Privacy

1 · Who we are

Steward is a Shopify application for winery clubs, allocations and release-day billing, operated by Steward, Bangalore, India. You can reach a human at hari@steward.wine.

2 · Our two roles

We handle two different kinds of information and our responsibility differs for each.

• Your account with us. Here we are the controller. This is the winery's name, the contact details of the people who use Steward, and our billing relationship through Shopify.
• Your members' information. Here we are a processor. The winery is the controller. We only handle member information to run the club you configured, and only on your instructions.

3 · What we collect

From the winery

• Shop domain, store settings, currency and time zone
• Names and email addresses of staff who use Steward
• An encrypted Shopify access token so the app can act on your behalf

From your Shopify store, on your instruction

• Member identity — name, email, phone and delivery addresses
• Club membership — tier, join date, cadence, fulfilment preference, pause and cancellation state
• Order and charge history for releases we ran, including what failed and why
• A payment method reference only — card brand, last four digits, expiry month and year, and Shopify's identifier for it

From this website

• Page analytics through Google Analytics 4: which pages are read and which films are played, the device and browser, roughly where in the world a visit comes from, and how it arrived. Outside the European Economic Area, the United Kingdom and Switzerland this sets first-party cookies to recognise a returning visit; inside them it runs without cookies. Advertising features and Google signals are switched off, and we never send Google your name or email address. You can refuse the cookies in your browser's settings or with Google's opt-out browser add-on
• Anything you type into a form on the site, which goes to our form provider, Formspree, and to us
• If you try the demos with your winery's name, colour or logo, they are kept in your own browser's local storage so the next page shows them too. They are never sent to us, and clearing this site's data in your browser removes them

4 · What we never collect

Full card numbers, CVV codes, or anything that could be used to charge a card outside Shopify. Card details are held by Shopify and your payment gateway. Steward asks Shopify to attempt a charge; Shopify performs it. We never receive, store or transmit the number.

We also never collect tax identifiers, age-verification records or licensing documents. Those are deliberately outside what Steward does.

5 · Why we hold it, and on what basis

6 · Where it lives, and who else touches it

Application data is stored in Sydney, Australia. We use a small number of sub-processors and no others:

We do not sell information, we do not share it for advertising, and we do not use your members' information to train anything.

7 · Transfers out of your country

We operate from India and store application data in Australia, so information may be handled outside the country you are in. Where required we rely on standard contractual clauses with our sub-processors and on the protections described above. Access tokens are encrypted at rest with AES-256-GCM and access to production data is limited to the two people who operate Steward.

8 · How long we keep it

• While you are a customer — for as long as you use Steward.
• When you uninstall — we stop processing immediately, and we delete your shop data within 90 days unless you ask us to delete it sooner, which we will do.
• Charge records may be kept in aggregate, with no personal information attached, for accounting.
• Backups roll off within 35 days.

9 · Deletion and access requests

We implement Shopify's mandatory privacy webhooks:

• customers/data_request — a member asks what you hold about them. We return everything Steward holds so you can respond.
• customers/redact — a member asks to be erased. We erase their personal information and keep only an anonymous charge record.
• shop/redact — sent 48 hours after uninstall. We erase the shop's data.

You can also just email us. You can export your entire member list at any time, from inside the app, without asking us. That is a product feature and a written commitment.

10 · Your rights

Depending on where you or your members are, rights may include access, correction, erasure, restriction, objection, portability and complaint to a regulator. This includes the Australian Privacy Act 1988, the New Zealand Privacy Act 2020, the UK and EU GDPR, and India's Digital Personal Data Protection Act 2023.

If you are a wine club member rather than a winery, contact your winery first — they control your information and we act on their instructions. If you contact us directly we will pass your request to them and help them answer it.

11 · Security

• Access tokens encrypted at rest with AES-256-GCM
• All traffic over TLS
• No card numbers anywhere in our systems
• Production access limited to the two founders, with multi-factor authentication
• Every webhook verified by HMAC before it is processed

If we ever suffer a breach affecting your data we will tell you without undue delay, and we will tell you what happened rather than what our lawyers would prefer.

12 · If Steward shuts down

We commit to 90 days' written notice and a complete export of your data in a format that imports elsewhere. This is in our terms, not just here.

13 · Changes

If we change this page materially we will email the address on your account before the change takes effect, not after.