Privacy Policy 

WiBES Privacy Policy

This policy is effective from November 18th, 2025.


Data controller

The Sustainable IT ApS (hereinafter "The Sustainable IT", "we", "our", "us") provides a platform that enables registered users (hereinafter "User", "you", "your") to see wine, beer, and soda information, make reviews, and ratings (hereinafter the "Services") via our mobile application WiBES. It also enables Users to follow other Users to see their ongoing reviews and connect with other Users from their social media accounts.

The Sustainable IT ApS is registered as a private limited company in Denmark under company registration number (CVR) 45086065. Our contact details are: Address: Gydebakken 7, 3520 Farum, Denmark Email: support@wibes.dk Contact: https://www.wibes.dk

This privacy policy (hereinafter "Privacy Policy") applies to all use of our website, www.wibes.dk, (hereinafter "Web"), and all uses of our applications for mobile devices (hereinafter "App"). The Web and the App are hereinafter collectively referred to as the "Platform". This Privacy Policy applies to your use of the Platform and our Services.

We will process your personal data in compliance with the General Data Protection Regulation (hereinafter "GDPR"). This Privacy Policy covers our processing of personal data collected when you register and access the Platform and use our Services.

The Sustainable IT ApS is the data controller of the personal data we collect from our Users in accordance with GDPR. This Privacy Policy describes how and when The Sustainable IT ApS collects, processes, discloses and shares your personal data when you use our Platform. If you have any questions or comments about this Privacy Policy, please contact us using one of the methods provided above.


User Relationship Management

We process your personal data to manage our user relationship with you, including managing your account, providing you with access to our Platform, and communicating with you regarding updates, policies, and updated terms and conditions.

As part of this activity, we process the following personal data:

  • Identification and contact information: name, email address, country of origin, username, and preferred language.

  • Information related to our relationship: including correspondence.

If you choose to register or sign in via a third-party application (Facebook, Apple, and Google), you authorize us to access and collect your name, profile picture, and (if you provide it) your email address.

The processing of your personal data is performed on the legal basis of:

  • Fulfilling our contractual obligations when delivering the Platform to you, cf. Article 6(1)(b) of the GDPR (processing necessary for the performance of a contract).

Your personal data is stored for as long as your account is active. Upon deletion of your profile, the identification and contact information will be stored for 1 month for administrative and security purposes.

User-generated content, such as ratings and uploaded images, will be fully and irreversibly anonymized upon account deletion. This data is disassociated from your personal identity, is no longer considered personal data, and is retained to ensure the continued functionality of the Services and the Platform.


Analysis, Development, and Service Improvement

We process your personal data to deliver, develop, and improve the Platform. This includes providing core features, enhancing our offerings, developing new updates, and creating personalized services.

1. Core Service: Image Analysis with Google Gemini When you upload images to WiBES, we process them to perform AI-driven image analysis, which is a core feature of the App.

  • Data Used: Images you upload.

  • Sub-processing and International Transfer: To provide this feature, we send your images to Google Gemini, an AI service provided by Google LLC. This processing occurs in the United States. We have a Data Processing Agreement (DPA) with Google to protect your data.

  • Legal Safeguard for Transfer: The transfer of your personal data to the US is legally secured, as Google LLC is certified under the EU-U.S. Data Privacy Framework. This framework has been deemed by the European Commission to provide an adequate level of protection for personal data (an "adequacy decision").

  • Sharing: The data generated from this analysis (e.g., information about the scanned image) is linked to your user account to provide you with your results. This data may also be shared with other users on the WiBES Platform as part of the Service.

  • Legal Basis: Fulfilling our contractual obligations to you by providing the core services of the app, cf. GDPR Article 6(1)(b) (processing necessary for the performance of a contract).

2. Improving our AI Models and Services To improve our services and train our AI models, we use data from image analyses.

  • Data Used: We use fully anonymized and aggregated data derived from user-uploaded images and analyses.

  • Legal Basis: This data is not considered personal data, as it cannot be traced back to you as an individual. Therefore, its use for training purposes does not require a GDPR legal basis.

3. Platform Analytics & Development We process technical data and user activity to understand how our Platform is used, identify popular features, ensure security, perform troubleshooting, and plan operational activities.

  • Data Used:

    • User activities on our Platform

    • IP address

    • Areas of interest

    • Technical data (device type, operating system, time of access)

  • Legal Basis: Our legitimate interest in improving and securing our Platform and Services, cf. GDPR Article 6(1)(f). We balance our interest against your right to privacy by using this data in an aggregated or pseudonymized form where possible.

4. Location Data

  • Data Used: Your device's precise location.

  • Legal Basis: We will only collect and process this data after receiving your explicit, opt-in consent, cf. GDPR Article 6(1)(a). You may withdraw this consent at any time through your device or App settings.

5. Cookies When visiting our Platform, we use cookies. All information related to our use of cookies and your choices is provided by our Consent Management Platform. Our basis for processing personal data via non-essential cookies is your consent.


Your Rights as a User

As our company is based in Denmark, your personal data is protected by the General Data Protection Regulation (GDPR). This gives you specific, enforceable rights regarding your data.

To exercise any of these rights, please contact us at support@wibes.dk. We will respond to your request in accordance with our legal obligations.

Here are the rights you have:

  • The Right to Access: You have the right to request a copy of the personal data we hold about you and information about how we process it.

  • The Right to Rectification: If you believe any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or complete it. You may also be able to update some information directly within your account settings.

  • The Right to Erasure (The "Right to be Forgotten"): You have the right to request the deletion of your personal data when it is no longer necessary for the purpose it was collected, or if you withdraw your consent.

    • As noted elsewhere in this policy, upon account deletion, we will delete your identification data (after a 6-month retention period for security purposes) and irreversibly anonymize your user-generated content (like ratings and images).

  • The Right to Restrict Processing: You have the right to request that we temporarily stop processing your personal data in certain circumstances (e.g., if you are contesting the accuracy of the data).

  • The Right to Object: You have the right to object to our processing of your data when it is based on our legitimate interests (such as for platform analytics). If you object, we will stop processing that data unless we can demonstrate compelling legitimate grounds that override your interests.

  • The Right to Data Portability: Where we process your data based on your consent or a contract (like your user account data), you have the right to request your data in a structured, commonly used, and machine-readable format (e.g., a JSON file) so you can transfer it to another service.

  • The Right to Withdraw Consent: Where we rely on your consent to process data (such as for Location Data or non-essential cookies), you have the right to withdraw that consent at any time.

Right to Lodge a Complaint

While we hope to resolve any concerns you have directly, you always have the right to lodge a complaint with a data protection authority.

As The Sustainable IT ApS is registered in Denmark, our lead supervisory authority is the Danish Data Protection Agency (Datatilsynet).

You can contact them here:

  • Website: www.datatilsynet.dk

  • Phone: +45 33 19 32 00

  • Email: dt@datatilsynet.dk


Data Sharing and Disclosure

We do not sell your personal data. We only share your data in the following circumstances and with the following parties to provide and improve our Services.

1. With Other Users on the Platform

Our Platform is a social network. Your username, profile information (if public), and the content you create (such as ratings, reviews, and uploaded images) are shared with other Users on the Platform to provide the core functionality of the Service.

2. With Third-Party Service Providers (Sub-processors)

We use third-party companies to help us operate, secure, and improve our Platform. These providers only have access to the personal data necessary to perform their specific tasks on our behalf and are bound by Data Processing Agreements (DPAs).

Our key sub-processors include:

  • AI Service Provider: As detailed in the "Analysis and Development" section, we share your uploaded images with Google LLC (for its Gemini service) to perform image analysis. This data is transferred to the United States under the protection of the EU-U.S. Data Privacy Framework.

  • Platform Hosting and Infrastructure: Our Platform and its data are hosted by [You must add your hosting provider here, e.g., Amazon Web Services, Microsoft Azure, or a local provider].

  • Analytics Providers: We may use third-party providers to help us analyze platform usage and user activity.

  • Third-Party Logins: If you choose to register or sign in using a third-party service (like Facebook, Apple, or Google), we share information with and receive information from that service as described when you connect your account.

3. For Legal and Security Reasons

We may disclose your personal data if we believe in good faith that it is necessary to:

  • Comply with a legal obligation, court order, or government request.

  • Enforce our Terms and Conditions or other policies.

  • Protect the security or integrity of our Platform (e.g., to prevent fraud or abuse).

  • Protect the rights, property, or safety of The Sustainable IT ApS, our Users, or the public.


Data Security and Retention

Data Security

We take the security of your personal data seriously. We have implemented appropriate technical and organizational measures to protect your data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

This includes measures such as data encryption, access controls, and secure data storage. We regularly review our security practices to ensure they meet industry standards.

However, please note that no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

Data Retention

We will only retain your personal data for as long as it is necessary to fulfill the purposes for which it was collected, or to comply with our legal and regulatory obligations.

Our retention policies are as follows:

  • User Account Data: Your identification and contact information (such as your name, email, and username) are stored for as long as your WiBES account is active. We will retain this data for a period of 6 months after you delete your account for administrative, anti-fraud, and security purposes.

  • User-Generated Content: As stated in the "User Relationship Management" section, your user-generated content (such as ratings and uploaded images) will be fully and irreversibly anonymized upon account deletion. This anonymized data is retained to ensure the continued functionality of the Platform.

  • Analytical Data: Data used for platform analytics and AI model improvement is stored in a fully anonymized or aggregated form and is therefore retained indefinitely, as it is no longer personal data.

  • Data from Consent: If we process data based on your consent (such as location data), we will stop processing it for that purpose if you withdraw your consent.