Cask Finder / Cask Master Privacy Policy

Privacy Policy for Cask Finder (also known as Cask Master)

Effective Date: March 26, 2025

1. Introduction

Welcome to Cask Finder (“the App”), developed by Mike Taylor-Cai (admin@bonuslevel.co.uk). This Privacy Policy explains how we collect, use, handle, and retain your information when you use our Android application, outlines your data protection rights (including those under GDPR, CCPA, VCDPA, and LGPD), and specifies the legal bases for our processing activities. Cask Finder is designed to help cask and real ale enthusiasts discover nearby pubs potentially serving these beverages, based on data from OpenStreetMap (OSM).

Your privacy is important to us. This App is designed with privacy in mind, collecting only the minimal data necessary for its core functionality and to support the App through advertising, as outlined in this policy. By using the App, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

The App collects or processes the following types of information, some of which may be considered Personal Information (PI) under applicable laws:

• Location Data (Precise): Your device’s precise location (ACCESS_FINE_LOCATION) is requested and used transiently while you use the “Nearby” feature. This is necessary to query for nearby pubs and display your position on the map. Cask Finder does not store your location history.
• Favourite Pub Data: OpenStreetMap identifiers (OSM ID) and potentially cached names/coordinates for pubs you favourite. This data is stored only locally on your device and is not transmitted to us.
• Advertising Data: Collected directly by third-party advertising networks (e.g., Google AdMob – [Confirm/Replace provider]) via their integrated Software Development Kits (SDKs). This typically includes:
  • Device Identifiers: Such as your unique Advertising ID (e.g., GAID on Android), considered PI.
  • IP Address: Also considered PI, used for geo-targeting and fraud prevention.
  • Device Information: Non-unique details like OS version, device type.
  • Ad Interaction Data: Information about ads displayed and your interactions.
  • App Usage Data: General usage patterns within Cask Finder potentially used for ad relevance.
    Cask Finder does not store this Advertising Data itself, only facilitates its collection by the ad network’s SDK.
• Non-Personal Information: Anonymized data related to app crashes or errors (device type, OS version, crash logs) used solely for stability improvement. This data does not identify you personally.
• Contact Information: If you choose to contact us directly (e.g., via email at admin@bonuslevel.co.uk), we will collect your email address and any information you provide in your message to respond to your inquiry.

In summary, the Personal Information processed in relation to this App includes your precise location (transiently), your device’s Advertising ID and IP address (primarily processed by ad networks), and your email address (if you contact us).

3. Information We DO NOT Collect (Directly by Cask Finder)

To be clear, Cask Finder itself does NOT:

• Require user accounts or logins.
• Collect personally identifiable information like your name, phone number, or postal address directly through the App interface.
• Store your Favourite Pubs data or any other user-specific operational data in the cloud or on our servers – it remains on your device.
• Track your activity across other applications or websites.

4. How We Use Your Information

For core app functionality (nearby pubs, maps, favourites, navigation), displaying ads (potentially personalized based on data collected by ad networks), measuring ad performance, improving the app, and responding to user contact.

5. Legal Basis for Processing

We process personal data based on the following legal grounds under applicable data protection laws like GDPR:

• Legitimate Interests: We rely on our legitimate interests to provide and improve the core functionality of the App, ensuring it works as expected and can be maintained. This includes: processing Location Data transiently, processing Non-Personal Information for stability, integrating necessary SDKs (like Google Maps), facilitating navigation handoff, displaying non-personalized ads, and responding to direct inquiries. We balance our interests against your rights.
• Consent: Your action of saving a favourite signifies consent for local storage. The display of personalized advertisements by ad partners relies on consent typically managed via your device’s OS settings or the ad network’s mechanisms.
• Processing by Third Parties: Third-party services process data based on their own legal bases outlined in their policies.

6. How We Share Your Information

We share information only as necessary and described below. We do not “sell” your personal information in the traditional sense (exchanging it for money). However, using third-party advertising partners may involve sharing data (like Advertising ID, IP address via their SDKs) in ways defined as “sale” or “sharing” under laws like CCPA, or processing for “targeted advertising” under laws like VCDPA.

• OpenStreetMap (Overpass API): Transient precise location sent for queries.
• Google Maps SDK: Google may collect data per its policy.
• Advertising Partners: Ad networks (e.g., Google AdMob – [Confirm/Replace provider & links]) collect Advertising Data directly via their SDKs. This sharing enables personalized/targeted advertising and measurement and may constitute “sharing” or “targeted advertising” under specific laws. Opt-out options are in Section 10. Review their policies:
  • Google AdMob: https://policies.google.com/technologies/ads, https://policies.google.com/technologies/partner-sites
  • (Add links for other ad providers if you use them)
• External Map Applications: Pub coordinates/details sent via Intent on user request.
• Legal Requirements: If required by law or valid legal process.

7. Data Retention

• Favourites Data: Kept locally until cleared/uninstalled.
• Location Data: Used transiently, not retained by Cask Finder.
• Advertising Data: Retained by partners per their policies.
• Non-Personal Crash Data: Retained reasonably long for bug fixing.
• Contact Info: Retained as necessary for inquiry resolution/records.

8. Data Storage and Security

Favourites stored locally. Ad data stored by partners. Reasonable security for local data, but no method 100% secure.

9. Your Choices and General Data Rights

You have certain choices and rights regardless of your location:

• Location Permission: Controllable via device settings.
• Favourites Management: Manageable within the App.
• Clearing Data / Uninstalling: Deletes local data including Favourites.
• Contact Us: You can contact us (admin@bonuslevel.co.uk) with questions or concerns.

10. Region-Specific Privacy Rights

Depending on your location, you may have additional specific rights regarding your personal data.

10.1. EEA / UK Residents (GDPR Rights)

If you are in the European Economic Area (EEA) or the UK, you have rights under the GDPR/UK GDPR including: Right to Access (Art. 15), Rectification (Art. 16), Erasure (Art. 17), Restriction of Processing (Art. 18), Data Portability (Art. 20), Object (Art. 21), and Lodge a Complaint (Art. 77). How these apply to data controlled by Cask Finder (local Favourites, contact info) versus third parties (ad networks, maps SDK) and how to exercise them is elaborated below (or contact us).

10.2. California Residents (CCPA/CPRA Rights)

If you are a California resident, you have rights under the CCPA/CPRA including: Right to Know, Delete, Correct, Opt-Out of Sale/Sharing, Limit Use of SPI (likely not applicable here), and Non-Discrimination.

• Opt-Out of Sale/Sharing: Sharing data with ad partners for targeted advertising may qualify. To opt-out, use device privacy settings (Limit Ad Tracking/Reset Ad ID), industry opt-out tools (DAA, NAI – links below), or specific ad partner mechanisms.
  • DAA: https://optout.aboutads.info/
  • NAI: https://optout.networkadvertising.org/

10.3. Virginia Residents (VCDPA Rights)

If you are a Virginia resident, you have rights under VCDPA including: Right to Access, Correct, Delete, Data Portability, and Opt-Out of Targeted Advertising, Sale, or certain Profiling.

• Opt-Out of Targeted Advertising / Sale: Use the same mechanisms described for California residents (device settings, industry tools, partner links).

10.4. Brazilian Residents (LGPD Rights)

If you are in Brazil, you have rights under LGPD including: Confirmation of Processing, Access, Correction, Anonymization/Blocking/Deletion, Data Portability, Deletion (consent-based), Info about Sharing, Info about Consent consequences, and Revocation of Consent.

Exercising Your Rights (All Regions):

• Data Controlled by Cask Finder: For local Favourites, manage directly in-app or clear data/uninstall. For contact information provided via email, contact us at admin@bonuslevel.co.uk to exercise rights like Access, Correction, or Deletion.
• Data Controlled by Third Parties: For data collected by ad networks, Google Maps, etc., you must contact those third parties directly using the procedures outlined in their privacy policies (linked in Sections 6 & 12).
• Opt-Out Mechanisms: Use device settings (Limit Ad Tracking / Reset Ad ID), industry opt-out tools (DAA, NAI linked above), and check specific ad partner policies.
• Lodge a Complaint: You have the right to complain to your local data protection authority. We encourage contacting us first.

11. Children’s Privacy / Age Restriction

Intended only for users of legal drinking age (typically 18 years or older). Not directed at individuals under 18. We do not knowingly collect personal information from anyone under 18. Contact us if you believe this occurred.

12. Third-Party Services

Review the privacy policies of integrated services:

• OpenStreetMap: https://wiki.osmfoundation.org/wiki/Privacy_Policy
• Google (Maps SDK, AdMob – [Confirm/Replace AdMob if needed]): https://policies.google.com/privacy, https://policies.google.com/technologies/ads
• (Add any other third-party services)

13. Data Controller

The data controller for limited personal data processed directly by Cask Finder (e.g., responding to contact) is:

Mike Taylor-Cai
Contact Email: admin@bonuslevel.co.uk

Third-party services (Ad Networks, Google Maps) are controllers for the data they process.

14. Data Protection Officer (DPO)

Under applicable data protection laws (such as GDPR), we are not required to appoint a formal Data Protection Officer for the activities carried out by Cask Finder. For any privacy-related inquiries or to exercise your data rights regarding data potentially controlled by Cask Finder, please contact the Data Controller (Mike Taylor-Cai) using the details provided in Section 13.

15. Changes to This Privacy Policy

We may update this Privacy Policy periodically. We will notify you of changes by posting the new policy within the App or on its Google Play Store listing. Review this policy periodically. Changes are effective when posted.

16. Contact Us

If you have any questions about this Privacy Policy, please contact the developer / Data Controller:

Mike Taylor-Cai
admin@bonuslevel.co.uk