Privacy Policy
BEBER is a wine recommendation application. We do not sell wine and we never resell your data. This policy explains, in plain language, what data we collect, why, and how you stay in control. The application is restricted to adults (18 and over).
This English version is a translation provided for convenience. In the event of any discrepancy, the French version prevails.
1. Who is responsible for your data
The data controller is TC CONSULTING (SAS with share capital of €1,000, Lille Metropole Trade and Companies Register 999 059 637, SIRET 999 059 637 00010), with its registered office at 75 rue Nationale, 59800 Lille, France, publisher of the BEBER mobile application. Legal representative: Thibault Cour, President.
2. What data we collect
We limit collection to what is strictly necessary to run the application and offer you relevant recommendations.
- Account: technical identifier, email address, display name and profile picture provided by your identity provider (Google or Apple).
- Taste profile: your quiz answers, your feedback on wines (likes, value for money), and the preferences inferred from them to personalize your recommendations.
- Journal, cellar and favourites: the wines you add to your Journal, your cellar or your favourites, the quantities, purchase dates and prices, storage locations, and the personal notes and tasting reviews you enter.
- Label scanning: the photos you take to identify a wine, processed to recognize the label then kept with your scan history so they can be shown to you there (a thumbnail for each scanned wine). They are stored in a space of your own, never shared with other users, and deleted with the history or when the account is deleted.
- Wine list photos: the photos of a restaurant's wine list that you pick from your photo library are sent to our servers (EXIF metadata removed), then to Gemini via Vertex AI (Google Cloud) to extract the list of wines. A copy is kept in our storage, attached to the establishment's list rather than to your personal space. For any request about it, write to privacy@beber.app.
- Subscription: when the BEBER Cave subscription is offered, the purchase is handled by RevenueCat, which receives your account's technical identifier and the purchase history needed to know whether your subscription is active. Your payment details stay with Apple; we have no access to them.
- Application usage: screens viewed, wines looked at, searches performed, basic interactions (to improve the product).
- Point-in-time location: only if you allow it, to display nearby restaurants and wine shops, attach a place to your scans and reviews, and locate the places you add. No background geolocation.
- Notifications: a technical token if you enable push notifications (recommendations, reminders, product updates; limited frequency, token kept 365 days and deleted with the account). An explanatory screen is shown before the system permission prompt; you may decline without penalty and change your mind at any time in the settings.
- Technical data: device type, application version and IP address (server logs).
- Business contacts (Restaurateurs form on beber.app): venue name, city, email address, message, and the PDF of your wine list if you attach one. This does not concern app users: it is used only to reply to you and to process your wine list.
- Age attestation (18+): your declaration of majority is recorded with a pseudonymized IP fingerprint (truncated hash, the raw IP address is never kept) and the device identification chain, solely for the legal traceability of the declaration (art. L. 3342-1 of the French Public Health Code).
What we do not collect: banking data, advertising identifiers, health data, contacts, background location.
3. Why we use your data
| Purpose | Legal basis (art. 6 GDPR) |
|---|
| Creating and managing your account | Performance of contract (Terms) |
| Personalized wine recommendations | Performance of contract (Terms) |
| Keeping your Journal, cellar and favourites | Performance of contract (Terms) |
| Label recognition via camera scan | Performance of contract (Terms) |
| Displaying nearby places | Consent |
| Push notifications | Consent |
| Product and algorithm improvement (analytics) | Consent |
| Audience measurement without identifier of onboarding and app usage (counters without any identifier, opt-out available) | Audience measurement exempt from consent (Art. 82 French Data Protection Act) |
| Replying to a restaurateur or wine shop and processing the wine list they send us (Restaurateurs form) | Pre-contractual steps taken at your request and legitimate interest (answering a professional enquiry) |
| Security, abuse prevention | Legitimate interest |
| Legal and accounting obligations | Legal obligation |
You can withdraw your consent at any time from your device settings (camera, location, notifications).
4. Who has access to your data
Your data is never sold, rented or shared for advertising purposes. We entrust certain operations to technical providers bound by contractual confidentiality and security obligations:
- Google Cloud Platform (Cloud Run, BigQuery, storage): application and database hosting. European Union (europe-west1 region).
- Firebase (Google): account authentication and push notifications. European Union, with a US component for the Firebase infrastructure, covered by Standard Contractual Clauses.
- Gemini via Vertex AI (Google Cloud): label photo recognition and wine catalog enrichment. Global endpoint, whose execution region is not guaranteed to be within the European Union, covered by Standard Contractual Clauses.
- Google Places API (Google): nearby place search. Global endpoint, whose execution region is not guaranteed to be within the European Union, covered by Standard Contractual Clauses.
- Upstash (Redis database): technical cache and rate limiting. European Union (Frankfurt).
- PostHog: pseudonymized product analytics, only if you have given your consent (hashed identifier, never your account identifier). European Union (Frankfurt).
- Sentry (Functional Software Inc.): application error monitoring, only if you have given your consent. United States, covered by the EU–US Data Privacy Framework.
- Apple: sign-in via "Sign in with Apple" and technical delivery of push notifications on iOS. United States, under the transfer safeguards set out in Apple's privacy policy.
- RevenueCat (RevenueCat, Inc.): subscription management (technical account identifier and purchase history). United States, transfer governed by the mechanisms described below.
Some of these providers may process data outside the European Union. Such transfers are governed by the mechanisms recognized under the GDPR (adequacy decisions, EU–US Data Privacy Framework, Standard Contractual Clauses).
This list is updated whenever a technical provider changes. For any question, write to privacy@beber.app.
5. How long we keep your data
We keep your data only as long as necessary for the purposes for which it was collected:
- Account data: for the lifetime of your account, then deleted from our live databases within 30 days of its deletion.
- Taste profile and preferences: for the lifetime of your account. They are also deleted automatically if they have not changed for 36 months (no quiz, no rating given on a wine); you can rebuild them at any time by retaking the quiz.
- Journal, cellar, favourites and tasting notes: for the lifetime of your account, deleted with it (within 30 days) or on request.
- Security backups: backup copies of our databases are kept for 13 weeks at most, then deleted automatically. Erased data may remain in them during that period, is never used, and is erased again if a backup ever has to be restored.
- Label photos: 12 rolling months, together with the scan history they belong to (deleted immediately with the account, or on request).
- Scan history: rolling 12 months.
- Usage events: 24 months maximum, then anonymized.
- Counters without identifier (audience measurement): 395 days maximum.
- Location: used in real time to display nearby places, attach a place to your scans and reviews, and locate the places you add. If you have consented to usage analytics, an approximate area (~1 km, never your exact position) may be kept for up to 90 days to guide wine-list coverage. Deleted on request or when your account is deleted.
- Business contacts (Restaurateurs form): 36 months after you submit it, then the record (venue name, city, email, message) is deleted automatically. The wine list PDF is kept in our Google Cloud storage (European Union) with no separate automatic purge: to ask for its deletion at any time, write to privacy@beber.app.
- Server logs: 90 days maximum (cloud audit logs: 400 days, immutable).
6. Your rights
Under the GDPR and the French Data Protection Act, you have the following rights over your data at any time:
- Access: obtain a copy of the data concerning you
- Rectification: correct inaccurate information
- Erasure: request deletion of your account and associated data
- Restriction: restrict certain processing
- Portability: receive your data in a machine-readable format
- Objection: object to processing based on legitimate interest
- Withdrawal of consent at any time
To exercise these rights, contact us at privacy@beber.app. In the vast majority of cases your request is handled in under 24 hours, and within 30 days at the latest (art. 12.3 GDPR). You can also delete your account directly from the application.
If you believe your rights are not being respected, you may lodge a complaint with the CNIL: www.cnil.fr/fr/plaintes.
7. Security
We implement appropriate technical and organizational measures to protect your data: encryption in transit, encryption at rest, authentication on every request, secure secret management and least-privilege access control.
8. Profiling and automated decisions
BEBER uses algorithms to suggest wines matching your taste. This profiling has no legal or similarly significant effect on you (art. 22 GDPR): it only serves to improve the relevance of recommendations. You can reset your taste profile at any time from the application.
AI-assisted content: part of the editorial text shown on wine pages (appellation and estate descriptions, sensory descriptions) is written with the help of AI models, from public sources and under automated editorial control before publication. Inaccuracies remain possible: you can report any factual error from within the application or at contact@beber.app.
9. Cookies and trackers
BEBER is a native mobile application and does not use cookies. No advertising identifier is collected. Only product analytics (EU servers, only with your consent) and technical error monitoring tools (only with your consent) are integrated, for product improvement and stability purposes, together with the audience measurement without identifier described below, which does not require consent.
Audience measurement without identifier. To understand where new users stop while discovering BEBER, and which screens are opened, the app sends a simple counter at each step completed or screen opened, at most once per day. These steps form a closed list: first launch, sign-in screen, sign-in, age verified, consent seen, accepted or declined, location requested, granted or denied, first home screen, home screen with no wine list nearby, quiz opened, first answer, quiz completed, first scan started, first scan result. The counted screens also form a closed list: app opened, scan result, wine page, history, My cellar (opened, bottle added, subscription offer shown), restaurant wine list, quiz completed. Each counter contains only the step or screen, the day, the platform (iOS or Android) and the major.minor app version. It contains no user identifier, no device identifier and no position, and your IP address is not stored (it is only used to rate-limit requests, in memory). These counters have no identifier, are not cross-referenced with other data and are not passed on to any third party. They are hosted on Google Cloud (BigQuery, European Union) and kept for 395 days. You can opt out at any time with the "Audience measurement" switch in the Privacy screen of the app. This measurement without identifier is exempt from consent (Article 82 of the French Data Protection Act, CNIL guidelines on exempt audience measurement tools): it therefore does not depend on your choice for usage statistics (PostHog), whether you accepted or declined it.
10. Minors
The application is strictly reserved for people aged 18 or over. A declarative age check (age gate) is in place at sign-up. If we learn that a minor has provided us with data, we will delete it without delay. Contact us at privacy@beber.app if needed.
11. Changes
This policy may be updated. In the event of a substantial change, we will inform you by in-app notification or by email at least 15 days before it takes effect. The "last updated" date at the top of the document is refreshed at each revision.
12. Contact
For any question about this policy or your personal data:
This policy is governed by French law. In the event of a dispute, the French courts shall have jurisdiction after an attempt at amicable resolution.