Privacy Policy

Effective date: April 23, 2026

This Privacy Policy describes how Voino.App ("we", "us", or "our") collects, uses, shares, and deletes your information when you use our mobile application (the "App").

1. Controller

Loyalty By Data LLC is the data controller for purposes of applicable data protection laws for Voino.App.

Contact: ivan@voino.app

2. Data We Collect

a. Account & Identity

Email address (if provided)
Authentication identifiers (Firebase Auth UID)
Username (handle) and display name

b. User Content

Wine label images (front/back)
Optional memory/occasion images
Wine data (name, winery, vintage, varietal, region)
Ratings, notes, timestamps, location (if added)
Social graph (followers/following)
Engagement data (likes, comments)

c. Device & Technical Data

Device type, OS, app version
Log data (crash reports, diagnostics)
Push notification tokens

d. Location

User-provided or derived location attached to a wine entry (optional)

3. Purposes of Processing

We process data to:

Provide core functionality of the App
Populate wine details using AI (label images only)
Enable social features (follow, like, comment)
Maintain security, prevent abuse, and debug issues
Send transactional or optional push notifications

        Important: Memory/occasion images are never sent
        to AI services.
      

4. Legal Bases (EEA/UK)

We rely on:

Contract — to provide the App
Legitimate interest — to improve, secure, and operate the service
Consent — for optional features (e.g., notifications, optional data)

5. Sharing & Processors

We do not sell personal data.

We share data only with processors necessary to operate the App:

Firebase (Google) — authentication, database, storage
AI provider — processing wine label images only
Infrastructure/analytics providers — hosting and performance monitoring

Processors are contractually bound to confidentiality and security obligations.

6. International Transfers

Your data may be processed outside your country (e.g., United States). Where required, we use appropriate safeguards such as Standard Contractual Clauses.

7. Data Retention

We retain personal data only as long as necessary to provide the service.

Upon account deletion, data is erased as described in Section 10. Residual backups may persist for a limited period but are automatically deleted or anonymized.

8. Your Rights

Subject to applicable law, you may:

Access your data
Rectify inaccurate data
Delete your data
Object to or restrict processing
Request data portability

Requests can be made in-app or via ivan@voino.app.

9. Security

We implement industry-standard technical and organizational measures. However, no system is completely secure.

10. Account Deletion (Apple-Compliant)

We provide in-app account deletion as required by Apple App Store guidelines.

How to delete your account:

Open Profile (Portfolio)
Go to Settings
Tap Delete Account
Confirm by typing the required phrase

Scope of deletion:

When you delete your account, we permanently delete:

Firebase Authentication account
User profile (Users/{uid})
All wines created by you (Wines where userId = uid)
Images stored in cloud storage (e.g., wines/{uid}/..., avatars/{uid}/...)
Social graph data (followers/following references)
Likes and comments associated with your account (where feasible)
Push notification tokens
Any associated app data tied to your UID

Timing:

Deletion is initiated immediately upon confirmation
Most data is deleted in real-time
Some systems may take up to 30 days to fully purge residual data (e.g., backups)

Important:

Deletion is permanent and irreversible
We do not retain copies of your personal content after deletion, except where legally required

If you cannot access your account:

You may request deletion by contacting: ivan@voino.app

We may require verification of ownership before processing the request.

11. Children

The App is not intended for children under 18. We do not knowingly collect data from children.

12. Cookies & Tracking

We use limited analytics for product improvement. We do not use third-party advertising trackers.

13. Changes

We may update this Privacy Policy. Material changes will be communicated within the App.

14. Contact

Email: ivan@voino.app

This Privacy Policy is designed to comply with Apple App Store Review Guidelines (Section 5.1.1) and applicable data protection laws including GDPR.