Privacy Policy section
1. WHAT IS THE PURPOSE OF THIS POLICY?
The mobile application Vinotag (“VINOTAG”) is a digital wine cellar management service provided remotely by FRIO ENTREPRISE, a simplified joint-stock company with a share capital of €753,264.60, whose registered office is located at ZI SUD, 143 Boulevard Pierre Lefaucheux, 72230 Arnage (France), registered under number 524 177 508 RCS Le Mans, reachable at +33 2 43 21 69 80 and at dpo@groupefrio.com.
This policy (the “Policy”) aims to inform you of how your personal data is processed by FRIO when you use VINOTAG (“You”, “Your”). We invite you to carefully read this Policy before continuing to use VINOTAG.
For the purposes of this Policy, the term “Personal Data” means any information relating to an identified or identifiable natural person.
2. DATA CONTROLLER
When providing VINOTAG, FRIO determines the means and purposes of the processing of your Personal Data and acts as the data controller.
FRIO undertakes to comply with:
- Regulation (EU) 2016/679 (GDPR)
- Directive 2002/58/EC
- French Law No. 78-17 of January 6, 1978, as amended
3. HOW DOES FRIO COLLECT YOUR PERSONAL DATA?
FRIO collects your Personal Data:
- when creating your account
- when using VINOTAG
- when submitting contact forms
- through customer service interactions
- through cookies and partners
4. WHAT CATEGORIES OF PERSONAL DATA ARE COLLECTED?
- Identification data: email, name, date of birth, location, technical ID, password
- Usage data: connection logs, usage history, settings
- Customer relationship data: communications, feedback
- Cellar data: inventory, consumption history, preferences
- AI-related data: prompts, responses, interactions
- Rights-related data: requests and identity verification
5. COOKIES
Cookies are text files stored on your device to improve your experience and recognize your device.
| Name | Purpose | Legal basis | Retention |
|---|---|---|---|
| Firebase Auth | Authentication | Contract | Session |
| Firebase Analytics | Audience measurement | Consent | 13 months |
| Crashlytics | Error tracking | Consent | < 12 months |
On your first visit, you may accept, refuse or configure cookies.
6. PURPOSES, LEGAL BASES AND RETENTION
| Purpose | Legal basis | Retention |
|---|---|---|
| Account management | Contract | Account duration + 5 years |
| Cellar management | Contract | Account duration + 5 years |
| AI recommendations | Contract / legitimate interest | Account duration + 5 years |
| Newsletter | Consent | 3 years |
7. RECIPIENTS
- FRIO staff
- Technical providers
- Google (Gemini AI)
- Authorities
8. DATA TRANSFERS OUTSIDE THE EU
Data may be transferred to the United States or the United Kingdom under:
- Data Privacy Framework
- Standard contractual clauses
9. SECURITY
FRIO implements technical and organizational measures to protect your Personal Data.
10. YOUR RIGHTS
- Right of access
- Right to rectification
- Right to erasure
- Right to object
- Right to data portability
- Right to withdraw consent
To exercise your rights:
- Email: dpo@groupefrio.com
- Address: Groupe FRIO, 143 Boulevard Pierre Lefaucheux, 72230 Arnage, France
You may also lodge a complaint with the CNIL: www.cnil.fr
11. MODIFICATIONS
This Policy may be updated at any time. We recommend that you regularly review the latest version.