Privacy Policy

Last updated: 11 May 2026 · Effective: 14 June 2026

Note: Yellow placeholders will be replaced before public launch with the registered Maltese company details, effective date, and final email addresses. This is the lawyer-reviewed final draft pending Maltese counsel sign-off.

1. Who we are

BottleBuddy is operated by [LEGAL ENTITY NAME], a company incorporated in Malta with company registration number [MALTA COMPANY REGISTRATION NUMBER] and registered address at [REGISTERED ADDRESS] ("BottleBuddy", "we", "us", or "our").

Contact: support@bottlebuddy.eu. Privacy contact: privacy@bottlebuddy.eu. Legal/DSA contact: legal@bottlebuddy.eu.

BottleBuddy provides a peer-to-peer mobile marketplace that helps people who have refundable deposit bottles ("Providers") connect with people willing to collect those bottles and redeem the deposit value themselves ("Collectors").

2. Scope of this Privacy Policy

This Privacy Policy explains how we collect, use, disclose, store, and protect personal data when you use the BottleBuddy mobile application, website, APIs, support channels, and related services.

This policy applies to users in the European Union and European Economic Area, including Malta. It is intended to satisfy transparency obligations under the GDPR and related Maltese data-protection law.

3. Personal data we collect

3.1 Data you provide directly

CategoryExamplesPurpose
Account dataEmail address, password hash, display name, profile photo, role preferenceAccount creation, authentication, profile operation, trust and safety
Location/listing dataCity, country, listing title, description, bottle counts, photos, pickup address, pickup notesCreating and displaying listings, matching users, coordinating pickups
CommunicationsPickup requests, chat messages, support messages, abuse reportsCoordinating pickups, support, moderation, dispute handling
Ratings/reviewsStar ratings, comments, rating count, average ratingTrust and reputation system
Subscription/payment metadataPlan, status, purchase channel, renewal/cancellation status, Stripe/customer IDs or app-store transaction referencesAdministering paid features, invoices, fraud prevention, legal compliance

3.2 Data collected automatically

CategoryExamplesPurpose
Device/app dataDevice platform, OS version, app version, crash logsSecurity, diagnostics, debugging, service improvement
Approximate locationGPS or device location when permission is grantedShowing nearby listings and map functionality
Usage eventsListing posted, pickup requested, pickup completed, account settings changedService operation, analytics, fraud prevention, feature improvement
Security dataIP address, login/session metadata, abuse signals, rate-limit dataSecurity, fraud prevention, account protection, enforcement

We do not intentionally collect contacts, microphone audio, browsing history, advertising IDs, or sensitive special-category data unless you voluntarily include such information in messages or uploaded content. Please do not upload or send unnecessary personal or sensitive information.

4. Exact pickup-address handling

Exact pickup addresses are sensitive. BottleBuddy is designed so that exact pickup information is not publicly visible.

5. Legal bases for processing

Legal basisProcessing purposes
Contract performance — GDPR Art. 6(1)(b)Creating and managing accounts, listings, pickup requests, chat, ratings, subscriptions, and support requests.
Consent — GDPR Art. 6(1)(a)Optional device location, optional push notifications, optional marketing communications, and optional permissions where required.
Legitimate interests — GDPR Art. 6(1)(f)Fraud prevention, platform safety, moderation, security logging, abuse prevention, service improvement, enforcing terms, and handling disputes.
Legal obligation — GDPR Art. 6(1)(c)Tax, accounting, legal compliance, regulatory requests, and legally required recordkeeping.

6. How we use personal data

7. Sharing and service providers

We do not sell personal data. We do not use third-party advertising trackers. We share personal data only where necessary for the service, legal compliance, safety, or support.

Recipient / providerPurposeLocation / safeguards
SupabaseDatabase, authentication, storage, backend infrastructureEU-West-1 (Ireland); DPA in place
StripePayment and subscription processing for web purchasesEU primary; may involve non-EEA processing under SCCs and Stripe DPA
Apple App StoreApp distribution, in-app purchases, diagnostics, subscription managementApple may process globally under its terms
Google PlayApp distribution, in-app purchases, diagnostics, subscription managementGoogle may process globally under its terms
OpenStreetMap NominatimAddress autocomplete and geocodingEU-hosted; queries do not include user identifiers
SentryCrash reporting and error monitoringEU host (sentry.io EU region); PII scrubbed before send
PostHogProduct analytics (event names + anonymous device IDs after sign-in: auth user ID only — no email, no chat content)EU cloud (eu.i.posthog.com)
CloudflareEmail routing (forwarding only — no message storage at Cloudflare beyond transit)EU presence; SCCs in place
Expo Push (APNs / FCM)Push notification deliveryApple / Google global infrastructure under their respective DPAs

8. Public visibility inside BottleBuddy

Other authenticated users may see your display name, avatar, approximate location, role, ratings, rating count, and listing information. Exact address, email address, private chat content, payment details, and support communications are not publicly visible.

9. International transfers

BottleBuddy uses EEA-based hosting for core app data. Some service providers — app stores, payment providers, diagnostics providers — may process limited personal data outside the EEA. Where required, we rely on appropriate safeguards such as adequacy decisions, Standard Contractual Clauses, data-processing agreements, and supplementary technical and organisational measures.

10. Retention

Data typeRetention
Account/profile dataUntil account deletion or closure, unless longer retention is required by law or for legitimate safety/fraud reasons.
ListingsNormally up to 90 days after expiry, cancellation, or completion.
Pickup records and ratingsNormally up to 24 months for trust, safety, and dispute handling.
Chat messagesNormally up to 90 days after pickup completion, unless needed for safety, dispute, or legal purposes.
Audit / security logs180 days (private.audit_log), then automatically deleted by scheduled job. Critical events are mirrored to Sentry for the standard Sentry retention.
Server/security logsNormally up to 30 days, unless needed for abuse prevention, security, or legal purposes.
Payment, invoice, tax, and subscription records10 years (Malta Companies Act and Income Tax Management Act), or longer/shorter as required by applicable law.

11. Your rights

Subject to applicable law and verification of your identity, you may request access, correction, deletion, restriction, portability, objection to legitimate-interest processing, withdrawal of consent, and information about safeguards for international transfers. You also have the right to lodge a complaint with your local supervisory authority, including the Malta Office of the Information and Data Protection Commissioner.

Send requests to privacy@bottlebuddy.eu. We aim to respond within one month unless an extension is permitted by law.

12. Account deletion

You may request deletion of your account through the app (Profile → Account → Delete account) or by contacting privacy@bottlebuddy.eu. Deletion is preceded by a 30-day grace period during which the account is soft-disabled but can be restored by signing in. After the grace period the underlying auth record is permanently removed and remaining content is anonymised. Information that must be retained for legal, accounting, fraud-prevention, dispute, or security purposes may be restricted or anonymised in place where deletion is not possible.

13. Children

BottleBuddy is not intended for children under 16 unless applicable local law permits a lower age and BottleBuddy has implemented the required safeguards. If we learn that a child has unlawfully created an account, we may delete the account and related data.

14. Security

No online service is completely secure. You should use a strong unique password (minimum 8 characters in BottleBuddy) and notify us promptly if you suspect unauthorised access.

15. Photos, avatars, and uploaded content

Photos, avatars, listing descriptions, and other uploaded content may be visible to other users depending on the feature. Listing and avatar images are stored in public buckets — anyone with the direct URL can view them, though enumeration is blocked. Photos uploaded through the app are compressed and stripped of EXIF metadata (including precise GPS coordinates from your phone's camera) before upload. Do not upload content that includes unnecessary personal information, other people without appropriate consent, or anything you do not want visible to other users.

16. Changes to this policy

We may update this Privacy Policy. If changes are material, we will provide reasonable notice, such as by email, in-app notice, or website notice. Where required by law, we will request fresh consent.

17. Contact

[LEGAL ENTITY NAME]
[REGISTERED ADDRESS]
Company number: [MALTA COMPANY REGISTRATION NUMBER]
Support: support@bottlebuddy.eu
Privacy: privacy@bottlebuddy.eu
Legal/DSA: legal@bottlebuddy.eu