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Privacy Policy

Privacy Policy

Application: My Wine Cellar (Winely)

Publisher: Cédric Legrand

Effective as of: 22 September 2026

Website: https://winely.app

© Cédric Legrand 2026 — All rights reserved.

Article 1 — Data Controller

Cédric Legrand, acting as the publisher of the application My Wine Cellar, is the controller of your personal data. It attaches great importance to the secure, transparent, and confidential collection and processing of your data, in accordance with Regulation (EU) 2016/679 (GDPR).

You can contact him at the following address: info@macaveavins.app.

Article 2 — Data Collected and Purposes

We only collect data strictly necessary for the provision and improvement of our services:

  • Identification data: Your email address (or the one provided by Google or Apple) is used to create and secure your account. An account can also be used without an email (Skip flow).
  • Profile data: Country, language, currency, and optionally onboarding answers (knowledge, cellar size, goal), to adapt the display and the service.
  • Content data: You can add information about your wines, including photographs of labels, which are essential to the main service of the Application.
  • Contact data: If you write to us via the form, we process your name, email, message and any attachments in order to respond.
  • Notifications: If you enable notifications, a device token and your preferences (categories) are stored so we can send useful reminders, for example before a trial ends. You can turn them off in Settings.
  • Transaction data: Information relating to Premium subscriptions (product identifier, dates, auto-renewal) is processed securely by the Apple App Store and the Google Play Store. A subscription status (active, trial, expired, renewal) is also stored in Firebase in order to deliver Premium Services in the Application. In-app purchase events are also transmitted to Meta Platforms (Facebook) via the Meta SDK integrated into the Application, in order to measure the performance of our advertising campaigns.
  • Technical data: We collect technical information about your device (type, model, system version, technical identifiers) and the application version, in order to maintain, diagnose and improve the service.
  • Behavioral data: We collect aggregated usage data via an analytics service (see Article 3). Certain key actions in the Application are also transmitted to Meta Platforms for advertising purposes (see Article 3).

The processing of this data is based on the performance of the contract binding us (provision of the service) and, for data transmitted to Meta, on your consent collected via the tracking authorization request (App Tracking Transparency on iOS). On Android, this processing is based on our legitimate interest in measuring the effectiveness of our advertising.

Article 3 — Data Sharing and Transfers

We do not sell or rent your personal data.

They may be shared with subcontractors for specific technical needs:

  • Third-party AI service providers: Label photographs are transmitted to specialized providers to automatically extract wine information. These transfers are secure. The list of relevant providers is available upon request at info@macaveavins.app.
  • Hosting and analytics services (Google Firebase): Your data is stored and your aggregated usage data is analyzed via Firebase. For more information: https://firebase.google.com/support/privacy.
  • Meta Platforms (Facebook): The Application integrates the Meta App Events SDK. Events related to key actions in the Application (registration, viewing the Premium offer, use of the scan feature, in-app purchases) are transmitted to Meta to measure the performance of our ads and optimize our campaigns. This data may include your advertising identifier, subject to your consent. For more information: https://www.facebook.com/privacy/policy.

Regarding transfers outside the EU: Firebase and Meta Platforms are American companies. These transfers are governed by the European Commission's standard contractual clauses (SCCs) and, where applicable, the EU-US Data Privacy Framework.

Article 4 — Retention Period

Your personal data is kept as long as your account is active.

When you delete your account from the Application settings, access is revoked immediately. Data that can identify you (email address, device technical information, notification token) and the content of your cellar (wine records, photographs, label scans) are deleted or anonymised so that you can no longer be identified. Aggregated statistical data that does not allow you to be re-identified may be kept for analysis. Transaction identifiers linked to a subscription may be kept for as long as needed for legal obligations and to handle any disputes with the App Store or Google Play.

You can delete your account at any time via the Application settings.

Article 5 — Consent and advertising tracking control

On iOS: Upon your first use of the Application, an advertising tracking authorization request (App Tracking Transparency) is presented to you. If you decline, your advertising identifier will not be transmitted to Meta and advertising tracking will be disabled. You can change this choice at any time in your device settings:

Settings > Privacy & Security > Tracking.

On Android: Advertising tracking is active by default, in accordance with standard platform practices. You can opt out in your device settings:

Settings > Privacy > Advertising.

Article 6 — Your Rights

In accordance with the GDPR, you have the right of access, rectification, erasure, restriction of processing, objection and portability of your data. To exercise these rights, including to obtain a copy of your data, contact us at info@macaveavins.app.

In the event of a dispute, you have the right to lodge a complaint with the Data Protection Authority in Belgium.

Article 7 — Security

We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including encryption and pseudonymization where possible.

All data is transmitted via encrypted connections (HTTPS/TLS).

Article 8 — Modifications

This privacy policy may be updated. The effective date appears at the top of the document. The current version is published in the Application and on the publisher's website.