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Privacy Policy

Effective: 3 October 2026 · Reviewed at least annually

The short version

  • Sommly is run by Ashwood Data LLC, a California limited liability company (“Sommly”, “we”, “us”).
  • You need an account, so we store your email address (or your Apple sign-in identifier) and the wine data you create: taste profile, ratings, notes, journal entries and scans.
  • Photos of wine lists and labels are sent to Google’s Gemini AI to be read, and are not stored by us. We keep the text that comes back.
  • Your chat with the AI sommelier is sent to Google to generate a reply. We keep your conversations with the sommelier on your account so your last one is there when you come back, and so we can find and fix answers that went wrong. You can clear them at any time in Profile, and deleting your account deletes them.
  • We do not sell your personal information, we do not share it for cross-context behavioral advertising, and there are no ad networks, data brokers, or tracking SDKs in this app.
  • We do not store your own location. The app can look up places for you, and that lookup goes to Apple’s MapKit, never to us. If you pick a place from the results, we save its name and the map point Apple publishes for that venue. A name you type without picking a result saves no map point.
  • If you subscribe to Sommly Reserve, we keep Apple’s record of the subscription (which plan, whether it is active, when it renews) with your account. We never receive your payment details.
  • You can delete your account and your own data from inside the app, in the Profile tab. It is immediate and permanent. Section 13 lists exactly what goes and the things that do not.
  • Sommly is for adults of legal drinking age. It is not for children.
  • Contact: hello@sommly.app

1. What information do we collect?

Information you give us

Account information. When you create an account we collect your email address and a password (stored only as a salted hash by our authentication provider; we never see or store your plaintext password). If you use Sign in with Apple, we receive an Apple user identifier and, on your first sign-in only, the name you choose to share. If you use Apple’s Hide My Email, we only ever see the relay address, not your real one.

Your name or nickname. Whatever you enter as a display name, or the name Apple supplied, editable or clearable any time in the Profile tab.

Your taste profile. Your answers to the onboarding taste quiz and the preference scores we derive from them: sweetness, acidity, tannin, body, oak, whether you lean fruit-forward, the regions and grape varieties you prefer, characteristics you dislike, and the “archetype” we assign.

Wines you name. Wines you enter as favorites, and the wine searches you run in the app. Search terms go to our database to find a match, and to our AI provider when the assistant looks something up for you. We do not keep a search-history list.

Ratings and tasting notes. Your score for a wine, from 1 to 5, any free-text notes, and the context you record (at a restaurant, at home).

Journal entries. Titles, free-text bodies, and, importantly, the restaurant or venue name you attach to a scan or entry, along with the date. Over time that builds a record of where and when you drink. Treat it with the care you’d give a diary, because that’s what it is.

Photos of wine lists and wine labels. See section 5. How we handle these is the part of this policy most worth reading.

Your conversations with the AI sommelier. Whatever you type, plus any photo you attach, and the sommelier’s replies. We keep the text of the conversation on your account; photos are not kept (section 5).

Anything you send us by email: support requests and feedback.

Information collected automatically

Onboarding analytics. We record how you move through onboarding: which screen you saw, which option you picked, when you changed a pick, skipped, went back, finished or abandoned, and how long you spent on each screen, in milliseconds. Each event carries a session identifier and, once you sign in, your account identifier.

Two things you should know, because they aren’t obvious:

App usage. Once you are signed in, we also record a short list of things you do in the app. Every event comes from a closed list of names written into both the app and our database, and a new kind of event is added to that list on purpose, in both places, and held to the same rules below. Today they cover:

Each of these rows carries your account identifier, a session identifier, the event name, the app version and build number, whether the app was running in a simulator, and the time. Some of them carry a few small structured details beside that, each from a closed list of detail names: whether a scan came from a wine list, a bottle or a photo you attached; a page count or a result count; how long something took, exactly or in broad bands; an outcome such as ok, failed or cancelled; how an entry was created, and which screen or button led to it; which action you took; whether the app had just launched; how many days had passed since you first opened the app, in broad bands; and, on the Reserve screen, which plan it showed first and whether it offered a free trial.

No free text ever reaches this record. The app admits whole numbers, true or false, and short labels from a fixed vocabulary, and nothing else, so a tasting note, a chat message, a photo, a wine name, a search term or a location cannot be expressed in an event at all. The database then independently rejects any event name and any detail name that is not on its own list, so a new kind of event or field cannot be smuggled in by a future version of the app without a database change too. Neither side admits a purchase or a price: there are no revenue events in this record, and a purchase itself records no event at all.

The session identifier is generated on your device, is not derived from your hardware, and starts over after thirty minutes of inactivity.

What we use these counts for, plainly: how many people use Sommly and how often, whether people come back after their first week, whether a change we shipped helped, which parts of the app lead people to Reserve or to sharing, and how many sommelier messages you have sent this calendar month, which is how the free tier’s monthly allowance is applied. We read all but the last in aggregate.

Device and app context. Alongside the onboarding screen views, we record your locale, time zone, app version and build number, and whether the app is running in a simulator. The app-usage rows above carry the app version, the build number and the simulator flag, and not your locale or time zone.

Where you are: only when you ask, and your own position is never stored. The scan screen and your journal’s place field both offer to fill in the restaurant name for you. There are two ways they do it: a location button, which asks iOS for your location while you’re using the app and lists places near you, and a search over the name you type, which uses your location only to order the results nearer first, when the app already has it. What happens next matters, so here it is exactly:

Crash and error reports. If the app crashes or hits an error, we receive a technical report: the stack trace and the error, your device model, your OS and app version, and a short trail of what the app did just before, such as the screens it showed and the web addresses of its recent requests to our servers and whether they succeeded. Before a report leaves your phone, the app strips account identifiers, email addresses and sign-in tokens out of it, and we have deliberately configured our monitoring tool not to attach a user record, your IP address or the contents of requests. A web address in that trail can still name a wine you looked up. We also collect performance traces on a sample of sessions (about one in five) to find slow screens and requests. Crash reporting does not run at all in builds running in Apple’s simulator.

Scan metadata. How many wines a scan found, the price range on the list, and how many pages you scanned.

What we do not collect

We want to be specific, because “we don’t collect much” is what everyone says. Sommly does not collect:

Sensitive information

We do not intentionally collect sensitive personal information as defined by GDPR Article 9 or the CCPA. Be aware that free text you write yourself, such as tasting notes, journal entries or chat messages, may contain anything you put there, including health or religious detail. Please don’t put anything there you wouldn’t want stored. We don’t analyze that text for sensitive characteristics and we don’t use it to infer anything about you beyond wine preference.

2. How do we process your information?

We use each category of data for a specific purpose, and only that purpose:

What we useWhat for
Email / Apple identifier, password hashCreate your account, sign you in, let you reset your password.
Display nameGreet you by name in the app.
Taste profile, ratings, dislikesRank and personalize wine recommendations for you.
Photos of wine lists and labelsRead the wines off the list or the label. Processed and discarded (section 5).
Chat messages + taste-profile summaryGenerate the assistant’s reply, tailored to your palate.
Your saved conversations with the sommelierShow you your most recent conversation when you return, and review answers so we can fix ones that went wrong.
Journal entries, scans, restaurant names and venue map pointsShow you your own history: what you drank, where, and what you thought.
Ratings and journal entriesPower your Wine Passport: bottle count, countries and regions tried, milestone stamps.
Onboarding analyticsFind where the quiz confuses people or loses them, and fix it. We look at this in aggregate; we are not interested in any one person’s answers.
The app-usage events (section 1)Count how many people use Sommly and how often, see whether people come back and whether a change helped, see which parts of the app lead people to Reserve or to sharing, and apply the free tier’s monthly sommelier-message allowance.
Crash reports and performance tracesFind and fix bugs, crashes and slow screens.
Your location, if you tap the location buttonAsk Apple’s MapKit which restaurants are near you, so we can offer you the name. Used for that one lookup and never stored.
The map point of a venue you picked from a listKept for the map view of your own history, which the app doesn’t draw yet. Saved only when you pick the place from map results, and cleared when you clear the place (section 1).
Wine name + local schedulingSend a local reminder the next morning asking how the wine was, if you enabled notifications.
Your emailReply when you contact us; send account and security emails.
Your Reserve membership: Apple’s identifier for the subscription, the plan, its status and renewal dateTo give Reserve members higher limits on the sommelier chat. The app also reads your membership from Apple on the device, to show you Reserve.

What we never do with it: we don’t build advertising profiles, we don’t sell it, we don’t share it for cross-context behavioral advertising, and we don’t use your content to train our own AI models. On what Google may do with data sent to its AI service, see section 5; we’re honest there about the limits of what we control.

3. What legal bases do we rely on?

For users in the EEA, the UK and Switzerland. Under GDPR we must have a valid legal basis for each purpose.

PurposeLegal basis
Running your account; recommendations, scanning, chat, journal, passportContract (Art. 6(1)(b)). This is the service you asked for.
Sending a photo or chat message to our AI providerContract (Art. 6(1)(b)). The feature can’t function otherwise.
Keeping your conversations so you can return to them, and reviewing them to fix wrong answersContract (Art. 6(1)(b)) for showing you your own conversation; Legitimate interests (Art. 6(1)(f)) for reviewing answers to improve them. You can clear them at any time, and you may object; see section 13.
Crash monitoring, security, abuse preventionLegitimate interests (Art. 6(1)(f)). Balanced by disabling personal-data collection in the tool.
Product analytics: the onboarding flow, and the app-usage events in section 1Legitimate interests (Art. 6(1)(f)). Understanding how the app is used and improving it. The events carry no free text, are never used to track you across other apps or sites, and are never sold or shared. You may object; see section 13.
Counting your sommelier messages against the free tier’s monthly allowanceContract (Art. 6(1)(b)). It is how the free tier works.
Keeping Apple’s record of your Reserve subscription with your accountContract (Art. 6(1)(b)). It is how Reserve’s higher limits reach your account.
Local reminder notificationsConsent (Art. 6(1)(a)). iOS asks you; withdraw any time in Settings.
The one-tap nearby-restaurant lookupConsent (Art. 6(1)(a)). iOS asks you, you tap the button each time, and you can withdraw the permission in Settings.
Saving the name and map point of the venue you pick on your journal entryContract (Art. 6(1)(b)). Your own history of what you drank and where is the service you asked for. The lookup that offers you the place is a separate step and runs on consent, above.
Legal obligations and lawful requestsLegal obligation (Art. 6(1)(c)).

You may object to processing based on legitimate interests at any time. See section 13.

4. When and with whom do we share your information?

We do not sell your personal information. We never have and we do not plan to. We share it only with the service providers below, each processing it on our instructions to make a specific feature work.

ProviderWhat they doWhat they receive
Supabase, Inc.Database, file storage, authentication, server functions, and the sending of your account and security emailAccount credentials, taste profile, ratings, journal (including confirmed venue names and their map points), scans, your saved conversations with the sommelier, your Reserve membership record, analytics events. Your email address, to send you a password reset or a confirmation. Photos pass through in transit. Database hosted in the United States (us-west-1).
Google LLC (Gemini API, incl. Search grounding)Reads your photos; generates the assistant’s replies; looks up wine detailsPhotos you scan or attach; chat messages and recent conversation; the wines from a scanned list, when you ask about it; a plain-language summary of your taste preferences; journal excerpts, including the notes you wrote and the restaurant names, when you ask about wines you’ve tried; search queries the assistant composes.
Sentry (Functional Software, Inc.)Crash and error monitoringStack traces and errors, device model, OS and app version, and a short trail of the app’s recent screens and requests. Configured not to send personal identifiers or IP addresses: the app strips account identifiers, email addresses and sign-in tokens before a report leaves your phone.
Apple Inc.Sign in with Apple; App Store and TestFlight distribution; selling and billing Sommly Reserve; the MapKit place lookupYour Apple sign-in identifier. If you tap the location button, your device sends your approximate location to MapKit for that one search; it goes to Apple, not to us. TestFlight users: Apple separately receives your email and crash/usage data under Apple’s policy, not ours.

Email delivery. Your account and security email is sent by our hosting provider today. If we move that to a dedicated email provider, or start receiving your replies through one, we will name it in the table above before that happens, as section 17 requires.

Each of these providers processes your data under its own published data processing terms, which limit it to processing on our instructions for the service we bought. We do not authorize any of them to use your data for their own purposes, and none of them is paid in data.

Other situations. We may disclose information if required by law, subpoena or valid legal process, or where we believe it necessary to protect our rights, investigate fraud, or respond to a threat to someone’s safety. If Sommly is involved in a merger, acquisition or sale of assets, your information may transfer as part of that deal. We’ll notify you before it becomes subject to a different privacy policy.

5. How does the AI work, and what does it see?

This is the section we’d want to read first, so here it is in plain terms.

Photos of wine lists and labels

  1. Your iPhone shrinks the photo and sends it to our server function.
  2. That function passes the image straight to Google’s Gemini AI, which reads the wines off it.
  3. Google returns structured text: names, producers, vintages, prices, tasting notes.
  4. We keep the text. We do not save the photo. The image is never written to our database or file storage; it exists only for the seconds it takes to process the request.
Two honest caveats

Google receives the image. Sommly uses the paid tier of Google’s Gemini API. Under Google’s paid-tier API terms as of the effective date above, Google does not use your prompts, your photos, or the responses to train or improve its models, a commitment the free tier does not make, which is why we pay for it. Google still handles the request under its own terms while it’s in their hands, including any short-term retention for abuse monitoring. That part is Google’s practice, not ours, and we don’t control it.

A photo of a restaurant wine list may capture more than the list: a neighboring table, a person, the venue’s decor. Please frame the shot on the list where you can.

Before your first scan, the app tells you the photo goes to Google’s Gemini AI to be read, puts what we keep and what a restaurant photo can catch one tap away under “How this works”, and asks you to agree. Declining is a real button, and the scan does not happen.

The AI sommelier chat

When you send a message, we send Google: your message, up to your last 20 messages and replies in that conversation, a plain-language summary of your taste preferences, and any photo you attached. When you ask from a scanned list with the list attached, your message also carries the wines read from that list (up to 60 of them, with their prices) and your budget, if you set one. You send this to Google by sending the message; the question the app asks before your first photo is about photos.

The assistant also has tools it can use on your behalf. If you ask about wines you’ve tried, it reads up to 25 of your most recent journal entries and includes them in the request to Google so it can answer: the entry titles, the notes you wrote, the restaurant names, the dates, your scores and any note you left with a score. The venue map points are not sent. If you ask it to remember a wine, it writes a new entry to your journal. If it needs current information (a price, a recent vintage), it runs a Google Search on a query it composes from your conversation.

We store your chat transcripts. Each message you send, and each reply the sommelier finishes, is saved to your account in our database: the words, the time, and which conversation it belongs to. When you ask from a scanned list, the words include the list sent with your question, and we also keep the short line naming that scan, with the restaurant name if you added one. With each reply we keep a note of which of the assistant’s tools it used, such as a journal lookup or a web search, and how the reply ended. A photo you attach is not stored; we keep its caption, or the words “Sent a photo”, in its place. A reply that fails partway is not saved.

We keep them for two reasons: so your most recent conversation is waiting when you reopen the app, and so we can read conversations to find and fix answers that went wrong. They are not used for advertising, not sold, and not shared with anyone beyond the service providers in section 4 that host our database.

You can delete all of them at any time in Profile, then Clear chat history. They are also deleted when you delete your account. Storing them changes what goes to Google in one way only: when you reopen the app within six hours of your last message, the recent messages of that conversation go with your next message, as they would have if you had never left. An older conversation is shown to you and not sent.

The AI can be wrong

Three things in Sommly come from three different places, and each can be wrong. Google’s Gemini AI reads your photos: the wines, producers, vintages and prices taken from a wine list or a label are its reading of the picture. The sommelier chat’s replies are written by Gemini, from what this section says it is sent. The picks on a scanned list are not written by an AI model: your phone ranks the wines on that list by fixed rules, from your taste profile, your own ratings and anything you add, such as a dish or a budget, and writes each pick’s one-line reason the same way. All of it, including the tasting notes, price readings and identifications the app shows, is informational, can be inaccurate or incomplete, and is not professional advice of any kind. Check anything that matters, especially a price on a wine list, and especially any health-related question, which you should take to a doctor and not to a wine app.

6. Third-party websites

The app and this site may link elsewhere: a producer’s site, a source the assistant cites, our TestFlight page. We don’t control those sites and aren’t responsible for their privacy practices. When you leave Sommly, read the privacy notice of wherever you land.

7. Cookies and tracking technologies

In the app: none. Sommly’s iOS app uses no cookies, no advertising identifier, no tracking pixels, and no third-party analytics or attribution SDK. We do not present an App Tracking Transparency prompt because we do not track you across apps or websites.

On this website: also none. This site sets no cookies and uses no analytics or tracking scripts. It runs no JavaScript at all and loads no third-party resources. Every image, icon and font on the page is served from our own domain or is already on your device. That’s why you aren’t being asked to accept cookies: there are none to accept.

If we ever add analytics, we’ll name the tool here, say what it collects, and, for anything capable of building a cross-site profile, ask EEA and UK visitors for consent first.

The app’s local data is stored on your device, not in cookies, and is removed when you delete the app.

8. How do we handle Sign in with Apple?

Apple gives us a stable identifier for you, an email address (your own, or a private relay address if you chose Hide My Email), and, only on your very first sign-in, the name you agreed to share. We store the identifier and email with your account and copy the name into your profile so we can greet you. We never receive your Apple ID password, and we receive nothing else about you. Apple’s own privacy policy governs what Apple does.

9. Is your information transferred internationally?

Yes. We are based in the United States and our database is hosted in the United States (region us-west-1). Our providers (Supabase, Google, Sentry and Apple) are US companies and may process your information in the United States and other countries where they or their subcontractors operate.

If you are in the EEA, the UK or Switzerland, this means your personal information leaves your country for somewhere whose data-protection laws may be less protective.

We want to be precise about what protects that transfer, because this is a place where privacy policies routinely overclaim. Supabase, Google and Sentry each publish a data processing addendum that incorporates the European Commission’s Standard Contractual Clauses and the UK International Data Transfer Addendum, and those published terms apply to the services we use. We rely on our providers’ standard terms. We have not negotiated bespoke transfer agreements with any of them, and we are not claiming to have.

An EEA and UK representative (GDPR Art. 27). We have not yet appointed a representative in the EEA or the UK. Until we do, direct any request to hello@sommly.app and we will handle it directly.

10. How long do we keep your information?

We keep your information for as long as it is needed for the purposes set out in this notice, and for as long as we have a legal, accounting or legitimate business reason to keep it. In practice that means your account data stays for as long as your account exists: we don’t currently run an automatic deletion schedule, and your wines, ratings, notes and journal stay with you until you delete them or delete your account, because that history is the point of the product.

We deliberately don’t publish a fixed retention window, such as “analytics deleted after 24 months”, because no automated job enforces one today, and a retention promise nobody keeps is worse than no promise. What we offer instead is the control that actually matters: delete your account and your own data goes at once, on demand, from inside the app (section 13), with the narrow exceptions named above and listed again in section 13.

11. How do we keep your information safe?

No system is perfectly secure and no internet transmission can be guaranteed. Please use a strong, unique password, and tell us at hello@sommly.app if you believe your account has been compromised. We read security reports first and we won’t be annoyed that you wrote.

If there is a breach. If a security incident affects your personal information, we will notify you and the relevant regulators within the deadlines the law sets: GDPR Art. 33 and 34 in the EEA and UK, and the US state breach-notification laws that apply to you. We state that here rather than leaving you to look it up.

12. Do we collect information from minors?

Sommly is for adults of legal drinking age and is not directed to children.

The app is about wine. It contains frequent references to alcohol, discusses alcoholic products in detail, and is rated accordingly on the App Store. You may use Sommly only if you are at least 21 years old, or the legal drinking age where you live, whichever is higher. See the Terms of Service.

We do not knowingly collect personal information from anyone under the legal drinking age, and never from a child under 13, and we do not knowingly permit anyone under the legal drinking age to use the service. We do not have age-verification technology and we do not ask for a date of birth.

Parents and guardians

If you believe a child has created an account or given us personal information, contact us at hello@sommly.app and we will delete the account and associated data promptly. We treat these requests as a priority.

13. What are your privacy rights?

Which of these rights you have depends on the law where you live. They’re all described here so you can see the whole set, and we honor each of them where the law that applies to you provides it. In practice we don’t ask people to prove their jurisdiction before we act on a request, and we would rather help than argue about it, but nothing in this notice grants you a right the law where you live does not.

How to exercise them

Email hello@sommly.app from the address on your account and tell us what you want. We’ll verify it’s really you, usually by confirming you control the account email, and respond within 45 days for US state-law requests (extendable once by 45 more days if we tell you why) and within one month for GDPR requests (extendable by two more months for complex requests). An authorized agent may act for you with written proof of authorization.

You can also do a lot of this yourself in the app: edit your name in the Profile tab, retake the taste quiz to replace your profile, and delete individual ratings and journal entries.

Deleting your account

You can delete your account and your own data from inside the app. Open the Profile tab and choose Delete Account. You’ll be asked to type DELETE to confirm, because this cannot be undone.

When you confirm, a server-side routine removes:

Your device’s local copies (cached taste signals and app preferences) are cleared in the same pass. There is no grace period and no recovery: when it’s done, it’s done. There is no export button. If you want a copy of your data, email hello@sommly.app from your account’s address before you delete, and we’ll send it.

What stays, and why

These do not go with your account:

  • The shared wine catalog. A bottle’s name, producer, region and grape are facts about the wine, not about you; once your rows are gone, nothing in that catalog is linked to you.
  • Our AI cost ledger (section 10): rows recording that a call to our AI provider happened and what it cost, holding no prompt, no reply and nothing you wrote, and carrying an account identifier that now points at no account.
  • Email you sent us (section 10), which is filed by the address it came from rather than against your account, so the deletion routine cannot find it. Ask us and we will delete it by hand.
  • Apple’s record of a subscription, with its link to your account removed (section 10). Apple still bills it until you cancel.
  • Copies in ordinary backups, for a limited time. Deletion removes your rows from the live database straight away. Routine backups of that database, taken before you deleted, still hold copies until those backups age out on their normal rotation. Those backups cover the database, not your scan-image folder.

If deletion fails part-way, the app tells you so plainly rather than pretending it worked. If that happens, email hello@sommly.app and we’ll finish it by hand and confirm when it’s done.

14. Do-Not-Track and universal opt-out signals

Do-Not-Track. Most browsers offer a “Do-Not-Track” setting. No common standard for honoring it has been finalized, so this website does not currently respond to DNT signals. If a standard is adopted, we’ll update this notice.

Universal opt-out mechanisms (Global Privacy Control). Several US state laws in California, Colorado, Connecticut, Texas and others require businesses to honor an opt-out preference signal such as GPC for the sale or sharing of personal information. Sommly doesn’t sell or share personal information for advertising, so there is nothing for a GPC signal to turn off. If that ever changes, we’ll honor GPC signals on this website and we’ll say so here first.

15. California residents (CCPA/CPRA)

If you’re a California resident, the CCPA as amended by the CPRA gives you specific rights.

CCPA categoryCollected?Examples
A. IdentifiersYesEmail, account identifier, Apple sign-in identifier, display name
B. Cal. Civ. Code §1798.80 informationYesName and email
C. Protected classificationsNoNone
D. Commercial informationYesWines rated, scanned or journaled; prices read off a list; your Reserve subscription record (plan, status, renewal date), never a price or payment details
E. Biometric informationNoNone
F. Internet or network activityYesIn-app screen views, taps, time-on-screen; the app-usage events in section 1; in-app wine searches; app version; crash reports
G. Geolocation dataYes, narrowlyThe map point of a venue you picked from a list of map results, saved on the journal entry it belongs to. We store no device location: whatever your device knows goes to Apple’s MapKit for the lookup and never reaches us, a name you type without picking a result saves no map point, and clearing the place asks the server to clear the map point too (section 1).
H. Sensory dataYesPhotos of wine lists and labels, processed and not stored
I. Professional / employmentNoNone
J. Education informationNoNone
K. InferencesYesYour taste profile and “archetype”
L. Sensitive personal informationNoNone of the categories the CCPA defines as sensitive

Sources: you, directly; your device, automatically; and Apple, if you use Sign in with Apple or subscribe to Reserve. Business purposes: as described in section 2. Disclosures: to the service providers named in section 4, each contractually limited to processing it for us.

Sale and sharing. We have not sold personal information, and have not shared personal information for cross-context behavioral advertising, in the preceding twelve months. We don’t do so now and we don’t sell or share the personal information of anyone, including minors under 16.

Your California rights: know, delete, correct, opt out of sale/sharing (nothing to opt out of), limit use of sensitive personal information (none collected), and non-discrimination. Email hello@sommly.app. We verify identity via your account email; an authorized agent may act for you with written permission.

Shine the Light (Cal. Civ. Code §1798.83): we don’t disclose personal information to third parties for their own direct-marketing purposes.

16. Other US state privacy rights

Comprehensive privacy laws in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and other states give residents rights to confirm, access, correct, delete and port their personal data, and to opt out of targeted advertising, sale, and certain profiling.

We don’t try to work out which state you’re in before we answer a request, so in practice the process in section 13 is the same for everyone; which rights you actually have is a question of the law of your own state, and this notice does not add to it. Email hello@sommly.app and we’ll respond within your state’s deadline (45 days in most states). If we deny a request you may appeal by replying to our decision; we’ll respond within 60 days and, if we still deny it, tell you how to complain to your state Attorney General.

Targeted advertising, sale, and profiling: we do none of these. We don’t use your data for targeted advertising, we don’t sell it, and we don’t use automated profiling to make decisions with legal or similarly significant effects about you. Ranking wine recommendations by your stated taste is the only profiling we do, and its worst-case consequence is a wine you don’t love.

Nevada residents: we don’t sell personally identifiable information as defined by Nevada law.

17. Do we make updates to this notice?

Yes. We update this notice when the app’s data practices change, and we review it at least once a year. The “Effective” date at the top always reflects the current version.

If we make a material change, such as a new category of data, a new provider or a new purpose, we’ll take reasonable steps to tell you, in the app or by email, and we’ll give advance notice or ask for your consent where the law requires it. The current version is the one published at sommly.app/privacy.html. We won’t retroactively apply a weaker policy to information we already collected under a stronger one.

18. Contact, review, update, or delete your data

Data controller: Ashwood Data LLC, a California limited liability company.

Privacy contact: hello@sommly.app, the same address for privacy requests, security reports and support.

Postal address: Ashwood Data LLC, 11420 Santa Monica Blvd, Unit 252091, Los Angeles, CA 90025.

To review, update or delete your data:

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