1. Who is responsible?
Clos.world CommV, Herebaan-West 46, 3530 Houthalen-Helchteren, Belgium (company number 1043.901.429) is the controller of the personal data in the app and on clos.world. Contact: hello@clos.world. More details under Legal.
2. What data do we process?
- Account — email address, password (encrypted by our authentication provider), and where applicable a Face ID/biometric login reference on your device.
- Cellar content — wines, photos, notes, preferences and related app data that you add.
- Technical — session and basic device/browser information needed to run the service; crash or error logs where applicable.
- AI features — images or text you choose to share for scanning, enrichment or similar features, insofar as those features are switched on.
- Kindred Palates — only if you choose to take part yourself: a screen name you pick, your fingerprint from Cellar DNA (five scores in the pentagon, your two strongest archetypes, your number of bottles and your language), the tasting circle you join, and what you share in that tasting circle yourself.
3. Why (purposes & legal basis)
- Contract — account, cellar, sync and the core features of Clos.
- Legitimate interest — security, preventing abuse, improving the service (without marketing tracking by default).
- Consent — Kindred Palates: you only take part if you switch it on yourself. You withdraw your consent with Stop taking part in Cellar DNA; your fingerprint and screen name are then deleted immediately.
- Legal obligation — where accounting or other law requires it (for example the accounting of subscriptions).
4. Who do we share data with?
We do not sell your data. We use processors that are needed to run Clos, typically:
- hosting & functions (including Netlify);
- database & authentication (including Supabase);
- AI/image processing for features you start.
These parties only process data on behalf of Clos, within the EU or with appropriate safeguards.
Payments — you buy and pay for a subscription through Apple. Apple processes that payment under its own privacy policy. Clos does not receive your payment details, only whether your subscription is active.
Other users — if you take part in Kindred Palates, Clos compares your fingerprint with those of other participants. If you join a tasting circle, the other members of that tasting circle see your screen name, how much your shapes overlap and the tasting circle’s average shape. Wines from your cellar that another member also has appear for the members who have them too — without showing who has them, and without prices, quantities or photos. Experiences and replies you share yourself (text, dish or occasion, date opened, vintage) are read by the members of your tasting circle under your screen name. If you report a contribution or block a member, we keep that to keep the tasting circle safe. If you leave your tasting circle, your contributions there are deleted. The rest of your cellar, your email address and your real name are never shown. You can leave your tasting circle or stop taking part at any time.
5. Retention
Account and cellar data are kept for as long as your account is active. After your account is deleted, we erase or anonymise what is no longer needed, except what we are legally required to keep.
6. Your rights
You can request access, rectification, erasure, restriction, portability and object to processing. Send a request via the contact details under Legal. You may also lodge a complaint with the Belgian Data Protection Authority (Gegevensbeschermingsautoriteit).
7. Cookies & local storage
Clos uses what is needed to keep you logged in and make the app work. We do not set advertising cookies. If we add optional analytics later, we will ask for your consent separately.
8. Minors
Clos is intended for people aged 18 and over. We do not direct the service at children.