Privacy Policy

Introduction

Consent to usage of the Web App

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in https://self.app/privacy and it is important that you read that information. By signing up to use this App, you are giving your consent to our processing of your personal data (including your name and contact details) as described in the policy https://self.app/privacy.

How you can withdraw consent

Once you provide consent you may change your mind and withdraw consent at any time by contacting us legal@self.app but that will not affect the lawfulness of any processing carried out before you withdraw your consent. Once your consent has been withdrawn we will delete your account and all associated data.

Personal Data

SELF (we) are committed to protecting your personal data and respecting your privacy.

This policy (together with our end-user licence agreement as set out at https://self.app/terms (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:

• SELF APP (which was last updated on 13th November 2024) theweb application software (App) available on hosted on https://self.app (App Site), accessible on your 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. This App is not intended for children and we do not knowingly collect data relating to children. 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

SELF, a company registered in Cayman Islands is the controller and is responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this policy).

We have appointed a data protection officer (DPO) OR data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our details are:

• Full name of legal entity: SELF, registered number: 413417, 2nd Floor, Caribbean Plaza, 878 West Bay Road, George Town, P.O. Box 30310, Grand Cayman, Cayman Islands, KY1-1202
• Jonathan MacDonald, Founder & CEO
• Email address: legal@self.app

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the Caymanian regulator for data protection issues.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on November 13th 2024. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Services Sites. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

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

We explain these categories of data further below.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

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 any of our Services, search for an App or Service, creating an account or setting up a profile, make an in-App purchase, or use any rewards or credits which are accrued through the use of the App or Service, share data via an App's social media functions 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 https://self.app/cookies for further details.
• Location Data. We also use GPS technology or other technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
• Information we receive from other sources including third parties and publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

• analytics providers such as Google based outside the Cayman Islands;
• advertising networks based inside and/or outside the Cayman Islands; and
• search information providers based inside/or outside the Cayman Islands.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside and/or outside the Cayman Islands;
• Identity and Contact Data from publicly available sources such as Companies House and the electoral register based inside the Cayman Islands; and
• 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.

Cookies

We may use cookies and other other related tracking technologies to distinguish you from other users of the App, App Site, the distribution platform, 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 https://self.app/cookies.

How we use your personal data

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.

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.

Purposes for which we will use your personal data

‍

Disclosures of your personal data

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:

• Internal Third Parties as set out below.
• External Third Parties as set out below.
• 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.

International transfers

Some of our external third parties are based outside the Cayman Islands so their processing of your personal data may involve a transfer of data outside the Cayman Islands.

If we transfer your personal data out of the Cayman Islands, we will 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. For further details, email legal@self.app
• Where we use certain service providers, we may use specific contracts approved by the Cayman Islands which give personal data the same protection it has in the Cayman Islands. For further details, email legal@self.app

Data security

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. 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. 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.

Data retention

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us. We will only retain your personal data for a limited period of time and for no longer than is necessary for the purposes for which your data is being processed. In some circumstances you can ask us to delete your data: see 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 7 years then we will treat the account as expired and your personal data may be deleted.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data. 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 legal@self.app.

Glossary

Lawful basis

Consent means processing your personal data where you have signified your agreement or clear opt-in to processing for a specific purpose. You can withdraw your consent at any time by contacting us. If you do decide to withdraw your consent, we will stop processing your personal data for that purpose unless there is another lawful basis we can rely on at which point we will let you know. 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. You have the right to object to this processing at any time. You will need to show either a compelling reason why our processing should continue which overrides your interests, rights and freedoms or that the processing is necessary for us to establish, exercise or defend a legal claim. 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.

Third parties

Internal third parties

Other companies in the acting as joint controllers or processors and who are based in Cayman Islands, UK, USA, EU or SA and provide IT and system administration services and undertake leadership reporting.

External third parties

Service providers who may be acting as processors based in Cayman Islands, UK, USA, EU or SA who provide services including IT and system administration services.

Your legal rights

You have the right to:

• 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.
• 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.
• 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.
• 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.
• 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:
• (a) if you want us to establish the data's accuracy;
• (b) where our use of the data is unlawful but you do not want us to erase it;
• (c) 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
• (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• 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.
• 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.

Description of categories of personal data

• Identity Data: First name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender or any other data which you provide us with consent for via the App.
• Contact Data: Billing address, delivery address, email address and telephone numbers or any other contact data which you provide us with consent for via the App.
• Financial Data: Bank account and payment card details or any other financial data which you provide us with details of via the App.
• Transaction Data: including but not limited to details about payments to and from you and details of in-App purchases made via the App.
• Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
• Content Data: includes information stored on your Device, including login information, photos, videos or other digital content, check-ins.
• Profile Data: includes your username and password, in-App 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.
• Location Data: includes your current location disclosed by GPS technology or any other technology.

‍