Privacy Policy

This Privacy Policy supersedes the version dated August 4, 2026.

Brewtanica LLC, a New Jersey limited liability company ("Company," "we," "us," or "our") operates the Brewtanica mobile application (the "App") and the website located at brewtanica.com (the "Site" and, together with the App, the "Services"). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our Services. It also describes your rights and choices regarding your information.

This Privacy Policy is designed to comply with applicable data protection laws, including the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), the General Data Protection Regulation (GDPR) where applicable, and the requirements of Apple's App Store and Google Play Store.

By using the Services, you agree to the collection and use of your information in accordance with this Privacy Policy. If you do not agree, please do not use the Services.

IMPORTANT: Advertising in the App

The Brewtanica mobile application does not display advertising as of the effective date of this policy. The App does include a third-party advertising software development kit, Google AdMob (provided by Google LLC). It is inactive: it is not initialized, it does not request advertisements, and it does not collect information from your device while advertising is switched off.

We may switch advertising on for the free version of the App at a later date. If we do: advertising will be shown only to users of the free version, never to Premium or ad-free subscribers or during a free trial; advertising will be non-personalized unless you give any permission that applicable law and your device require, including Apple's App Tracking Transparency permission on iOS; and we will not access your device's advertising identifier (IDFA on iOS or Advertising ID on Android) or track your activity across other companies' apps or websites without that permission. While advertising is active, the AdMob SDK collects the information described in Section 3.2.

We will update this Privacy Policy before advertising is first displayed in the App, and notify you in the App. Advertising also appears on our public website at brewtanica.com, and only to visitors of that website. Section 13 describes the Site's advertising practices in full. Nothing in Section 13 applies to the App.

1. Information We Collect

We collect information in the following categories:

1.1 Information You Provide Directly

When you create an account, use App features, or contact us, you voluntarily provide information such as your name, email address, date of birth, profile details, beer scans, ratings, reviews, photographs, and any other content you choose to submit. If you opt in to a Malt Royalty portrait sitting, you also provide one photograph of your own face; that photograph is governed by Section 5, which applies instead of the general terms of this policy wherever the two differ.

1.2 Information Collected Automatically

When you use the App, we automatically collect certain information, including device information, usage data, and, if you have enabled location services, your approximate or precise location. We use standard technologies such as software development kits (SDKs) and product analytics tools to collect this information. The App includes an advertising SDK that is inactive, as described in "Advertising in the App" above. We do not use advertising identifiers or cross-app tracking technologies in the App.

1.3 Information from Third Parties

We may receive information about you from third parties, such as social media platforms and identity providers if you choose to sign in with or link an Apple or Google account, and from our analytics and infrastructure providers. We do not receive information about you from advertising partners or data brokers, and we do not purchase personal information about you from any source.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Provide and Operate the Services: To create and manage your account, process scans, display ratings, and deliver core features.

• Build the Beer Catalog: To extract, verify, and publish label-derived product information contributed by users, as described in Section 4.

• Personalization: To tailor your experience, including beer recommendations, badge awards, and venue suggestions.

• Ale Intelligence: To generate personalized briefings and conversational recommendations, as described in Section 3.3.

• Social Features: To enable connections with other users, display activity feeds, and facilitate content sharing.

• Location Services: To show nearby venues, validate check-ins, and provide location-based recommendations.

• Communication: To send service-related notifications, respond to support requests, and provide updates about the Services.

• Analytics and Improvement: To understand usage patterns, diagnose technical issues, and improve features and performance.

• Portrait Badges: To generate, store, and display a Malt Royalty portrait badge from a photograph you choose to provide, as described in Section 5. We use that photograph for no other purpose.

• Subscription Management: To administer free trials, process subscription status, and manage entitlements.

• Safety and Security: To detect, prevent, and address fraud, abuse, security incidents, and violations of our Terms of Service.

• Legal Compliance: To comply with applicable laws, regulations, legal processes, or government requests.

We do not use your information to deliver advertising in the App, to build advertising profiles, or to measure advertising effectiveness.

3. How We Share Your Information

We do not sell your personal information. Except as described in "Advertising in the App" above, we do not share your personal information with advertising networks or ad-tech vendors. We may share your information in the following circumstances:

3.1 With Other Users. Certain information, such as your username, profile photo, scans, ratings, reviews, and badges, may be visible to other users of the Services based on your privacy settings. You can control the visibility of your activity through your account settings.

3.2 Service Providers and Sub-Processors. We share information with third-party service providers who perform services on our behalf. These providers are contractually obligated to use your information only for the purposes we specify. Our principal sub-processors are:

Except for Google LLC in its AdMob role, none of these providers is an advertising network, and none is permitted to use your information for advertising purposes.

3.3 Ale Intelligence and Language Model Processing. Ale Intelligence, our conversational beer companion, sends limited context to third-party large language model providers in order to generate responses. That context is restricted to taste-profile summaries, scan-history summaries, and the content of your query. We do not send your name, email address, date of birth, or precise location to these providers. We retain the text of the questions you ask Ale Intelligence, and some of its responses, until you delete your account, to operate the feature, monitor its quality and safety, and improve it. The history of a conversation session is deleted within 24 hours after the session ends. GPS data used for venue-related answers is processed in real time and not stored as location history. We contractually require that your information not be used to train these providers' models.

3.4 Venue and Brewery Partners. We may share aggregated, de-identified data with venue and brewery partners to help them understand trends and improve their offerings. We do not share your personally identifiable information with partners without your consent.

Menu QR codes. Venues and breweries may display Brewtanica QR codes on their menus and screens. When you scan one, we record a view of that beer at that venue. A view recorded in the App is linked to your account. A view recorded on the web is linked to a visitor identifier that we compute from your IP address and browser information using a secret that changes daily; we do not store your IP address. Venues and breweries see only aggregate counts of views, never who viewed. We keep view records for at least two years so that we can provide venue and brewery partners with a history of views.

3.5 Legal Requirements. We may disclose your information if required to do so by law, in response to valid legal process (such as a subpoena or court order), or when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.

3.6 Business Transfers. In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have regarding your information.

4. Catalog Contributions and Data Retention

4.1 Data Retention Generally

We retain your personal information for as long as your account is active or as needed to provide the Services. We may also retain information as necessary to comply with legal obligations, resolve disputes, enforce our agreements, and for legitimate business purposes such as analytics and fraud prevention.

4.2 Catalog Contributions

Brewtanica is a crowdsourced encyclopedia of beer. When you scan a beer container, the factual product information derived from that scan — including the label and container photograph, barcode data, ABV, brewery information, nutritional information where available, and any regional variation — becomes part of the Brewtanica catalog, a permanent public reference work (a "Catalog Contribution").

Catalog Contributions are factual reference records about commercially available products. They are not personal information about you, and they do not identify you once de-identified as described below.

Catalog Contributions survive account deletion in de-identified form. When you delete your account, we sever the link between your identity and your Catalog Contributions. The product record remains in the catalog; your name, username, and account identifiers are removed from it. Where a contribution is credited, the credit becomes anonymous.

We rely on the following legal bases for retaining de-identified Catalog Contributions after an erasure request: Article 17(3) of the GDPR, which limits the right to erasure where processing is necessary for archiving purposes in the public interest, for scientific or historical research purposes, or for the establishment, exercise, or defense of legal claims; Recital 26 of the GDPR, under which the principles of data protection do not apply to anonymous information that does not relate to an identifiable natural person; and California Civil Code § 1798.105(d), which sets out exceptions to a business's obligation to delete.

4.3 Retention on Account Deletion

When you request account deletion, the following applies:

• Your account enters a thirty-day cooling-off period, during which you may cancel the deletion from within the App. Your account is inaccessible to other users during this period.

• You are prompted to export your data before the deletion completes.

• After the cooling-off period, your account record, profile, email address, photographs you uploaded that are not part of a Catalog Contribution, and other personal information are permanently deleted.

• Badges you earned are preserved in de-identified form as part of the catalog's historical record. A Malt Royalty portrait badge is the exception: it is deleted, not de-identified. See Section 5.7.

• Catalog Contributions are retained in de-identified form, as described in Section 4.2.

• We retain a one-way cryptographic hash (SHA-256) of your email address for two years following deletion, solely to prevent abuse of trial periods, badge systems, and leaderboards by repeated account creation. This hash cannot be reversed to recover your email address, and it is not used for any other purpose.

• If your account was suspended at the time of the request, deletion is handled through our support team rather than automatically.

• You may request revocation of all active sessions at the time of your deletion request.

De-identified or aggregated analytics data may be retained indefinitely.

5. Portrait Badges (Malt Royalty)

Malt Royalty is the highest tier of the Brewtanica badge system. Every user who reaches it receives the standard Malt Royalty badge automatically. Subscribers who reach it may, in addition and entirely at their option, sit for a portrait badge: a single photograph of the subscriber's own face, captured in the App, from which we generate one sculpted portrait rendered into the fixed Malt Royalty badge design.

The portrait badge is optional and opt-in. We do not collect any photograph of your face for this purpose unless you first read the in-App consent notice and give your affirmative, recorded consent. If you decline, or if you never respond, nothing is collected and the standard Malt Royalty badge remains yours.

5.1 What We Collect

On-device framing signals. While you are posing, the App uses your device's built-in face-landmark detection to coach your framing — to tell you to center yourself, level your chin, face forward, or find brighter light. These signals are computed on your device, are used only to decide when to enable the shutter, and are never transmitted to us, stored by us, or retained on your device after the sitting ends. We do not receive them.

5.2 How We Use It

We use the sitting photograph for two purposes, and no others: to generate your portrait badge, and to screen that badge and the photograph behind it for safety.

Generating the badge means: preparing the study from your photograph, generating the badge from the study, checking the result against the badge template for fidelity, retrying if the check fails, and then storing and displaying the finished badge.

Safety screening is described in Section 5.4. In short: before we generate anything, an automated content check reads your photograph to confirm it is a genuine photograph of a single adult face and contains nothing sexual, violent, or hateful; after generation, a second check reads the finished badge before it can be published. Where either check is uncertain, the sitting is held and a member of our team reviews it. This is the only inference we draw from your photograph, we draw it only to decide whether the sitting may proceed, and we do not retain it as a characteristic of you.

We use the photograph, the study, and the badge for nothing else. We do not use them to identify or authenticate you, to recognize you in any other image, to match or compare you against any other person or any database, to train or fine-tune any machine-learning model, for advertising or marketing, or to build a profile of you. We do not sell, lease, trade, or otherwise profit from them.

5.3 Who Processes It

No other third party receives your photograph, the study, or the badge. Only Anthropic ever receives the original photograph; Google receives only the greyscale study; Pixelcut receives only the finished badge.

5.4 Safety Screening and Human Review

Because a portrait badge can be published where other people see it, every sitting is screened.

Before generation. Your sitting photograph is sent to Anthropic's Claude vision service, which returns one of three verdicts: approve, reject, or escalate. It approves only where the image is a genuine photograph showing exactly one clearly visible adult face, with no sexual, violent, or hateful content. It rejects where any of that clearly fails — in particular, where the person appears to be a minor. Where it is genuinely uncertain, including where age is borderline, it escalates rather than approving.

After generation. The finished badge is screened a second time, before it can be published, against the same standards.

Human review. Where either check escalates, or where generation cannot produce an acceptable badge, the sitting is held and a member of our team reviews it by hand and decides whether it can proceed. That review is limited to that decision.

What this means for your photograph. The screening reads your photograph in order to reach a verdict, including forming a judgement about whether you appear to be an adult. We use that judgement only to decide whether the sitting may proceed. We do not record it as a characteristic of you, we do not use it to estimate or store your age, and it plays no part in anything else about your account — your age eligibility is established at registration from the date of birth you provide, not from your face.

5.5 Retention and Destruction Schedule

We publish the following schedule and adhere to it. Destruction of the photograph is additionally backed by an automatic expiry policy applied to the whole of the private storage location, so it does not depend on any single deletion step succeeding.

Nothing in this schedule preserves an image of your face. After twenty-four hours from upload, at the latest, no photograph of you and no study derived from it remains in our systems in any state — whether your badge succeeded, failed, or is awaiting review.

5.6 Where the Portrait Badge Appears

Nothing is shown to anyone else until you say so. When your badge is ready you are the first and only person to see it, at the reveal. It reaches any surface other people can see only when you separately choose to publish it. Declining to publish costs you nothing: the badge remains yours, privately.

Once you publish, your portrait badge replaces the standard Malt Royalty badge wherever that badge is shown. The consent you give authorizes display on the surfaces listed below, and on no others — we will not extend your portrait badge to any surface that is not on this list, and we will not add one without first updating this policy:

• Your badge detail screen and the badge reveal — visible to you whether or not you publish
• Your Brewtanica profile and badge collection
• The activity feed, subject to your profile privacy setting
• Leaderboards
• Share cards — the images and web pages generated when a badge is shared. Share cards are served from a public address and can be viewed by anyone holding the link, including people who have no Brewtanica account and are not signed in.

That last one is the reason this notice exists in the form it does: once published, a portrait badge is not a private ornament. If you would rather your likeness not reach a public surface, decline the sitting, keep the badge unpublished, or withdraw your consent afterward (Section 5.7) — the standard Malt Royalty badge takes its place and nothing further is displayed.

The portrait badge is stored at an address scoped to your account alone. It is never written to a shared badge image address, and it is never displayed as another user's badge.

5.7 Withdrawing Your Consent

You may withdraw your consent at any time, from the badge screen in the App, without giving a reason and without affecting anything else about your account.

When you withdraw:

• The finished portrait badge is deleted from storage.
• The standard Malt Royalty badge returns in its place, on every surface listed in Section 5.6.
• Any sitting photograph or study still in storage is deleted. In the ordinary case there is none, because it was already destroyed under Section 5.5.
• Your consent record is retained on the schedule in Section 5.5, marked as withdrawn.
• You may sit again later if you wish, subject to the re-sitting limit described in our Terms of Service.

Deleting your Brewtanica account also deletes your portrait badge. Unlike Catalog Contributions (Section 4.2), a portrait badge is never retained in de-identified form — a portrait of your face cannot be de-identified, and we do not attempt it.

5.8 We Do Not Create a Faceprint

We want to be precise about this, because the distinction matters.

We do not create, collect, capture, store, or use a biometric identifier or biometric information. We do not generate a faceprint, face template, face embedding, or numerical representation of your facial geometry. We do not perform facial recognition. We do not compare your face to any other face, to any prior photograph of you, or to any database. Nothing produced in this feature can be used to identify you in another image, and nothing produced in it is used for identification, verification, or authentication of any kind.

What the feature does is narrower: it takes one photograph, reduces it to a greyscale study, and uses that study as an artistic reference so that a generated sculpture resembles you. The output is a picture. It is not a measurement of you.

The on-device face-landmark detection described in Section 5.1 is used only to coach your pose and to decide when the shutter may fire. It produces no record, is not transmitted, and is discarded when the sitting ends.

The safety screening in Section 5.4 is the one place we form a judgement from your face, and it is worth being exact about its limits. The screening asks whether the image shows a genuine photograph of a single adult, free of prohibited content, and returns approve, reject, or escalate. It does not measure your face, produce a template of it, estimate a numerical age, or record any characteristic of you. Its output is a verdict about whether the sitting may proceed, and that is all we keep.

Illinois, Texas, and Washington residents. Because reasonable people can differ about how photographs of faces should be characterized under state biometric-privacy laws — including the Illinois Biometric Information Privacy Act, the Texas Capture or Use of Biometric Identifier Act, and the Washington My Health My Data Act — we have built this feature to the standard those laws set even though we do not believe they apply to it. Specifically: we obtain your written consent before any capture; we tell you, in advance and in writing, the specific purpose of the collection and the length of time the data will be kept; we publish the retention and destruction schedule in Section 5.5; we destroy the underlying images on that schedule; and we never sell, lease, trade, or otherwise profit from them.

5.9 Eligibility

Portrait sittings are available only to subscribers who have reached Malt Royalty and who are of legal drinking age, consistent with the age requirements that govern all use of the App (Section 10). You may sit only for yourself. Our Terms of Service set out the full conditions, including the limit on re-sittings.

6. Data Security

We implement commercially reasonable administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, use, alteration, and disclosure. These measures include encryption of data in transit, encryption of data at rest, secure server infrastructure, and access controls.

However, no method of electronic transmission or storage is completely secure. While we strive to protect your information, we cannot guarantee its absolute security. You are responsible for maintaining the security of your account credentials.

7. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information:

7.1 Access and Portability. You may request a copy of the personal information we hold about you in a structured, commonly used, and machine-readable format. A data export is also offered to you as part of the account deletion flow.

7.2 Correction. You may request that we correct inaccurate or incomplete personal information. You can also update much of your information directly through your account settings.

7.3 Deletion. You may request that we delete your personal information, subject to the exceptions described in Section 4. You can delete your account through the App settings, or by contacting us at privacy@brewtanica.com.

7.4 Opt-Out of Sale/Sharing. We do not sell your personal information and we do not share it for cross-context behavioral advertising. If our practices change, we will provide a clear mechanism to opt out in compliance with applicable law.

7.5 Location Data. You may disable location services for the App through your device settings at any time. Note that disabling location services may limit certain features.

7.6 Push Notifications. You may manage or disable push notifications through your device settings.

7.7 Website Advertising Preferences. If you visit brewtanica.com, you may manage advertising cookies as described in Section 13. These controls relate to the Site only. Advertising in the App is described in "Advertising in the App" above.

7.8 Non-Discrimination. We will not discriminate against you for exercising any of your privacy rights.

To exercise any of these rights, please contact us at privacy@brewtanica.com. We will respond to your request within the timeframe required by applicable law (typically within 30 to 45 days).

8. Apple App Tracking Transparency

The App does not track you across other companies' apps and websites. Because we do not engage in tracking as defined by Apple's App Tracking Transparency (ATT) framework, the App does not present an ATT permission prompt, and we do not access or use your device's advertising identifier (IDFA).

If we introduce tracking, including personalized advertising, into the App in the future, we will request your permission through the ATT framework before doing so, and we will update this Privacy Policy accordingly.

9. Google Play Data Safety

In compliance with Google Play's Data Safety requirements, we disclose the following:

• Data collected: Account information, location, app activity (scans, ratings, check-ins), photographs, device identifiers, and usage data. Photographs include, for users who opt in to a Malt Royalty portrait sitting, one photograph of the user's own face, collected and destroyed as described in Section 5.

• Data shared: Data is shared only with the service providers and sub-processors identified in Section 3.2, and with venue and brewery partners in aggregated, de-identified form. No data is shared with data brokers. No data is shared with advertising networks while in-app advertising is inactive; see "Advertising in the App" above.

• Data handling practices: Data is encrypted in transit and at rest; you may request data deletion through the App or by contacting us; data is used for app functionality, analytics, and personalization. Data is not used for personalized advertising or for the creation of advertising profiles.

10. Children's Privacy and Age Restrictions

The Services are intended solely for individuals who are of legal drinking age in their jurisdiction of residence. In the United States this is 21 years of age; in other jurisdictions the applicable minimum age governs. We do not knowingly collect personal information from anyone below the legal drinking age in their jurisdiction. If we become aware that we have inadvertently collected such information, we will take steps to delete it as soon as practicable.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at privacy@brewtanica.com.

11. International Data Transfers

Your information may be transferred to, stored, and processed in the United States or other countries where our service providers operate. These countries may have data protection laws that differ from the laws of your jurisdiction. By using the Services, you consent to such transfers. Where required by applicable law, we will implement appropriate safeguards (such as Standard Contractual Clauses) to protect your information during international transfers.

12. Third-Party Links and Services

The Services may contain links to third-party websites, services, or applications that are not operated by us, including brewery purchase links and mapping applications. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you access through the Services.

13. Website, Cookies, and Online Advertising

This section applies exclusively to your use of the Site at brewtanica.com. None of the practices described in this section occur in the Brewtanica mobile application.

13.1 Cookies and Similar Technologies. The Site uses cookies, local storage, and similar technologies to operate core features (such as remembering that you have completed age verification), to understand how visitors use the Site (analytics), and to support advertising as described below. You can control or delete cookies through your browser settings; disabling cookies may limit certain Site features, and you may be asked to complete age verification again.

13.2 Analytics. We use analytics providers (such as PostHog) to collect information about how visitors interact with the Site, including pages viewed, referring pages, approximate location derived from IP address, and device and browser characteristics. This information helps us improve the Site and is used in aggregate form.

13.3 Third-Party Advertising (Google AdSense) — Site Only. We use Google AdSense to display advertisements on the Site. Google and its partners are third-party vendors that use cookies to serve ads based on your prior visits to the Site and to other websites on the Internet. Specifically:

• Google's use of advertising cookies enables it and its partners to serve ads to you based on your visits to the Site and/or other sites on the Internet.

• You may opt out of personalized advertising by visiting Google's Ads Settings (https://www.google.com/settings/ads).

• You may opt out of some (but not all) third-party vendors' use of cookies for personalized advertising by visiting www.aboutads.info/choices.

• Third-party vendors and ad networks other than Google may also serve ads on the Site; where they do, their cookies are governed by their own privacy policies.

13.4 Consent in the EEA/UK. Where required by applicable law (including in the European Economic Area and United Kingdom), we will request your consent before setting non-essential cookies, including advertising cookies, and ads served to you may be non-personalized unless you consent.

13.5 Do Not Track. Some browsers offer a "Do Not Track" signal. The Site does not currently respond to Do Not Track signals, but the opt-out mechanisms described above remain available to you.

13.6 No Linkage to Your App Account. We do not link Site advertising cookies or ad-derived identifiers to your Brewtanica account, and we do not use Site advertising data to personalize your experience in the App.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you through the Services or by other reasonable means and update the "Effective Date" at the top of this policy.

Switching on advertising in the App is a material change: we will update this policy before any advertising appears, provide notice in the App, and obtain any consent required by applicable law.

We encourage you to review this Privacy Policy periodically. Your continued use of the Services after any changes constitutes your acceptance of the updated Privacy Policy.

15. California-Specific Disclosures (CCPA/CPRA)

If you are a California resident, you have the following additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

• Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you, the sources of collection, the business purposes, and the categories of third parties with whom we have shared your data.

• Right to Delete: You may request deletion of your personal information, subject to the exceptions set out in California Civil Code § 1798.105(d). As described in Section 4.2, de-identified Catalog Contributions are retained after deletion; because they no longer identify you, they fall outside the scope of the deletion right.

• Right to Correct: You may request correction of inaccurate personal information.

• Right to Opt Out of Sale/Sharing: We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising. The App does not display advertising as of the effective date, and any advertising we switch on will be non-personalized unless you give permission. Advertising on the Site is described in Section 13 and is governed by the opt-out mechanisms set out there.

• Right to Limit Use of Sensitive Information: Your date of birth is collected solely for age verification purposes and is not used for profiling. We do not process biometric information for the purpose of uniquely identifying you, and we therefore do not collect that category of sensitive personal information. A photograph submitted for a portrait badge is used only to generate that badge and to screen it for safety, is destroyed on the schedule published in Section 5.5, and is never used to identify you or to build a profile of you. The safety screening described in Section 5.4 forms a single judgement — whether the image shows an adult and is free of prohibited content — solely to decide whether the sitting may proceed; no characteristic of you is recorded from it. We do not use or disclose sensitive personal information for any purpose beyond those permitted by California Civil Code § 1798.121(a).

To submit a request, contact us at privacy@brewtanica.com. We may need to verify your identity before processing your request. You may also designate an authorized agent to make a request on your behalf.

16. European Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR) and similar laws, including the right to access, rectification, erasure, data portability, restriction of processing, and the right to object. Our legal bases for processing include performance of a contract, legitimate interests, consent, and legal obligations.

Where you opt in to a Malt Royalty portrait sitting, our legal basis for processing the photograph is your explicit consent, which you may withdraw at any time as described in Section 5.7. Withdrawal does not affect the lawfulness of processing carried out before it. We do not process the photograph to uniquely identify you, and so do not treat it as biometric data within the meaning of Article 9(1); we nonetheless rely on explicit consent under Article 9(2)(a) as an additional safeguard. The photograph is not subject to the Catalog Contribution retention described in Section 4.2 and is erased in full.

The right to erasure is subject to the limitations described in Section 4.2. De-identified Catalog Contributions are retained after an erasure request in reliance on Article 17(3) and Recital 26 of the GDPR. All information that identifies you is erased.

You also have the right to lodge a complaint with a supervisory authority in your jurisdiction. To exercise your rights, contact us at privacy@brewtanica.com.

17. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Brewtanica LLC

Privacy Inquiries: privacy@brewtanica.com

General Inquiries: legal@brewtanica.com

Website: https://www.brewtanica.com

Your privacy matters to us. Thank you for trusting Brewtanica with your information.