IMPORTANT INFORMATION AND WHO WE ARE
Plate-Up Limited is the controller and is responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this policy).
Our full details are:
- Full name of legal entity: Plate-Up Limited
- Name or title of DPO: Conor Boyle
- Email address: Legal@plateup.app
- Postal address: Plate-Up Limited, Medina House, 2 Station Avenue, Bridlington East Riding of Yorkshire YO16 4LZ, United Kingdom.
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues, or any other competent supervisory authority of an EU member state if the App is downloaded outside the UK.
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 Websites and App 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. For example, if you follow or comment on the Instagram page associated with our Services, we and other users of Instagram may be able to view your profile and the posts you submit, depending on your privacy settings. Your use of third-party platforms remains subject to the terms and conditions and privacy policies of such platforms, such as Instagram’s terms of service and data policy.
Single-Sign Ons – If you sign up for Plate-Up through a third party application like Facebook, Google or Apple, you authorize us to collect your authentication information, such as your username and encrypted access credentials, and other information available through the third party application account, including the following information:
Service Providers and Business Partners – We may also receive information about you from our service providers and business partners, including companies that assist with payment processing, analytics, data processing and management (e.g. to measure ad quality and responses to ads, and to display ads that are more likely to be relevant to you, including for Plate-Up products) account management, hosting, customer and technical support, and other services which we use to personalize your Plate-Up experience. We explain in more detail why and how we use this information below.
THE DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you as follows:
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
- Contact Data: billing address, delivery address, email address and telephone numbers.
- Financial Data: bank account and payment card details.
- Transaction Data: includes details about payments to and from you, details of in-App purchases and other details of products and services you have purchased from us and our third parties.
- Technical Data: includes 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.
- 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 and time zone setting.
- Content Data: includes information stored on your Device, including friends’ lists, login information, photos, videos or other digital content and check-ins.
- Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences (including dietary and fitness goals), height, weight, and active calories, feedback and survey responses.
- Usage Data: includes details of your use of any of our Apps or your visits to any of our Websites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
- Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Location Data: When you use certain features of the App or Website, we may collect data about your general location (e.g. IP address). We use this data to provide you with location-based services (such as advertising and personalized content). Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings.
Where you consent to provide this information to us, we collect data about your height, weight, active calories, activity and dietary preferences, which may allow us to infer Special Categories of Personal Data about you. We do not collect any information about criminal convictions and offences.
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 and the Websites (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 or any Website, 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 any other activities commonly carried out in connection with an App or Website 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.
- Location Data. We also use GPS 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.
- 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;
- advertising networks; and
- search information providers;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
- Identity and Contact Data from data brokers or aggregators;
- Identity and Contact Data from publicly available sources; and
- 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.
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 (i) where you have consented before the processing; (ii) where we need to perform a contract we are about to enter or have entered with you; (iii) 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; (iv) where we need to comply with a legal or regulatory obligation.
We use personal information to manage and operate our business, including to run our Services to carry out our obligations arising from our contract with you, as well as to conduct customer research and recruit staff. Where necessary, we may also use personal information to protect the interests of the Company, our employees and affiliates (for example in the event of a legal claim).
When you contact us, we keep a record of your communication to help us know who we’ve spoken to and why. We may use your email address to inform you about our business, such as letting you know about upcoming events or changes to our business.
We may use your information to deliver marketing to you provided we have your consent to do so.
We use the information we collect from our website to provide, maintain, protect and improve it and to protect our users. We may use information collected from cookies and other technologies to improve your user experience and the overall quality of our Services.
We may also collect, use and share aggregated data. Aggregated data may be derived from personal data but is not considered personal data in law as this data cannot directly or indirectly reveal your identity. For example, we may aggregate usage data to calculate the percentage of users accessing a specific App feature. However, if ever we combine aggregated data with your personal data so that it could identify you, we will treat it as personal data.
We also use artificial intelligence to help you access a wider range of recipes. This processing does not actively process your personal data and, in any case, is not used to solely make decisions which may have a significant or legal effect upon your rights and freedoms.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
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.
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.
- Internal Third Parties - Plate-Up Limited does not currently have any other companies in its group.
- External Third Parties:
- Service providers acting as data providers, processors and developers based in United Kingdom, Thailand and India who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- Google Analytics, Apple Analytics, Smartlook to analyse date for the reasons set out above.
- The supermarkets of your choice including Amazon, Tesco, Waitrose and Ocado to enable your purchases. To facilitate these transactions, depending on your chosen third party provider, your third party provider’s username and passwords may be saved locally on your phone.
- HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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 have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements.
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. 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.
YOUR LEGAL RIGHTS
You have a number of rights in relation to your personal information under data protection law. Should you contact us in relation to the personal data we may hold, as detailed below, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either (i) the date that we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request.
Accessing your personal information
You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. This is known as a Subject Access Request. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
Correcting and updating your personal information
The accuracy of your information is important to us. If you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us at firstname.lastname@example.org.
Withdrawing your consent
Where we rely on your consent as the legal basis for processing your personal information, as set out under PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA, you may withdraw your consent at any time by contacting us. If you would like to withdraw your consent to receive any direct marketing to which you previously opted-in, you can do so using the unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, but we will keep your details on our files for the purpose of ensuring that we exclude you from any contact in due course.
Objecting to our use of your personal information and automated decisions made about you
Where we rely on legitimate business interests as the legal basis for processing your personal information for any purpose(s), as outlined under PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA, you may object to us using your personal information for these purposes by emailing or writing to us. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise, we will provide you with our justification as to why we need to continue using your data.
You may also object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use the unsubscribe tool located at the bottom of all marketing communications.
Erasing your personal information or restricting its processing
In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request. You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations, we may only process your personal information while its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
Transferring your personal information in a portable data file (“data portability”)
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA, you may ask us to provide you with a copy of that information in an appropriate format. We will provide this to you electronically in a commonly used form. You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
Complaining to the national data protection authority
You have the right to complain to the national data protection authority if you are concerned about the way we have processed your personal information. Although you have the right to complain to the data protection authority, we encourage you to contact us (as set out below) first with a view to letting us help in resolving any issues, concerns or questions. In the UK, please visit the Information Commissioner’s Office (ICO) website for further details.
You can exercise any of these rights at any time by contacting us at Plate-Up Limited, Medina House, 2 Station Avenue Bridlington East Riding of Yorkshire, YO16 4LZ, United Kingdom.
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 Interest means 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.