This policy explains, without evasion, what data WineCellarApp collects, what each piece is for, who it is shared with, and what you can demand from us. It covers the iOS and Android apps and this website.
Data controller: WineCellarApp is operated by Murilo Naves Borges, an individual, who is the controller of the data processed here under the Brazilian General Data Protection Law (LGPD, Law 13.709/2018). Contact: contato@winecellarapp.com.br.
- 1. What data we collect
- 2. Label photos and AI processing
- 3. Subscription and payment
- 4. Push notifications
- 5. Analytics, diagnostics and session recording
- 6. Advertising
- 7. Legal basis for each processing activity (LGPD)
- 8. Who we share it with
- 9. How long we keep it
- 10. Your rights and how to exercise them
- 11. How to delete your account and your data
- 12. Security
- 13. Children and minors
- 14. Contact
1. What data we collect
Account data
You can create an account in two ways:
- Email and password. We store your email and a hash of your password — never the password in readable form.
- Social login with Google or Apple. We receive an account identifier from the provider, your email and, when available, your name. We do not receive your Google or Apple password. If you use Apple's "Hide My Email", we only receive the relay address it generates.
Data you create inside the app
- Your cellar: wines you add, quantity, vintage, producer, country, type, price paid and the bottle's position in the cellar.
- Wines consumed: a history of what you opened and when.
- Your notes and ratings for each wine.
- Referral code: the code we generate for you and the code you used when signing up, so we can link who referred whom.
- Friends and achievements: connections you create and your gamification progress.
- Label photos you upload (detailed in section 2).
Technical data collected automatically
- Device model, operating system and version, language and region.
- App/device identifiers used by analytics and advertising services.
- IP address, access logs and app errors/crashes.
We do not collect your precise GPS location.
2. Label photos and AI processing
When you photograph a label for the app to identify the wine, the image is sent to our server and processed automatically. It is not a purely on-device process.
That processing uses third-party providers:
- Google Cloud Vision — reading the text on the label (OCR).
- Google Gemini and OpenAI — interpreting what was read, identifying the wine, pairings, recipes and the AI sommelier's answers.
In those calls we send the image and/or the text needed for the task. When you talk to the AI sommelier, we also send the data from your cellar relevant to the question — that is what allows the recommendation to come from the bottles you actually own.
Treat these providers as processors: they process under our instruction, to fulfil your request. We contract these APIs under enterprise terms, in which the content sent is not used to train their models.
Do not send the app photos containing other people's personal data or sensitive information: the feature exists to read wine labels.
International transfer
These providers operate servers outside Brazil. By using the app you understand that the data needed for those features may be processed abroad, under the contractual safeguards of each provider, as set out in articles 33 and following of the LGPD.
3. Subscription and payment
The WineCellarApp subscription is recurring and charged by the App Store (Apple) or Google Play (Google), depending on where you bought it. We use RevenueCat to broker and validate those purchases.
We do not receive and do not store your card details. Payment happens entirely inside the store. What reaches us, via RevenueCat, is the state of the subscription: whether it is active, which plan, start and renewal dates, whether it is in a trial period, and an anonymous purchase identifier.
To cancel, use the subscriptions section of your App Store or Google Play account — cancellation happens in the store, not in the app.
4. Push notifications
We use Firebase Cloud Messaging (Google) to send notifications — for example, achievement alerts, news and reminders. For that we store a push token for your device.
You can turn notifications off at any time in your operating system settings, without losing access to the rest of the app.
5. Analytics, diagnostics and session recording
To understand what works and to fix defects, we use:
| Service | What we use it for |
|---|---|
| Firebase Analytics (Google) | Usage statistics: screens opened, most-used features, retention. |
| Firebase Crashlytics (Google) | Crash and error reports, with device data and the error trace. |
| UXCam | Recording of the app session: taps and navigation between screens, to find where people get stuck. |
| Microsoft Clarity | Heatmaps and session recording, mainly on this website. |
UXCam and Clarity record how you interact with the screens. We configure these tools not to capture the content of sensitive fields, such as passwords and payment details. They do not record the camera, the microphone or the screen of other applications.
6. Advertising
For non-subscribers, the app shows ads through Google AdMob. If you have an active subscription, we show no ads.
AdMob may use your device's advertising identifiers to measure and, if you allow it, personalise ads. You control this in the operating system itself:
- iOS: Settings → Privacy & Security → Tracking (the ATT permission). If you decline, ads continue, but they are not personalised.
- Android: Settings → Google → Ads → delete or reset the advertising ID.
7. Legal basis for each processing activity (LGPD)
| Processing | Legal basis (Law 13.709/2018) |
|---|---|
| Creating and maintaining your account; storing your cellar, notes and history | Performance of a contract — art. 7, V |
| Processing the label photo through OCR/AI and answering the AI sommelier | Performance of a contract — art. 7, V (it is the feature you asked for) |
| Billing and subscription control | Performance of a contract — art. 7, V |
| Push notifications | Consent — art. 7, I (the permission you grant in the OS) |
| Analytics and error diagnostics | Legitimate interest — art. 7, IX (maintaining and improving the app) |
| Personalised advertising | Consent — art. 7, I (the device tracking permission) |
| Non-personalised advertising for non-subscribers | Legitimate interest — art. 7, IX (sustaining the free version) |
| Keeping access logs | Legal obligation — art. 7, II, together with art. 15 of the Brazilian Internet Act |
8. Who we share it with
We do not sell your data. We share only what is necessary, and only with those who operate part of the service:
- Google — Cloud Vision and Gemini (label reading and interpretation), Firebase (authentication, database, push, analytics, Crashlytics), AdMob (ads), Google Play (purchases).
- OpenAI — generating the AI answers.
- Apple — Sign in with Apple and App Store purchases.
- RevenueCat — subscription management.
- UXCam and Microsoft Clarity — usage analysis.
- Authorities — only upon a valid court order or legal request.
What other users see: if you use the social part of the app, your display name, achievements and whatever you choose to share are visible to the friends you added. Your cellar is not public.
9. How long we keep it
- Account and cellar data: for as long as your account exists. If you request deletion, we follow section 11.
- Label photos: kept linked to the wine in your cellar for as long as it is registered.
- Access logs: 6 months, as required by art. 15 of the Brazilian Internet Act.
- Tax / subscription billing data: for the period required by applicable law.
Deadlines:
- Deletion at your request: we erase your data from the active database within 30 days of the request.
- Backups: backups are rotated, and deleted data leaves them within 90 days.
- Usage data (analytics): retained for 14 months, the period configured in the analytics tool itself.
10. Your rights and how to exercise them
Under the LGPD (art. 18), you may at any time request:
- Confirmation and access — to know whether we process your data and obtain a copy of it.
- Correction — to correct incomplete or incorrect data.
- Anonymisation, blocking or erasure — of unnecessary or excessive data, or data processed unlawfully.
- Portability — to receive your data in a usable format.
- Erasure of data processed on the basis of consent — see section 11.
- Information about sharing — who we share your data with.
- Withdrawal of consent — for example, turning off push or ad tracking.
- Objection — to processing carried out on the basis of legitimate interest.
To exercise any of these, write to contato@winecellarapp.com.br. We reply within 15 days. We may ask you to confirm your identity before releasing or erasing data — that is to protect your account.
11. How to delete your account and your data
You have two ways, and both delete the account:
- Inside the app: Profile → Settings → Delete account.
- By email: send the request to contato@winecellarapp.com.br from your registered email address, with the subject "Account and data deletion".
Deletion erases your account, your cellar, your notes, your consumption history, your label photos and your referral code. It is irreversible and cannot be undone afterwards.
Two things continue to exist, for reasons outside our control:
- Your subscription is not cancelled by deleting the account. Cancel it in your App Store or Google Play subscriptions, otherwise billing continues.
- Access logs and billing data that the law requires us to keep are retained for the legal period, isolated and not used for any other purpose.
12. Security
We use HTTPS for all communication between the app and the server, passwords stored only as a hash, access control over the database, and managed Google Cloud/Firebase infrastructure. No system is impenetrable — if an incident occurs with relevant risk to you, we will notify you and the Brazilian data protection authority (ANPD), as required by art. 48 of the LGPD.
13. Children and minors
WineCellarApp deals with alcoholic beverages and is intended for people aged 18 or over. We do not knowingly collect data from children or adolescents. If we identify an account belonging to someone under 18, it will be removed. If you are a parent or guardian and believe this has happened, write to us.
14. Contact
Questions, data requests or privacy complaints:
- Email: contato@winecellarapp.com.br
Data Protection Officer, under art. 41 of the LGPD: Murilo Naves Borges — contato@winecellarapp.com.br.
If we change this policy, we update the date at the top and, when the change is relevant, we tell you in the app.