permitted or required by law.

5.3 We will not send marketing messages to Singapore telephone numbers unless you have given clear and unambiguous consent or the Do Not Call Registry permits it. You may opt out of marketing at any time using the unsubscribe link or by contacting us.

6. Disclosure of personal data

6.1 We may disclose personal data to:

(a) service providers acting on our behalf, including warehouse, logistics, delivery, insurance, payment, identity-verification, cloud hosting, IT and communications providers, and professional advisers;

(b) the counterparty to a marketplace transaction, but only to the extent necessary to complete, document or resolve a dispute about that transaction;

(c) competent authorities, including the Singapore Police Force, Singapore Customs, the Inland Revenue Authority of Singapore and other regulators, courts and law enforcement agencies, where required or permitted by law;

(d) a purchaser or successor in connection with a sale, merger or restructuring of our business, subject to confidentiality obligations; and

(e) any other person with your consent.

6.2 We require our service providers to protect personal data and to use it only for the purposes for which it was disclosed.

6.3 We do not sell personal data.

7. Transfers outside Singapore

7.1 Some service providers (for example, cloud hosting and payment providers) may process personal data outside Singapore. Where we transfer personal data overseas, we take steps to ensure the recipient provides a standard of protection comparable to the PDPA, including through contractual safeguards.

8. Protection and retention

8.1 We make reasonable security arrangements to protect personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, and against loss of storage media. No method of transmission or storage is completely secure.

8.2 We retain personal data for as long as necessary for the purposes for which it was collected and for our legal, regulatory, tax, accounting and business purposes. Transaction and custody records are generally retained for at least 5 years after the transaction or the closure of your Account, or longer where required by law or where needed for a dispute. CCTV footage recorded at our own premises is generally retained for up to 30 days, unless it is needed for an incident investigation, insurance claim or legal proceedings. CCTV at third-party Storage Facilities is operated by the facility operator under its own retention policy.

8.3 In the event of a data breach that is likely to result in significant harm to you, we will notify you and the Personal Data Protection Commission as required by the PDPA.

9. Cookies and analytics

9.1 We use cookies and similar technologies that are necessary for the Services to function (for example, log-in and security), and, with your consent where required, for analytics and to remember your preferences. We do not currently use third-party analytics or advertising tools on our website. Our hosting provider records standard server logs (such as IP address, browser type and pages requested) for security and to keep the website running. If we introduce analytics or marketing tools we will update this Policy and, where required, ask for your consent.

9.2 You can control cookies through your browser settings and our cookie banner. Disabling certain cookies may affect the functioning of the Services.

10. Access and correction

10.1 You may request access to personal data we hold about you and information about how it has been used or disclosed in the past year, and may request correction of any error or omission. Send requests to our Data Protection Officer.

10.2 We will respond within 30 days or tell you when we can respond. We may charge a reasonable fee for access requests, and will tell you the fee in advance. We may decline requests where the PDPA permits.

11. Minors

11.1 The Services are not available to persons under 18. We do not knowingly collect personal data from persons under 18. If you believe a minor has provided us with personal data, please contact us so that we can delete it.

12. Third-party sites

12.1 The Services may link to third-party websites. We are not responsible for their privacy practices.

13. Changes

13.1 We may update this Privacy Policy from time to time. The current version will be posted on our website, and material changes will be notified to you.

14. Contact — Data Protection Officer

Data Protection Officer, VIN DE GARDE PTE. LTD. (UEN 202616134D) [115A Commonwealth Drive, #01-01, Tanglin Halt Industrial Estate, Singapore 149596] hello@garde.sg

14.1 If you are not satisfied with our response, you may contact the Personal Data Protection Commission (www.pdpc.gov.sg).