Privacy Policy for Swirl

Effective Date: April 18, 2026

Swirl (“we,” “our,” or “us”) operates the Swirl mobile application (the “App”). This Privacy Policy explains how we collect, use, and protect your information when you use our App.

1. Information We Collect

a. Personal Information (if applicable)

We may collect personal information that you voluntarily provide, such as:

Name
Email address
Account login details

b. Usage Data

We automatically collect certain information when you use the App, including:

Device type and operating system
App usage activity (e.g., features used, interactions)
IP address (approximate location)

c. Location Data (if enabled)

If you grant permission, we may collect your device’s approximate location to enhance features (e.g., showing nearby product availability).

2. How We Use Your Information

Provide and maintain the App
Improve user experience and app performance
Personalize content and recommendations
Monitor usage and detect technical issues
Communicate with you (if you contact us)

3. Data Sharing and Disclosure

We do not sell your personal data.

We may share limited data with:

Service providers (e.g., analytics, hosting)
Legal authorities, if required by law

4. Third-Party Services

Swirl may use third-party services such as analytics providers or APIs.

Important Disclaimer:

Swirl wine app is not affiliated with, endorsed by, or connected to the Liquor Control Board of Ontario (LCBO) or the Government of Ontario in any way.

This is an independent, third-party application that provides access to publicly available LCBO data. Swirl operates independently and is not an official LCBO service.

5. Data Retention

We retain your information only as long as necessary to provide the App, comply with legal obligations, and resolve disputes.

6. Security

We take reasonable measures to protect your information. However, no method of transmission or storage is 100% secure.

7. Your Rights

You may have the right to:

Access the personal data we hold about you
Request correction or deletion
Withdraw consent where applicable

To make a request, contact us at: swirlapp@gmail.com

8. Children’s Privacy

Swirl is not intended for individuals under the legal drinking age in their jurisdiction. We do not knowingly collect data from minors.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be posted within the App with a revised effective date.

10. Contact Us

If you have questions about this Privacy Policy, contact us at:

Email: swirlapp@gmail.com