Privacy Policy

1. Who we are

We operate the Platform, a tool that lets members keep track of their cask portfolio. This policy explains what we do with personal information when you use it.

2. What we collect

2.1 Your account

1. Your name and email address;
2. Your password, stored only as a cryptographic hash and never in readable form;
3. If you enable two-factor authentication, your authenticator secret and your backup codes stored as hashes. We cannot read your backup codes, which is why we cannot recover them for you;
4. An optional profile photograph, if you upload one;
5. Your notification and display preferences;
6. Your account status.

We do not collect your date of birth, home address, identity-document details, bank details or payment card details through the Platform. If those are held anywhere, they were collected elsewhere and this policy does not cover that collection.

2.2 Your portfolio

Information about the casks recorded against your portfolio: distillery, liquid, volumes and strengths, dates, purchase costs and terms, valuations, insurance and warehousing arrangements, regauges, samples, movements between warehouses, and documents uploaded against a cask together with any notes on them.

For members whose portfolio is their own, this is financial information about you.

2.3 Security and sign-in

1. Every sign-in attempt: the email address used, the network (IP) address it came from, whether it succeeded, and when. We record failed attempts as well as successful ones, in order to detect attacks on accounts;
2. Each session: the network address and browser you signed in from, when it started, when it was last active, and when and why it ended;
3. Password-reset requests.

2.4 Activity and audit records

We keep two kinds of record of what happens in the Platform:

1. Technical records, for diagnosing faults: which page was requested, by whom, how long it took, and any error and its technical detail;
2. Audit records, for accountability: who changed which record, when, the values before and after the change, any reason given, and the network address and browser used.

2.5 People who open a Share Link

If a member creates a Share Link, we record each time it is opened: the viewer's network address, browser details, the page they came from, and the time. We show that activity to the member who created the link. We determine the approximate country of a viewer's network address using a database held on our own systems; the address is not sent to anyone else for this.

If you have opened a Share Link that was sent to you, this is what we record about it, and the person who sent you the link can see it.

2.6 Cookies

We use a session cookie to keep you signed in. It is necessary for the Platform to work and cannot be turned off while you use it. We do not use advertising or analytics cookies in the Platform.

3. Where the information comes from

1. From you: what you enter and upload;
2. From administrators: much of the portfolio information is entered on your behalf, from warehouse records, insurance documents, valuations and purchase paperwork;
3. Automatically: the security, session, activity and audit records described above are generated as you use the Platform.

4. Why we use it, and on what basis

Giving you access to your portfolio — performance of our contract with you.

Authenticating you and securing your account — performance of our contract; our legitimate interest in protecting accounts.

Detecting and investigating misuse and attacks — our legitimate interest in the security of the Platform and of other members.

Keeping audit records of changes — our legitimate interest in accountability; our record-keeping obligations.

Sending notifications you have enabled — performance of our contract; your preferences.

Recording your acceptance of our terms and this policy — compliance with our legal obligations.

Diagnosing and fixing faults — our legitimate interest in operating the Platform.

5. Who can see it

Other members. This depends on how your group is set up. In one arrangement the Individual whole portfolio and all its users can see all of it; in the other, each member sees only their own casks and their own data. The separation between groups, and between individual portfolios, is enforced by the database itself, not only by the application.

Administrators of your group. Staff with an administrator role can see the portfolios and accounts within that group, and act on them.

Platform administrators. A small number of people who operate the Platform hold a platform-level account that can reach data across all groups. This access exists so the Platform can be supported, maintained and repaired. Their actions are written to the audit records.

People you share with. Anyone you give a Share Link to can see the parts of the cask record you selected, for as long as the link is live.

We do not sell personal information, and we do not share it for marketing.

6. Who processes it for us

Microsoft Azure - hosting. All Platform data is stored on Azure infrastructure.

Our email provider (MS 365) - the address and content of emails the Platform sends you. Their credentials are held encrypted.

Google Fonts - the Platform's typefaces are served from Google. Each time you load a page, your network address, browser details and the page you are on are sent to Google in order to fetch them. This happens before you sign in, including on the sign-in page itself.

We may also disclose information where we are required to by law, or to establish or defend legal claims.

7. Where it is stored

Platform data is stored in Microsoft Azure's UAE North region. Backups are held in the same region, in three independent layers.

8. How long we keep it

1. Your account and portfolio records - while your account is open, and after it closes for defined period.
2. Sign-in attempt records - 30 days.
3. Session records - [not currently purged].
4. Technical activity records - currently retained indefinitely.
5. Audit records - retained indefinitely, see below.
6. Records of your acceptance of these documents - for as long as we may need to evidence it.

About our audit records. They are held in a form that cannot be changed or deleted, including by us. That is deliberate: a record of who changed what is worth nothing if it can be edited afterwards. The consequence is that audit records cannot be erased on request, and they survive the closure of your account.

9. Your rights

Subject to the law that applies, you can ask us to:

1. Give you a copy of the personal information we hold about you;
2. Correct information that is wrong;
3. Delete information, within the limits described below;
4. Restrict or object to certain uses;
5. Withdraw consent, where we relied on it.

To make a request, contact us at legal@caspoma.com.

The honest limits on deletion. We want to be clear about what we can and cannot do:

1. Closing your account does not erase it. Your account record is marked as closed and retained, so that the history of the portfolio remains intelligible and our audit records continue to make sense.
2. Audit records cannot be deleted at all, for the reason given in section 8.
3. Portfolio records may need to be retained to meet legal, tax and record-keeping obligations, and where another member's records depend on them.

If you ask us to delete information and we cannot, we will tell you what we have kept and why.

10. How we protect it

1. Passwords are stored as hashes, never in readable form;
2. Two-factor authentication will be available soon, with single-use backup codes stored as hashes;
3. Session identifiers are stored only as hashes, so a copy of our database would not expose live sessions;
4. Separation between groups, and between individual portfolios, is enforced in the database;
5. Repeated failed sign-ins are detected and throttled;
6. Credentials for our email provider are encrypted at rest;
7. You can see and end your own active sessions;
8. Changes to records are written to audit records that cannot be altered.

No system is completely secure, and we cannot guarantee the security of information transmitted to us.

11. If something goes wrong

If personal information is lost or disclosed in a way that is likely to harm you, we will tell you and the relevant authority as required by the law that applies to us, and explain what happened and what we are doing about it.

12. Children

The Platform is for members only, and membership is open to adults over the age of 21. It is not directed at children and we do not knowingly collect information about them.

13. Changes

This policy is versioned. Each published version carries a version number and an effective date, and every previous version remains permanently readable at its own address. The version in force is the one shown at [PRIVACY URL].

We will tell you about a significant change by email or a notice in the Platform.

14. Contact and complaints

Questions about this policy, or to exercise a right: legal@caspoma.com

If you are unhappy with how we have handled your information, please tell us first.