Data protection
Last updated: 21 September 2025
1. Introduction
Winebutler.info is operated by GAPAS AG, a Swiss company.
We are committed to protecting your privacy and processing your personal data in compliance with the Swiss Federal Data Protection Act (nDSG) and the European General Data Protection Regulation (GDPR).
This policy explains what data we collect, how we use it, and what rights you have.
2. Controller and Contact Details
The controller of your personal data is GAPAS AG, Rainweg 4b, 6313 Menzingen, Switzerland.
Data Protection Officer: Stefan Gabriel.
Email: contact@winebutler.info.
3. Scope of this Policy
This policy applies to the marketing website (winebutler.info), the web application (app.winebutler.info / login.winebutler.info), and the partner program (sponsors and affiliates).
It applies to all users worldwide.
4. Categories of Personal Data We Collect
Marketing website forms: user contact form: name, first name, email (mandatory), message, IP address, checkbox for consent.
Partner form: company, website, logo, name, email, phone (optional), message, IP address, checkbox for consent.
Authentication and account management (Auth0 EU): email (mandatory), password hash, name (optional), managed by Auth0 (data hosted in the EU).
Winebutler Core (Q&A logs and OpenAI API): pseudonymous user identifier, question and answer text; processing of user questions is performed through the OpenAI API, which receives the text of the question and returns an answer.
Data stored for max. 12 months.
Technical data: server logs (IP addresses, timestamps, error logs, system performance) may be collected through internet service providers such as Amazon Web Services, Azure or Host Europe according to their own privacy policies.
5. Purposes and Legal Bases
We process data for the following purposes: provision of our services (contract necessity); security and fraud prevention (legitimate interest); quality assurance and service improvement (legitimate interest, limited storage); marketing and partner program (logos, sponsor messages; consent or legitimate interest).
We do not perform profiling or automated decision-making.
6. Use of Partner Data and Sponsorships
Partner logos, descriptions, and links are displayed publicly on our website.
Sponsorship messages are displayed at the end of Winebutler answers in sequential order (no targeting, no profiling).
7. Disclosure of Data to Third Parties
We do not sell your personal data.
Data is not shared with third parties except as required for service provision: Auth0 (authentication provider, EU data center) for login and account management; OpenAI (AI service provider, global) for interpreting questions and formulating answers via the API; hosting providers (for example Azure, AWS, Host Europe and Servicehoster) for technical operation; and service contractors for maintenance and support.
Where external services are used, we always choose privacy-friendly settings.
In particular, we opt out of providers using our data for their own product improvement or analytics purposes whenever possible.
8. International Data Transfers
Data is generally processed in Switzerland and the EU.
If data is transferred outside of Switzerland or the EU/EEA, we ensure adequate protection through adequacy decisions or standard contractual clauses (SCCs).
9. Data Retention
Q&A logs are stored for a maximum of 12 months.
This period is necessary to identify recurring quality issues and ensure long-term service improvements.
Contact form submissions are retained as long as necessary to respond, then deleted.
Partner data is stored for the duration of the partnership and statutory retention periods.
Server logs are typically retained for 30–90 days.
10. Data Subject Rights
You have the following rights under applicable law: access to your data; rectification of inaccurate data; deletion (right to be forgotten); restriction of processing; objection to processing; data portability; and withdrawal of consent at any time.
To exercise your rights, contact contact@winebutler.info.
We respond to requests regarding data subject rights without undue delay, and generally within 30 days.
11. Security Measures
We apply the principle of data minimization, host with data protection friendly service providers, use strict access control for authorized and authenticated staff only, and perform regular security updates and monitoring.
12. Cookies and Analytics
We do not use cookies or tracking technologies, except those technically necessary (for example, for Auth0 login).
The marketing website uses Koko Analytics, which does not track personal data.
13. Changes to this Policy
We may update this policy from time to time.
If we make significant changes to this policy, we will actively notify registered users by email at least 30 days before the changes take effect.
The latest version is always available on winebutler.info.
14. Supervisory Authority and Complaints
If you have concerns about how we process your personal data, please contact us first at contact@winebutler.info so we can address the matter directly.
You also have the right to lodge a complaint with a supervisory authority: in Switzerland, the Federal Data Protection and Information Commissioner (FDPIC); in the EU/EEA, your local data protection authority.