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● Legal Document

Privacy Policy & Terms of Use

Last updated: April 2026  |  Controller: iTrois Tecnologia e Inovação  |  App: Sommie v1.0.73+

✓ LGPD Compliant ✓ GDPR Compliant ✓ ISO 27001 (AWS Bedrock) ✓ SOC 2 Type II (AWS Bedrock) ★ Voice & Photo Processing — NEW

Part I — Terms of Use

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1. Acceptance

By downloading, installing, or using the Sommie app, you agree to be bound by these Terms of Use and our Privacy Policy. If you do not agree with any part of these terms, we recommend that you do not use the service. Continued use of the app constitutes acceptance of any updates to these terms.

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2. About the App

Sommie is a virtual sommelier powered by artificial intelligence, offering personalized wine recommendations, intelligent food pairings, educational content about the wine world, and access to wine tourism experiences.

To provide these features, Sommie uses third-party artificial intelligence services, as described in detail in the Privacy Policy. The app also provides voice input and photo submission features to facilitate user interaction — these are described in full in Sections 3A and 3B of the Privacy Policy.

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3. Registration and Access

To use certain features of Sommie, you must create an account by providing accurate information, including your name, email address, date of birth, and consumption preferences. You are responsible for maintaining the confidentiality of your login credentials and for all activities that occur under your account.

4. User Responsibilities

By using Sommie, you agree to use the app ethically and in accordance with all applicable laws and regulations, not to share offensive, false, defamatory, or illegal content, and to keep your login credentials confidential and secure.

When using the voice input and photo submission features, you declare that you hold all necessary rights over the content you submit and that such content does not infringe upon the rights of any third party. You also acknowledge that original audio recordings and images are processed locally and discarded immediately after conversion to text, as described in Sections 3A and 3B.

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5. Intellectual Property

All content within Sommie — including but not limited to texts, images, logos, algorithms, AI models, and features — is the exclusive property of iTrois Tecnologia e Inovação. Reproduction, distribution, or modification of any content without prior written authorization is strictly prohibited.

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6. Updates to Terms

iTrois reserves the right to update these Terms of Use and the app's features at any time. Material changes will be communicated via in-app notification or email with at least 15 days' advance notice. Continued use of the app after such notice constitutes acceptance of the updated terms.


Part II — Privacy Policy

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1. Data Collection

We collect the following categories of data to provide, maintain, and improve Sommie's services. All data collection is based on a lawful basis under the LGPD (Law 13.709/2018) and GDPR, as indicated below.

Category Data Collected Purpose Legal Basis
Registration Data Name, email address, date of birth, phone number Account creation, authentication, communications Contract performance
Sensory Profile Wine preferences, flavors, aromas, occasions Personalize recommendations and food pairings Consent / Contract
Usage Data Interaction history, searches, content accessed Improve experience and personalize the service Legitimate interest
Location Approximate location (optional) Wine tourism suggestions (only with consent) Consent
Messages & Queries Text entered when interacting with the sommelier Generate AI sommelier responses Consent
Voice Data NEW Audio recordings captured by device microphone, with consent Facilitate voice interaction; converted to text before any AI processing Consent (Art. 7, I, LGPD)
Photos & Images NEW Images from device camera or gallery, with consent Reading wine labels and menus via OCR to generate text Consent (Art. 7, I, LGPD)
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2. Use of Data

We use the collected data for the following purposes:

PurposeDescription
App FunctionalityAuthenticate users, enable features, ensure security and performance
Product PersonalizationCustomize wine recommendations and food pairings based on the user's sensory profile
AI Response GenerationProcess queries and generate virtual sommelier responses via third-party AI service
Voice-to-Text Conversion NEWConvert voice recordings to text locally to facilitate user interaction
OCR Processing NEWExtract text from photos locally to facilitate reading of wine labels and menus
AnalyticsEvaluate user behavior to improve existing features and plan new ones
Legal ComplianceComply with applicable legal and regulatory obligations

Data is never used for third-party advertising, marketing communications, or any purpose other than those listed above without explicit user consent.

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3. Use of Third-Party AI Service

To provide the virtual sommelier features, personalized recommendations, and intelligent food pairings, Sommie uses the Claude Sonnet language model, developed by Anthropic, PBC, accessed through the Amazon Bedrock platform, operated by Amazon Web Services, Inc. (AWS).

Amazon Bedrock — Claude Sonnet (Anthropic)
Third-party AI service provider

Amazon Web Services confirms the following data protection guarantees for Amazon Bedrock:

Data not stored after processing Not shared with Anthropic Not used to train AI models ISO 27001 SOC 2 Type II LGPD & GDPR Compliant

What data is sent to the AI service

When you interact with the virtual sommelier, the following information may be transmitted to the AI model for processing:

Data TypeTransmitted to AI?Notes
Typed messages & questions✓ YesDirect text input from user
Sensory profile & preferences✓ YesFlavor, aroma, occasion context
Query context✓ YesDish type, occasion, price range
Transcribed text from voice NEW✓ Yes (text only)After local speech-to-text conversion; original audio is discarded
OCR-extracted text from photos NEW✓ Yes (text only)After local OCR processing; original image is discarded
Original audio files✗ NeverDiscarded immediately after transcription
Original photos/images✗ NeverDiscarded immediately after OCR
Contact info (name, email, phone)✗ NeverNot transmitted to AI
Device identifiers✗ NeverNot transmitted to AI
Payment information✗ NeverNot collected or transmitted
Important: Original voice files (audio) and original photos/images are NEVER sent to the third-party AI service (AWS Bedrock / Claude Sonnet). Only the text resulting from transcription or OCR processing is shared, ensuring greater user privacy.
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3A. Voice Data Processing

NEW
This section is new and was added in April 2026 to describe how voice data is processed in Sommie.

How it works

When you use the voice input feature, audio is captured by your device's microphone and converted to text using automatic speech-to-text (STT) transcription technology. This conversion is performed locally on your device or on iTrois' own infrastructure, without sending the original audio to any third-party AI service.

Voice Processing Flow
VOICE
🎤 Microphone
captures audio
🔄 Speech-to-Text
(local / iTrois)
🗑 Original audio
discarded
📄 Transcribed text
(text only)
🤖 Claude Sonnet
(AWS Bedrock)
⚠ The original audio file is NEVER sent to the third-party AI service — only the transcribed text is transmitted.

What happens to the original audio

The original audio file is discarded immediately after transcription and is not stored on iTrois' servers, not shared with any third party, and not retained in any form. Only the transcribed text is retained for processing the sommelier's response.

What is shared with the AI

Only the text resulting from transcription — equivalent to what you would type manually — is sent to the third-party AI service (Claude Sonnet via AWS Bedrock) to generate the virtual sommelier's response.

Legal basis (LGPD / GDPR)

Voice data processing is carried out based on your express consent (Art. 7, I, LGPD / Art. 6(1)(a) GDPR), requested when the voice feature is activated for the first time. You may revoke this consent at any time:

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3B. Photo & Image Data Processing

NEW
This section is new and was added in April 2026 to describe how photo and image data is processed in Sommie.

How it works

When you submit a photo, the image is processed by Optical Character Recognition (OCR) technology, which extracts the textual content present in the image (such as wine label information, menu text, or product descriptions). This processing is performed locally on your device or on iTrois' own infrastructure, without sending the original image to any third-party AI service.

Photo Processing Flow
PHOTO
📷 Camera/Gallery
captures image
🔍 OCR Processing
(local / iTrois)
🗑 Original image
discarded
📄 Extracted text
(text only)
🤖 Claude Sonnet
(AWS Bedrock)
⚠ The original image file is NEVER sent to the third-party AI service — only the OCR-extracted text is transmitted.

What happens to the original image

The original photo is discarded immediately after OCR processing and is not stored on iTrois' servers, not shared with any third party, and not retained in any form. Only the extracted text is retained for processing the sommelier's response.

What is shared with the AI

Only the text extracted by OCR technology — equivalent to what you would type manually when transcribing the image content — is sent to the third-party AI service (Claude Sonnet via AWS Bedrock) to generate the virtual sommelier's response.

Biometric and sensitive data

Sommie does not request or process photos of people, identity documents, or any images that may contain sensitive personal data. The photo submission feature is intended exclusively for reading product labels, wine menus, and packaging.

Legal basis (LGPD / GDPR)

Image processing is carried out based on your express consent (Art. 7, I, LGPD / Art. 6(1)(a) GDPR), requested when the photo submission feature is activated for the first time. You may revoke this consent at any time:

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3C. App Store Privacy Labels

NEW
This section was added in April 2026 to reflect the updated Privacy Nutrition Labels declared in the Apple App Store for Sommie.

In compliance with Apple App Store guidelines (5.1.1(i) and 5.1.2(i)), the following Privacy Nutrition Labels are declared for Sommie:

Sommie — App Store Privacy Label (April 2026)
Data Linked to You
Contact Info Identifiers User Content (Messages) ★ Audio Data (Voice) ★ Photos or Videos Search History Usage Data Location (Approximate)
Data Not Linked to You
Diagnostics (Crash & Performance)
Data Not Used for Tracking
✓ Sommie does not track users for advertising purposes
Apple Category Data Type Linked to User Purpose Tracking
Contact InfoName, Email, PhoneYesApp FunctionalityNo
IdentifiersUser IDYesApp FunctionalityNo
User ContentOther User Content (sommelier messages)YesApp FunctionalityNo
User Content Audio Data (voice) NEW Yes App Functionality No
User Content Photos or Videos NEW Yes App Functionality No
Search HistorySearch HistoryYesApp Functionality, PersonalizationNo
Usage DataProduct Interaction, PreferencesYesApp Functionality, AnalyticsNo
LocationCoarse LocationYesApp FunctionalityNo
DiagnosticsCrash Data, Performance DataNoApp FunctionalityNo
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4. Data Sharing

iTrois does not sell users' personal data. Data sharing occurs exclusively in the following situations:

RecipientData SharedNOT SharedLegal Basis
AI Service
(AWS Bedrock / Claude Sonnet)
Text messages, sensory preferences, query context, transcribed voice text, OCR-extracted photo text Original audio files, original photos/images Prior user consent (Section 3)
E-commerce & Wine Tourism Partners Data necessary for the requested integration Voice data, photos, sensitive data Express and specific user consent
Public Authorities Data required by law or court order Legal obligation
Under no circumstances is data shared with third parties for advertising or marketing purposes without explicit user consent.
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5. User Rights

In accordance with the LGPD (Law 13.709/2018) and GDPR, you have the following rights regarding your personal data. To exercise any of these rights, contact us at privacidade@itrois.tech.

🔍 Access

Request confirmation and access to your processed data, including transcribed voice text and OCR-extracted text.

✎ Correction

Request correction of incomplete, inaccurate, or outdated data.

🗑 Deletion

Request deletion of data processed based on consent, including text generated from voice and photos.

🚫 Consent Revocation

Revoke consent for AI use, voice input, or photo submission independently at any time.

📤 Portability

Request portability of your data to another service provider in a structured format.

📝 Information

Obtain information about entities with whom we share your data.

Managing Consents

Each consent can be managed independently in the app's privacy settings:

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6. Security

We adopt technical and administrative measures to protect your data in compliance with LGPD (Law 13.709/2018) and GDPR. Access to the AI service is performed through the Amazon Bedrock platform, which holds ISO 27001 and SOC 2 Type II security certifications, ensuring data protection during processing.

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Voice and photo data are processed in a secure environment and discarded immediately after the corresponding text is generated. No persistent storage of original audio or image files occurs at any point in the processing pipeline.
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7. Data Retention

We retain data only as long as necessary for service provision or as required by applicable law.

Data TypeRetention PeriodNotes
AWS Bedrock input/outputNot stored after processingEach query processed in real time and discarded by AWS
Original audio (voice) NEW Discarded immediately Deleted after speech-to-text conversion; no storage at any point
Original photos/images NEW Discarded immediately Deleted after OCR processing; no storage at any point
Transcribed/OCR text NEW Active session only Discarded at session end, unless user opts to save query history
Profile & preferencesWhile account is activeOr until deletion request is received
Registration dataMinimum legal periodAfter account closure, as required by applicable law
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8. Cookies

We use cookies and similar technologies to enhance navigation and the app experience, maintain session state, and analyze usage patterns. You can manage cookie preferences in your device settings. We do not use cookies for cross-site tracking or advertising purposes.

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9. Minors

Sommie is intended for users 18 years of age or older, consistent with the legal drinking age in Brazil and most jurisdictions. Minors may only use Sommie under the supervision and with the consent of a legal guardian, who must accept these terms on behalf of the minor. We do not knowingly collect personal data from minors without parental consent.

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11. Changes to This Policy

This Privacy Policy may be updated periodically to reflect changes in our practices, legal requirements, or new features. Relevant changes will be communicated via in-app notification or email with at least 15 days' advance notice. Continued use of Sommie after notification of changes implies acceptance of the updated policy.

The current version of this policy is always available at sommie.io/Politica-de-privacidade-US/.

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12. Contact & Data Protection Officer

For any questions, requests to exercise your rights, or privacy concerns, please contact us:

iTrois Tecnologia e Inovação

DPO: Camilo Sales
Address: Rua Luiza Grinalda, 665 / Loja A, Sala 02 – Centro, Vila Velha, ES, Brazil
Website: sommie.io

Last updated: April 2026  |  Version 2.0  |  Ver em Português