This Privacy Policy explains how ROOGUL ("BOOZER", "we", "us", "our") collects, uses, and shares information when you use the BOOZER app and website.
This policy is designed for the UK GDPR and the Data Protection Act 2018. It does not constitute legal advice.
Who we are & contact details
Controller: ROOGUL, registered office: Holbeche House 437 Shirley Road, Acocks Green, Birmingham, England, B27 7NX.
Email: studio@roogul.com
Data Protection Contact / DPO (if applicable): Ryan Elliott, studio@roogul.com.
The data we collect
- Account data: name/username, email, age confirmation (18+), password (hashed), settings, acceptance of Terms/Privacy (timestamp + version).
- Content data: photos you upload (beer/lager in glasses, cups, bottles, or cans), captions, comments, likes, and your public profile info.
- Image analysis data: automated labels and confidence scores from our AI check (e.g., "beer/lager in glass/cup/bottle/can"), moderation flags and reasons.
- Usage & device data: app interactions, crash logs, device type/OS, approximated region/country, IP address, and general diagnostics.
- Payment data (if applicable): last-4 of card, billing country, transaction IDs via our payment provider (we don't store full card numbers).
- Cookies & similar tech: essential session cookies; optional analytics (see Cookies section).
How we use your data (purposes & lawful bases)
| Purpose | Examples | Lawful basis |
|---|---|---|
| Provide the app | Create account, core features, social feed | Contract (Art. 6(1)(b)) |
| AI image verification | Check if photo shows beer/lager in a valid container; moderation flags | Legitimate interests (Art. 6(1)(f)) — keep platform safe & relevant |
| Safety & moderation | Detect abuse, enforce rules, prevent fraud | Legitimate interests; Legal obligations |
| Analytics & improvement | Performance, crash logs, feature usage | Legitimate interests; Consent for non-essential analytics |
| Marketing (optional) | In-app updates, email/newsletters | Consent (opt-in); right to withdraw anytime |
AI processing with OpenAI
When you upload a photo, we send it to OpenAI for automated analysis (e.g., "beer/lager in glass/cup/bottle/can") to verify submissions and maintain community standards. This is an automated process; humans do not routinely review your images unless required for moderation or legal reasons.
- Processor: OpenAI (United States and other regions where its infrastructure operates).
- Data shared: the image and minimal metadata necessary for analysis.
- Retention by us: we retain outputs/flags necessary to operate the app, provide stats, and keep the platform safe.
International transfers
Your data may be processed outside the UK (e.g., by OpenAI or other providers). Where we transfer data internationally, we rely on appropriate safeguards such as the UK International Data Transfer Addendum, Standard Contractual Clauses, or other lawful mechanisms.
How we share data
- Service providers (processors): hosting, analytics, crash reporting, content delivery, email, payments.
- Legal/disclosure: to comply with law, respond to lawful requests, or protect rights, safety, and security.
- Business transfers: merger, acquisition, or asset sale, where your data may transfer as part of the transaction.
Data retention
We keep personal data only as long as necessary for the purposes above:
- Account data: for the life of your account and up to 12 months after closure (for dispute/security), unless law requires longer.
- Photos & analysis outputs: for your profile/history and community integrity; you can delete individual posts; backups roll off on a schedule.
- Legal/abuse logs: retained as required to enforce rules and meet legal obligations.
Your rights (UK GDPR)
You have the right to access, rectify, erase, restrict or object to processing, and data portability. You also have rights relating to automated decision-making. To exercise these rights, contact us at [support@yourdomain.com]. You can also complain to the ICO (see below).
Children
BOOZER is for adults aged 18+. We do not knowingly collect data from children.
Security
We use appropriate technical and organisational measures to protect your data. However, no system is completely secure. Please keep your account credentials confidential and notify us of any suspected unauthorised access.
Cookies & analytics
We use essential cookies for login/security. We may also use optional analytics. Where required, we'll ask for your consent and provide controls to change your preferences.
How to contact us & complaints
Contact: studio@roogul.com
You have the right to complain to the Information Commissioner's Office (ICO). See ico.org.uk/make-a-complaint.
Changes to this policy
We may update this policy from time to time. We'll notify you via in-app notice or email and update the "Last updated" date above.