Privacy policy for app

Skippio Privacy Policy

This Privacy Policy covers the services provided by Digibar Limited trading as Skippio (“Skippio”,

“we”, “us” or “our”). Skippio is incorporated in Ireland with company registration number 715901

and having its registered address at 23 Wesley Heights, Dundrum, Dublin 16, D16 N290, Ireland.

This Privacy Policy provides details of the way in which we process personal data in line with our

obligations under the General Data Protection Regulation (No. 2016/679) (“GDPR”), the Data

Protection Act 2018 and any other laws which apply to us in relation to the processing of personal

data (collectively referred to as “Data Protection Laws”). In this Privacy Policy, “controller”,

“personal data” and “process” (and its derivatives) have the meanings given to those terms in Data

Protection Laws.

Personal data generally means information that can be used to individually identify a person, and

processing generally covers actions that can be performed in connection with data such as

collection, use, storage and disclosure. Skippio will be the controller of your personal data processed

in connection with our services. We may process your personal data across a range of systems and

tools.

The Skippio Platform is the technology solutions developed by Skippio and made available to you,

including our technology solution which enables you to order products from Businesses. The

businesses who operate on the Skippio Platform (“Business” or “Businesses”) will have necessary

access in respect of any personal data that is processed for placing and completing orders made with

a Business via the Skippio Platform.

The purpose of this Privacy Policy is to explain Skippio’s data processing activities, including how and

why we process personal data.

Personal Data We Collect

We collect personal data in relation to you when you provide it directly to us through the Skippio

Platform, when third parties such as Payment providers or Businesses provide us with personal data

about you or when personal data about you is automatically collected in connection with your use of

the Skippio website * order.skippio.io or www.skippio.io (the “Website”). If you are acting on behalf

of a Business or are a Skippio corporate customer, we collect personal data through the Business’s or

corporate customer’s engagement with Skippio including personal data that is collected from you

and from the Business or corporate customer or through an account created on the Skippio

Platform.

In providing our services, we may collect and process the following information:

Personal Data Collected Directly From You

We receive personal data directly from you including when you provide it to us through use of the

Website, placing an order for Food and/or Beverages with a Business through the Skippio Platform

or through creating an account on the Skippio Platform, including, but not limited to:

• Demographical, biographical and contact information. Information such as name, age, sex, email address, telephone number.

• Order information: product data.

• Special category data order information. You may choose to include details in your Food

and/or Beverages order that indicate health information or religious beliefs.

Personal Data Collected From Third Party Sources

Third Parties may provide us with personal data. For example, when you purchase Food and/or

Beverages via our payment provider(s) on the Skippio Platform or a Business may provide us with

personal data about you in order for us to fulfil orders placed with the Business through the Skippio

Platform. This includes Demographical, biographical, and contact information, order information and

special category order information.

Deletion of Profile/ Data

• We offer account removal in the application. (profile section)
• You can also request to delete your account and data using our contact form.(https://www.getskippio.com/contact)

• In order to delete account & account data, users must navigate to the profile section of the app, from there you will see the "Delete account" option. By clicking delete account, you will then have to confirm account deletion by typing "DELETE" and pressing confirm. The final step will ask you to confirm your password. Your account and data will then be deleted.
• By deleting your account - we will be deleting all of your data. There is no additional retention period.

Our Legal Justification for Processing Personal Data

The below table sets out how and why we process your personal data as described above, the legal

justification that supports this processing and the categories of personal data processed.

Why we process your Personal data Legal justification Categories of personal data.

Administration purposes

To:

• fulfil your Food and/or Beverages order placed with a Business through the Skippio Platform;

• communicate with you;

• respond to inquiries; and

• provide support and assistance through the Skippio Platform

Such processing is necessary for the performance of a contract between you and a Business. Where you choose to provide special category data order information, the legal justification is your explicit

consent

Demographical, biographical and contact information, order

information, automatically collected data and in certain cases,

special category data order information

Personalisation services, troubleshooting, data

We have a legitimate interest to personalise our services to Demographical, biographical, contact information, order

information,analysis and survey purposes ensure you are provided with the best possible service.

We have a legitimate interest in operating and maintaining

the Website and to manage, monitor and improve our services. We sometimes use surveys to assist with this automatically collected

data and in certain cases, special category data order information

Training, quality monitoring or evaluating the services we provide

Such processing is necessary for the legitimate interests pursued by us in monitoring and improving our services and their usage and ensuring that our users use the Website and the Skippio Platform, as

applicable, in accordance with our terms and conditions and

policies

Demographical, biographical, contact information, order

information, automatically collected data and in certain cases, special category data order information

Statistical information that is not related back to

individuals to help us improve the services we offer

We have a legitimate interest in carrying out certain analytics

to ensure the services we provide to Businesses are effective and operate appropriately

User activity on the Skippio Platform (e.g. duration on a particular

page, most popular choices etc). This data is aggregated so that it is not referable to any individual user

Corporate purposes

To:

• engage and deal

with Businesses and

Skippio corporate

customers; If you are acting on behalf of a Business or a Skippio corporate customer and we are provided with personal data, we will process that as necessary including to perform the Skippio Terms & Conditions and/or other applicable contractual terms as necessary. Such processing is in our legitimate interests of managing customer relationships

Demographical, biographical and contact information, including

the name of the Business or Skippio corporate customer on whose behalf you act and the role you occupy in respect of such an entity

Legal and contractual matters

To:

• ensure our services and Website are used in accordance with applicable terms and conditions and policies.

• comply with Skippio’s legal obligations;

• enforce and defend our rights and resolve disputes; and

• comply with our contractual obligations relating to service providers

We have a legitimate interest in ensuring that our services and the Website are used in accordance with our terms and conditions of use and policies and to protect against or deter fraudulent, illegal or harmful actions

Where necessary for the purpose of complying with our legal obligations such as in respect of taxation, accounting, payment card rules andstandards, data protection, consumer, public health laws or adhering to court orders

We have legitimate interests in establishing, exercising or defending a legal claim, a prospective legal claim, legal proceedings or prospective legal proceedings and in resolving disputes

Demographical biographical, contact information, order

information, automatically collected data and in certain cases, special category data order information

Corporate matters

To:

• administer and manage the Skippio group’s financial and taxation affairs;

and

• facilitate internal and external audits and corporate transactions including fundraising and mergers and acquisitions transactions

Such processing is in Skippio’s legitimate interest to ensure prudent and effective management of its business and to scale and develop our business. Skippio also has legal obligations in respect of legal and financial matters under company law and accounting regulations

Demographical, biographical and contact information, order information and automatically collected data

Disclosure requests

To:

We will disclose personal data where we receive a legally binding request to disclose personal data from law enforcement or other bodies or Demographical, biographical information, contact information,

• comply with Skippio’s legal obligations where we have a legitimate interest in assisting law enforcement or other agencies in respect of an investigationreward information and employment information

Individual Data Subject Rights

Data Protection Laws provide certain rights in favour of data subjects (the “Data Subject Rights”).

Data Subject Rights include the right to:

• receive detailed information on the processing (as per transparency obligations on

controllers) which we have provided through this Privacy Policy;

• access personal data;

• rectify or erase personal data (i.e. right to be forgotten);

• restrict processing;

• withdraw consent to processing based on consent. The withdrawal of consent will not affect

the lawfulness of processing based on consent before its withdrawal;

• data portability;

• object to processing of personal data based on legitimate interests and object to processing

of personal data for direct marketing purposes;

• object to automated decision making (including profiling); and

• complain to any competent data protection supervisory authority or Skippio’s lead

supervisory authority, the Data Protection Commission.

These Data Subject Rights will be exercisable by you subject to limitations as provided for under Data

Protection Laws.

If you require more information about how a Business processes your personal data or you wish to

exercise any of your data subject rights in respect of the processing of your personal data by a

Business you should contact the Business directly.

You may contact us or make a request to exercise any Data Subject Right by

contacting Daniel.coen@skippio.io Your request will be dealt with in accordance with Data

Protection Laws.

Disclosing Your Information

Your personal data may be shared with wholly-owned subsidiaries of Skippio in respect of

collaboration between entities in the Skippio group and any other wholly-owned subsidiaries of

Skippio that may be incorporated.

Skippio may engage other companies and people to perform tasks on our behalf and may need to

share personal data with them to enable us to provide you with our services.

These other companies and people include:

• delivery service providers. To be able to provide Food and/or Beverages delivery services,

these providers receive your demographical, biographical, contact information and order

information.• hosting service providers. To be able to provide online hosting services, these providers

receive your biographical and contact information, order information and special category

data information.

• data analysis service providers. To be able to provide data analysis services, these providers

receive order information.

• marketing assistance providers. To be able to provide marketing assistance, these providers

receive your demographical, biographical, and contact information and order information.

• payment service providers. To be able to provide payment services, these providers receive

biographical and contact information and order information.

Skippio may also disclose personal data to Businesses. As part of the Food and/or Beverages

ordering process, a Business may obtain from Skippio demographical, biographical and contact

information, order related information and special category data order information.

Skippio may disclose personal data in some scenarios e.g. when you violate our terms and conditions

or other policies. Skippio may disclose such personal data, at our sole discretion, if we believe it

necessary or appropriate in connection with investigation of fraud, IP infringement, piracy, or other

unlawful activity. This may require disclosure of demographical, biographical and contact

information and automatically collected data, amongst other personal data.

As set out in the table above, we will disclose personal data where we receive a legally binding

request to disclose personal data from law enforcement or other bodies or where we have a

legitimate interest in assisting law enforcement or other agencies in respect of an investigation.

As set out in the table above, in some cases, Skippio may buy or sell its assets which may involve the

transfer of user information. Skippio will transfer such information if we are acquired by or merged

with another company.

Businesses

As noted above, as part of the Food and/or Beverages ordering process, a Business may obtain from

Skippio demographical, biographical and contact information, order information, special category

data order information or other personal data.

Where you consent to direct marketing, your consent is provided directly to Skippio. You may

unsubscribe from direct marketing through the opt-out link included in marketing communications.

Business’s Privacy Policy and notices will govern in respect of marketing activities and analytics

conducted by Skippio acting as a processor.

Data Retention

We will keep personal data only for as long as the retention of such personal data is deemed

necessary for the purposes for which that personal data are processed (as described in this Privacy

Policy) unless we are required to retain your personal data for a longer period (e.g. in the event of

legal proceedings or investigations).

Data Transfers Outside the EEA

We may transfer personal data outside of the European Economic Area (the “EEA”). Any such

transfers will be in accordance with applicable law and appropriate safeguards such as the standard

contractual clauses approved under EU law from time to time. Any transfers of personal data from

the EEA to the United Kingdom will be conducted on the basis of the European Commission’s

adequacy decision in respect of the UK, available on the European Commission

(https://ec.europa.eu/info/law/...).

Necessity of Provision of Certain Personal Data

Certain information, such as demographical, biographical and contact details and order details have

to be provided to enable us to provide our services to you. If you do not provide this information, it

will mean that we are not able to provide our services to you.

Third Party Links

On occasion we include links to third parties on the Website. Where we provide a link it does not

mean that we have any control over the linked website or its privacy policy or that we endorse, or

approve that website’s policy towards visitor privacy. You should review the linked website’s privacy

policy before sending them any personal data.

Service-related Announcements

Skippio may send you service-related announcements. You may not opt-out of service-related communications.

Contacting Us

For further information about this Privacy Policy or the processing of your personal data by or on

behalf of Skippio, please contact us at Daniel.coen@skippio.io

While you may make a complaint in respect of Skippio’s compliance with Data Protection Laws to

any competent data protection supervisory authority or Skippio’s lead supervisory authority, the

Data Protection Commission, we ask that you contact us in the first instance to give us the

opportunity to address your concerns.

Changes

The manner in which we process personal data will evolve and we will update this Privacy Policy

from time to time to reflect changing practices. We will update the “Last Modified” date accordingly

at the end of this Privacy Policy. We will notify you of material updates but please review this Privacy

Policy from time to time.

Last Modified

This Privacy Policy was last updated in December 2024.

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