Privacy Policy

1. Overview and scope

This privacy policy applies to the website of Westios UG (haftungsbeschränkt) (hereinafter "Westios"), to the product-demonstration sites provided by Westios, and to our "Vintner" software including the "Vintner POS" mobile point-of-sale app. We process personal data in accordance with the General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG).

2. Controller

Westios UG (haftungsbeschränkt)
Baaderstr. 50, 80469 Munich, Germany
Represented by: Tim Westhoff
E-mail: datenschutz@westios.com

3. Rights of data subjects

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing (Art. 21). You may withdraw any consent given at any time with effect for the future. An informal notice to datenschutz@westios.com is sufficient.

You also have the right to lodge a complaint with a supervisory authority. The competent authority is the Bavarian State Office for Data Protection Supervision (BayLDA), Promenade 18, 91522 Ansbach, Germany (www.lda.bayern.de).

4. Hosting and server log files (Vercel)

Our website is hosted by Vercel Inc. (340 S Lemon Ave #4133, Walnut, CA 91789, USA); the application is operated primarily in the EU region (Ireland). Each time the site is accessed, server log data is recorded for technical reasons (browser type and version, operating system, referrer URL, IP address, date and time of access). Processing is based on our legitimate interest in secure and stable operation (Art. 6(1)(f) GDPR). A data processing agreement is in place with Vercel; insofar as data is transferred to the USA, this takes place on the basis of the EU Standard Contractual Clauses.

5. Contact form

If you contact us via the contact form, we process your details (name, e-mail address, optionally company and message) to handle your enquiry. For delivery we use the e-mail service Azure Communication Services (ACS) of Microsoft Corporation, operated via the European Azure region. A data processing agreement pursuant to Art. 28 GDPR is in place with Microsoft.

The legal basis is our legitimate interest in responding (Art. 6(1)(f) GDPR) or Art. 6(1)(b) GDPR insofar as the enquiry is aimed at a contract. The data is deleted once it is no longer required and no statutory retention obligations apply.

6. Sign in with Google

The administration area of our "Vintner" software lets winery administrators and staff sign in with their Google account ("Sign in with Google"). Using this feature is optional; sign-in with an e-mail address and password is available as an alternative.

Google user data accessed (Data Accessed): When you sign in with Google, we access the following data from your Google account via the standard sign-in scopes "openid", "email" and "profile": your e-mail address, your name, your profile picture and the unique identifier of your Google account. We do not access Gmail, Google Drive, contacts, calendar or any other Google service.

How we use Google user data (Data Usage): This data is used solely for authentication — i.e. to establish your identity, match you to the user account authorised for the respective administration area, and grant you access. Your e-mail address and name are stored in the associated administrator user account. We do not use this data for advertising, do not build profiles from it, do not sell it and do not share it with third parties; it is only transmitted to our authentication provider Supabase (see section 11) as far as technically necessary for signing in. Our use of information received from Google APIs adheres to the Google API Services User Data Policy, including its Limited Use requirements.

The legal basis is Art. 6(1)(b) GDPR (providing access to the administration area) or Art. 6(1)(f) GDPR (legitimate interest in secure sign-in). The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

7. Vintner POS (point-of-sale app)

Vintner POS is our mobile point-of-sale app used by winery staff to process in-person sales. When you use the app we process: (a) staff login data (e-mail address, authentication) to secure access; (b) sale and order data (items, amounts, timestamps); (c) customer data entered for a receipt or invoice (name and, where provided, e-mail address, tax code / codice fiscale and lottery code).

For customer data collected in-store, the respective winery is the controller; Westios acts as a processor pursuant to Art. 28 GDPR. We never receive or store full card numbers.

8. Payment processing (Stripe)

Card and contactless payments (including Tap to Pay on iPhone and Android) are processed via Stripe. The Stripe account used for a payment belongs to the respective winery; the winery is the merchant of record and Stripe is its independent payment service provider. Westios only provides the software and is not a party to the payment.

Stripe handles the card data directly; we receive only the payment result (success or failure, a reference and, where applicable, the last digits of the card). The provider is Stripe Payments Europe, Ltd. (Ireland) or Stripe, Inc. (USA); Stripe’s own privacy policy applies: https://stripe.com/privacy.

9. Electronic receipts and invoices

To issue the legally required electronic receipt or invoice, transaction data and — where provided — customer tax data is transmitted to the competent tax authority via our provider openapi.it. The legal basis is compliance with a legal obligation (Art. 6(1)(c) GDPR).

10. App diagnostics, crash reports and device identifiers (mobile app)

To keep our "Vintner POS" mobile app stable and to fix errors, we collect diagnostic and crash data. For this we use the service Sentry (Functional Software, Inc.). This processes technical information such as crash logs, error messages, app version, operating-system and device information (device type/model) and one or more device identifiers. This data is used solely to detect, diagnose and fix errors and to improve the reliability of the app; it is not used for advertising and is not sold.

In addition, crash and diagnostic data may be collected automatically by the app-store operator (Google Play) and by the device operating system. For security and fraud prevention in card payments, Stripe’s payment SDK may also process device identifiers (see section 8). This data is transmitted over an encrypted connection (SSL/TLS).

The legal basis is our legitimate interest in the stable, secure and error-free operation of the app (Art. 6(1)(f) GDPR). Sentry is operated in the EU region where possible; insofar as data is transferred to the USA, this takes place on the basis of the EU Standard Contractual Clauses.

11. Data storage (Supabase)

Platform and app data is stored in a database and file store of the provider Supabase, Inc.; the data is held within the European Union. A data processing agreement pursuant to Art. 28 GDPR is in place with Supabase.

12. Overview of processors

• Google Ireland Limited — authentication via "Sign in with Google" (openid/email/profile only; optional login to the administration area)
• Sentry (Functional Software, Inc.) — crash reports and diagnostics for the mobile app (error monitoring; EU region where possible, EU Standard Contractual Clauses)
• Vercel Inc. — hosting (US company, EU-preferred processing; EU Standard Contractual Clauses)
• Microsoft / Azure Communication Services — e-mail delivery for the contact form (EU region; EU Standard Contractual Clauses)
• Supabase, Inc. — database and file storage (data held in the EU; EU Standard Contractual Clauses)
• Stripe Payments Europe, Ltd. / Stripe, Inc. — payment processing as the respective winery’s independent payment service provider
• openapi.it — issuance of electronic receipts and invoices (Italy/EU)

13. SSL/TLS encryption

For security reasons this website uses SSL/TLS encryption, recognisable by the padlock symbol in your browser’s address bar and by "https://".

14. Retention

Personal data is deleted once the purpose of processing no longer applies and no statutory retention obligations apply. Server log files are generally deleted after a short period (usually 30 days).