Privacy Policy

1. About BottleBank and This Policy

1.1 BottleBank.io is a Business-to-Business (B2B) SaaS platform operated by Nuvaryn Pte Ltd. Our direct customers are nightlife venues, bars, clubs, and hospitality organisations (“Subscribers”). BottleBank does not have a direct contractual relationship with individual patrons (“End Customers”) whose data is managed on the Platform by Subscriber staff.

1.2 This Privacy Policy applies to:

• Personal data of Subscriber representatives, including venue managers and other venue staff;
• Personal data of End Customers entered into the Platform by Subscriber staff on behalf of the venue; and
• Visitors to https://bottlebank.io.

1.3 BottleBank Data Use Restrictions: BottleBank will not sell, share across Subscriber organisations, monetise, repurpose, or use End Customer data for any purpose beyond delivering the platform service to the Subscriber that collected that data. End Customer data is strictly isolated per Subscriber. BottleBank does not and will never use End Customer data for advertising, cross-tenant analytics, data brokerage, or any commercial purpose beyond the contracted service.

1.4 Subscribers are independently responsible for PDPA compliance in respect of their End Customer data. BottleBank processes such data as a data processor, acting strictly on the Subscriber’s instructions.

2. Data Controller and Processor Roles

3. Personal Data We Collect

3.1 Subscriber Staff and Admin User Data

Collected directly when a Subscriber registers an account or adds User Accounts:

• Full name and job title
• Business email address (used for OTP authentication)
• Phone number (optional)
• Account type assigned within the Platform (Admin account for managers; User account for all other venue staff)
• Login history, last active timestamp, and device trust information
• Authentication events: IP address, login attempts, successes, and failures

3.2 End Customer Data (Entered by Subscriber Staff)

Entered into the Platform by venue staff on behalf of the Subscriber:

• Full name
• Email address (raw and normalised)
• Phone number (raw and normalised) — used to send WhatsApp and email notifications
• Date of birth (optional)
• Pronouns (optional)
• Membership tier, visit count, and total spend history
• Profile photo (optional, uploaded by staff)
• Source tracking (how the customer record was created)
• Verification status (phone, email)

3.3 Bottle and Operational Records

• Bottle serial number (format: BB-YYYY-NNNN), product details, and custom label
• Fill level (0 to 100%) and volume
• Park date, expiry date, and current bottle status
• Storage location and customer ownership records

3.4 Communication Logs

• WhatsApp message logs: recipient phone number, template used, delivery status, and timestamp (immutable)
• Email notification logs: recipient address, event trigger, delivery status, and timestamp
• Monthly message usage counters per organisation

3.5 Billing and Financial Data

• Subscription plan, billing cycle, and subscription status
• Invoice history and credit notes
• Stripe customer identifier (credit card data is stored solely by Stripe, not by BottleBank)
• Usage records (bottles parked vs. quota)
• Payment method selection (PayNow, Bank Transfer, or card) — card details not stored by BottleBank

3.6 Technical and Usage Data

• IP addresses captured during authentication events
• Platform usage and audit logs (immutable)
• Device identifiers used for session management and device trust

4. Purposes of Data Collection and Use

4.1 Subscriber Staff Data

• Creating and managing Admin User accounts and role-based access
• Authenticating users via OTP email
• Maintaining security and authentication audit logs
• Managing billing, invoicing, and subscription lifecycle
• Providing customer support and communicating Platform updates

4.2 End Customer Data (Processed on Subscriber’s Behalf)

BottleBank processes End Customer data solely on the Subscriber’s instructions for the following purposes:

• Recording and tracking bottle storage at the Subscriber’s venue
• Sending automated transactional WhatsApp notifications: bottle parked confirmation, seven (7) day expiry reminder, and bottle transfer alert
• Sending email notifications for the same events
• Enabling End Customers to view their bottle status via the guest portal (unique URL, read only, no login required)
• Maintaining an immutable audit trail of all bottle-related actions for the Subscriber’s records

5. Legal Basis for Processing

6. Disclosure of Personal Data

6.1 Third-Party Service Providers

BottleBank shares personal data with the following sub-processors solely to deliver the Platform:

BottleBank will notify Subscribers in writing at least thirty (30) days before engaging any new sub-processor or making material changes to existing sub-processor arrangements.

6.2 No Sale of Personal Data

BottleBank does not sell, rent, trade, or otherwise disclose personal data to any third party for commercial purposes outside of service delivery.

6.3 Legal Disclosure

BottleBank may disclose personal data where required by law, court order, or regulatory authority in Singapore or any applicable jurisdiction. Where legally permissible, BottleBank will provide reasonable notice to the affected Subscriber.

7. Cross-Border Data Transfers

7.1 Data is stored on Supabase infrastructure. The data residency region is configurable. Subscribers may request Singapore-region storage. BottleBank will confirm the applicable region upon request.

7.2 WhatsApp messages transit via YCloud and Meta’s global infrastructure. By enabling WhatsApp notifications, the Subscriber acknowledges this cross-border transit.

7.3 BottleBank ensures that all cross-border data transfers are conducted in compliance with the PDPA’s data transfer obligations and that receiving organisations provide a comparable standard of protection.

8. Data Retention

8.1 Subscriber staff data is retained for the duration of the active account.

8.2 End Customer data is retained in accordance with the Subscriber’s (data controller’s) instructions. Subscribers may view, edit, or delete End Customer records at any time via the Platform.

8.3 Bottle records and audit logs are immutable and are retained for the duration of the Subscriber’s account. They cannot be edited or deleted after creation.

8.4 Upon subscription expiry without renewal, data is retained in accordance with the data retention and deletion timeline specified in the Terms of Service. BottleBank does not provide bulk data export functionality. Subscribers are responsible for maintaining their own operational records during the active subscription period.

8.5 Invoice history and billing records are retained as required by Singapore accounting and tax regulations, regardless of subscription status.

9. Data Subject Rights Under the PDPA

9.1 Rights of Subscriber Staff

Subscriber staff may exercise the following rights by contacting admin@bottlebank.io:

• Right of Access — request a copy of personal data held by BottleBank about you.
• Right of Correction — request correction of inaccurate or incomplete personal data.
• Right of Withdrawal of Consent — where processing is consent-based, withdraw consent at any time (without affecting the lawfulness of prior processing).

BottleBank will respond to verified requests within thirty (30) days.

9.2 Rights of End Customers

End Customers do not have a direct contractual relationship with BottleBank. End Customers wishing to exercise their PDPA rights (access, correction, or withdrawal) should contact the relevant Subscriber (venue) directly, as the Subscriber is the data controller for End Customer data.

The Subscriber can fulfil these requests directly within the Platform:

• Access: Subscriber staff with Admin access can view all data held for any End Customer within the Platform.
• Correction: Subscriber staff with Admin access can edit and correct End Customer records directly.
• Deletion: Subscriber staff with Admin access can delete End Customer records directly from the Platform.

No request to BottleBank is required for the above actions. The Subscriber, as Data Controller, is responsible for responding to End Customer requests within the timeframes required by the PDPA.

10. Platform-Only Data Policy

10.1 All End Customer personal data collected and stored through the BottleBank platform is intended for use exclusively within the Platform. BottleBank does not provide any bulk data export, download, or extraction functionality for End Customer personal data.

10.2 End Customer data was collected for the specific purpose of bottle storage management and loyalty tracking within the BottleBank platform. The extraction of this data for use outside the Platform — including but not limited to third-party marketing, direct messaging through external channels, or sale of data — would constitute a use inconsistent with the purpose for which the data was collected under the PDPA.

10.3 Subscribers may view and manage End Customer data within the Platform at all times during their active subscription.

11. Security Measures

12. Data Breach Notification

12.1 In the event of a data breach affecting End Customer personal data, BottleBank will notify the affected Subscriber in writing within seventy-two (72) hours of becoming aware of the breach, including a description of the nature of the breach, the categories and approximate number of records affected, the likely consequences, and the measures taken or proposed to address the breach.

12.2 The Subscriber, as Data Controller, is responsible for determining whether the breach must be reported to the PDPC under the PDPA’s mandatory data breach notification obligations and for making any such report. BottleBank will provide reasonable assistance.

13. Cookies and Tracking

13.1 The BottleBank.io website and Platform use cookies and similar technologies to support authentication sessions, security features, and platform analytics. BottleBank does not use marketing, advertising, retargeting, or cross-site tracking cookies. We do not display advertisements and do not share data with advertising networks.

13.2 Strictly necessary cookies (session authentication, OTP verification, device trust, CSRF protection) are essential for the Platform to function and cannot be disabled.

13.3 Analytics cookies (Vercel Analytics, Web Vitals) collect anonymous page view and performance data. No personally identifiable information is collected. You may opt out via your browser’s “Do Not Track” setting.

13.4 Third-party cookies may be set by Stripe (payment processing) and Cloudflare (security and CDN). These are governed by their respective privacy policies.

13.5 The End Customer guest portal uses a unique session token for identification. No persistent marketing cookies are set for End Customers.

13.6 You can control cookies through your browser settings. Blocking strictly necessary cookies will prevent you from logging in to the Platform.

14. Children’s Data

BottleBank does not knowingly collect personal data of individuals under the age of eighteen (18). The Platform is designed for nightlife and hospitality venues serving adults. Subscribers are responsible for ensuring that End Customer data entered into the Platform relates only to adults of legal age.

15. Changes to This Policy

BottleBank reserves the right to update this Privacy Policy. Material changes will be communicated to Subscribers via the Platform dashboard or by email to the registered account address, with at least fourteen (14) days’ notice prior to the change taking effect. Continued use of the Platform after the effective date constitutes acceptance of the updated Policy.

16. Contact and Complaints