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Whisky Smarts / Privacy Policy

Privacy Policy

Whisky Smarts  ·  Effective date: 1 June 2026  ·  Enso Ventures S.à r.l-S, Luxembourg

1. Who we are

Whisky Smarts is developed and operated by Enso Ventures S.à r.l-S, a company registered in Luxembourg ("we", "us", "our"). Our contact address for privacy matters is privacy@ensoventures.org.

Age notice: Whisky Smarts is an app for tracking and analysing whisky. It is intended for use by adults of legal drinking age in their jurisdiction. We do not verify user age, but by using the app you confirm you are of legal drinking age where you reside.

2. What data we collect

We collect only the data required to operate the app and improve it.

2.1 Data you provide directly

  • Account information — email address, display name, and authentication credentials (Google SSO, Apple SSO, or email/password via Firebase Auth).
  • Whisky log entries — expression name, distillery, bottler, country, region, style, age statement, ABV, peat level, cask type, maturation details, chillfiltered/natural colour status, volume, price, your personal rating, tasting notes (nose, palate, finish), and any web link you attach.

2.2 Data generated automatically

  • Usage analytics — app events (screens viewed, features used, session length) collected via Firebase Analytics. You can disable this at any time from Settings → Analytics opt-out. When disabled, no analytics events are sent.
  • Technical data — app version, device platform (iOS/Android), last seen timestamp. Stored in Firestore to support app compatibility and developer tooling.
  • Crash reports — anonymous crash and performance data via Firebase Crashlytics to identify and fix bugs.

2.3 Data we do not collect

  • We do not collect location data.
  • We do not collect payment information (subscription payments are processed by Apple and Google; we receive only subscription status confirmation).
  • We do not access your device contacts, camera roll, or microphone beyond what you explicitly invoke when scanning a bottle label.
  • We do not build advertising profiles or sell your data to any third party.

3. How we use your data

PurposeData usedLegal basis (GDPR)
Provide the app and sync your whisky data across devicesAccount info, whisky log entriesContract (Art. 6(1)(b))
Generate palate insights and recommendationsWhisky log entriesContract (Art. 6(1)(b))
Improve the app through usage analyticsAnalytics eventsLegitimate interest (Art. 6(1)(f)) — opt-out available
Diagnose and fix crashesCrash reports, app versionLegitimate interest (Art. 6(1)(f))
Manage subscription statusSubscription confirmation from Apple/GoogleContract (Art. 6(1)(b))

4. Data storage and security

Your data is stored in Google Firebase (Firestore), hosted in the EU (europe-west3 — Frankfurt region). Firebase applies encryption at rest and in transit. Access is controlled by Firestore security rules that restrict each user to their own data only.

We retain your data for as long as your account is active. If you delete your account, all associated data is permanently and irreversibly deleted.

5. Third-party processors

ProcessorPurposeData shared
Google Firebase (Firestore, Auth, Analytics, Crashlytics)Database, authentication, analytics, crash reportingAccount info, whisky data, usage events
Apple App Store / Google PlayApp distribution and subscription managementSubscription status only (no personal data)
Google (Sign in with Google)AuthenticationGoogle account email and display name
Apple (Sign in with Apple)AuthenticationApple account email (or private relay) and display name
Anthropic (Claude API)Server-side generation of palate narrative cards from your aggregated whisky preference data. Processing occurs within our Cloud Function infrastructure; your raw whisky entries are not transmitted — only aggregated statistical outputs derived from them.Aggregated preference data (no raw personal data). Anthropic does not retain data submitted via the API per their usage policy.

We do not use advertising networks, data brokers, or marketing platforms.

6. Your rights (GDPR)

If you are in the EU or UK, you have the following rights:

  • Access — request a copy of the personal data we hold about you.
  • Correction — request correction of inaccurate data.
  • Erasure — request deletion of your personal data. You can do this directly in the app: Settings → Data Management → Delete Data.
  • Portability — export all your personal data as a structured JSON file: Settings → Data Management → Export my data.
  • Restriction and objection — contact privacy@ensoventures.org.
  • Withdraw analytics consent — Settings → Analytics opt-out toggle. Effective immediately.
  • Lodge a complaint — with the Commission Nationale pour la Protection des Données (CNPD) in Luxembourg, or your local data protection authority.

7. Account and data deletion

Delete your data only (keep account active) — Settings → Data Management → Delete Data. This permanently removes all your whisky log entries, analytics history, and personal data. Your account credentials are preserved.

Delete your account entirely — Settings → Account → Delete Account. This permanently and irreversibly removes your account, all whisky data, and all personal information. This action cannot be undone.

8. Children

Whisky Smarts is not directed at persons under 18, or under the legal drinking age in their jurisdiction, whichever is higher. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, contact privacy@ensoventures.org and we will delete it promptly.

9. California residents (CCPA)

CategoryCollectedSold or shared
Identifiers (email, user ID)YesNo
Personal records (whisky log entries)YesNo
Usage data (analytics events)Yes (opt-out available)No
Location dataNoNo
Financial informationNoNo
Sensitive personal informationNoNo

We do not sell personal information. California residents may exercise CCPA rights by contacting privacy@ensoventures.org.

10. Changes to this policy

We may update this policy from time to time. Material changes will be notified in-app. The effective date at the top of this page reflects the date of the most recent revision. Continued use of the app after a change constitutes acceptance.

11. Contact

For any privacy questions or to exercise your rights: privacy@ensoventures.org

Enso Ventures S.à r.l-S
Luxembourg

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