PRIVACY POLICY

BREWTIFI APPLICATION

Last Updated: [September 20, 2025]

  1. NAME OF THE DATA CONTROLLER
    1. The BREWTIFI mobile application (the "Application" or "App") is the property of BREWTIFI TECH S.R.L., a limited liability company having its registered headquarters in 1 Pipera Boulevard, Hyperion Towers Building, Office 3, 7th Floor, Voluntari, Ilfov County, Romania, registered with the Trade Registry under no. J2025056317005, Sole Identification Number 52233491 (hereinafter "BREWTIFI", "Company", "we", "us", or "our").
    2. The use of the Application is governed by the Terms and Conditions of Use ("Terms of Use") available here. Please read them carefully. If you do not agree with all of them, please do not use our Application.
    3. This Privacy Policy on Personal Data Processing (referred to as “Privacy Policy”) concerns the personal data processing carried out by BREWTIFI as a data controller through its website brewtifi.com and its Application. The terms used in this Privacy Policy have the same meanings as in our Terms of Use, unless otherwise defined in this Privacy Policy. By accessing and using the Application you agree to our use, collection, and disclosure of personal information in accordance with the Privacy Policy.
    4. You can review the most current version of the Privacy Policy at any time within the Application. We reserve the right to update, change, or replace any part of the Privacy Policy by posting updates and/or changes to our Application. It is your responsibility to check this page periodically for changes. Your continued use of or access to the Application following the posting of any changes constitutes acceptance of those changes.
    5. You are entitled to know the purposes for which we process your personal data, and we will inform you prior to processing your personal data for any other purposes than those for which you disclosed your personal data to us.
  2. PERSONAL DATA WE PROCESS FOR USING THE APPLICATION
    1. We will collect the following personal data from you:

      • first and last name;
      • Primary Email Address;
      • Login via a Third-Party Account;
      • age;
      • Location data;
      • telephone number;
      • city, county, and country of residence;
      • User Content you submit, post, or otherwise make available through the Application, including via our AI-powered chatbot, as well as any other data resulting from your interaction with us.
      • Third-Party Account Information made available to us by accessing the Application through a Third-Party Account (e.g., Facebook, Instagram). This may include your name, email address, profile picture, a public user ID associated with your Third-Party Account.
  1. HOW WE COLLECT PERSONAL DATA
    1. We collect the personal data that you provide voluntarily (in electronic format), as well as information and data made available by accessing via a Third-Party Account. Please be advised that you are free to decide whether or not to provide us with such personal data, and there is no adverse effect for you. However, it is not possible to provide you with access to the Application, either partially or fully, in the absence of certain categories of data necessary for this process.
    2. By linking a Third-Party Account to your Account, you authorize BREWTIFI to access, use, and, where applicable, store Third-Party Account Content so that it is available in your Account within the Application. Unless otherwise specified in the Terms of Use, all Third-Party Account Content shall be deemed User Content. You may disable the connection between your Account and any Third-Party Account at any time through the “Settings” section of the Application.
  2. THE PURPOSES AND THE LEGAL GROUNDS FOR PROCESSING
    1. We collect your personal data for the purpose of providing the services and performing the agreement concluded with you with respect to our Application. We also process your personal data for the purposes of registering on the Application, for the optimal functioning of the Application, for contacting you (g., in case of a security incident), for combating and preventing any kind of fraud related to the Application, for dealing with complaints and claims related to the Application, and for ascertaining, enforcing and defending BREWTIFI’s rights and interests.
    2. The legal grounds for the processing of personal data are:
      1. the performance of a contract, by accepting the Terms of Use and registering on the Application;
      2. the legitimate interest of BREWTIFI, namely the optimal provision of the Application, the prevention and fight against fraud, the settlement of any complaints or claims related to the Application, the ascertainment, enforcement and defence of BREWTIFI's rights and interests;
      3. your consent to registration on the Application.
    3. When you subscribe to receive professional communications from us, by means of the website or Application, we will ask for your consent for the processing of personal data in order to be able to supply those services for which you have requested the subscription. Thus, in such cases, the legal ground for processing of such data is your consent.
    4. If at any moment in time, you decide you do not want to benefit from these communications and consequently you withdraw your consent, we will respect your decision and we will stop processing your personal data for professional communication purposes and marketing.
  1. USE OF COOKIES AND SIMILAR TECHNOLOGIES
    1. Our website and Application contain cookies and similar technologies, which collect personal data. The collection of your personal data is strictly limited to what is necessary to provide you with an experience of the highest quality with regard to the use of our website and Application. We collect certain technical information when you use our website or mobile app. This may include your IP address, the type of device and browser you are using, and other identifiers that help us recognize your device. We may also collect information about how you navigate our website, interact with the materials and emails we send you, and use this data to improve our services and provide you with more relevant content.
    2. We collect your personal data through cookies and similar technologies placed on our website and Application. The details on the processing of personal data through such tools are available in our Cookie Policy.
    3. We use cookies and similar technologies to provide you with a better user experience, to perform analytics that help us improve our services, and to deliver content and advertisements that are relevant to your interests.
    4. For more information with respect to the use of cookies and similar technologies on our website and Application, please visit our Cookie Policy available here.
  2. RETENTION PERIOD
    1. We will retain personal data for the period necessary to fulfil the purposes mentioned above, except where legal provisions require us to store data for a longer period.
    2. Personal data processed in relation to your user Account for the Application shall be generally processed for the duration necessary for us to provide you with access to the Application, but no longer than the termination of the agreement between you and BREWTIFI.
    3. If you have chosen to receive communications from BREWTIFI, we will store your personal data for as long as you have given us your consent to receive communications from us. We will periodically review your consent and ask you to reconfirm if you wish to continue benefiting from this service.
    4. We shall delete your personal data when it is no longer necessary for the purposes for which they have been collected or when you withdraw your consent (if the processing of your data is based on consent), provided that we are not legally required or otherwise permitted to continue to hold such data. We may retain your personal data for an additional period, in case their immediate deletion would require us to overwrite our automated disaster recovery and backup systems
  1. RECIPIENTS
    1. As a rule, we do not share with or transfer your personal data to third parties. However, if the disclosure or transfer of your personal data is required or if we are obliged by law, we shall inform you in the shortest possible time with regard to such transfer, unless the applicable law prevents us from sending such notification. If we disclose or transfer your personal data to third parties, we shall do so according to the applicable laws and take the necessary measures reasonably available to us to ensure their integrity and protection.
    2. For the processing of personal data, we may use data processors, g., providers of IT solutions necessary for business management, including financial accounting solutions, providers of contact management solutions or conference organisers. We shall conclude agreements for the processing of personal data with all data processors, which will include adequate clauses to ensure that data processors undertake obligations to process personal data (including to delete it) in full accordance with applicable laws and which provide an adequate level of protection to your personal data.
    3. We also use third party service providers, which may collect personal data from you, such as:

      • Google Ireland Limited, an Irish company registered in Gordon House, Barrow Street, Dublin 4, Ireland, whose privacy policy is available here;
      • Meta Platforms Ireland Limited, an Irish company registered in 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland, whose privacy policy is available here.
    4. Please note that your personal data will not be transferred outside the European Economic Area without your consent or without the implementation of appropriate additional safeguards as required by law.
  1. SECURITY OF YOUR PERSONAL DATA
    1. We will take all necessary organisational and technical measures in order to ensure the security, integrity and confidentiality of your personal data.
    2. If we find an incident with respect to the security of personal data that poses a risk to your rights and freedoms, we will notify the National Supervisory Authority for Personal Data Processing (“ANSPDCP”) within 72 hours. You will also be personally informed about the security incident if it is likely to pose a high risk to your rights and freedoms.
  1. MISCELLANEOUS
    1. The Application may contain links to other sites. If you click on a Third-Party Link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the privacy policies of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
    2. The Application does not address anyone under the age of 16. We do not knowingly collect personal data from children under 16 years of age. In the case we discover that a child under 16 has provided us with personal data, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us so that we can take necessary actions.
  2. YOUR RIGHTS
    1. Please be informed that if you have expressed your consent to the processing activities, you may withdraw this consent at any time with future effects. Such withdrawal will not affect the lawfulness of the processing performed prior to the withdrawal of the consent. As a general rule, in cases where you withdraw your consent, we will no longer allow the processing of your personal data and will take appropriate action to delete any records with your personal data. However, if the processing could be based on other legitimate grounds under the applicable legal provisions, we will proceed with that processing and inform you accordingly.
    2. You have the following rights to process your personal data:
      1. The right of access to personal data. You have the right to request access to your personal data processed by us.
      2. The right to rectification. You have the right to obtain from us the rectification of your incorrect, incomplete, or outdated personal data. Depending on the purpose of the processing, you may fill in incomplete personal data, including by means of an additional statement.
      3. Right to erasure (“the right to be forgotten”). You have the right to ask us to delete your personal data. Personal data whose retention is in accordance with the legal provisions cannot be deleted.
      4. The right to restriction of processing. In the circumstances provided by law, you may request the restriction of the processing of your personal data.
      5. The right to data portability. You may request us to transfer to you or to another data controller a copy of your personal data that the BREWTIFI processes about you.
      6. The right to object to the processing of your personal data.You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data by us, and consequently, we can no longer process your personal data. If you have a right to object and you exercise this right, your personal data will no longer be processed for such purposes by us. Exercising this right will not incur any costs.
  1. EXERCISE YOUR RIGHTS
    1. If you have any questions regarding the processing of your personal data or if you wish to make any request to us and exercise any of your rights with respect to the processing of personal data, please contact us at: hello@brewtifi.com.
    2. Each request will be reviewed as soon as possible but no later than one month.
    3. If you believe that we have not resolved all of your requests or are dissatisfied with our responses, you may file a complaint against us with the ANSPDCP. The supervisory authority will inform you about the state of the complaint within a reasonable time. You may also refer to the competent courts of law.
    4. In the event we decide to amend this Privacy Policy, we will publish the new version on our website and in our Application, which will supersede the current version. Any change to the information contained in this Privacy Policy will be brought to your attention. No change to the Privacy Policy will affect the rights conferred by the law.
    5. Thank you for trusting us with your personal data and for finding the necessary time to read our Privacy Policy. Please feel free to contact us if you have any questions related to our processing of your personal data.