Privacy Policy

1Information We Collect

The information we collect depends on how you use OINOS.

Account information

When you create or maintain an account, we may collect information such as your name, email address, account identifier and authentication information necessary to provide and secure your account.

Learning information

When you use the learning platform, we may collect information such as completed lessons, bookmarks, notes, flashcard activity, spaced-repetition progress, quiz results, practice and mock-examination results, written answers and other learning activity or preferences.

This information allows OINOS to remember where you are in your studies and provide the learning features available through your account.

Photographs

If you choose to add them, we collect a profile photograph and photographs of wine labels that you attach to your tasting notes. Photographs are optional: they are collected only when you add them yourself, and you can delete them at any time.

Location of a tasting

If you choose to add it to a tasting note, we record an approximate location. It is never collected in the background, precise location is not collected, and you can remove it from a note at any time.

Technical information

When you access OINOS, our systems may process technical information such as IP address, device type, browser type, operating system, access times, requested pages or resources and technical or security logs.

We use this information where necessary to operate, maintain and secure the platform, diagnose problems and prevent misuse.

Communications

If you contact OINOS, we may process the information contained in your communication together with your contact details and any information necessary to respond to your request.

Purchase information

Payments are processed by our payment provider through its secure payment infrastructure. Complete payment-card credentials are not received or stored by OINOS.

We may retain information relating to the transaction itself, such as what was purchased, the amount and currency, transaction status, billing country, payment-provider identifiers and confirmations made during checkout, including acceptance of applicable terms and any request for immediate access to digital content.

Our payment provider may separately collect and process payment, billing, fraud-prevention and transaction information in accordance with its own privacy terms.

2Why We Use Your Information

We use personal information only where we have a reason to do so.

Depending on the circumstances and applicable law, this may include:

Providing OINOS and performing our contract with you

We process account, learning and purchase information where necessary to create and maintain your account, provide purchased content, save your progress, operate learning tools and provide the services you request.

Operating and protecting OINOS

We may process technical and security information where necessary for our legitimate interests in maintaining a reliable and secure platform, preventing misuse, diagnosing technical problems and protecting OINOS and its users.

Providing support and communicating with you

We use contact and account information to respond to enquiries, provide service communications and resolve account, access or payment issues.

Improving the service

We may use information about how OINOS functions and how its features are used to identify problems and improve the platform. Where possible and appropriate, we use aggregated or de-identified information for this purpose.

Complying with legal obligations

We may retain or process certain information where required for accounting, tax, consumer-protection, fraud-prevention or other legal obligations.

Consent

Where applicable law requires consent for a particular activity, we will ask for it before carrying out that activity. You may withdraw consent where the processing depends on consent.

We do not sell personal information and do not share personal information with third parties for their own advertising or cross-context behavioural advertising.

3Learning Data

Learning information is used to make OINOS useful as a continuing educational environment rather than a collection of isolated pages.

For example, learning data may allow OINOS to:

• —remember completed lessons and your position within a Volume;
• —maintain bookmarks and notes;
• —determine when flashcards are due for review;
• —display quiz and assessment results;
• —maintain practice and mock-examination history; and
• —operate other learning and revision features associated with your account.

Your individual learning history is not sold to third parties or provided to third parties for advertising.

4Cookies and Similar Technologies

OINOS currently uses technologies that are necessary to operate the platform, maintain sessions, keep accounts secure and remember limited interface or functional preferences.

We do not currently use advertising cookies or technologies designed to track you across unrelated websites for behavioural advertising.

Where applicable law requires consent for a non-essential cookie or similar technology, we will request that consent before using it.

If we introduce analytics, advertising or other non-essential tracking technologies in the future, we will update this Privacy Policy and implement any consent or choice mechanisms required by applicable law.

5Service Providers

We use a limited number of external providers to operate OINOS. They receive or process information only to the extent necessary for the relevant service, subject to applicable contractual, privacy and security requirements.

Hosting

Account information and learning data are hosted on infrastructure located in the European Union, in Copenhagen, Denmark, provided by Webdock.io ApS.

Payments

Stripe provides payment-processing services.

Payment-card details are submitted through Stripe's payment infrastructure rather than being stored by OINOS. Stripe provides us with information necessary to confirm and administer a transaction, such as payment status, transaction identifiers and related purchase information.

Stripe may process certain payment, billing, fraud-prevention and transaction information under its own legal obligations and privacy terms.

Email

We use Google Workspace to support transactional and service-related email, including email-address confirmation, password recovery, purchase confirmation and customer support communications.

Your email address and the content and technical information associated with those messages may therefore be processed through Google's infrastructure.

Automated marking of written answers

Where OINOS offers automated marking of a written practice or mock-examination answer, the answer text, relevant question and marking criteria may be sent to Anthropic through its commercial services for automated analysis.

OINOS is designed not to include your name, email address or OINOS account identifier in the material submitted for automated marking.

However, if you include personal information yourself within the text of an answer, that information may form part of the material submitted for marking. We therefore ask that you do not include names, contact details or other unnecessary personal information in written practice answers.

The resulting assessment or feedback may be returned to OINOS and associated with your account so that it can be displayed as part of your learning activity.

We do not permit our service providers to use OINOS user information for their own advertising.

6International Data Transfers

Our principal account and learning data are hosted in the European Union.

Some of the service providers used by OINOS operate internationally and may process information in countries outside the European Economic Area or the country in which you live.

Where personal information is transferred internationally and applicable data-protection law requires safeguards, we or the relevant provider use recognised transfer mechanisms, which may include adequacy decisions, approved standard contractual clauses or other legally recognised safeguards.

7Data Retention

We keep personal information only for as long as reasonably necessary for the purposes for which it was collected, including applicable legal, accounting and security requirements.

In practice:

Account and learning history

Account information and learning history are generally retained while your account remains active so that your progress, flashcard intervals, notes and other learning information remain available when you return.

If an account remains inactive for 24 months, we may delete the account and associated learning history. Where reasonably practicable, we will contact the email address associated with the account before doing so.

Purchase and accounting records

Information that we are required to retain for accounting, tax, fraud-prevention or legal purposes may be retained for up to 7 years, or for another period required by applicable law.

These records may be retained even if the associated OINOS account is deleted and will be limited to information reasonably necessary for those purposes.

Technical and security logs

Technical and security logs may be retained for up to 12 months, after which they are deleted or aggregated or de-identified where appropriate.

Communications

Support and other communications may be retained for as long as reasonably necessary to resolve the relevant matter and maintain appropriate business records.

Transactional system messages may be retained for a limited period necessary for operational, security, consumer-protection and record-keeping purposes.

When you request deletion of your account, we will delete or de-identify account and learning information unless retention is required or permitted for a legitimate legal, security or record-keeping purpose.

8Security

We use reasonable technical and organisational measures designed to protect personal information against unauthorised access, disclosure, alteration, loss or misuse.

These measures may include access controls, secure authentication, encrypted communications, restricted administrative access, system monitoring and appropriate safeguards with service providers.

No method of transmitting or storing information online can guarantee absolute security.

You are also responsible for keeping your account credentials confidential and should contact us if you believe your account has been accessed without authorisation.

9Your Privacy Rights

Depending on where you live and the laws that apply to you, you may have rights concerning your personal information.

These may include the right to:

• —access personal information we hold about you;
• —correct inaccurate or incomplete information;
• —request deletion of personal information;
• —request restriction of certain processing;
• —object to certain processing;
• —receive certain information in a portable format;
• —withdraw consent where processing is based on consent; and
• —lodge a complaint with an appropriate data-protection authority.

Some rights are subject to legal conditions or exceptions and may not apply in every circumstance.

We will not discriminate against you for exercising privacy rights provided by applicable law.

You may exercise available privacy rights through account-management tools where provided or by contacting support@eidoscollective.com.

We may need to verify your identity before completing certain requests in order to protect your information.

If you are in the European Economic Area or United Kingdom, you also have the right to lodge a complaint with the data-protection authority responsible for your country or region.

10Account Deletion

You may request deletion of your OINOS account and associated personal information.

Deleting an account will normally remove the account and associated learning history from active OINOS systems, subject to reasonable technical processing periods and any information we are legally required or permitted to retain.

Certain purchase records, security information or other records may be retained where necessary to comply with law, prevent fraud, resolve disputes or establish, exercise or defend legal claims.

Deletion of an account does not necessarily require our independent service providers to delete information they process for their own lawful purposes, such as records a payment provider is legally required to retain.

11Age and Alcohol-Related Content

OINOS is an educational and editorial platform concerning wine and alcoholic beverages.

OINOS accounts are intended for people aged 21 or over.

By creating an account, you confirm that you are at least 21 years old. You should use OINOS only where accessing this type of content is lawful in the place where you live.

OINOS is not directed at children, and we do not knowingly collect personal information through OINOS accounts from anyone under 21.

If we become aware that an account has been created by someone under 21, we may close the account and delete the associated information, subject to any information we are legally required to retain.

12United States Privacy Rights

Residents of certain US states may have additional privacy rights under applicable state law.

Depending on the law that applies, these may include rights to access, correct or delete personal information and to obtain information about how personal information is collected, used or disclosed.

OINOS does not sell personal information or use it for cross-context behavioural advertising.

Where a state privacy law applies to OINOS, we will honour the rights and protections required by that law.

Requests may be submitted to support@eidoscollective.com. We may take reasonable steps to verify your identity before responding.

13Changes to This Privacy Policy

We may update this Privacy Policy as OINOS develops or where our services, technology, legal obligations or service providers change.

The current version will be published on this page together with its revision date.

If we make a material change to the way we use personal information, we will provide additional notice where required by applicable law.

14Contact

For questions about this Privacy Policy or to exercise your data-protection rights, contact:

support@eidoscollective.com · EidosCollective LLC · 30 N Gould St, Ste N, Sheridan, Wyoming 82801, USA