This privacy policy was last modified on 24th August 2023

1. OUR APPROACH TO PRIVACY

   • Postcode Collective Limited ("Rabble", "we", "our" or "us") is committed to protecting and respecting your privacy. This Privacy Policy sets out how we collect, store, process, transfer, share, and use data that identifies or is associated with you ("personal data") and information regarding our use of cookies and similar technologies.
   • We operate an online platform for team buying that Rabble makes available as a service to hosts and buyers through our mobile application (the “Rabble App”) that is available to download on your device (the "Rabble Service").
   • This Privacy Policy applies to personal data that we collect as a controller through the Rabble Service and personal data that we collect as a controller through our website at https://www.therabble.app (the "Rabble Website"). The Rabble Service and the Rabble Website are collectively referred to in this Privacy Policy as the "Rabble Platform."
   • Please ensure that you have read this Privacy Policy and understand how we collect, store, use, and disclose your personal data before accessing or using the Rabble Service.

2. WHO IS RESPONSIBLE FOR THE USE OF YOUR PERSONAL DATA

   • Rabble is the controller of the personal data we hold about you in connection with your use of the Rabble Platform. This means that we determine and are responsible for how your personal data is used.

3. PERSONAL DATA we collect FROM you when you use the RABBLE PLATFORM, and how we use it

   • We collect personal data that you voluntarily submit directly to us when you use the Rabble Platform. This can include information you provide to us when you set up an account on the Rabble Service, fill in a form on the Rabble Service or the Rabble Website, participate in buying teams, correspond with us by phone, e-mail or otherwise, subscribe to our mailing lists, newsletters or other forms of marketing communications, or use some other feature of the Rabble Platform.
   • This information may include, for example, your contact and payment details. If you choose not to provide such personal data, we may not be able to provide those parts of the Rabble Platform to you or respond to your other requests.
   • The table at Annex 1 sets out in detail the categories of personal data we collect about you and how we use that information when you use the Rabble Service or visit the Rabble Website, as well as the legal basis which we rely on to process the personal data and recipients of that personal data.

4. Information we collect about you automatically

   • We also automatically collect personal data indirectly about how you access and use the Rabble Platform, and information about the device you use to access the Rabble Platform when you visit the Rabble Platform, read our emails, or otherwise engage with us. We use this information to provide you the features and functionality of the Rabble Platform, to monitor and improve the Rabble Platform, and to develop new products and services. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar tracking technologies.
   • The table at Annex 2 sets out in detail the categories of personal data we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal data and recipients of that personal data. For more information on cookies and other tracking technologies we use, please see Section 10.
   • We may link or combine the personal data we collect about you and the information we collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us.
   • We may anonymize and aggregate any of the personal data we collect (so that it does not directly identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving the Rabble Platform, and developing new products and features. We may also share such anonymized and aggregated information with others.

5. HOW LONG WILL WE STORE YOUR PERSONAL DATA WITH RABBLE

   • The tables at Annex 1 and Annex 2 set out retention periods for different aspects of your personal data within the Rabble Platform. Where the tables do not set out a retention period for an aspect of your personal data, Rabble will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for our legitimate business interests and satisfying any legal or reporting requirements.
   • To determine the appropriate retention period for personal data with Rabble, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and the applicable legal requirements.

6. RECIPIENTS OF PERSONAL DATA WITH RABBLE

   We may share your personal data within the Rabble Platform with the following persons (as required in accordance with the purposes set out in Annexes 1 and 2):

   • Food and drink sellers: Rabble may share your personal data with sellers of food and drink products to facilitate the orders you place through the Rabble Service.
   • Service providers and advisors: Rabble may share your personal data with third-party vendors and other service providers that perform services for us or on our behalf, which may include providing professional services such as legal and accounting services, mailing, email or chat services, fraud prevention, web hosting, or providing analytic services.
   • Purchasers and third parties in connection with a business transaction: Your personal data may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control, or acquisition of all or a portion of Rabble's business.
   • Law enforcement, regulators, and other parties for legal reasons: Rabble may share your personal data with third parties as required by law or if we reasonably believe that such action is necessary to comply with the law and the reasonable requests of law enforcement, detect and investigate illegal activities and breaches of agreements, including our Terms of Service, and/or exercise or protect the rights, property, or personal safety of Rabble, its users, or others.

7. MARKETING AND ADVERTISING WITH RABBLE

   • From time to time, Rabble may contact you with information about our products and services, including sending you marketing messages and asking for your feedback.
   • Rabble will only send you marketing messages if you have given us your consent to do so.
   • Most marketing messages Rabble sends will be via the Rabble Service in the form of push notifications. For some marketing messages, Rabble may use personal data we collect about you to help us determine the most relevant marketing information to share with you.
   • You can unsubscribe from receiving promotional email communications or other marketing messages from Rabble by updating your preferences via your account profile settings on the Rabble App or by unsubscribing to the Newsletter via the option in the email. Rabble makes every effort to promptly process all unsubscribe requests.
   • You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Rabble Service, technical and security notices).

8. STORING AND TRANSFERRING YOUR PERSONAL DATA WITH RABBLE

   • Security. Rabble implements appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, change, or damage. All personal data Rabble collects will be stored by our cloud hosting provider on secure servers. Rabble will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information, or national identification numbers.
   • International Transfers of your Personal Data with Rabble. The personal data we collect may be transferred to and stored in countries outside of the jurisdiction you are in where Rabble and our third-party service providers have operations. If you are accessing our Rabble Service from the European Economic Area ("EEA"), your personal data will be processed outside of the EEA, in the UK.

   In the event of such a transfer with Rabble, we ensure that: (i) the personal data is transferred to countries recognized by the European Commission or the UK Secretary of State (as applicable) as offering an equivalent level of protection; or (ii) such transfer is to a third party that is a member of a compliance scheme recognized as offering adequate protection for the rights and freedoms of data subjects, as determined by the European Commission or the UK Secretary of State (as applicable). If you wish to inquire further about these safeguards used, please contact Rabble using the details set out at the end of this Privacy Policy.

9. Rights FOR UK AND EEA USERS

   • If you are accessing our Rabble Service from the United Kingdom or the EEA, in accordance with applicable privacy law, you have the following rights in respect of your personal data that we hold:
     • Right of access. The right to obtain access to your personal data along with certain related information.
     • Right of portability. The right, in certain circumstances, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
     • Right to rectification. The right to obtain rectification of any inaccurate or incomplete personal data we hold about you without undue delay.
     • Right to erasure. The right, in some circumstances, to require us to erase your personal data without undue delay if the continued processing of that personal data is not justified.
     • Right to restriction. The right, in some circumstances, to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.
     • Right to withdraw consent. If you have provided consent for the processing of your personal data, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal data before your withdrawal.
   • You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
   • If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.
   • You also have the right to lodge a complaint to your local data protection authority. Information about how to contact the UK Information Commissioner's Office is available here. If you are based in the European Union, information about how to contact your local data protection authority is available here.

10. Cookies and Similar Technologies used on RABBLE PLATFORM

    • Our Rabble Platform uses cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together "cookies") to distinguish you from other users of our Platform. This helps us to provide you with a good experience when you browse the Rabble App or the Rabble Website and also allows us to monitor and analyze how you use and interact with the Rabble App or the Rabble Website so that we can continue to improve the Rabble App and the Rabble Website. It also helps us and our advertising partners to determine products and services that may be of interest to you, in order to serve you targeted advertisements.

11. Tracking Technologies used in our emails

    • Our emails may contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. This helps us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and to understand if you have opened and read any important administrative emails we might send you.

12. Interest Based Advertising

    • We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history and use of the Rabble Service. We may share, or we may permit third party online advertising networks, social media companies and other third party services to collect information about your use of the Rabble Service over time so that they may play or display ads on the Rabble Service, on other websites, apps or services you may use, and on other devices you may use.
    • Typically, but not always, this information is collected through cookies and similar tracking technologies. These third parties may collect, or we may share, mobile identifiers, such as the ID for Advertising for iOS (IDFA), Google Advertising ID, as well as your device's IP address, information about other applications on your device, your location, information about your use of the Rabble Service, email address or hashed data and information about which advertisements you have seen or clicked on.
    • We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
    • We may also use certain forms of display advertising and other advanced features through Google Universal Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Rabble Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at **https://google.com/ads/preferences** or by vising NAI’s online resources at **http://www.networkadvertising.org/choices**.
    • We and our third-party partners may also link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to the Rabble Service. We may also work with third party partners who employ tracking technologies, or the application of statistical modelling tools, to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as user ID) with third party advertising partners to help recognise you across devices. We and our partners can use this cross-device linkage to serve interest-based advertising and other personalised content to you across your devices, to perform analytics and to measure the performance of our advertising campaigns.
    • You may be able to limit the use of these identifiers for interest-based advertising on a particular device through the settings on your device by selecting "limit ad tracking" (iOS) or "opt out of interest based ads" (Android). You may also be able to opt-out of some, but not all, interest-based ads served by mobile ad networks by visiting **http://youradchoices.com/appchoices** and downloading the mobile AppChoices app.
    • To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit:
      • the Network Advertising Initiative’s online resources, at **http://www.networkadvertising.org/choices**;
      • the DAA’s resources at aboutads.info/choices; and/or
      • Your Online Choices at youronlinechoices.eu.
    • Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s or Your Online Choices’ online resources will only opt you out from receiving interest-based ads on that specific browser or device, but you may still receive interest-based ads on your other devices. You would need to perform the opt-out on each browser or device you use.
    • Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or devices, or use another operating system, you will need to opt-out again.
    • Please note that opting out of interest-based advertising does not mean you will no longer see advertising on your device – it just means that adverts may no longer be tailored to your interests.

13. CONTROL OVER YOUR INFORMATION

You may update your profile information, such as your contact information, and may change some of your data sharing preferences on your Account page/by emailing us at [email protected].

1. LINKS TO THIRD PARTY SITES

The Rabble Platform may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these

1. OUR POLICY TOWARDS CHILDREN

The Rabble Service is not directed at persons under 18 and we do not knowingly collect or solicit personal data from children. In the event that we learn that we have inadvertently collected personal data from a child, we will delete that information as quickly as possible. If you believe that we might have any information from a child, please contact us at [email protected]

1. CHANGES TO THIS POLICY