Punto di Spuma — Privacy Policy

Last updated: 17 October 2026

1. Controller

The controller of the personal data described in this policy is BERE SPUMANTI Sp. z o.o., ul. Milenijna 43 lok. 2, 03-130 Warszawa, Poland; NIP 5243007016, REGON 528661626, KRS 0001106084. Contact for all privacy matters, including data deletion: biuro@berespumanti.pl.

Punto di Spuma is a brand of BERE SPUMANTI Sp. z o.o.

2. Scope

This policy covers personal data that Punto di Spuma processes when you interact with the brand's pages, profiles and channels on social media and messaging platforms (Facebook, Instagram, Threads, X (Twitter), TikTok, YouTube, WhatsApp, Telegram, LinkedIn), and when the brand's own software connects to those platforms through their official APIs. This software consists of automation modules (OpenClaw) that run on servers controlled by BERE SPUMANTI Sp. z o.o. The supmgm.info website only publishes this policy and related information; it does not collect data from you (see section 10).

3. Data we process

• public data of the brand's pages and profiles;
• content that the brand publishes;
• comments and private messages addressed to the brand, together with the information the platform provides with them, such as your public name or user identifier;
• aggregated statistics of the brand's pages.

4. Purposes and legal bases

• publishing the brand's content — our legitimate interest in communicating about the brand and its products (Art. 6(1)(f) GDPR);
• replying to your comments and messages, including advice on the brand's products — steps taken at your request before entering into a contract, or performance of a contract (Art. 6(1)(b) GDPR); otherwise our legitimate interest in answering you (Art. 6(1)(f) GDPR);
• analysing page statistics — our legitimate interest in understanding how our pages perform (Art. 6(1)(f) GDPR).

We do not sell personal data and do not share it with third parties for advertising.

5. Use of AI services

The text of comments and messages addressed to Punto di Spuma may be processed by AI services of large language model providers — Anthropic (Claude) and OpenAI (GPT) — to prepare replies and advice on the brand's products. Replies are based on reference information about the brand's products. This data is not used to train the providers' models.

6. Where data is stored and transfers

Our automation modules run on servers in the European Union (currently Poland and Italy). If servers in other countries of the European Economic Area (EEA) are used, the same level of protection applies.

Personal data is transferred outside the EEA only through Cloudflare (hosting and content delivery of the supmgm.info website) and the AI services listed in section 5, and only with the safeguards required by the GDPR: standard contractual clauses or the EU–U.S. Data Privacy Framework, as applicable to each provider.

7. Retention

Data received through connected social networks and OAuth authorisations (access tokens and other data received through the connection) is stored for no longer than 4 weeks. Correspondence and comments of customers are kept for the duration of our cooperation and for up to 2 years after the last contact. Documents relating to transactions are kept for the period required by law (e.g. accounting documents — 5 years from the end of the financial year). Logs and backups are kept for up to 4 weeks; a backup snapshot is taken once a week.

8. Your rights

Where the law provides for it, you have the right to access your personal data, to have it rectified or erased, to restrict its processing, to data portability, and to object to processing based on legitimate interest. To exercise these rights, write to biuro@berespumanti.pl.

You also have the right to lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, UODO), ul. Stawki 2, 00-193 Warszawa, Poland.

9. Data deletion

To request deletion, follow the instructions on the data deletion page. We confirm the request and delete the data from active systems within 72 hours; from backups automatically within 4 weeks. Data we are required by law to keep (e.g. accounting documents) is retained for the legally required period.

10. This website

The pages of supmgm.info do not use cookies or browser local storage and contain no forms, analytics or tracking code. The website is hosted and delivered by Cloudflare, which processes IP addresses and technical data of requests in order to deliver the pages.

11. Changes

We publish changes to this policy on this page and update the date above.