1. Introduction

Welcome to Swirl your wine (the "App"). We respect your privacy and are committed to protecting the personal information you share with us. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application. Please read this policy carefully to understand our views and practices regarding your personal data.

2. Information we collect

We may collect and process the following types of information:

• Personal Information: This includes your name, email address, date of birth, and other information that you provide when you register for the App or use certain features.

• Wine Preferences: Information about your wine preferences, tasting notes, and ratings.

• Images: Wine-related images you upload, including photos of wine labels, bottles, and menus. These images are only visible to you and are not shared with other users.

• Behavioral Data: Your wine rating patterns, search history, and interaction data within the App.

• Usage Data: Information about your interaction with the App, including the pages you view, the features you use, and your activity within the App.

• Location Data: With your consent, we may collect location data to provide you with location-based features, such as nearby wine recommendations.

• Device Information: Information about the device you use to access the App, including the device model, operating system, and unique device identifiers.

  
  

3. How we use your information

We use the information we collect for the following purposes:

• To provide and maintain our services, including personalized wine recommendations.

• To manage your account and provide customer support.

• To communicate with you about updates, promotions, and news related to the App.

• To analyze usage trends and improve the functionality and performance of the App.

• To train and improve our machine learning models and recommendation algorithms to provide better personalized experiences and wine suggestions.

• To comply with legal obligations and protect our rights.

  
  

4. Machine learning and recommendation systems

We use the information you provide, including your wine preferences, ratings, tasting notes, and uploaded images, to train machine learning models and improve our recommendation algorithms. This helps us:

• Provide more accurate wine recommendations

• Improve wine recognition and classification through image analysis

• Enhance the overall user experience

• Develop better features and functionality

Your uploaded images are only visible to you and are not shared with other users. We may use these images in anonymized form to train our wine classification models. We implement computer vision technology to ensure uploaded images are wine-related content only.
You can opt out of having your data used for machine learning purposes by contacting us at hey@swirlyourwines.com, though this may affect the quality of recommendations you receive.

5. Legal basis for processing (EU Users)

For users in the European Union, our legal basis for processing your personal data includes:

• Consent: For location data, marketing communications, and optional features

• Contract Performance: To provide the App services you've requested

• Legitimate Interest: To improve our services, including through machine learning and analytics, provided this doesn't override your privacy rights

  
  

6. Sharing your information

We may share your information with third parties in the following situations:

• Service Providers: We may share your information with third-party service providers that assist us in operating the App, such as hosting providers, analytics services, and marketing partners.

• Legal Compliance: We may disclose your information if required to do so by law or in response to valid requests by public authorities.

• Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.

We do not sell, trade, or otherwise transfer your personal information to third parties for their marketing purposes.

7. Data retention

We will retain your personal information for as long as your account is active or as needed to provide you services. When you delete your account, we will delete your personal information within 30 days, though we may retain anonymized data (that cannot be linked back to you) for improving our services and machine learning models. You can request complete deletion of all your data by contacting us at hey@swirlyourwines.com

8.Your rights

Depending on your location, you may have the following rights regarding your personal information:

• Access: You have the right to request access to the personal information we hold about you.

• Correction: You have the right to request that we correct any inaccuracies in your personal information.

• Deletion: You have the right to request the deletion of your personal information, subject to certain exceptions.

• Objection: You have the right to object to the processing of your personal information in certain circumstances, including for machine learning purposes.

• Data Portability: You have the right to receive a copy of your personal information in a structured, commonly used, and machine-readable format.

• Withdraw Consent: Where processing is based on consent, you have the right to withdraw that consent at any time.

To exercise these rights, please contact us at hey@swirlyourwines.com. We will respond to your request within one month.

9. Security

We implement reasonable security measures to protect your personal information from unauthorized access, use, or disclosure. This includes encryption of data in transit and at rest, access controls, and regular security assessments. However, no method of transmission over the internet or electronic storage is 100% secure.

10. Children's privacy

Our App is not intended for use by children under the age of 13 or anyone under the age of 18 according to EU laws. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under the age of 13, we will take steps to delete that information as soon as possible.

11. International data transfers

If you are accessing the App from outside Sweden, please be aware that your information may be transferred to, stored, and processed in a country other than your own, where data protection laws may differ from those in your jurisdiction. We ensure appropriate safeguards are in place for such transfers in accordance with applicable data protection laws.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last updated" date at the top. For significant changes, we may also notify you via email or through the App. We encourage you to review this Privacy Policy periodically.