Swapmeals | Privacy

This privacy statement explains how we collect, use and store personal data that you provide to us. "Personal Data" is defined in Data Protection Regulation 2016/679 ("General Data Protection Regulation" or "GDPR") as data concerning an identified or identifiable natural person. An identifiable person is someone who can be identified, directly or indirectly, by reference to an identifier such as a name, position data or specific health data. This statement also provides information about our security procedures, your privacy rights (including how to access your personal data) and what protection the law provides you. This statement shall be updated from time to time. We will let you know if this is the case and mention the changes applied. We also recommend that you read and understand any other notice you receive from us when we collect or process your data. We must rely on the accuracy of the personal data we collect about you so that we can comply with the conditions set out in this privacy statement. We therefore kindly ask you to inform us of changes in your personal data during our contractual relationship.

Content

Who are we?
What data do we collect about you?
For what purposes will your personal data be used and on what basis?
Your legal rights
Your legal rights – additional information
Data retention & security
Third parties receiving personal data
Closure

1. Who are we?

"We" are Verdi Food B.V., active under our trade name "Swapmeals". We are located at Villafloraweg 1, 5928SZ, Venlo, the Netherlands and we are registered in the trade register under number 70122296. Our website is https://www.swapmeals.com

Swapmeals mainly offers recipes that fit within a generally healthy diet. In addition, Swapmeals wants to offer customers the opportunity to tailor these recipes to their health status or health goals. We work with an online platform on which the offered recipes can be personalized based on your nutritional needs. You can choose to have ingredients in recipes adjusted (swapped) using your Noory Profile, your Swapmeals account, or by simply selecting certain dietary and/or dietary preferences without using an account. When you use a Swapmeals account, we collect and use your personal data that you provide during your visit to the Swapmeals website to enable the aforementioned service. When you use your Noory profile, we explain to you how we collect, use and store your personal data that you provide to us in the Noory Privacy Statement.

Your privacy rights, as set out in this privacy statement, apply to all personal data we collect, based on your expressed consent or because this is necessary for the performance of the contract we have concluded with you. We may collect your personal data if you communicate with Swapmeals, for example if you use Swapmeals' services and if you contact customer support. We have appointed a Data Protection Officer (DPO) who is responsible for monitoring questions related to this privacy statement and your privacy rights. For questions about this privacy statement and your privacy rights, please contact our DPO using the contact details below. We stress that the DPO has a duty of confidentiality with regard to questions and/or issues that you submit to the FG. Contact details FG: privacy@verdifood.com.

2. What data do we collect about you?

If you create a Swapmeals account, we collect your personal data and in particular the following:

Account details: we collect your e-mail address and password.

Personalization data: we collect your name and avatar photo.

Technical data: through cookies or similar techniques, we collect your IP address, cookie ID, web browser, time zone and location, the web pages you have visited on our website and the advertisements you have viewed or clicked through, the operating system and platform and other technology on the equipment.

Data for product availability: we collect information about your country of residence.

3. For what purposes will your personal data be used and on what basis?

We process your account data to implement a contract with you (Article 6(1)(b) GDPR). We process your other personal data as indicated above for the following purposes, provided that you have given your consent (Article 6(1)(a) GDPR):

Creating and offering a (limited) personalized, online nutrition profile for the presentation of recipes and 'swap' possibilities based on your nutritional profile;

Facilitate that you can order the ingredients in your chosen recipes from a supermarket with which Swapmeals collaborates;

Personalizing your profile and our communication with you;

Sending messages for marketing purposes, including Swapmeals' newsletters;

4. Your legal rights

After you have provided personal data to us, you have reasonable access to that information yourself so that you can update, modify, or request an overview or deletion. More specifically, these are your rights based on the current privacy legislation:

Request for access

You can request access to your personal data that we have collected about you. You can receive a copy of the personal data we hold about you and check that we process it lawfully.

Request for rectification

You can request the rectification of the personal data we have collected about you. You may have incomplete or incorrect data we hold about you corrected, although we do need to verify the accuracy of the new data you provide to us.

Request for deletion ("Right to be forgotten")

This right allows you to ask us to delete or erase personal data when processing it is based on your consent and you withdraw this consent so that there is no longer another legal basis for processing. You also have the right to ask us to delete or delete your personal data if there is no good reason to process it further and if we have processed your information unlawfully. However, please note that for specific legal reasons, we cannot always comply with your request for removal. If this is the case and applies, you will be informed at the time of your request.

The right to limited processing

You have the right to request limited processing of your personal data if (i) you believe that the personal data you provide is no longer correct and you want to give us a certain period of time to check the inaccuracy of the personal data, or (ii) if processing is unlawful and you request the limited use of personal data instead of erasure of personal data, or (iii) we no longer need the personal data for the purposes of processing but you need this data for the determination, exercise or defence of legal claims. The personal data that need to be processed based on (one of) these conditions will only be processed based on explicit consent given by yourself.

The right to data portability

You have the right to obtain the personal data we have collected about you in a structured, commonly used and machine-readable form. You also have the right to request the transfer of the personal data to a third party.

5. Your rights – additional information

Right to withdraw consent

If the processing of your personal data is based on your prior, explicit consent, you will have the right to withdraw your explicit consent. Withdrawal of your express consent will not affect the lawfulness of the processing based on your explicit consent before the withdrawal. Withdrawing consent is as easy as giving consent. If you have indicated that you want to receive our marketing messages, you will, for example, be given an opt-out option. If you no longer wish to give us permission to process certain personal data in your food profile, you can delete it yourself in your nutrition profile.

In this principle, this is free of charge

You do not have to pay a fee to access your personal data (or to exercise other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or exaggerated. We may also refuse to comply with your request in this case.

Verification of your identity

We may need to ask you for specific information that will allow us to confirm your identity and ensure your right to access your personal data or exercise your other rights. This is a security measure to ensure that personal data is not disclosed to a person who does not have the right to receive this data. We may also contact you for further information regarding your request in order to speed up our response.

6. Data retention & security

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected this data, in particular to comply with legal, accounting or reporting requirements. In order to determine the correct retention period for personal data, we take into account the quantity, nature and sensitivity of the personal data, the potential risk of damage due to unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can fulfil those purposes by using means other than the retention of your personal data. Our website https://www.swapmeals.com is secure, up-to-date and complies with the latest security guidelines. Your personal data will be stored securely on Servers of Google Cloud Platform (GoogleIreland Limited) based in the European Union. These security measures prevent your personal data from being accidentally lost, used or opened, altered, disclosed or destroyed in an unauthorized manner. We use security procedures and business systems to limit the use of your personal data to the DPO, authorized employees, agents, contractors and other third parties who need to know this information for business reasons. The personal data to which they have access shall be kept to a minimum in relation to the business purpose for which they are intended. These parties are all bound by a duty of confidentiality.

7. Third parties receiving personal data

We share your personal data with third parties with whom we cooperate to provide our products and services – only and to the extent necessary for the proper functioning of Swapmeals, with regard to the aforementioned purposes. Your personal data will not be shared with third parties for advertising or promotional purposes. In order to comply with our contractual obligations, we work specifically with:

Genzai B.V. for building our website and its functionalities;

Google Ireland Limited for the secure storage of your personal data;

Omnigen B.V. for installing the website and its functionalities on Google Cloud Platform. Omnigen is an official partner of Google and acts as a knowledge and implementation partner.

Auth0 Inc. for access and user management, authentication, and data security with data storage in the EU region;

SendInBlue, France, for sending emails to our users;

Zendesk Inc. for answering questions of users;

Pinterest Europe Limited and Meta Platforms Ireland Limited for tracking and optimising conversions and campaign performance.

We have imposed the same data protection and confidentiality obligations set out in this privacy statement on the third parties we work with. If and when we attract other third parties to provide our services, we will inform you about this, insofar as it concerns the sharing of your personal data. We will only enter into cooperation with a third party if this party can demonstrate that appropriate security measures have been taken and confidentiality can be guaranteed.

8. Closure

As mentioned above, you can contact the DPO for questions about this privacy statement and/or your privacy rights. We also note that if we need to collect personal data about you in the context of a contract we have concluded with you and you do not wish to provide (part of) this personal data, we may not be able to perform the contract we have with you or try to conclude with you. In that case, we may be forced to cancel the parts of the contract that we cannot perform. We will inform you about this if this is the case.

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