Privacy Policy

1. Data Controller

Larissa Rezende, an individual residing in Spain, is the data controller for the personal data collected through Tino. You can contact us directly from within the app or write to tinoscanner@gmail.com (our official privacy channel for exercising your rights). Larissa Rezende also acts as Data Protection Officer (DPO, art. 41 of the Brazilian LGPD) and handles requests at tinoscanner@gmail.com.

2. What Data We Process and Why

• Account details (name, email, credentials): to create and maintain your account, dearest. Legal basis: contract fulfillment.
• Label photos you upload to the scanner: to identify the wine and display them in your history. Legal basis: contract fulfillment.
• Cellar and history (saved wines, analyses, preferences): to provide the service and tailor recommendations just for you. Legal basis: contract fulfillment.
• Usage and security data (analysis counters, technical logs, IP address): to prevent abuse and fraud, and ensure the service is always available. Legal basis: legitimate interest.
• Subscription data (plan status, payment provider identifiers): to manage your Premium access. Legal basis: contract fulfillment and legal obligation.

3. Who We Share Data With

• Paddle, as our Merchant of Record, for sales, subscription management, payments, tax compliance, and billing.
• Technology providers for hosting, database, and AI-powered image analysis, who act as data processors.
• Professional advisors (legal or accounting) and authorities, when required by law.

Some providers may process data outside the European Economic Area; in such cases, appropriate safeguards apply, such as the European Commission's standard contractual clauses or adequacy decisions.

4. Retention

We retain account data for as long as your account is active. Label photos are kept for up to 12 months or until you delete them. If you close your account, we will delete your personal data, photos, cellar, and history, except for information we are legally obliged to retain (e.g., billing records).

5. Your Rights

You can exercise, at any time, your rights of access, rectification, erasure, restriction, portability and objection, as well as withdraw your consent (GDPR), together with the rights to confirmation of processing, anonymisation, blocking or deletion of unnecessary data, information on who we share your data with, and review of automated decisions (LGPD). From your profile you can download your data and delete your account immediately. We will respond to any request within one month (up to fifteen days in Brazil). You may also lodge a complaint with the Spanish Data Protection Agency (www.aepd.es) or, if you are in Brazil, with the National Data Protection Authority (www.gov.br/anpd).

6. Security

We implement appropriate technical and organizational measures: encryption in transit, user access control, private storage of photos, and access via temporary links that only work for the owner.

7. Cookies

We only use essential cookies and local storage to keep you logged in and remember basic preferences. We do not use advertising cookies. If we add analytics or marketing cookies in the future, we will ask for your prior consent, and you will be able to manage them within the app.

8. Applicable law

If you reside in the European Union or the European Economic Area, your data is processed in accordance with the General Data Protection Regulation (GDPR) and the consumer law of your habitual residence Member State. If you reside in Brazil, the Brazilian General Data Protection Law (LGPD, Law No. 13,709/2018), the Internet Civil Framework and the Consumer Protection Code apply. Both laws share the same principles: legal bases (Art. 7 LGPD and Art. 6 GDPR), minimisation, transparency and data subject rights. The right of withdrawal and refund varies by country: 7 days in Brazil and 14 days in the EU (our 30-day refund policy covers both periods).