Privacy Policy

Effective: March 2026

1. Introduction & Data Controller

This Privacy Policy describes how Tyga.Cloud Ltd (company number 14643275), registered in England and Wales ("we", "us", "our"), collects, uses, and protects personal data when you use the BottleScanner.my platform ("Service"). BottleScanner.my is a division of Tyga.Cloud Ltd.

Data Controller: Tyga.Cloud Ltd, Ground Floor, Unit 2 Mallard Court, Mallard Way, Crewe Business Park, Crewe, Cheshire, CW1 6ZQ, United Kingdom.

Data Protection Officer: dpo@tyga.cloud

2. Information We Collect

Information you provide:

• Email address (waitlist signup)
• Images uploaded for bottle scanning

Information collected automatically:

• IP address and approximate location
• Browser type, device type, and operating system
• Pages visited, features used, and session duration
• Referral source
• Cookies and similar technologies (see our Cookie Policy)

Scan data:

• AI identification results (brand, product name, spirit type)
• Matched product information
• Scan timestamps and source site

Images uploaded for scanning are processed in memory and are not permanently stored.

3. How We Use Information

We use your personal data to:

• Provide, operate, and maintain the Service
• Process bottle scans and return identification results
• Send waitlist notifications and service updates
• Analyse usage to improve the Service
• Detect, prevent, and address fraud or security issues
• Comply with legal obligations

4. Legal Basis for Processing (GDPR Article 6)

Purpose	Legal Basis
Providing the scanning Service	Legitimate interest (Art. 6(1)(f))
Waitlist signup & notifications	Consent (Art. 6(1)(a))
Analytics and service improvement	Legitimate interest (Art. 6(1)(f))
Marketing communications	Consent (Art. 6(1)(a))
Legal compliance	Legal obligation (Art. 6(1)(c))

5. Data Sharing & Third Parties

We share personal data only with parties necessary to deliver the Service:

Provider	Purpose	Data Shared
Anthropic (Claude API)	AI bottle identification	Uploaded images (processed, not stored by us)
MongoDB	Database hosting	All stored application data (encrypted)
Redis	Caching	Cached page data
SendGrid	Email delivery	Email addresses for waitlist notifications

We do not sell your personal data. We may disclose data if required by law, court order, or to protect the rights and safety of Tyga.Cloud Ltd and its users.

6. International Transfers

Some of our service providers are based outside the United Kingdom and European Economic Area (EEA). Where personal data is transferred internationally, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the UK Information Commissioner's Office.

7. Data Retention

We retain your personal data as follows:

• Waitlist emails — retained until you unsubscribe or the service launches
• Scan records — retained for analytics and service improvement; anonymised after 12 months
• Uploaded images — processed in memory only; not permanently stored

8. Your Rights (GDPR)

If you are located in the UK or EEA, you have the following rights under the General Data Protection Regulation:

• Right of access — request a copy of the personal data we hold about you
• Right to rectification — request correction of inaccurate data
• Right to erasure — request deletion of your personal data ("right to be forgotten")
• Right to restrict processing — request that we limit how we use your data
• Right to data portability — receive your data in a structured, machine-readable format
• Right to object — object to processing based on legitimate interests
• Right to withdraw consent — withdraw consent at any time where processing is based on consent

To exercise these rights, contact our Data Protection Officer at dpo@tyga.cloud. We will respond within 30 days.

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk.

9. CCPA Rights (California)

If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with additional rights:

• Right to know — what personal information we collect, use, and share
• Right to delete — request deletion of your personal information
• Right to opt-out — opt out of the sale of personal information (we do not sell personal data)
• Right to non-discrimination — we will not discriminate against you for exercising your rights

To exercise CCPA rights, contact us at dpo@tyga.cloud.

10. Children's Privacy

BottleScanner.my is not intended for use by anyone under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have collected personal data from a person under 18, we will take steps to delete it promptly.

11. Security Measures

We implement appropriate technical and organisational measures to protect your personal data, including:

• Encryption of data in transit (TLS/SSL) and at rest
• Regular security assessments and vulnerability scanning
• Access controls and authentication mechanisms
• Regular backups and disaster recovery procedures

While we take reasonable precautions, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of your data.

12. Cookies

We use cookies and similar technologies to operate and improve the Service. For detailed information about the cookies we use and how to manage your preferences, please see our Cookie Policy.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified via email or on-site notification. The "Effective" date at the top of this page indicates when the policy was last revised.

14. Contact & DPO

For questions about this Privacy Policy or to exercise your data rights, contact our Data Protection Officer:

Data Protection Officer
Tyga.Cloud Ltd
Ground Floor, Unit 2 Mallard Court, Mallard Way
Crewe Business Park, Crewe, Cheshire, CW1 6ZQ
Email: dpo@tyga.cloud