Last updated October 06, 2024
This Privacy Notice
for Poach Apps Ltd
( 'we', 'us', or
'our' ),
describes how and why we might access, collect, store, use, and/or share (
'process' ) your personal information when you use
our services ( 'Services'
), including when you:
- Download and use
our mobile application ( Poach Recipes) , or any other application of ours that links to this Privacy Notice
- Engage with us
in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this Privacy Notice
will help you understand your privacy rights and choices. We are responsible for making decisions
about how your personal information is processed. If you do not agree with our policies and
practices, please do not use our Services. If you still have any
questions or concerns, please contact us at team@poachapp.com
.
SUMMARY OF KEY POINTS
This summary provides key points from our Privacy Notice,
but you can find out more details about any of these topics by clicking the link following each
key point or by using our table of contents below to find the section you
are looking for.
What personal information do we process? When you
visit, use, or navigate our Services, we may process personal information depending on how you
interact with us and the Services, the choices you make, and the products and features you use. Learn
more about personal
information you disclose to us.
Do
we process any sensitive personal information? Some of the information may be considered
'special' or 'sensitive' in certain
jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs.
We do not process sensitive personal information.
Do
we collect any information from third parties?
We do not collect any information from third parties.
How do we process your information? We process your
information to provide, improve, and administer our Services, communicate with you, for security and
fraud prevention, and to comply with law. We may also process your information for other purposes with
your consent. We process your information only when we have a valid legal reason to do so. Learn more
about how we process
your information.
In
what situations and with which parties do we share personal
information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal
information.
How do we keep your information safe? We have adequate
organisational and technical
processes and procedures in place to protect your personal information. However, no electronic
transmission over the internet or information storage technology can be guaranteed to be 100% secure,
so we cannot promise or guarantee that hackers, cybercriminals, or other
unauthorised third parties will not be able to defeat our security
and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.
What are your rights? Depending on where you are
located geographically, the applicable privacy law may mean you have certain rights regarding your
personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to
exercise your rights is by submitting a data subject access request
, or by contacting us. We will consider and act upon any request in
accordance with applicable data protection laws.
Want to
learn more about what we do with any information we collect? Review the Privacy Notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO
WE COLLECT?
Personal information you disclose to
us
In
Short: We collect personal information
that you provide to us.
We collect
personal information that you voluntarily provide to us when you
express an interest in obtaining information about
us or our products and Services, when you participate in activities on the Services, or otherwise
when you contact us.
Sensitive Information.
We do not process sensitive information.
Application Data. If you use our application(s), we also may
collect the following information if you choose to provide us with access or permission:
- Mobile Device Data. We automatically collect device
information (such as your mobile device ID, model, and manufacturer), operating system, version
information and system configuration information, device and application identification numbers,
browser type and version, hardware model Internet service provider and/or mobile carrier, and
Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may
also collect information about the phone network associated with your mobile device, your mobile
device’s operating system or platform, the type of mobile device you use, your mobile device’s
unique device ID, and information about the features of our application(s) you accessed.
This
information is primarily needed to maintain the security and operation of our application(s),
for troubleshooting, and for our internal analytics and reporting purposes.
All
personal information that you provide to us must be true, complete, and accurate, and you must
notify us of any changes to such personal information.
Information automatically collected
In
Short: Some information — such
as your Internet Protocol (IP) address and/or browser and device characteristics —
is collected automatically when you visit our
Services.
We
automatically collect certain information when you visit, use, or navigate the Services. This
information does not reveal your specific identity (like your name or contact information) but
may include device and usage information, such as your IP address, browser and device
characteristics, operating system, language preferences, referring URLs, device name, country,
location, information about how and when you use our Services, and other technical
information. This information is primarily needed to maintain the security and operation of
our Services, and for our internal analytics and reporting purposes.
The
information we collect includes:
- Log
and Usage Data. Log and usage data is service-related, diagnostic, usage, and
performance information our servers automatically collect when you access or use our
Services and which we record in log files. Depending on how you interact with us, this log
data may include your IP address, device information, browser type, and settings and
information about your activity in the Services (such
as the date/time stamps associated with your usage, pages and files viewed, searches, and
other actions you take such as which features you use), device event information (such as
system activity, error reports (sometimes called
'crash dumps' ), and hardware settings).
- Device Data. We collect device data such as
information about your computer, phone, tablet, or other device you use to access the
Services. Depending on the device used, this device data may include information such as
your IP address (or proxy server), device and application identification numbers, location,
browser type, hardware model, Internet service provider and/or mobile carrier, operating
system, and system configuration information.
- Location Data. We collect location data such as
information about your device's location, which can be either precise or imprecise. How much
information we collect depends on the type and settings of the device you use to access the
Services. For example, we may use GPS and other technologies to collect geolocation data
that tells us your current location (based on your IP address). You can opt out of allowing
us to collect this information either by refusing access to the information or by disabling
your Location setting on your device. However, if you choose to opt out, you may not be able
to use certain aspects of the Services.
2. HOW DO WE
PROCESS YOUR INFORMATION?
In Short: We process your
information to provide, improve, and administer our Services, communicate with you,
for security and fraud prevention, and to comply with law. We may also process your
information for other purposes with your
consent.
We
process your personal information for a variety of reasons, depending on how you interact
with our Services, including:
Poach Apps Ltd
85 Great
Portland Street
London
,
London
W1W 7LT
United Kingdom
Based on the applicable laws
of your country
or state of residence in the US
, you may
have the right to request
access to the personal
information we collect from
you, details about how we have
processed it, correct
inaccuracies, or delete your
personal information. You may
also have the right to
withdraw your consent to
our processing of your
personal information. These
rights may be limited in some
circumstances by applicable
law. To request to review,
update, or delete your
personal information, please
fill out and submit a
data subject
access
request
.
- To save or
protect an individual's vital
interest. We may process your
information when necessary to save or protect an
individual’s vital interest, such as to prevent
harm.
3. WHAT LEGAL
BASES DO WE RELY ON TO PROCESS YOUR
INFORMATION?
In
Short: We only process your personal
information when we believe it is necessary and
we have a valid legal reason (i.e. legal basis) to
do so under applicable law, like with your
consent, to comply with laws, to provide you
with services to enter into or fulfil our contractual
obligations, to protect your rights, or to fulfil our legitimate
business interests.
If you
are located in the EU or UK, this section
applies to
you.
The General Data
Protection Regulation (GDPR) and UK GDPR require
us to explain the valid legal bases we rely on in
order to process your personal information. As
such, we may rely on the following legal bases to
process your personal information:
- Consent. We
may process your information if you have given
us permission (i.e.
- Legal
Obligations. We may process your
information where we believe it is necessary
for compliance with our legal obligations,
such as to cooperate with a law enforcement
body or regulatory agency, exercise or defend
our legal rights, or disclose your information
as evidence in litigation in which we are
involved.
- Vital
Interests. We may process your
information where we believe it is necessary
to protect your vital interests or the vital
interests of a third party, such as situations
involving potential threats to the safety of
any person.
If you
are located in Canada, this section
applies to
you.
We may process your
information if you have given us specific
permission (i.e.
express consent) to use your personal
information for a specific purpose, or in
situations where your permission can be inferred
(i.e. implied
consent). You can withdraw
your consent at any
time.
In some exceptional
cases, we may be legally permitted under
applicable law to process your information
without your consent, including, for
example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations
and fraud detection and prevention
- For business
transactions provided certain conditions are
met
- If it is contained in
a witness statement and the collection is
necessary to assess, process, or settle an
insurance claim
- For identifying
injured, ill, or deceased persons and
communicating with next of kin
- If we have reasonable
grounds to believe an individual has been, is,
or may be victim of financial abuse
- If it is reasonable
to expect collection and use with consent
would compromise the availability or the
accuracy of the information and the collection
is reasonable for purposes related to
investigating a breach of an agreement or a
contravention of the laws of Canada or a
province
- If disclosure is
required to comply with a subpoena, warrant,
court order, or rules of the court relating to
the production of records
- If it was
produced by an individual in the course of
their employment, business, or profession and
the collection is consistent with the purposes
for which the information was produced
- If the
collection is solely for journalistic,
artistic, or literary purposes
- If the
information is publicly available and is
specified by the regulations
In
Short: We may share
information in specific situations described
in this section and/or with the following
third
parties.
We may need to
share your personal information in the following
situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
5.
HOW LONG DO WE KEEP YOUR
INFORMATION?
In
Short: We keep
your information for as long as
necessary to
fulfil
the purposes outlined in
this Privacy Notice unless
otherwise required by
law.
We
will only keep your personal
information for as long as it is
necessary for the purposes set out
in this Privacy Notice, unless a
longer retention period is required
or permitted by law (such as tax,
accounting, or other legal
requirements).
When
we have no ongoing legitimate
business need to process your
personal information, we will either
delete or
anonymise
such information, or, if this
is not possible (for example,
because your personal information
has been stored in backup archives),
then we will securely store your
personal information and isolate it
from any further processing until
deletion is possible.
6.
HOW DO WE KEEP YOUR
INFORMATION
SAFE?
In
Short: We aim
to protect your personal
information through a system of
organisational and
technical security
measures.
We
have implemented appropriate and
reasonable technical and
organisational security
measures designed to protect the
security of any personal information
we process. However, despite our
safeguards and efforts to secure
your information, no electronic
transmission over the Internet or
information storage technology can
be guaranteed to be 100% secure, so
we cannot promise or guarantee that
hackers, cybercriminals, or other
unauthorised
third parties will not be
able to defeat our security and
improperly collect, access, steal,
or modify your information. Although
we will do our best to protect your
personal information, transmission
of personal information to and from
our Services is at your own risk.
You should only access the Services
within a secure environment.
7.
DO WE COLLECT INFORMATION
FROM
MINORS?
In
Short: We do
not knowingly collect data from or
market to
children under 18 years of age .
We do
not knowingly collect, solicit data
from, or market to children under 18
years of age, nor do we knowingly
sell such personal information. By
using the Services, you represent
that you are at least 18 or that you
are the parent or guardian of such a
minor and consent to such minor
dependent’s use of the Services. If
we learn that personal information
from users less than 18 years of age
has been collected, we will
deactivate the account and take
reasonable measures to promptly
delete such data from our records.
If you become aware of any data we
may have collected from children
under age 18, please contact us at
team@poachapp.com
.
8.
WHAT ARE YOUR PRIVACY
RIGHTS?
In
Short:
Depending on your state of
residence in the US or in some
regions, such as
the European Economic Area (EEA),
United Kingdom (UK), Switzerland,
and Canada ,
you have rights that allow you
greater access to and control over
your personal information.
You
may review, change, or terminate
your account at any time,
depending on your country,
province, or state of residence.
In
some regions (like the
EEA, UK, Switzerland, and Canada ),
you have certain rights under
applicable data protection laws.
These may include the right (i) to
request access and obtain a copy of
your personal information, (ii) to
request rectification or erasure;
(iii) to restrict the processing of
your personal information; (iv) if
applicable, to data portability; and
(v) not to be subject to automated
decision-making. In certain
circumstances, you may also have the
right to object to the processing of
your personal information. You can
make such a request by contacting us
by using the contact details
provided in the section '
HOW
CAN YOU CONTACT US ABOUT THIS
NOTICE?
'
below.
We
will consider and act upon any
request in accordance with
applicable data protection laws.
If you
are located in the EEA or UK and you
believe we are unlawfully processing
your personal information, you also
have the right to complain to your
Member
State data protection
authority
or UK
data protection
authority.
If you
are located in Switzerland, you may
contact the Federal
Data Protection and
Information
Commissioner.
Withdrawing
your consent: If we
are relying on your consent to
process your personal information,
which may be express and/or implied
consent depending on the applicable
law,
you have the right to
withdraw your consent at any time.
You can withdraw your consent at any
time by contacting us by using the
contact details provided in the
section '
HOW
CAN YOU CONTACT US ABOUT THIS
NOTICE?
'
below
.
However,
please note that this will not affect
the lawfulness of the processing
before its withdrawal nor, when
applicable law allows,
will it affect the processing
of your personal information conducted
in reliance on lawful processing
grounds other than consent.
If you have
questions or comments about your
privacy rights, you may email us at
team@poachapp.com
.
9.
CONTROLS FOR DO-NOT-TRACK
FEATURES
Most
web browsers and some mobile
operating systems and mobile
applications include a Do-Not-Track
(
'DNT' )
feature or setting you can activate
to signal your privacy preference
not to have data about your online
browsing activities monitored and
collected. At this stage, no uniform
technology standard for
recognising
and implementing DNT signals
has been
finalised
. As such, we do not currently
respond to DNT browser signals or
any other mechanism that
automatically communicates your
choice not to be tracked online. If
a standard for online tracking is
adopted that we must follow in the
future, we will inform you about
that practice in a revised version
of this Privacy
Notice.
California
law requires us to let you know how we
respond to web browser DNT signals.
Because there currently is not an
industry or legal standard for
recognising
or
honouring
DNT signals, we do not respond
to them at this time.
10.
DO UNITED STATES RESIDENTS
HAVE SPECIFIC PRIVACY
RIGHTS?
In
Short: If you
are a resident of
California, Colorado, Connecticut,
Delaware, Florida, Indiana, Iowa,
Kentucky, Montana, New Hampshire,
New Jersey, Oregon, Tennessee,
Texas, Utah, or Virginia , you
may have the right to request
access to and receive details
about the personal information we
maintain about you and how we have
processed it, correct
inaccuracies, get a copy of, or
delete your personal information.
You may also have the right to
withdraw your consent to our
processing of your personal
information. These rights may be
limited in some circumstances by
applicable law. More information
is provided
below.
Categories
of Personal Information We
Collect
We
have collected the following
categories of personal information
in the past twelve (12)
months:
Category | Examples | Collected |
A.
Identifiers
|
Contact
details, such as real name,
alias, postal address,
telephone or mobile contact
number, unique personal
identifier, online
identifier, Internet
Protocol address, email
address, and account
name
|
|
B.
Personal information as
defined in the California
Customer Records
statute
|
Name,
contact information,
education, employment,
employment history, and
financial
information
|
|
|
Gender,
age, date of birth, race and
ethnicity, national origin,
marital status, and other
demographic
data
|
|
|
Transaction
information, purchase
history, financial details,
and payment
information
|
|
|
Fingerprints
and
voiceprints
|
|
|
Browsing
history, search history,
online
|
|
|
Device
location
|
|
|
Images
and audio, video or call
recordings created in
connection with our business
activities
|
|
|
Business
contact details in order to
provide you our Services at
a business level or job
title, work history, and
professional qualifications
if you apply for a job with
us
|
|
|
Student
records and directory
information
|
|
|
Inferences
drawn from any of the
collected personal
information listed above to
create a profile or summary
about, for example, an
individual’s preferences and
characteristics
|
|
|
|
|
We may
also collect other personal
information outside of these
categories through instances where you
interact with us in person, online, or
by phone or mail in the context
of:
- Receiving
help through our customer support
channels;
- Participation
in customer surveys or contests; and
- Facilitation
in the delivery of our Services and to
respond to your inquiries.
Sources
of Personal
Information
Learn
more about the sources of personal
information we collect in '
WHAT
INFORMATION DO WE
COLLECT?
'
How
We Use and Share Personal
Information
Learn about
how we use your personal information
in the section, ' HOW
DO WE PROCESS YOUR
INFORMATION?
'
Will
your information be shared with
anyone
else?
We
may disclose your personal
information with our service
providers pursuant to a written
contract between us and each
service provider. Learn more about
how we disclose personal
information to in the section,
'
WHEN
AND WITH WHOM DO WE SHARE YOUR
PERSONAL
INFORMATION?
'
We
may use your personal information
for our own business purposes,
such as for undertaking internal
research for technological
development and demonstration.
This is not considered to be
'selling'
of your personal
information.
We
have not disclosed, sold, or
shared any personal information to
third parties for a business or
commercial purpose in the
preceding twelve (12) months.
We will
not sell or share personal
information in the future
belonging to website visitors,
users, and other consumers.
Your
Rights
You
have rights under certain US state
data protection laws. However, these
rights are not absolute, and in
certain cases, we may decline your
request as permitted by law. These
rights include:
- Right
to know whether or not we
are processing your personal data
- Right
to access your personal
data
- Right
to correct inaccuracies
in your personal data
- Right
to request the deletion
of your personal data
- Right
to obtain a copy of the
personal data you previously shared
with us
- Right
to non-discrimination for
exercising your rights
- Right
to opt out of the
processing of your personal data if
it is used for targeted advertising
(or sharing as defined under California’s privacy law) 'profiling'
Depending
upon the state where you live, you
may also have the following
rights:
- Right to
obtain a list of the categories of
third parties to which we have
disclosed personal data (as
permitted by applicable law,
including
California's and Delaware's privacy law)
- Right to
obtain a list of specific third
parties to which we have disclosed
personal data (as permitted by
applicable law, including Oregon’s
privacy law)
- Right to
limit use and disclosure of
sensitive personal data (as
permitted by applicable law,
including California’s privacy
law)
- Right to
opt out of the collection of
sensitive data and personal data
collected through the operation of a
voice or facial recognition feature
(as permitted by applicable law,
including Florida’s privacy
law)
How
to Exercise Your
Rights
To
exercise these rights, you can
contact us by
submitting
a data
subject access
request,
by emailing us at
team@poachapp.com ,
or by
referring to the contact details at
the bottom of this
document.
Under
certain US state data protection
laws, you can designate an
authorised
agent to make a request on
your behalf. We may deny a request
from an
authorised
agent that does not submit
proof that they have been validly
authorised
to act on your behalf in
accordance with applicable
laws.
Request
Verification
Upon
receiving your request, we will need
to verify your identity to determine
you are the same person about whom
we have the information in our
system. We will only use personal
information provided in your request
to verify your identity or authority
to make the request. However, if we
cannot verify your identity from the
information already maintained by
us, we may request that you provide
additional information for the
purposes of verifying your identity
and for security or fraud-prevention
purposes.
If you
submit the request through an
authorised
agent, we may need to collect
additional information to verify
your identity before processing your
request and the agent will need to
provide a written and signed
permission from you to submit such
request on your
behalf.
Appeals
Under
certain US state data protection
laws, if we decline to take action
regarding your request, you may
appeal our decision by emailing us
at
team@poachapp.com
. We
will inform you in writing of any
action taken or not taken in
response to the appeal, including a
written explanation of the reasons
for the decisions. If your appeal is
denied, you may submit a complaint
to your state attorney general.
California
'Shine The Light'
Law
California
Civil Code Section 1798.83, also
known as the
'Shine The Light' law,
permits our users who are California
residents to request and obtain from
us, once a year and free of charge,
information about categories of
personal information (if any) we
disclosed to third parties for
direct marketing purposes and the
names and addresses of all third
parties with which we shared
personal information in the
immediately preceding calendar year.
If you are a California resident and
would like to make such a request,
please submit your request in
writing to us by using the contact
details provided in the section '
HOW
CAN YOU CONTACT US ABOUT THIS
NOTICE?
'
11.
DO WE MAKE UPDATES TO THIS
NOTICE?
In
Short: Yes, we will
update this notice as necessary
to stay compliant with relevant
laws.
We
may update this Privacy Notice
from time to time. The updated
version will be indicated by an
updated
'Revised'
date at the top of this
Privacy Notice. If we make
material changes to this Privacy
Notice, we may notify you either
by prominently posting a notice of
such changes or by directly
sending you a notification. We
encourage you to review this
Privacy Notice frequently to be
informed of how we are protecting
your
information.
12.
HOW CAN YOU CONTACT US
ABOUT THIS
NOTICE?
If
you have questions or comments
about this notice, you may
email us at
team@poachapp.com or
contact
us by post
at:
13.
HOW CAN YOU REVIEW,
UPDATE, OR DELETE THE DATA
WE COLLECT FROM
YOU?