1. Introduction

WhiskyCircle ("we", "us", "our") respects your privacy and is committed to protecting your personal data. This privacy policy applies to the use of our website, progressive web app (PWA) and mobile applications.

WhiskyCircle is provided by Waypointer Digital B.V., registered in the Netherlands. For questions, you can contact us at privacy@whiskycircle.app.

2. What data do we collect?

We collect the following categories of personal data:

• Account data — name, email address, username, profile photo
• Usage data — whisky collection, reviews, ratings, recipes, friends and interactions
• Technical data — IP address, browser type, device information, operating system
• Location data — only if you explicitly grant permission (e.g. for check-ins at events or venues)
• Push notification tokens — device tokens for sending push notifications, only if you grant permission
• Camera data — only when you use the barcode scanner or photo upload; images are not stored unless you upload them as a profile photo or review photo

Users can add their own content, such as tasting notes, ratings and comments. This content may be visible to other users depending on your privacy settings.

3. How do we use your data?

We use your personal data for the following purposes:

• Creating and managing your account (performance of the agreement)
• Providing features such as whisky collections, reviews and social interactions
• Generating personal taste profiles and recommendations
• Connecting you with other users in the community
• Sending notifications and emails (based on your settings)
• Improving our services and resolving technical issues (legitimate interest)
• Awarding badges and rewards
• Processing payments for subscriptions

4. AI services

WhiskyCircle uses AI services to enhance the user experience. This includes:

• Generating taste profiles and whisky recommendations
• Generating images and videos for the app
• Enriching whisky information from external sources

For this we use services from Google (Gemini), Anthropic (Claude), Mistral AI and fal.ai. Data sent to these services consists of whisky-related data (names, descriptions, taste profiles) and is not used to train AI models. Personal data such as your name or email address is not sent to AI services.

5. Sharing of data

We share your personal data only in the following cases:

• With other users, depending on your profile and privacy settings
• If we are legally obliged to provide data

Additionally, we use the following service providers (processors) who process data on our behalf:

All these parties process data solely on our behalf and in accordance with applicable legislation. Where possible, data is processed within the European Economic Area (EEA).

6. Security

We take appropriate technical and organizational measures to protect your personal data against unauthorized access, loss or misuse. All data transfers are encrypted via secure connections (HTTPS). Passwords are stored using industry-standard hashing (bcrypt).

7. Your rights

Under the GDPR, you have the following rights:

• Right of access — you can request what data we hold about you
• Right to rectification — you can have incorrect data corrected
• Right to erasure — you can request deletion of your data
• Right to object — you can object to certain processing activities
• Right to data portability — you can request your data in a machine-readable format

You can exercise these rights by contacting us at privacy@whiskycircle.app.

8. Account deletion

You can delete your account at any time via the app settings (Profile → Settings → Delete account). Upon deletion, all your personal data, including your collection, reviews, messages and profile data, will be permanently deleted within 30 days. You can also send a deletion request to privacy@whiskycircle.app.

9. Cookies

We only use functional cookies that are necessary for the service to operate, such as session cookies for authentication. We do not use tracking cookies for advertising purposes.

10. Retention period

We retain your personal data as long as your account is active. After account deletion, your personal data will be removed within 30 days, unless we are legally required to retain certain data for a longer period (e.g. for tax obligations).

11. Age restriction

WhiskyCircle is intended for users who have reached the legal minimum age for alcohol consumption (18 years in the Netherlands). We do not knowingly collect data from persons under this age. If we discover that a minor has registered, we will delete the account and associated data as soon as possible.

12. Contact

For questions about this privacy policy or to exercise your rights, you can contact us at privacy@whiskycircle.app.

13. Changes

We may update this privacy policy from time to time. Significant changes will be communicated via the app or by email.