Privacy Policy

Last Updated: July 1, 2022.

 

We at Breadfast (defined below) respect and protect the privacy of visitors to our websites and our users (customers). This Privacy Policy describes our information handling practices when you access our services, which include our content on the websites located at Breadfast.com, or any other websites, mobile applications, pages, features, or content we own or operate (collectively, the “Site(s)”) or when you use the Breadfast mobile app, the Breadfast Card App (as defined below), any Breadfast, Breadfast Exchange, Breadfast Prime, or Breadfast Custody API or third party applications relying on such an API, and related services (referred to collectively hereinafter as “Services”).

Please take a moment to read this Privacy Policy carefully. If you have any questions about this Policy, please submit your request through our chat portal within Breadfast app

We may modify this Privacy Policy from time to time which will be indicated by changing the date at the top of this page. If we make any material changes, we will notify you by email (sent to the email address specified in your account), by means of a notice on our Services prior to the change becoming effective, or as otherwise required by law.

 

1. ACCEPTANCE OF THIS PRIVACY POLICY

By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. We may provide additional “just-in-time” disclosures or information about the data processing practices of specific Services. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data.

If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.

 

2. OUR RELATIONSHIP TO YOU

The Breadfast operating entity you contract with determines the means and purposes of processing your personal information in relation to the Services provided to you (typically referred to as a “data controller”).

You may be asked to provide personal information anytime you are in contact with any Breadfast services. The Breadfast services may share your personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, and content (additional details below). For example, even if you do not reside in Egypt, your information may be shared with Breadfast, Inc. which provides global support for all Services including technical infrastructure, product development, security, compliance, fraud prevention, and customer support.

If you have any questions about your Breadfast Account, your personal information, or this Privacy Policy, please submit your request through our contact information listed under the HOW TO CONTACT US section

 

3. THE PERSONAL INFORMATION WE COLLECT

Personal information is typically data that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties. The definition of personal information depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Privacy Policy.

Information you provide to us: To establish an account and access our Services, we’ll ask you to provide us with some important information about yourself. This information is either required by law (e.g. to verify your identity), necessary to provide the requested services (e.g. you will need to provide your bank account number if you’d like to link that account to Breadfast), or is relevant for certain specified purposes, described in greater detail below. As we add new features and Services, you may be asked to provide additional information.

If you choose not to share certain information with us, we may not be able to serve you as effectively or offer you our Services. Any information you provide to us that is not required is voluntary.

We may collect the following types of information from you:

  • Personal Identification Information: Full name, date of birth, nationality, utility bills, photographs, phone number, home address, password, and/or email.
  • Additional profile information (such as date of birth, gender, location, and preferred language)
  • Formal Identification Information: Your payment information (such as your credit/debit card number, security/CVV code, expiration date, and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.
  • Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.
  • Your communications and contact history with us (such as service call recordings, chat and instant messages, communications with our social media channels, Audio, electronic, visual and similar information.
  • Correspondence and other information (such as product reviews, forum posts, survey responses, participation in promotions, and/or other user-generated content or information provided to our support team or user research team

 

How we use information you give to us Why we collect it
Registration We need your name and contact details to create your account. This information is necessary for the adequate performance of certain services and offerings on the Site and the App, and to fulfill our contract with you when you place an order.
Accept payment, fulfill orders, provide refunds We use your name and contact details to fulfill our contract with you and deliver your orders, and we use your payment information to process payments and comply with applicable law.
Application for financing solutions offered by financing providers We collect your financing information on behalf of the financing provider you choose and send the information to that financing provider to facilitate your application to financing products.
Sending you account information We need your name and contact details to deliver important account information to you, such as order confirmations and notices, changes to account settings, and notices about the Site, the App, or the terms and policies that apply to them.
To offer an improved user experience We use your communications and contact history with us, as well as other information such as additional profile information, to operate, protect, improve and optimize the Site and the App and to personalize and customize your experience.
Analytics, training and quality assurance We may use information you provide to us to train our staff, improve our services and offerings, and perform other internal analytics and performance monitoring.
Communication, marketing and advertising We may use information you provide to us to deliver and personalize our communications with you, or to administer referral programs, rewards, surveys, sweepstakes, contests or other promotional activities. We may also use automatically collected information to trigger marketing communications, for example shopping cart reminders via SMS.

 

Information we collect from you automatically: To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information helps us address customer support issues, improve the performance of our Sites and Services, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:

  • Online Identifiers: Geo location/tracking details, mobile GPS information, browser information , operating system, browser name and version, and/or personal IP addresses
  • Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies. 
  • Purchase history and saved items (such as what you bought, what you’ve placed in or removed from your cart, or what items you’ve saved)

 

We may also use identifiers to recognize you when you access our Sites via an external link, such as a link appearing on a third party site. For example, we may automatically receive and record the following information on our server logs:

  • How you came to and use the Services;
  • Log data and device information (such as details about how you’ve used the Site or the App, IP address, access dates and times, hardware and software information, Device type and unique device identification numbers; device information, and page/product views or clicks)
  • Device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);
  • How your device interacts with our Sites and Services, including pages accessed and links clicked;
  • Broad geographic location (e.g. country or city-level location); and
  • Other technical data collected through cookies, pixel tags, web beacons, mobile identifier,. and other similar technologies that uniquely identify your browser.

 

Information we collect from our affiliates and third parties: From time to time, we may obtain information about you from our affiliates or third party sources as required or permitted by applicable law (for example if you link, connect, or login to the Site or the App with your Google, Facebook, Instagram or Twitter accounts) or other sources (such as your contacts or brands we partner with)

These sources may include:

  • Our Breadfast Family of Companies: Our “family of companies” is the group of companies related to us by common control or ownership (“Affiliates”). In accordance with applicable law, we may obtain information about you from our Affiliates as a normal part of conducting business, if you link your various Breadfast accounts (e.g., Breadfast Wallet account or Breadfast Commerce account in order to convert and make withdrawals into your bank account), so that we may offer our Affiliates’ Services to you.
  • Databases & ID Verification Partners: We obtain information about you from databases and ID verification partners for purposes of verifying your identity in accordance with applicable law. Such information may include your name, address, your email address, mailing address, phone number and password) and other relevant data. We obtain such information to comply with our legal obligations. In some cases, we may process additional data about you to assess risk and ensure our Services are not used fraudulently or for other illicit activities. In such instances, processing is necessary for us to continue to perform our contractual obligations with you and others. 
  • Transaction Data: We may analyze transaction data to ensure parties utilizing our Services are not engaged in illegal or prohibited activity under our Terms, and to analyze transaction trends for research and development purposes.
  • Joint Marketing Partners & Resellers: For example, unless prohibited by applicable law, joint marketing partners or resellers may share information about you with us so that we can better understand which of our Services may be of interest to you.
  • Advertising Networks & Analytics Providers: We work with these providers to provide us with de-identified information about how you found our Sites and how you interact with the Sites and Services. This information may be collected prior to account creation.
  • Social media handles (such as your Twitter or Instagram handle)
  • Other information (such as demographic data, fraud detection information and information about you and your activities, experiences and interactions on and off the Site and the App)

 

How we use information from third parties Why we collect it
Registration and profile We will use information from third party services if you register with us using another service, such as Facebook or Google, including Google’s one-tap login service. Connecting to third-party applications or services is optional. If you create your account by connecting through another service, we will collect public information from that connected account to help complete your profile.
Communication, marketing and advertising We may use information we collect or receive from third parties to deliver and personalize our communications with you, or to administer referral programs, rewards, surveys, sweepstakes, contests or other promotional activities.
Non-member referrals We may obtain your information from a friend or other contact who wants to invite you to use the Site or App. We will use your information to facilitate your invitation and administer our referral program.
To create and maintain a secure environment We may obtain your information from third party service providers and/or partners (e.g. identity verification services) and combine it with information we have about you for fraud prevention and risk assessment efforts.

 

4. ANONYMIZED AND AGGREGATED DATA

Anonymization is a data processing technique that modifies personal information so that it cannot be associated with a specific individual. Except for this section, none of the other provisions of this Privacy Policy applies to anonymized or aggregated customer data (i.e. information about our customers that we combine together so that it no longer identifies or references an individual customer).

Breadfast may use anonymized or aggregate customer data for any business purpose, including to better understand customer needs and behaviors, improve our Services, conduct business intelligence and marketing, and detect security threats. We may perform our own analytics on anonymized data or enable analytics provided by third parties. Types of data we may anonymize include, transaction data, click-stream data, performance metrics, and fraud indicators.

 

5. HOW YOUR PERSONAL INFORMATION IS USED

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We generally use personal information to create, develop, operate, deliver, and improve our Services, content and advertising; and for loss prevention and anti-fraud purposes. We may use this information in the following ways:

  • To maintain legal and regulatory compliance

Most of our core Services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. For example, Breadfast must identify and verify customers using our Services in order to comply with laws across jurisdictions. This includes collection and storage of your identification. In addition, we use third parties to verify your identity by comparing the personal information you provide against third-party databases. When you seek to link a bank account to your Breadfast Account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. If you do not provide personal information required by law, we might have to close your account.

  • To enforce our terms in our user agreement and other agreements

Breadfast handles sensitive information, such as your identification and financial data, so it is very important for us and our customers that we actively monitor, investigate, prevent, and mitigate any potentially prohibited or illegal activities, enforce our agreements with third parties, and/or prevent and detect violations of our posted user agreement or agreements for other Services. In addition, we may need to collect fees based on your use of our Services. We collect information about your account usage and closely monitor your interactions with our Services. We may use any of your personal information collected for these purposes. The consequences of not processing your personal information for such purposes is the termination of your account.

  • To detect and prevent fraud and/or funds loss

We process your personal information in order to help detect, prevent, and mitigate fraud and abuse of our services and to protect you against account compromise or funds loss.

  • To provide Breadfast’s Services

We process your personal information to provide the Services to you. For example, when you want to require a service on our platform, we require certain information such as your identification, contact information, and payment information. We cannot provide you with Services without such information. Third parties such as identity verification services may also access and/or collect your personal information when providing identity verification and/or fraud prevention services.

  • To provide Service communications

We send administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services. You may not opt-out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes.

  • To provide customer service

We process your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.

  • To ensure quality control

We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services such as inaccurate transaction records or other interruptions.

  • To ensure network and information security

We process your personal information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. The threat landscape on the internet is constantly evolving, which makes it more important than ever that we have accurate and up-to-date information about your use of our Services. Without processing your personal information, we may not be able to ensure the security of our Services.

  • For research and development purposes

We process your personal information to better understand the way you use and interact with Breadfast’s Services. In addition, we use such information to customize, measure, and improve Breadfast’s Services and the content and layout of our website and applications, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our Services.

  • To enhance your experience

We process your personal information to provide a personalized experience, and implement the preferences you request. For example, you may choose to provide us with access to certain personal information stored by third parties. Without such processing, we may not be able to ensure your continued enjoyment of part or all of our Services.

  • To facilitate corporate acquisitions, mergers, or transactions

We may process any information regarding your account and use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions.

  • To engage in marketing activities

Based on your communication preferences, we may send you marketing communications (e.g. emails or mobile notifications) to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers. Our marketing will be conducted in accordance with your advertising marketing preferences and as permitted by applicable law.

  • For any purpose that you provide your consent. 

We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time, and as required under the applicable law, we may request your permission to allow us to share your personal information with third parties. In such instances, you may opt out of having your personal information shared with third parties, or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to limit the use of your personal information, certain features or Breadfast Services may not be available to you.

 

6. LEGAL BASES FOR PROCESSING YOUR INFORMATION

We generally only process your data where we are legally required to, where processing is necessary to perform any contracts we entered with you (or to take steps at your request prior to entering into a contract with you), where processing is in our legitimate interests to operate our business and not overridden by your data protection interests or fundamental rights and freedoms, or where we have obtained your consent to do so. In some rare instances, we may need to process your personal information to protect your vital interests or those of another person. Below is a list of how Breadfast uses your personal information, as described above in the HOW YOUR PERSONAL INFORMATION IS USED Section, with the corresponding legal bases for processing. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.

Section & Purpose of Processing Legal Bases for Processing
(2) To enforce our terms in our user agreement and other agreements (4) To provide Breadfast’s Services (5) To provide Service communications (6) To provide customer service (7) To ensure quality control Based on our contract with you or to take steps at your request prior to entering into a contract.
(9) For research and development purposes (10) To enhance your experience (11) To facilitate corporate acquisitions, mergers, or transactions (12) To engage in direct marketing activities Based on our legitimate interests. When we process your personal data for our legitimate interests we always ensure that we consider and balance any potential impact on you and your rights under data protection laws.
(1) To maintain legal and regulatory compliance (3) To detect and prevent fraud and/or funds loss (8) To ensure network and information security (13) To protect your or our’s vital interests Based on our legal obligations, the public interest, or in your vital interests.
(10) To enhance your experience (12) To engage in third party marketing activities (14) For any purpose to which you consent Based on your consent.


7. WHY WE SHARE PERSONAL INFORMATION WITH OTHER PARTIES

We take care to allow your personal information to be accessed only by those who require access to perform their tasks and duties, and to share only with third parties who have a legitimate purpose for accessing it. Breadfast will never sell or rent your personal information to third parties without your explicit consent. We will only share your information in the following circumstances:

  • With third party identity verification services in order to prevent fraud. This allows Breadfast to confirm your identity by comparing the information you provide us to other third party databases. These service providers may create derivative data based on your personal information that can be used in connection with the provision of identity verification and fraud prevention services.
  • With financial institutions with which we partner to process payments you have authorized.
  • With service providers under contract who help with parts of our business operations. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else. Examples of the types of service providers we may share personal information with (other than those mentioned above) include:
    • Network infrastructure
    • Cloud storage
    • Payment processing
    • Transaction monitoring
    • Security
    • Document repository services
    • Customer support
    • Internet (e.g. ISPs)
    • Data analytics
    • Information Technology
    • Marketing
  • With companies or other entities that we plan to merge with or be acquired by. You will receive prior notice of any change in applicable policies.
  • With companies or other entities that purchase Breadfast assets pursuant to a court-approved sale or where we are required to share your information pursuant to insolvency law in any applicable jurisdiction.
  • With our professional advisors who provide banking, legal, compliance, insurance, accounting, or other consulting services in order to complete third party financial, technical, compliance and legal audits of our operations or otherwise comply with our legal obligations.
  • With law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our User Agreement or any other applicable policies.
  • We share personal information about you with our Affiliates as a normal part of conducting business and offering Services to you.

Where we believe it is necessary in order to protect the vital interests of any person. If you establish a Breadfast Account indirectly on a third party website or via a third party application, any information that you enter on that website or application (and not directly on a Breadfast website) will be shared with the owner of the third party website or application and your information will be subject to their privacy policies. For more information see the “Third-Party Sites and Services” section below.

 

8. HOW WE PROTECT AND STORE PERSONAL INFORMATION

We understand how important your privacy is, which is why Breadfast maintains (and contractually requires third parties it shares your information with to maintain) appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information you entrust to us.

We may store and process all or part of your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, in the US and elsewhere in the world where our facilities or our service providers are located. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

For example, we use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities. Full credit card data is securely transferred and hosted off-site by payment vendors in compliance with Payment Card Industry Data Security Standards (PCI DSS). This information is not accessible to Breadfast or Breadfast staff. 

However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognize that you play a vital role in protecting your own personal information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.

Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us using the contact information provided in the “How to contact us” section below.

 

9. RETENTION OF PERSONAL INFORMATION

We store your personal information securely throughout the life of your Breadfast Account. We will only retain your personal information for a minimum of six years or as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your personal information are described below.

  • Personal information collected to comply with our legal obligations under financial or fraud detection laws may be retained after account closure for as long as required under such laws.
  • Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis until you unsubscribe. Thereafter we will add your details to our suppression list to ensure we do not inadvertently market to you.
  • Content that you post on our website such as support desk comments, photographs, videos, blog posts, and other content may be kept after you close your account for audit and crime prevention purposes (e.g. to prevent a known fraudulent actor from opening a new account).
  • Recording of our telephone calls with you may be kept for a period of up to six years.
  • Information collected via technical means such as cookies, web page counters and other analytics tools is kept for a period of up to one year from expiry of the account.

 

10. BREADFAST INTERNAL APPS

 

BREADFAST DRIVER APP

This section applies to Delivery personnel, individuals who provide delivery of goods from a retailer registered on Breadfast to a user who is using the service and has requested through the app or website to be delivered specific goods.

 

DATA COLLECTION AND USAGE

The following data is shared from Breadfast’s main application and website to the Breadfast Driver app to facilitate the delivery service:

  • Data provided by users. This includes: name, email, phone number, address, payment method chosen for a specific transaction.
  • Data created during usage of the service by the Driver. This includes location data (Breadfast collects this data when the Driver app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of the Driver’s mobile device.
  • Location data (Drivers and delivery recipients). We collect precise or approximate location data from drivers mobile devices if they enable us to do so. Breadfast collects this data from the time a ride or delivery is requested until it is finished, and any time the app is running in the foreground of their mobile device. We use this data to enhance the use of the Breadfast service, so our users can track the progress of their delivery in real time, improve the pick up and drop off process and detect possible fraud.
  • Transaction information: We collect transaction information related to the use of our services during the drop off, including the type of services requested or provided, order details, delivery information, date and time the service was provided, amount charged, distance traveled, and payment method.
  • Device data: We may collect data about the devices used by the Driver to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.

 

HOW PERSONAL DATA IS USED ON THE DRIVER APP:

Breadfast collects and uses data to enable reliable and convenient delivery, and other products and services. We also use the data we collect:

  • To enhance the safety and security of our Drivers and users
  • Using data from drivers’ or delivery persons’ devices to help identify unsafe driving behavior such as speeding or harsh braking and acceleration, and to inform them of safer driving practices. We also use data from delivery persons’ devices to verify the type of vehicles they used to provide deliveries.
  • Using device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities.
  • To provide a personalized service to each user so each user can track the progress of the delivery of the goods ordered and have an as accurate as possible estimated time of arrival
  • To enable, track and share the progress of rides or deliveries
  • To confirm service execution in a timely and satisfactory manner by tracking the driver’s route and delivery speed
  • For customer support data when needed, to investigate and address user concerns
  • For research and development

 

BREADFAST PICKER APP

This section applies to Delivery personnel, individuals who provide delivery of goods from a retailer registered on Breadfast to a user who is using the service and has requested through the app or website to be delivered specific goods.

 

DATA COLLECTION AND USAGE

The following data is shared from Breadfast’s main application and website to the Breadfast Picker app to facilitate the delivery service:

  • Data provided by users. This includes: name, email, phone number, address, payment method chosen for a specific transaction.
  • Data created during usage of the service by the Picker. This includes location data (Breadfast collects this data when the Picker app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of the Picker’s mobile device.
  • Location data (Pickers and delivery recipients). We collect precise or approximate location data from pickers mobile devices if they enable us to do so. Breadfast collects this data from the time a ride or delivery is requested until it is finished, and any time the app is running in the foreground of their mobile device. We use this data to enhance the use of the Breadfast service, so our users can track the progress of their delivery in real time, improve the pick up and drop off process and detect possible fraud.
  • Transaction information: We collect transaction information related to the use of our services during the drop off, including the type of services requested or provided, order details, delivery information, date and time the service was provided, amount charged, distance traveled, and payment method.
  • Device data: We may collect data about the devices used by the Picker to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.

 

HOW PERSONAL DATA IS USED ON THE PICKER APP:

Breadfast collects and uses data to enable reliable and convenient delivery, and other products and services. We also use the data we collect:

  • To enhance the safety and security of our Pickers and users
  • Using device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities.
  • For customer support data when needed, to investigate and address user concerns
  • For research and development

 

DATA SHARING AND DISCLOSURE

Breadfast may share the data we collect via the Picker app:

  • With business partners (retailers, service providers), this includes sharing: Riders’ first name, pickup and/or dropoff locations
  • Delivery recipients’ first name, delivery address, and order information with their delivery person and business partner.
  • We also provide riders and delivery recipients with receipts containing information such as a breakdown of amounts charged, driver or delivery person first name, route map, and such other information required on invoices in the country or region where the picker operates.

 

11. THIRD-PARTY SITES AND SERVICES

If you authorize one or more third-party applications to access your Breadfast Services, the information you have provided to Breadfast may be shared with those third parties. A connection you authorize or enable between your Breadfast account and a non-Breadfast account, payment instrument, or platform is considered an “account connection.” Unless you provide further permissions, Breadfast will not authorize these third parties to use this information for any purpose other than to facilitate your transactions using Breadfast Services. Please note that third parties you interact with may have their own privacy policies, and Breadfast is not responsible for their operations or their use of data they collect. Information collected by third parties, which may include such things as contact details, financial information, or location data, is governed by their privacy practices and Breadfast is not responsible for unauthorized third-party conduct. We encourage you to learn about the privacy practices of those third parties.

Examples of account connections include:

  • Merchants: If you use your Breadfast account to conduct a transaction with a third party merchant, the merchant may provide data about you and your transaction to us.
  • Your Financial Services Providers: For example, if you send us funds from your bank account, your bank will provide us with identifying information in addition to information about your account in order to complete the transaction.

Information that we share with a third party based on an account connection will be used and disclosed in accordance with the third party’s privacy practices. Please review the privacy notice of any third party that will gain access to your personal information. Breadfast is not responsible for such third party conduct.

 

12. INTERNATIONAL DATA TRANSFERS

To facilitate our global operations, Breadfast may transfer, store, and process your personal information within our Affiliates, third-party partners, and service providers based throughout the world. We will protect your personal information in accordance with this Privacy Policy wherever it is processed and will take appropriate contractual or other steps to protect the relevant personal information in accordance with applicable laws. We contractually obligate recipients of your personal information to agree to at least the same level of privacy safeguards as required under applicable data protection laws. By communicating electronically with Breadfast, you acknowledge and agree to your personal information being processed in this way.

If you have a complaint about our privacy practices and our collection, use or disclosure of personal information please submit your request through our contact information listed under the HOW TO CONTACT US section.

 

13. YOUR PRIVACY RIGHTS AND CHOICES

Depending on applicable law where you reside, you may be able to assert certain rights related to your personal information identified below. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, Breadfast has absolute discretion in providing you with those rights.

Your rights to personal information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another’s privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons.

  • Access and portability. You may request that we provide you a copy of your personal information held by us. This information will be provided without undue delay subject to a potential fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. In certain circumstances, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another data controller.
  • Rectification of incomplete or inaccurate personal information. You may request us to rectify or update any of your personal information held by Breadfast that is inaccurate. You may do this at any time by logging in to your account and clicking the Account Settings tab.
  • Erasure. You may request to erase your personal information, subject to applicable law. If you close your Breadfast Account, we will mark your account in our database as “Closed,” but will keep certain account information, including your request to erase, in our database for a period of time as described above. This is necessary to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account, and to comply with Breadfast’s legal obligations. However, if you close your account, your personal information will not be used by us for any further purposes, nor shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.
  • Withdraw consent. To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of Breadfast’s processing based on consent before your withdrawal.
  • Restriction of processing. In some jurisdictions, applicable law may give you the right to restrict or object to us processing or transferring your personal information under certain circumstances. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
  • Automated individual decision-making, including profiling. Breadfast relies on automated tools to help determine whether a transaction or a customer account presents a fraud or legal risk. In some jurisdictions, you have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.

Marketing communications. You can opt-out of receiving marketing communications from Breadfast. Direct marketing includes any communications to you that are only based on advertising or promoting our products and services. We will only contact you by electronic means (email or SMS) based on our legitimate interests, as permitted by applicable law, or your consent. If you do not want us to send you marketing communications, please go to your account settings to opt-out or submit a request through our contact information listed under the HOW TO CONTACT US section.

 

14. HOW TO CONTACT US

 

How to make a privacy request

You can make privacy rights requests relating to your personal information by going to your Account Settings in your account or, if you cannot access the Settings, by contacting us through our customer chat available within Breadfast app or via email at cx@breadfast.com. Our Account Settings also allows you to set your communication preferences and make individual rights requests relating to your personal information. We strongly encourage you to make any individual rights requests through the Account Settings because it ensures that you have been authenticated already (based on the information you have provided to open your account and by providing the necessary login credentials and multi-factor authentication to access the account). Otherwise, when we receive an individual rights request via other intake methods, we may take steps to verify your identity before complying with the request to protect your privacy and security.

 

How to lodge a complaint

If you have questions or concerns regarding this Privacy Policy, believe that we have infringed your rights, or if you have a complaint, we encourage you to first submit a request via our Support Portal at cx@breadfast.com so that we can try to resolve the issue or dispute informally. If that does not resolve your issue, you may contact the Breadfast Investigations Team at investigations@breadfast.com