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Privacy policy

Privacy policy
Version number: 1.0
Effective date: 01/07/2020

1. Who are we?

1.1 We are 100Nuts Ltd trading as Smach. For privacy queries, you can contact us at privacy@smach.ai or via the "Contact Us" link in our application. Other contact details are available on our website, which address is provided below.

This policy applies to our Smach mobile application and any related services (the "App"), our Smach browser extension (the "Extension"), and our website www.smach.ai (the "Website"). The App, the Website, and the Extension form our "Service"


2. What's the point of this policy?

2.1. It tells you what to expect when we collect your personal information via our Service. Please only use our Service if you are completely happy with this policy.

2.2. Generally, the policy covers only information provided to us. If you give personal information to other people, such as payment providers or other websites, please check their privacy policies.

2.3. This privacy policy makes reference to the General Data Protection Regulation (EU Regulation 2016/679, "GDPR").
3. Might the policy change?

3.1 Yes. If so, we will notify you by SMS / email / in-app message or otherwise. We will assume you agree if you carry on using our Service afterwards.
4. What do we collect and why we collect it?

4.1 We collect personal information ("personal information" or "personal data") which you consent to upload to our Service or otherwise give us such as:
Some of your personal data may be classified as sensitive under GDPR. As a rule, we will never share any of your sensitive personal data with third parties. Non-sensitive personal data (such as contact details or name) or activity data may be shared with third parties if it is necessary to perform a specific action in our Service, or for targeted marketing purpose, only if you give your explicit consent, as described in sections 5 and 7 below.
4.2 We collect information (your "activity information" or "activity data") about your activity on our Service, such as:
4.3 We also collect other automated information ("automated usage data") about your use of our Service such as: the internet protocol (IP) address used to connect your device to the internet, connection information such as browser type and version, information about your device including device-type and device identifier, operating system and platform, mobile network data, a unique reference number linked to the data you enter on our system, login details.

4.4 If you use our location-related services: information about your location (your "location data") to enable us to suggest shopping venues near you. You will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by closing your account or as otherwise specified in the App (if applicable).

4.5 Our Service offers you the ability to register and login using your third party social media account details (such as your Apple ID login). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public.

4.6 We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on our Service. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

4.7 The following information about you may be provided to us by other people: limited billing information sent to us by our payment provider for verification purposes e.g., your name, email address and billing / delivery addresses.
5. What's our reason / legal basis for collecting the information?

5.1 Because it's necessary to take steps at your request to enter into a contract with you and/or to perform such a contract. This applies to personal data, activity data, as well as to location data which you supply to us.

5.2 Because it's in our "legitimate interests", e.g., to manage and improve our Service including tracking usage patterns and preventing or detecting fraud or abuse. This applies to automated usage data as well as to reviews and similar information which you provide for public display on our Service.

5.3 Because you've specifically agreed on our Service (e.g, by ticking a consent box). This applies to contact or other information which you give or allow us to use for newsletters or other targeted marketing. This also applies to your activity data. You can withdraw permission at any time as explained on our Service or by emailing us at the above email address.

5.4 Because we may wish to use it in an anonymised / aggregated way such that you cannot be identified or linked with it, in which case it is not "personal information" and is not covered by this policy.
6. How long do we keep personal information?

6.1 Until your account is closed or our contract with you has otherwise ended (or earlier if your account has been inactive for a certain amount of time provided we say so in our terms and conditions). You can close your account by following the instructions on our Service.

6.2 We may hold on to some of your information for longer (typically up to six years) if reasonably needed for legal, regulatory or tax reasons, deal with disputes, prevent fraud or abuse and/or enforce our terms and conditions.

6.3 We will keep your information which we use only for newsletters or other marketing until you tell us to stop sending you such messages.
7. To whom do we send or make available your personal information?

7.1 To other people who supply us with a service, e.g. hosts, payment providers, and businesses which help us send communications or monitor our Website and which provide us with e-commerce and other IT services. We use services from the following companies: Google (Google Analytics), Amazon (Amazon Web Services AWS).

7.2 To online grocery websites you ask us to put you in relation with, by sending them the minimum amount of information to help you enter in a transactional relationship with them, such as your name, your contact details and/or your basket information.

7.3 To other businesses to enable them to send you marketing messages, by sending them your contact details, if you have given permission. You can withdraw permission at any time as explained on our service or by emailing us at the above email address.

7.4 To other users of our Service, to the product reviews' pages of online grocery websites or to third party websites and apps selected by yourself (such as social media), if you include personal information in a photo, review or other public action on our Service. You can ask us to remove displayed information by emailing us at the above email address.

7.5 To credit reference agencies, regulators and the police and other law enforcement authorities to help deal with fraud and abuse and/or comply with legal requirements.

7.6 To insurers and professional advisers in connection with our insurance cover or to deal with legal claims.

7.7 To potential buyers so far as reasonably necessary, in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business.
8. Do we send your information outside the European Economic Area?

8.1 We may send some of your information internationally, including to countries outside the European Economic Area. Where we do so, any transfers are done in accordance with rules set by the GDPR. Examples of information sent internationally includes pictures taken with our photo functionality, which could be processed on third parties' servers located outside the European Economic Area.

8.2 Your personal data is stored within the European Economic Area and will not be transferred to any third countries
    9. What rights do you have?

    9.1 If the legal requirements are met: to ask us for access to your personal information, to rectify it if there are mistakes, to delete or restrict its use in certain circumstances or to "data portability" or to withdraw any consent you've given (e.g. marketing)

    9.2 You may also have the right to object to use of your personal information in certain circumstances.

    9.3 If you have a complaint about how we are dealing with your personal information, please contact us via the email address above, or directly with the App. If you are not happy with our response or believe we are not handling your personal information in accordance with the law, you have the right to complain to the Information Commissioner's Office (ICO).

    9.4 For more information about your rights, visit the ICO's website: www.ico.org.uk.