PRIVACY POLICY

Consent to installation of the App

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in our cookie policy and it is important that you read that information. Before installation of this App, please indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in the policy . YES I consent to the installation of the App for the purposes of [PURPOSE OF APP]. NO I do not consent to the installation of the App.

How you can withdraw consent

Once you provide consent by selecting "YES", you may change your mind and withdraw consent at any time by contacting us [help@rebake.co] but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

[Consent to processing Location Data]

YES I consent to processing of my Location Data ([including details of my current location disclosed by [GPS technology OR [OTHER TECHNOLOGY]] so that location-enabled Services are activated [to [PURPOSE OF LOCATION-ENABLED SERVICES]].NO I do not consent to processing of my Location Data and location-enabled Services are disabled in my settings.])

Location Data

[Rebake Limited] (we) are committed to protecting your personal data and respecting your privacy.

Introduction

This policy to the applies to your use of:

• REBAKE LIMITED (“REBAKE”) (which was last updated on 12th August 2024) website and mobile application software (App) [available on our site - rebake.co] OR hosted on [App Store and Google Play] (App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
• Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children, and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This policy is provided in a layered format so you can click through to the specific areas set out below. [Alternatively, you can download a pdf version of the policy here: [LINK].]

1. Important information and who we are

REBAKE is the controller and is responsible for your personal data (collectively referred to as ["Company"], "we", "us" or "our" in this policy).

Contact details

Our full details are:

• Full name of legal entity: Rebake Limited
• Registered Company Number: 14975916
• Email address: help@rebake.co
• Telephone Number: + 44 7300 235106
• Postal Address: Hereford Square London

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues. Please give us the opportunity to address your concerns before contacting the ICO. We value the chance to resolve any issues directly with you.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 10th August 2024

It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you [by SMS OR by email ORwhen you next start the App or log onto one of the Services Sites]. The new policy may be displayed on-screen, and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

2. The data we collect about you

We will only collect information about you as allowed by regulations and law. We may collect it from a range of sources, and it may relate to any of our products or services you apply for, currently hold, or have held in the past. We may collect, use, store and transfer different kinds of personal data about you as follows:

• Individual Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Identity Data includes photo identification, passport information, National Insurance number, National ID card and nationality, your signature and your biometric information such as your voice for Voice ID, or additional information that we receive from external sources that we need for compliance purposes.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Dataincludes bank account and payment card details
• Transaction Data includes details about payments to and from you and details of in-App purchases.
• Device Data includes [the type of mobile device you use,] [a unique device identifier [(for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device)],] [mobile network information,] [your mobile operating system,] [the type of mobile browser you use,] [time zone setting,] [OTHER INFORMATION]. [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website].
• Content Data includes information stored on your Device, including [friends' lists,] [login information,] [photos, videos or other digital content,] [check-ins,] [OTHER INFORMATION].
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Location Data includes your current location disclosed by [GPS technology OR [OTHER TECHNOLOGY]].

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. How is your personal data collected?

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, [make an in-App purchase,] [share data via an App's social media functions,] [enter a competition, promotion or survey,] [or] [OTHER ACTIVITIES COMMONLY CARRIED OUT IN CONNECTION WITH AN APP] and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.
• Location Data. We may also use [GPS technology OR [OTHER TECHNOLOGY]] to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by [disabling Location Data in your settings OR [OTHER WAY IN WHICH CONSENT CAN BE WITHDRAWN]].
• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties [and public sources] as set out below
• Device Data from the following parties:
  analytics providers [such as Google based outside the UK];
  advertising networks [such as Google based outside the UK];
  and search information providers [such as Google based outside the UK].
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services [Stripe based [inside ORoutside] the UK];
• Identity and Contact Data from publicly available sources [such as Companies House and the electoral register based inside the UK]; and
• We work with the following business partners and service providers to provide you with our Services:
• Infrastructure
• Google LLC (Google Cloud Platform, Firebase)
• Amazon Web Services, Inc
• Platform hosting
• Apple, Inc. (Apple Store)
• Google, Inc. (Google Play Store)
• Web hosting
• Vercel, Inc. (Vercel)
• Domain management
• Namecheap, Inc.
• Monitoring
• Google LLC (Firebase)
• Database
• MongoDB, Inc
• Registration and Authentication
• Google LLC (Firebase)
• Website content management
• Builder IO
• Payments
• Stripe, Inc
• [Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.]

Cookies

We use cookies [and/or other tracking technologies] to distinguish you from other users of the App, App Site, the distribution platform (Appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy .

4. How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

• Where you have consented before the processing.
• Where we need to perform a contract, we are about to enter or have entered with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

[We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.]

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

5. Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table [Purposes for which we will use your personal data]:

• External Third Parties as set out in the [Glossary].
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

[We do not transfer your personal data outside the UK].

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data security

All information you provide to us is stored on our secure servers. Any payment transactions [carried out by us or Stripe - our chosen third-party provider of payment processing services] will be encrypted using [Secured Sockets Layer technology OR [ALTERNATIVE ENCRYPTION TECHNOLOGY]]. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality

[We will collect and store personal data on your Device using [application data caches and browser web storage (including HTML5) OR [ALTERNATIVE MECHANISMS]] and other technology.]

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so. Although we do our best to protect your Personal Data we cannot guarantee its security during the transmission of information via the internet, as any such transmission is at your own risk.

8. Data retention

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for [six] years after they cease being customers for [tax] purposes. This allows us to comply with legal and regulatory requirements or use it where we need to for our legitimate purposes such as managing your account and dealing with any disputes or concerns that may arise. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see [your legal rights] below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • if you want us to establish the data's accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• You also have the right to ask us not to continue to process your personal data for marketing purposes.
• You can exercise any of these rights at any time by contacting us at help@rebake.co

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interestmeans the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Internal third parties

• Our employees, agents and/or professional advisors.

External third parties

• Service providers based in [the United Kingdom, United States and Ireland ] who provide [IT and system administration services].
• Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers based in [the United Kingdom] who provide [consultancy, banking, legal, insurance and accounting services].
• HM Revenue and Customs, regulators and other authorities [acting as processors or joint controllers] based in [the United Kingdom], [who require reporting of processing activities in certain circumstances].
• MARKET RESEARCHERS FOR DATA ANALYSIS TO FURTHER OPTIMISE OUR SERVICES.

MOBILE APPLICATIONS refer to any mobile applications owned by Rebake Limited that are available on the Apple App Store and Google Play Store.

USER or YOU refer to any third party that accesses the Website and is not either (i) employed by Rebake Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Rebake Limited Ltd and accessing the Website in connection with the provision of such services.

WEBSITEmeans rebake.co and any sub-domains of this website unless expressly excluded by their own terms and conditions.