Welcome to Tipsi, a UK-based alcohol-related app ("we," "us," "our"). This Privacy Policy explains how we collect, use, and protect your personal data when you use our App. We are committed to complying with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and related UK laws. We take your privacy seriously, especially given the sensitive nature of alcohol-related personal data.

1. Personal Data We Collect

To provide our services, we collect the following types of personal data:

• Identity and contact details (name, email, phone number)

• Age verification information to comply with legal age restrictions on alcohol services

• Device information (model, operating system, unique identifiers)

• Usage data including app interactions and preferences related to alcohol products and content

• Location data to provide location-specific offers and services (with explicit consent)

• Payment and transaction details for purchases or subscriptions within the App

• Data collected via cookies and tracking technologies to enhance user experience and marketing

• Camera access – We request access to your device camera solely for the purpose of uploading a profile photo. Camera data is processed on-device and is not stored on our servers or transmitted to third parties unless you explicitly choose to upload the photo as part of your profile.

2. How We Use Your Data

Your data is processed for purposes including:

• Verifying your legal age and complying with UK alcohol sales regulations

• Operating and improving the App and related services

• Delivering personalised content, recommendations, and promotions related to alcoholic beverages

• Processing transactions, subscriptions, and customer support related to alcohol products

• Sending marketing communications and promotional offers (only with your consent)

• Conducting analytics to improve product offerings and user experience

• Complying with legal obligations related to alcohol sale and advertising

3. Legal Basis for Processing

We process your data based on:

• Your explicit consent, especially for marketing, camera access, and location tracking

• Compliance with legal obligations concerning alcohol sales and age restrictions

• Performance of a contract for transactions or subscriptions

• Our legitimate interests in improving services, balanced against your rights

4. Sharing and Disclosure

We share your data with:

• Trusted service providers supporting app operations, payment processing, and marketing

• Regulatory and enforcement authorities, when required by law (e.g., age verification checks)

• Third-party partners providing alcohol products, promotions, and delivery services, with safeguards in place

We do not sell personal data.

5. Data Transfers Outside the UK

If your data is transferred internationally, we ensure compliance with UK GDPR by implementing UK-approved adequacy mechanisms or standard contractual clauses.

6. Your Privacy Rights

You have rights including:

• Accessing, correcting, or deleting your personal information

• Objecting to processing based on legitimate interests or for marketing

• Withdrawing consent to marketing messages, camera access, or location tracking at any time

• Data portability for applicable data

• Filing complaints with the UK Information Commissioner's Office (ICO)

7. Special Considerations

Given the nature of our services, we take special care to:

• Confirm users' age before granting access to alcohol-related content or sales functionality

• Follow strict marketing and advertising regulations related to alcohol under UK law

• Limit data collection to what is necessary for legal compliance and service provision

• Request camera permission only when the user actively chooses to upload a profile photo, and never access the camera in the background

8. Data Security

We implement robust security measures including encryption, controlled access, and regular audits to protect your data.

9. Data Retention

Your data will be retained only as long as necessary to comply with legal requirements or to provide services. Specific retention periods for age verification, transaction, and marketing data are documented internally.

10. Cookies and Tracking

We obtain your consent for cookies and similar technologies used for analytics, personalisation, and advertising purposes, with preferences manageable through the App.

11. Updates to this Policy

We may update this Privacy Policy periodically to reflect regulatory changes or new practices. Significant changes will be notified, and your continued use of the App signifies acceptance of the updated policy.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us at:

Email: shweta@tipsi.org

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at www.ico.org.uk if you believe your data has been handled unlawfully.