• our application software (App) available on App Store and our site (App Site) once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
• any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites), unless the EULA states that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

• Important Information and Who We Are
• The Data We Collect About You
• How Is Your Personal Data Collected?
• How We Use Your Personal Data
• Disclosures of Your Personal Data
• International Transfers
• Data Security
• Data Retention
• Your Legal Rights
• Glossary
• Description of Categories of Personal Data

• Full name of legal entity: NomHQ Ltd
• Email address: dpo@nomhq.com
• Postal address: 128 City Road, London, EC1V 2NX
• Telephone: 020 3740 5088

• Identity Data.
• Contact Data.
• Financial Data.
• Transaction Data.
• Device Data.
• Profile Data.
• Usage Data.
• Marketing and Communications Data.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to or purchase any of our Services or products, search for an App or Service, share data via an App's social media functions, enter a competition, promotion or survey, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our Cookie Policy for further details.
• Information we receive from other sources including third parties. We will receive Contact, Financial and Transaction Data from providers of technical, payment and delivery services along with Device Data from analytics providers such as Google based outside the UK.
• Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

We use cookies and/or other tracking technologies to distinguish you from other users of the App, App Site, the distribution platform (Appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our Cookie Policy. We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

• Where you have consented before the processing.
• Where we need to perform a contract we are about to enter or have entered with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purpose/activity	Type of data	Lawful basis for processing
To install the App and register you as a new App user	Identity Contact Financial Device	(a) Your consent
To process purchases and deliver Services including managing payments and collecting money owed to us	Identity Contact Financial Transaction Device Marketing and Communications Location	(a) Your consent (b) Performance of a contract with you (c) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you including notifying you of changes to the App or any Services	Identity Contact Financial Profile Marketing and Communications	(a) Your consent (b) Performance of a contract with you (c) Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) (d) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To enable you to participate in a prize draw, competition or complete a survey	Identity Contact Device Profile Marketing and Communications	(a) Your consent (b) Performance of a contract with you (c) Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)
To administer and protect our business and this App including troubleshooting, data analysis and system testing	Identity Contact Device	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
(a) To deliver content and advertisements to you (b) To make recommendations to you about goods or services which may interest you (c) To measure and analyse the effectiveness of the advertising we serve you (d) To monitor trends so we can improve the App Identity	Contact Device Content Profile Usage Marketing and Communications Location	(a) Your consent (b) Necessary for our legitimate interests (to develop our products/Services and grow our business)

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• Named Third Parties as set out in the Glossary.

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK. All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology or an alternative encryption technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. We will collect and store personal data on your Device using application data caches and browser web storage and other technology. Certain Services may include social networking, chat room or forum features. Ensure when these features that you do not submit any personal data that you do not want to be seen, collected or used by other users. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see Your legal rights below for further information. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. In the event that you do not use the App for a period of 12 months then we will treat the account as expired and your personal data may be deleted. Under certain circumstances you have the following rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• a. Request access to your personal data.
• b. Request correction of your personal data.
• c. Request erasure of your personal data.
• d. Object to processing of your personal data.
• e. Request restriction of processing your personal data.
• f. Request the transfer of your personal data.
• g. Right to withdraw consent at any time.

You also have the right to ask us not to continue to process your personal data for marketing purposes. You can exercise any of these rights at any time by contacting us at dpo@nomhq.com Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. Internal Third Parties

Other companies in the UKAUS Group acting as joint controllers or processors and who are based in the UK and Australia and provide IT and system administration services and undertake leadership reporting.

External Third Parties

Service providers acting as processors based in the UK who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

Named Third Parties

Name of Third Party	Function	Links to Privacy & Cookies Policies
Stripe Payments UK Ltd	Process payment information.	cookies policy privacy policy
Shanghai Sunmi Technology Co., Ltd	Provide hardware for receipt printing.	cookies policy device privacy policy website privacy policy

You have the right to:

• a. Request access
  to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.


• b. Request correction
  of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.


• c. Request erasure
  of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.


• d. Object to processing
  of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.


• e. Request restriction of processing
  of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • i. if you want us to establish the data's accuracy;
  
  
  • ii. where our use of the data is unlawful but you do not want us to erase it;
  
  
  • iii. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  
  
  • iv. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  
  


• f. Request the transfer
  of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.


• g. Withdraw consent at any time
  where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

• Identity Data: first name, last name, username or similar identifier, title and date of birth.


• Contact Data: billing address, delivery address, email address and telephone numbers.


• Financial Data: bank account and payment card details.


• Transaction Data: includes details about payments to and from you and details of purchases.


• Device Data: includes the type of device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's network interface, or the mobile phone number used by the Device), network information, your operating system, the type, configuration and version of browser you use, time zone setting, device’s display settings and device’s RAM usage.


• Profile Data: includes your username and password, purchase history, your interests, preferences, feedback and survey responses.


• Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.


• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences