Winona — Privacy Policy
DEVOPSLY LTD ("we", "us", "our") operates the Winona mobile application and related services (the "Service"). This Privacy Policy explains what personal data we collect, why we collect it, how we use and share it, and the rights you have over it.
This Policy should be read together with our Terms and Conditions. Where a term is defined in the Terms and used here with the same meaning (such as "User Content" or "Aggregated Data"), that definition applies.
1. Who We Are
DEVOPSLY LTD is the data controller responsible for your personal data under UK data protection law (and, where applicable, the EU GDPR). Our registered address is 120a Camden Road, London, NW1 9EE, United Kingdom.
2. Information We Collect
2.1 Information You Provide to Us
- Account information: name, email address, password, and profile details.
- User Content: wine notes, tasting comments, collections, and photos you create, upload, or store in the App.
- Event and Organiser information: if you are an Organiser, event descriptions, wine lists, pricing, and attendee lists you manage through the CMS.
- Payment information: we do not currently process payments in the App. If we introduce paid features in future (as contemplated by our Terms and Conditions, Section 11), a third-party payment processor will collect your payment details directly, we will not store your full card details ourselves, and we will update this Policy accordingly.
- Sign-in information: if you sign in with Apple, we receive the identifier, and any name or email you choose to share, provided by Apple.
- Communications: messages you send us, including support requests and content reports.
2.2 Information We Collect Automatically
- Location data: with your permission, we collect your device location to show you nearby events and venues. You can disable this at any time in your device settings, though some features may not work without it.
- Device and usage data: device type, operating system, app version, log data, and how you interact with the Service.
- Photos and label images: images you upload for wine identification, which may be processed using image recognition and optical character recognition (OCR) technology (see Section 5).
- Push notification tokens: a device identifier used to deliver notifications to you, if you enable them.
2.3 Aggregated and Contextual Usage Data
As described in our Terms and Conditions, we derive aggregated and contextual usage data from your activity (such as tasting trends, behavioural patterns, and demographic or regional patterns), which may in some cases be indirectly identifiable. This is described in detail in Section 6.
3. How We Use Your Information
We use your personal data to:
- Create and manage your account, and provide the Service's core features (notes, collections, events).
- Show you relevant nearby events using your location.
- Process payments for Purchases and Organiser Fees.
- Identify wines and extract label information using AI and OCR (see Section 5).
- Send you push notifications and service communications, where enabled.
- Maintain the security and integrity of the Service, including fraud prevention and enforcement of our Terms.
- Generate Aggregated Data for analytics and for sharing with Organisers and analytics providers (see Section 6).
- Comply with our legal obligations.
4. Legal Bases for Processing
Where UK/EU GDPR applies, we rely on the following legal bases:
- Contract: processing necessary to provide the Service you signed up for (account, notes, events, payments).
- Legitimate interests: for security, fraud prevention, product improvement, and generating Aggregated Data, balanced against your rights and interests.
- Consent: for location access, push notifications, and any optional marketing communications, which you can withdraw at any time.
- Legal obligation: where we must retain or disclose data to comply with the law.
5. AI, OCR, and Automated Processing
When you upload a photo of a wine label, that image is sent to OpenAI, whose vision-capable AI models we use to identify the wine and extract label information. We may also use the Brave Search API, server-side, to look up additional wine information; this only involves wine-related search terms, not your personal data.
This processing assists you in creating your notes and collection; it does not make legal or similarly significant decisions about you, and no automated decision-making with legal effect is performed on your personal data.
OpenAI processes API data under its own data protection terms; as of the last update to this Policy, OpenAI does not use data submitted through its API to train its models by default, and retains it only briefly for abuse-monitoring purposes. We do not control, and are not responsible for, changes OpenAI or Brave may make to their own data practices.
To fill in: confirm the current OpenAI API data retention/training terms at the time of publishing (these can change), and check whether Winona has a Data Processing Agreement or zero-retention agreement in place with OpenAI, which would strengthen this section.
6. Sharing Your Information
6.1 With Event Organisers
If you attend an event, the Organiser may receive Aggregated Data about attendee engagement with their event, as described in our Terms and Conditions (Section 8). This data may sometimes be indirectly identifiable, for example through a public profile or username. You can opt out of future data sharing at any time in your privacy settings; this stops future sharing but does not remove data from reports already compiled.
If you provide contact details directly to an Organiser (for example, at check-in), the Organiser acts as an independent data controller for that information and is responsible for their own compliance.
6.2 With Service Providers
We share personal data with third-party service providers who perform services on our behalf, under contractual obligations to protect your data and use it only for the purposes we specify. We currently use:
- Supabase — our core backend: database, authentication, file storage, realtime features, and server-side processing.
- Netlify — hosting for the Organiser content management system (CMS) only; not used for the consumer App.
- PostHog — product analytics, to understand how the App is used.
- Sentry — crash and error reporting.
- OpenAI — AI-based wine label recognition (see Section 5).
- Brave Search — optional, server-side wine information lookup (see Section 5).
- Resend — delivery of transactional emails (e.g. account and event notifications).
- Apple — Sign in with Apple authentication, and delivery of push notifications via Apple Push Notification service (APNs), via Supabase Auth.
We will update this list as our service providers change.
6.3 Legal and Business Reasons
We may disclose your information where required by law, to protect our rights or the safety of others, in connection with a merger, acquisition, or sale of assets, or to enforce our Terms and Conditions.
We do not sell your personal data.
7. International Data Transfers
Our core backend (Supabase) stores data in London, UK (AWS eu-west-2). Our analytics provider, PostHog, uses its EU Cloud instance. Some other service providers we use may process personal data in the United States, including OpenAI (wine label images, for recognition), Netlify (Organiser CMS hosting), Sentry (crash reports), and Resend (email addresses, for delivery).
Where personal data is transferred outside the UK or European Economic Area, we rely on appropriate safeguards recognised under UK and EU data protection law, such as the UK International Data Transfer Agreement (IDTA), the EU Standard Contractual Clauses (SCCs) incorporated by the relevant provider, or another lawful transfer mechanism.
8. Data Retention
We retain your personal data for as long as your account is active, and as described in our Terms and Conditions (Section 14) after you delete it: your content is removed from public areas of the Service immediately, while backup copies may be retained for a limited period for security, technical, and legal reasons, and are not accessible to other users or the public.
Aggregated Data compiled before you opted out of data sharing is retained as described in Section 6.1 and our Terms and Conditions.
We retain payment records for as long as required by applicable tax and accounting law.
9. Your Rights
If UK/EU data protection law applies to you, you have the right to:
- Access the personal data we hold about you.
- Correct inaccurate or incomplete data.
- Request deletion of your data, subject to the retention described in Section 8.
- Restrict or object to certain processing, including processing based on legitimate interests.
- Receive a copy of your data in a portable format.
- Withdraw consent at any time where processing is based on consent (e.g. location, push notifications), without affecting processing carried out before withdrawal.
- Opt out of Aggregated Data sharing at any time in your privacy settings.
To exercise these rights, contact us using the form referenced in Section 13. You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk, or with your local supervisory authority if you are in the EU.
10. Children's Privacy
The Service is not directed at, and is not intended for use by, anyone under the age required by our Terms and Conditions (the greater of 18 or the legal drinking age in their jurisdiction). We do not knowingly collect personal data from underage users. If we become aware that an underage user has provided us with personal data, we will delete their account and associated data, as described in our Terms and Conditions.
11. Push Notifications and Marketing Communications
If you enable push notifications, we use your device's notification token to send you updates about events, your account, and the Service. You can disable push notifications at any time in your device settings.
If we send marketing communications, we will only do so with your consent (or another valid legal basis where permitted), and every communication will include a way to opt out.
12. Data Security
We use appropriate technical and organisational measures to protect your personal data, including access controls and secure storage. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
13. Contact Us and Complaints
Questions about this Policy, or requests to exercise your rights under Section 9, can be sent using our contact form at winona.wine/contact, or by post to DEVOPSLY LTD, 120a Camden Road, London, NW1 9EE, United Kingdom.
If you are not satisfied with our response, you have the right to complain to the ICO (ico.org.uk) or your local data protection authority.
14. Changes to This Policy
We may update this Policy from time to time. We will notify you of significant changes through the App or by email. Continued use of the Service after changes take effect constitutes acceptance of the revised Policy.