Privacy Policy

Who is responsible

PERSOM LIMITED, a company incorporated in Hong Kong, is responsible for the personal information it handles to operate PERSOM and persom.wine. We act as the data user under Hong Kong privacy law and as a controller where applicable data-protection law uses that term.

Our registered office is Suite C, Level 7, World Trust Tower, 50 Stanley Street, Central, Hong Kong. For privacy questions, access or correction requests, or deletion assistance, contact privacy@persom.wine.

What this policy covers

This policy covers our website, correspondence and our handling of enquiries through PERSOM’s social accounts. It also explains the intended data uses of the PERSOM iOS app, which is in development. App-specific processing and choices will be explained before you submit information through a test or released version.

Instagram, TikTok and Apple operate their own services under their own privacy policies. This policy covers what PERSOM does with information it receives; it does not replace their policies.

Visiting the website

You can read the website without creating an account or uploading photographs. The website has no subscription checkout, mailing-list signup or embedded Instagram or TikTok feed. Its contact links open your email application.

Cloudflare delivers and protects the website. Handling a page request involves technical information such as your IP address, requested address, request time and browser information. Security and diagnostic processing helps deliver pages, detect abuse and investigate faults. These functions are separate from the optional analytics described below.

Our images and fonts are served with the website. Instagram and TikTok links take you to those platforms only when you choose to open them; they are not embedded feeds.

Cookies, storage and optional analytics

Optional website measurement is off until you accept it. If you accept, Cloudflare Web Analytics measures visits and page performance to help us improve the website. Its reports can include pages viewed, referring sites, device and browser categories and loading measurements. Cloudflare describes this analytics service as operating without analytics cookies or local-storage identifiers and without tracking individuals across its customers’ websites.

Our own preference cookie, persom_privacy, records whether you accepted or rejected optional analytics and the version of that choice. It contains no account identifier and is set for 180 days. It is used to remember your privacy choice on this website. Your browser may delete it earlier; you can also clear it yourself. If preferences cannot be saved, analytics remains off.

Use “Privacy choices” in the footer to accept, reject or change your selection. Rejecting analytics does not prevent access to the website or support. Withdrawing an accepted choice reloads the page to stop analytics running in that page. Withdrawal does not undo information already sent while consent was active. If JavaScript is disabled, optional analytics stays off.

Cloudflare may use security cookies when a protection feature or challenge requires them. These are distinct from optional measurement. Browser caching may also retain page assets to load them more efficiently. You can manage cookies and cached files in your browser, although blocking security functionality may affect access.

We do not add advertising pixels or social-media tracking tools to these pages. A browser’s Do Not Track signal does not change the controls described here; optional analytics still requires your affirmative choice. We honour an enabled Global Privacy Control signal by keeping optional analytics off.

Contacting PERSOM

If you email us, we receive your email address, any name supplied, the message, attachments and associated correspondence information. A social-media enquiry can include your handle, profile information visible to us and the messages you send. We use this information to answer the enquiry, provide requested assistance, investigate a reported problem and maintain a relevant correspondence record.

Contacting us is voluntary. We need a way to reply and enough detail to understand your request; other information and attachments are optional. Without those essentials we may be unable to help. Please avoid sending passwords, payment-card details, identity documents or photographs containing unrelated people or private information.

Our persom.wine mailboxes use Namecheap Private Email to receive, store and send correspondence. Enquiries sent through Instagram or TikTok also pass through that platform’s messaging service. Where necessary to resolve your request, relevant details may be shared with a technical service provider or professional adviser. We may also disclose information when legally required or necessary to establish, exercise or defend legal claims. We do not add support enquiries to a marketing mailing list.

Namecheap’s Private Email terms, section 3 state that it may use AI security tools, including OpenAI Moderation, to scan limited portions of email content for spam, phishing or harmful activity. This provider security processing is separate from its optional AI writing assistant; disabling that assistant does not establish that security screening is disabled. The same terms describe no model training from moderation data and an exception for abuse-monitoring logs kept for up to 30 days. These are Namecheap’s stated arrangements, not a guarantee that every email or service record has that retention period.

Photographs and Wine Cards in the app

PERSOM uses the bottle photos you submit to identify wines and create Wine Card imagery. In the current development version, Apple’s on-device image-processing tools isolate the bottle and render a processed portrait. That local portrait-making step is separate from external wine recognition.

The original photograph, a version prepared for processing, a processed bottle portrait and the wine information extracted from the image are different records. Photographs can contain incidental personal information, including visible people, surroundings or embedded metadata. Image processing does not by itself make that information anonymous.

The app is also designed to use submitted wine-list and dish images or text to understand the wines and meal you want to explore. Submit only material you are entitled to use, and avoid including unrelated personal information.

The development version uses OpenAI for external recognition and recommendation functions. Depending on the task, prepared images, text recognised from them, your submitted text and relevant wine or meal context can pass through PERSOM’s processing service to OpenAI. On-device text recognition does not mean that photographs always stay on your device. The separate generation of wine-style illustrations uses descriptive prompts, rather than editing your submitted bottle photograph.

Before external-AI features are made available to testers or customers, the app must identify the recipient, explain what information is sent and why, and request the permission required for sharing personal information with third-party AI. Camera or photo-library permission and this policy are not substitutes for that separate sharing permission. The notices for the version offered will explain its actual service configuration, relevant provider arrangements and available choices; this website does not certify that those app controls are already operational.

Permission to provide the requested service does not grant permission to publish your uploads, use them in advertising or add user-derived portraits to a shared catalogue. Any wider use requires a separate, appropriate permission and rights basis. See our Terms of Use.

Preferences, activity and subscriptions in the app

PERSOM is designed to use saved wines, wines recorded as drunk or tasted, ratings and confirmed meal context to personalise recommendations and maintain your wine history. Entering a dish for a search is different from confirming that you consumed it with a wine.

Account identifiers, where used, link the relevant records to the account. Subscription and entitlement information establish whether the applicable app features are available. The information required depends on the sign-in and subscription functions offered in the version you use.

App subscriptions are intended to be purchased through Apple’s App Store. PERSOM does not provide a website subscription checkout. Apple handles the payment credentials used for purchases through its service; subscription assistance does not require you to send those credentials to PERSOM.

Personalising your PERSOM experience is a different purpose from training a general-purpose AI model. The permission to process an image for your request is not a blanket permission for unrelated model training.

Keeping and deleting information

We use different retention rules for different records:

• Correspondence: we retain messages while an enquiry is open and for relevant follow-up. Continued retention depends on unresolved issues, a continuing service relationship, and whether a particular record is needed for a dispute or legal duty. Records that no longer serve those purposes should be deleted rather than kept simply because a mailbox has space.
• Email service backups: Namecheap’s Private Email terms, section 5 specify daily service backups retained for up to four weeks for restoration and internal purposes. This is the provider’s stated backup period, not a verified promise that deleting a message immediately removes every copy, log or preserved record. Account-specific deletion propagation remains under review.
• Website security and diagnostics: Cloudflare handles the technical records used to deliver and protect the site. We have not enabled automatic exports of request logs to a separate PERSOM archive. Cloudflare publishes a default of seven days for end-user activity logs where it stores them; this is a provider default, not a guarantee that every security record or derived report expires after seven days. Its separate operational retention criteria consider the processing purpose, data sensitivity, risks, whether less data would suffice and applicable legal requirements. See Cloudflare’s log-retention statement and privacy policy.
• Incident records held by PERSOM: if a security issue generates an investigation or correspondence record, we retain the relevant information while investigating, applying and checking a remedy, or addressing a related claim. Once those needs and any legal preservation requirement end, the record should be deleted or stripped of personal information that is no longer needed.
• Optional Web Analytics: Cloudflare makes the previous six months of reports available to us to compare visits and page performance. This is the documented reporting window, not a promise that all provider logs or backups are erased on that date. Separate provider security and operational records follow the criteria described above. Withdrawal stops future optional measurement as explained under “Cookies, storage and optional analytics”.
• Privacy preference: the persom_privacy cookie expires after 180 days unless you renew your choice or your browser removes it earlier.

These rules distinguish the records we hold from records managed within a provider’s service. A request to delete a message or withdraw analytics consent does not imply immediate erasure of every backup or a record subject to a legal preservation requirement. Contact privacy@persom.wine for help identifying the retention treatment of a particular record.

App uploads, processed portraits, extracted information, saved activity, caches, logs and backups require separate retention and deletion treatment. The current development version stores accepted bottle portraits on the device for reuse, and its processing service can retain recognition results and wine or meal information in caches. These can outlast the original search. A temporary task ending, or a tasting entry being removed, must not be understood to erase every derived portrait or cached record.

External AI providers’ retention is separate from PERSOM’s own storage. A request setting that disables storage of an AI response is not, by itself, proof of immediate deletion of all provider security records. The app’s data-handling notice will explain the storage, retention, account scope and deletion arrangements for the version offered before those features are used. We do not yet represent that the development version has a verified, complete deletion process across the device, service, providers and backups.

You can ask privacy@persom.wine for access, correction or deletion assistance and information about the records relating to you. Deleting an account, cancelling a subscription and removing the app are separate actions. See Support.

Your rights and choices

Depending on the law that applies, you may be entitled to access or correct your information, request deletion, restrict or object to particular processing, obtain a portable copy, or withdraw consent. These rights can have conditions and exceptions. Withdrawal does not affect processing that was lawful before consent was withdrawn.

Send your request to privacy@persom.wine, explaining what you need. We may ask for proportionate information to verify your identity and locate the relevant record. Please do not send identity-document scans unless a necessary, suitable verification process has been agreed. We will explain any applicable limitation or permitted charge and respond within the period required by the relevant law.

You may complain to the Hong Kong Privacy Commissioner for Personal Data, the UK Information Commissioner where relevant, or your competent European data-protection authority. Other local complaint rights remain available where they apply.

Legal grounds and international processing

Where EU or UK data-protection law applies, we use the following grounds for the website and correspondence processing described here:

• Delivering pages, diagnosing faults and preventing abuse: legitimate interests in keeping the website available, reliable and secure. This involves necessary technical request information; optional audience measurement has a separate consent basis.
• General enquiries and routine correspondence: legitimate interests in answering people who contact us and managing the resulting conversation. We use the information needed for that purpose and do not treat an enquiry as marketing consent.
• A service you request under a contract, or steps you ask us to take before entering one: contractual necessity, only for information and actions actually needed to fulfil that request. A general question does not automatically create this basis.
• Optional Cloudflare Web Analytics: your consent, which you can refuse or withdraw through “Privacy choices”.
• Remembering your privacy selection: legitimate interests in respecting your choice and avoiding repeated prompts, using the limited preference cookie described above.
• Responding to data-protection requests and other processing required by a legal duty applicable under EU or UK law: compliance with that legal obligation. Establishing, exercising or defending a legal claim relies on our legitimate interests in protecting our rights, where appropriate.

For legitimate-interests processing, we consider necessity, reasonable expectations and the effect on your rights. You can object by contacting privacy@persom.wine. We assess the objection and explain the outcome under the applicable law. These website grounds do not establish the grounds for every future app feature.

PERSOM LIMITED is established in Hong Kong and its director manages correspondence from Thailand. Our service providers also process information outside those countries:

• Cloudflare, Inc. provides website delivery, security and optional Web Analytics through its international network, including processing in the United States. Its Data Processing Addendum forms part of its standard service terms for processing on customers’ behalf. For eligible transfers to the United States, that addendum provides for Cloudflare’s Data Privacy Framework certification. For other restricted transfers covered by the addendum, it incorporates the EU Standard Contractual Clauses and, for UK-protected data, the UK International Data Transfer Addendum. Its subprocessor list describes supporting providers and locations.
• Namecheap, Inc. provides our Private Email service. Namecheap identifies its Private Email servers as located in Phoenix, United States. Its Data Processing Addendum is incorporated into its terms for Private Email and includes the EU Standard Contractual Clauses. The current UK-specific transfer documentation for this email service is under review; we do not represent that this point has been resolved.

You can read the linked contractual safeguards or request information and a copy of the safeguards relevant to your data from privacy@persom.wine, subject to proportionate redaction of confidential information. These arrangements do not mean all processing takes place in Hong Kong, or that every country has an adequacy decision. Contacting us or browsing the website is not blanket consent to an international transfer.

Security, age suitability and updates

The website is available over HTTPS. Please use the HTTPS address when visiting. No internet transmission or storage method can be guaranteed completely secure. If you identify a security concern, contact support@persom.wine without including passwords or other secrets.

PERSOM is intended for adults who may lawfully consume alcohol where they are. It is not directed at children. If you believe a child has supplied personal information, contact privacy@persom.wine so we can assess the circumstances and appropriate action.

We will update this policy when relevant practices change and identify when the revised policy takes effect. Material changes and any new permission requests will be presented in a way appropriate to the affected service.