#Privacy Policy *Last updated: December 11th, 2020* ## Introduction **Thank you for joining PlateHunt!** PlateHunt Ltd ("we", "us", "our", "PlateHunt", "Company") is committed to respecting and protecting your privacy and your data, in compliance with laws and guidelines, and the EU General Data Protection Regulation ("GDPR"). This Privacy and Data Protection Policy ("Privacy Policy") defines how we collect, use and keep your data safe. Please read and understand this Privacy Policy carefully. By accessing the PlateHunt mobile application and the services it depends on ("Application", "Service"), and the website "www.platehunt.com" ("Website"), you agree to have read, understood and accepted all the terms of this Privacy Policy in its entirety without modification, and you consent to the collection and use of data by us as outlined in this Privacy Policy. We reserve the right to amend this Privacy Policy at our discretion at any time. The Privacy Policy "Last updated" date will be changed accordingly, and the updated version will be effective as soon as it is accessible. We may notify you of these changes by sending you a notification. We encourage you to periodically review this Privacy Policy to be informed of how we protect your data and information. PlateHunt Ltd is your Data Controller and responsible for your Personal Data. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us by email at privacy@platehunt.com. This Privacy Policy is incorporated in the [Terms and Conditions](https://www.platehunt.com/terms/) of the Application. The Application is intended for users who are at least 18 years old, and you must not use the Application unless you are aged 16 or older. We do not knowingly collect data relating to children. ## Data we collect ### Personal Data "Personal Data" refers to personally identifiable information. 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: 1. Profile and Identity Data: This is data relating to your name, gender, date of birth. This data may be retrieved from your basic account information (name, email, gender, date of birth, profile picture, friends list) on social media platforms (for example Facebook, Twitter) that you choose to share with us by linking your social media account to your PlateHunt account. 2. Contact Data: This is data relating to your email address, phone number. 3. Technical Data: This is data relating to your IP address, browser type, device type, versions, location. 4. Marketing Data: This is data relating to your preferences in receiving marketing information or other information from us. 5. Usage Data: This is data relating to your use of the Website, Application and related services. It includes, but is not limited to, information about your native actions that are integral to the Application, such as posting, liking and interacting with other users. ### Aggregated Data "Aggregated Data" refers to data which may be derived from your Personal Data but is not considered Personal Data in law as it does not and will not directly or indirectly reveal your identity. We may collect, use, store, transfer and share different kinds of Aggregated Data, including, but not limited to: 1. Restaurants aggregate ratings and metrics from users recommendations and activity. 2. Anonymised demographics data for statistical and research purposes. In the case we combine or connect Aggregated Data with your Personal Data in a way 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 Sensitive Data We do not collect any "Special Category Data" about you, nor "Criminal Offense Data", sensitive information which includes details about race, ethnicity, religion, sexual orientation, political opinions, criminal convictions and offences. ## How we use your data ### Lawful basis for processing Under GDPR there are different valid lawful basis for processing your Personal Data. We will only collect and process your Personal Data when the law allows us so, in particular in the following circumstances: 1. Consent: We offer you the choice and control over how we use your data, for example when asking to opt in to a service. 2. Contract: We require certain information from you in order to provide you with the service agreed in the Terms and Conditions. 3. Legitimate Interests: We may need certain information from you in order to meet our legitimate interests, including (but not limited to) running our business or protecting our services. This information will not have a material impact on your rights, freedom or interests. ### Uses We present the different categories of your Personal Data we collect, on what lawful basis we do so, and the purpose. The purposes for which we use your data may be broader than described, but we will never process your data without a lawful basis for doing so, and for non-related purposes. 1. Profile and Identity Data: - Contract: We need to process this data in order to create your profile in the Application. You will need to include Personal Data when creating your profile on the Application, so the content you create is linked to your profile and to you, and we are able to provide the services the Application is designed for. - Consent: We need to collect basic information (name, email, gender, date of birth, profile picture, friends list) from the social network accounts you have linked to the Application in order to complete your profile creation. You may give us your explicit consent by signing up through your social network account and by linking your social network account to the PlateHunt account. 2. Contact Data: - Legitimate Interests: We need to process this data in order to provide support to you in case there are issues with the Application. For example, we use your email address to send you the Personal Data you have requested according to GDPR and to contact you for security or service issues. 3. Technical Data: - Legitimate Interests: We need to process this data in order to protect our services and the Application and for running our business and network security. 4. Marketing Data: - Consent: You may give us your explicit consent to receive targeted advertisements from third-parties and personal communication and experiences. 5. Usage Data: - Contract: We need to process your interaction (posting, commenting, liking and interaction with other users) with the Application in order to provide the services and content the Application is designed for. - Legitimate Interests: We need to process your interaction (logs, metrics) with the Application in order to run our business and network security. Some of these metrics will be used as Aggregated Data. We need to process your interaction (feedback, reports, survey responses) in order to improve the Application. ### Change of Purpose We will only use your Personal Data for the purposes for which we have collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. ## Third parties We will not disclose your Personal Data to any third party without your express consent, except where we are required to do so in order to comply with our legal obligations, exercise and enforce our legal rights, protect our employees, prevent or investigate crime or prosecute offenders. In any case, this disclosure will comply with the relevant laws. We may use third-party advertising companies to serve advertisements when you visit the Application. These companies may use information about your visits to the Application and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you. You may opt out of targeted experiences and advertisements at any time. The Application may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Application, any information you provide to these third parties is not covered by this Privacy Policy. In the event the Company anticipates a change in control or the acquisition of all or part of our business or assets we may share Personal Data with interested parties. If the Company is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or that transaction. Upon such transfer, the privacy policy of the acquiring entity may govern the further use of your Personal Data. ## Your Privacy Rights ### Data Deletion You may delete your account at any time. This operation will remove your profile, your Personal Data, your generated content and all other information or data linked to you from our systems. ### Data Request You may request to receive a copy of your Personal Data through the Application, or to amend any data we hold about you, should it be incorrect. We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). You will not have to pay a fee to access your Personal Data. However, should your request be clearly unfounded, excessive or repetitive, we may charge a reasonable fee or we may refuse to comply with your request. We try to respond to all legitimate requests within one month. It may take us longer than a month if your request is complex or you have made a number of requests, but we will notify you and keep you updated. ### Data Protection We care about your data, and we strive to keep it secure. We implement a variety of security measures, including adopting a secure protocol within our Service. Any Personal Data collected by us is only accessible to a limited number of employees who are bound by obligations of confidentiality and have special rights to the system. Unfortunately, no transmission of data over the internet if guaranteed to be completely secure, and third parties not under the control of PlateHunt Ltd may intercept or access transmissions or private communications unlawfully. We cannot warrant the security of any Personal Data you transmit to us, and any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us. ### Data Restriction You can request we stop sending you targeted marketing material, and we stop showing you targeted advertisements from third-parties. We will continue to retain other non opt-in Personal Data. ### Data Retention We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. ### Data Transfer We currently store your data in the EEA. Some of our external third parties may be based outside the EEA and their processing of your Personal Data will involve a transfer of data outside the EEA. In case we need to 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. - We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. ## Contact us You can contact us for queries about your Personal Data or this Privacy Policy at: privacy@platehunt.com You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.