Swill – Privacy Policy

Last updated 28 September 2026

Swill is a wine-tasting bluffing game for iOS and Android made by Kurasika Technologies Limited (company number 17067978, registered office 12 Old Mills Industrial Estate, Paulton, Bristol, BS39 7SU, United Kingdom). We are the data controller for the personal data described here. Questions and requests: tendai@kurasika.tech.

1. What we collect and why

DataWhy we use itWhere it comes from
A guest account identifierTo keep your scores, tables and history together. Swill creates this automatically the first time you open the app; you never have to register.Generated by the app
Display nameShown to the other players at your table.You type it
Photo (optional)If you choose to add a portrait, the photo you take or pick is sent to OpenAI to be turned into an illustrated drawing in the Swill style. The drawing becomes your avatar and the original photo is deleted from our servers as soon as the drawing exists.You take or pick it
Email address (optional)Only if you choose to sign in with Apple or Google so that you can restore your account on another device. We do not send marketing email.Apple or Google, via WorkOS
Tasting notes, bluffs and votesThis is the game. What you write is shown to the other players at the same table. Bluffs may be sent to an AI model to be polished if you tap that option.You type it
Invite code useIf you enter a friend's invite code when you join, we record that they invited you.You type it
Purchase statusWhether you own Swill Pro. Payment itself is handled by Apple or Google; we never see your card details.Apple / Google, via RevenueCat

Swill does not show advertising, does not use analytics or tracking SDKs, does not access your location or contacts, and does not sell personal data.

2. Who processes it for us

Each of these acts on our instructions under a data-processing agreement. Where data leaves the UK or EU (OpenAI, WorkOS and RevenueCat are in the United States) the transfer is covered by standard contractual clauses.

3. Legal basis

We process your data to provide the game you asked for (performance of a contract) and, for the optional portrait and sign-in features, on the basis of your consent, which you give by using the feature and can withdraw by deleting the portrait or your account.

4. How long we keep it

Your profile and game history are kept while your account exists. Uploaded photos are deleted immediately after the drawing is made. If you delete your account, everything tied to it is removed within 30 days; anonymised game statistics that cannot identify you may be kept.

5. Deleting your account

Open Profile in the app and tap Delete my account. This removes your profile, portrait, notes, invite record and purchase record from our systems. You can also email tendai@kurasika.tech from any address and we will delete the account within 30 days. Purchases are refunded, if at all, by Apple or Google under their own rules.

6. Your rights

Under UK and EU data-protection law you can ask for a copy of your data, ask us to correct or delete it, object to or restrict processing, and complain to the Information Commissioner's Office (ico.org.uk) or your local authority. Write to tendai@kurasika.tech.

7. Children

Swill is a game about wine and is intended for adults of legal drinking age. It is not directed at children and we do not knowingly collect data from anyone under 18.

8. Changes

If this policy changes we will update the date at the top and, for significant changes, tell you in the app.