Privacy Policy

1. Introduction

Welcome to Dash - we’re glad to have you onboard! We’re on a mission to empower your favorite small and medium sized businesses through data insights and better loyalty management. In this Privacy Policy we explain how we collect, use and protect your data when using our app. By using the Dash app, you accept our Privacy Policy.

2. About this policy

The Policy should be read in conjunction with any other applicable policies, terms and conditions in place between you and us.

Please note that if you are having any trouble accessing this policy, please reach us by email at albert@usedash.io.

3. Terms of reference

To make this Policy more user friendly, we want to start by introducing you to what we mean when using some of the key terms in this Policy.

• “App” refers to the Dash app that can be downloaded in the App Store or Google Play to your phone or tablet.
• “EU” refers to the European Union.
• “DK” refers to Denmark.
• “Platform” is used to describe our Dashboard, App and online services and products in unison.
• “Partner” or “Store” refers to the businesses (e.g. coffee companies, bakeries etc.) using the Platform to provide their loyal customers a digital stamp card.
• “Cookie Policy” (and collectively “Cookie Policies”) refers to the cookie policies for our Users and Companies as applicable.
• “Dash” (and variously “we,” “us” and “our”) refers to our company Dash. ApS, Toldbodgade 11 3 th, 1253 København K, Denmark.
• “Website” covers all domains on usedash.io.
• “User” refers to you as a consumer using the Dash app.

4. Information we collect from users

4.1 Information needed to use the app

When you use the App, we will collect some personal information about you as a User. Without it, we would not be able to provide all the services requested. Please note that all your personal data is treated with utmost caution and will always be anonymized when displayed to our Partners. From the view of our Partners (your preferred companies) your personal information will be linked to a unique customer ID and not directly to your name.

The personal information that we request include the following:

• Geo-location: Country and your precise or approximate location depending on whether you choose to share your location with us. With respect to geo-location, we process this information based on your consent, which you provide (and may at any time revoke) in the settings on your phone or tablet.
• Email: Depending on how you choose to create a profile, we might need your email to verify your profile.
• Name: To provide a full name is optional, but we request your name to make future marketing more personalized and relevant for you.
• Gender: We request to know your gender to provide you with a more relevant and personalized experience of the app and to also provide our Partners with deeper customer insights and a better understanding of their loyal customer base.
• Date of birth: We request to know your date of birth to first and foremost verify whether you need parental consent to use our App. It also used to provide you with a more personalized experience of the app and to provide our Partners with deeper customer insights and a better understanding of their loyal customer base.
• Zip code: We request to know your zip code to provide you with a more relevant and personalized experience of the app and to also provide our Partners with deeper customer insights and a better understanding of their loyal customer base.

We may also process this personal information based on our legitimate interests to:

• provide, improve and develop our Platform
• communicate with you
• provide, tailor, measure, and improve our advertising and marketing

as further explained in section 6 of this Policy. Where required by applicable legislation, we will ask for your consent before using your personal information for marketing purposes, including sending you direct marketing communications.

4.2 Information automatically collected when using the Dash platform

When you use the Platform, we will automatically collect some personal information. This may include:

• Usage information: ssuch as the pages or content you view or click on, the clickstream patterns and length of time spent on each site as well as searches you conduct, stamp cards you add, stamps you receive, and which Store in our app you are a customer of.
• Log Data and Device Information: such as details about how you’ve used the Platform, IP address, access dates and times, hardware and software information, device type, device event information, unique identifiers (e.g. IDFA and IDFV), crash data, and the pages you have viewed or engaged with on the Platform and before or after using the Platform.

We process this personal information based on our legitimate interests to:

• provide, improve or develop our Platform
• provide, tailor, measure, and improve our advertising and marketing as further explained in section 6 of this Policy.

4.3 Information we collect from third parties

We collect personal information from other sources, such as:

• Third party services: If you link, connect, or login to the Platform using a third party service (e.g. Google), you direct the service to send us profile information such as your name and email as controlled by that service or as authorized by you via your privacy settings at that service.

We process this personal information based on your consent which you provide upon directing the third party service to send us your profile information.

5. Information we collect from our partners and other business contacts

5.1 Information needed to use the Platform

When you register and create a Partner account to make stamp cards available on the Platform, we collect some personal information about you as a contact person for your Store or as an individual Store owner.

This information includes:

• Profile information: name, email, phone number, stores addresses, store names.
• Tax information: your Store’s VAT number.

If you are an individual Store owner, we process this personal information because it is necessary for performing the agreement with you for your Store’s use of the Platform. If you are an employee of a Store, our legal basis for processing this personal information is our legitimate interest in being able to provide the Platform.

We may also process the above personal information because it is necessary for the purposes of the legitimate interests pursued by us in order to:

• provide, improve and develop our Platform
• communicate with you
• provide, tailor, measure, and improve our advertising and marketing

as further explained in section 6 of this Policy. Our legal basis for this processing is our legitimate interest, or, where required by applicable legislation, your consent. If we rely on your consent for our processing, we will specifically ask for this.

5.2 Information automatically collected when using the Platform

When you use the Platform, we will automatically collect some personal information from your usage of the system.
This may include:

• Usage Information: such as the pages or content you view or click on, the clickstream patterns and length of time spent on each site as well as searches you conduct and actions you perform on the Platform,
• Log Data and Device Information: such as details about how you’ve used the Platform, IP address, access dates and times, hardware and software information, device type, device event information, unique identifiers (e.g. IDFA and IDFV), crash data, and the pages you have viewed or engaged with before or after using the Platform.
• Cookies and Similar Technologies: as described in our Cookie Policy.

We process this personal information based on the legitimate interests pursued by us in order to:

• provide, improve or develop our Platform
• provide, tailor, measure, and improve our advertising and marketing

as further explained in section 6 of this Policy and in our Cookie Policy for the Store side of the Platform.

5.3 Information collected from our Partners

As part of our daily operations and communication and interaction with our Partners and their Stores, we collect some personal information about you as our Partner, your Stores or as an employee of one of our Partners:

• Business contact information: name, email address, phone number, company name, address and your role within the business.
• Tax information: your company’s VAT number if you are an individually owned business.

If you are an individual business owner, we process this personal information because it is necessary for performing the agreement that we have with you.

If you are an employee of one of our Partners, our legal basis for processing this personal information is our legitimate interest in being able to fulfill the agreement with your employer.

We may also process the above personal information based on the legitimate interests pursued by us in order to:

• provide, improve and develop our Platform
• communicate with you
• provide, tailor, measure, and improve our advertising and marketing

as further explained in section 6 of this Policy.

5.4 Information you chose to give us

You may choose to provide us with additional personal information about you. This information could include:

• Email correspondence: information that you provide as part of our email correspondence with you.
• Other information: information that you provide to us on your own initiative in connection with support queries or other interaction that you have with us.

Our legal basis for this processing is our legitimate interest, or, where required by applicable legislation, your consent. If we rely on your consent for our processing, we will specifically ask for this.

Where we do not ask for your consent, we process this personal information because it is necessary for the purposes of the legitimate interests pursued by us in order to:

• provide, improve and develop the Platform
• communicate with you
• provide, tailor, measure, and improve our advertising and marketing

as further explained in section 6 of this Policy.

We will never ask for or require that you submit any of your special categories of personal data to us. However, if you choose to share health information or other special categories of personal information with us on your own initiative, we process this information based on our legitimate interests and in order for us to be able to establish, exercise or defend legal claims. In special circumstances, where required by applicable legislation, we may rely on your consent for our processing.

5.5 Information we collect from third parties

We may collect personal information in the form of your name, contact details and other relevant business related information, e.g. your role and the company you work for, from publicly accessible sources such as:

• websites, and
• Online directories

if we need to contact you for a specific purpose as part of our daily operations, or, where allowed under applicable legislation, for marketing purposes, where your consent is not required by the applicable legislation. Our legal basis for this processing is our legitimate interest in being able to get in contact with you as part of our daily operations and to promote our services.

5.6 Information collected from recipients of our email communications

Dash makes use of external service providers to send out our email communications. These services may record the following information about recipients of our emails:

• who opens the email, (email address)
• when the email is opened (date and time)
• which links in the email that recipients are clicking on
• whether the email is received and links are activated from a mobile device or through a browser
• Information about which communication/campaign from our side the above is related to,

Dash receives reports from our external service providers with the information mentioned above. We use this information to analyze which links in our email communications readers click through to, and use this information to design our future email communications. We process this information based on our legitimate interest in being able to organize future email communications on the basis of the information collected. You may at any time opt out of receiving our marketing emails by clicking the unsubscribe link in our marketing emails.

6. How we use the information we collect

6.1 Provide, improve, and develop the Platform

We will use some of the personal information we collect about you for the purpose of providing you with the best possible Platform.

For Users of our App this includes:

• creating and managing your account with us and processing your stamps and stamp cards,
• personalizing and customizing your experience based on your interactions with the Platform, your search and stamp card history as well as your profile information and preferences e.g., by showing you a map or list view of nearby Stores and suggesting the most relevant Stores,
• performing analytics, debugging, and conducting research,
• conducting analyses in order to provide you with the relevant functionality.

For users of the Partner side of our Platform this includes:

• creating and managing your Store’s account with us and processing stamps for stamp cards at your Store,
• inform your Store on rewards, stamps, and required actions,
• inform Users of updates from your Store, e.g. new stamp cards,
• personalizing analytics, debugging, and conducting research,
• conducting analyses in order to provide you with relevant functionality.

6.2 Communicate with you

We will use some of the personal information we collect about you for the purpose of allowing us to get in touch with you. This includes:

• responding to your e-mails and/or support inquiries,
• sending you notifications of technical or legal nature, e.g. upon revision of our policies,
• sending you notifications and announcements about us and our products via email, SMS and/or push notifications to the extent that you have opted in to receive such communications.

To the extent permitted by local law, we may send you marketing communications without relying on your consent as a legal basis or rely on your soft opt-in to receive such marketing communications, as applicable.

6.3 Provide, tailor, measure, and improve our advertising and marketing

For Users:
We will use some of the personal information collected about you for the purpose of helping us in our continuous efforts to empower small and medium sized businesses through data insights and better loyalty management. This may entail:

• personalizing, measuring, and improving our advertising,
• analyzing preferences in order to tailor our promotional messages, marketing, advertising, and other information,
• sending you promotional messages, marketing and advertising based on your preferences as well as social media advertising through social media platforms,
• administering surveys, contests, sweepstakes, or other promotional activities or events sponsored or managed by Dash or its Partners, and inviting you to events and relevant opportunities.

For Partners or employees of Partners:
We will use some of the personal information collected about you for the purpose of helping us in our continuous efforts to empower small and medium sized businesses through data insights and better loyalty management. This may entail:

• personalizing, measuring, and improving our advertising,
• analyzing how you and our other Partners use the Platform in order to tailor our promotional messages, marketing, advertising, and other information,
• sharing your data with third parties such as our advertising networks (only if you have opted in to marketing cookies on the Store side of the Platform), to help us identify other people and businesses that may wish to join us in our mission to improve customer loyalty,
• sending you promotional messages, marketing and advertising based on your preferences as well as social media advertising through social media platforms,
• administering surveys or promotional activities or events sponsored or managed by Dash or its Partners, and inviting you to events and relevant opportunities.

6.3.1 Targeted advertising

We may ourselves, or with third-party vendors, use your information to deliver targeted advertising to you when you use our Platform or visit other websites. Cookies, clickstream data, and other similar technologies may be used in this process. For example, if you are searching for information related to our services, we or our vendor may cause an advertisement to appear on other websites you view with information on our App and our services. This form of advertising, sometimes called “targeted advertising,” “behavioral advertising,” or “cross-context behavioral advertising,” enables us and our vendors to know about your interests in connection with the delivery of a specific ad. We believe that such advertising is helpful because it allows you to see advertisements that are relevant to your interests.

7. Reasons we share information

7.1 Sharing with your consent or at your direction

Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third-party application or website to link to your Dash account or participating in promotional activities with Dash Partners or third parties.

If you have opted-in to marketing cookies on our Platform, we may share your data with third party advertising platforms to increase awareness of our Platform and mission, drive traffic to Dash, or otherwise promote our Platform as further described in section 6.3 of this Policy and our Cookie Policies for Users and the Store side of the Platform, respectively.

7.2 Data processors

We may share personal information with service providers to help us run our business and deliver the Platform. These service providers may assist us to fulfill the purposes set out in this Policy, including (but not limited to) by:

• Processing payments,
• hosting software functions which enable the functioning and development of our Platform,
• providing hosting services,
• supporting tools for improving the functionality, availability, resilience and security of the Platform,
• performing data analytics,
• providing performance measurements for our ads and campaigns,
• automating SMS, email and ads delivery, such as e.g. sending out newsletters,
• managing our social media and online advertising presence,
• providing integrated tools which helps us deliver customer care services.

Whenever we use a service provider to process personal data on our behalf, we make sure that they are contractually bound to protect your personal information by way of a data processing agreement.

7.3 Third party geo-location services

We use third party geo-location services, whom we share data with, to provide our Platform and to help us run our business as described below. These third party geo-location services may process personal information for their own purposes as controllers. If you are a User of our Website we may share your approximate geo-location (city level) (subject to your consent as described in section 4.1) with our third party geo-location service provider, Mapbox.

If you are a user of the Store side of the Platform, we share the address of your Store with our third party geo-location provider, Mapbox, based on our legitimate interest in being able to see where your Store is located on a map for the purposes of the legitimate interests pursued by us in order to:

• provide, improve and develop the Platform
• communicate with you
• provide, tailor, measure, and improve our advertising and marketing.

Mapbox features and content is subject to the then-current versions of the: (1) Mapbox Terms of Service at https://www.mapbox.com/legal/tos; and (2) Mapbox Privacy Policy at https://www.mapbox.com/legal/privacy#product-privacy-policy. We encourage you to familiarize yourself with these terms before using our Services.

7.4 Franchisors (only relevant for franchisees)

If you are an individually owned franchisee belonging to a franchise chain, we may share the following information with your franchisor depending on the agreement we have with your franchise chain:

• name
• email address
• Store name and address
• information about your Store’s use of the Platform (e.g. stamps and rewards given)
• information about User experiences with your Store,
• and information of relevance to the franchisor about communication and interactions that you have had with our care team.

If you are an employee of a franchisee, we may share your name and email address relevant for the Platform with the franchisor. Our legal basis for sharing this personal information is our and the franchisor’s legitimate interest in being able to manage your franchise chain’s agreement with us and your Store’s presence on the Platform.

7.5 Public authorities

We may disclose your personal information to courts, law enforcement, governmental or public authorities, including to the police in connection with criminal investigations, only if and to the extent we are required or permitted to do so by law.

7.6 PR and media agencies

We may share your personal information with third parties such as PR, media and or other types of promotional agencies, if you have consented to participate in our promotional activities or have entered into a contract with us for participation in such promotional activities. Depending on the circumstances these PR and media agencies may be processing personal information as either independent controllers or as processors, processing personal information on our behalf and under our instruction. Where the PR or media agency is processing personal information as data processors, our relationship will be governed by a data processing agreement in accordance with applicable legislation.

7.7 Business transfers

In the event we are involved in a bankruptcy, insolvency, merger, acquisition or reorganization event, your personal information may be transferred or shared as part of that transaction (e.g., for due diligence purposes) with advisors, counterparties, authorities and other relevant third parties as necessary. This Policy will continue to apply to your information also after the information has been transferred or shared with any new Dash entity.

7.8 Sharing with other third parties

In order to provide you with our services, we may need to engage third-party service providers, such as cloud storage providers or analytics services, to assist us in fulfilling our contractual obligations and to improve our platform. These service providers will have access to personal information solely for the purposes of performing the services on our behalf. We ensure that any third-party service providers we engage are bound by appropriate data protection and confidentiality obligations.

8. Storage period

We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

• the length of time we have an ongoing relationship with you and provide our Platform to you e.g., for as long as you have an account with us or keep using the Platform,
• whether there is a legal obligation to which we are subject as certain local laws require us to keep records of your activity for a certain period of time before we can delete them, and/or
• whether retention is advisable in light of our legal position e.g., in regard to applicable statutes of limitations, litigation or regulatory investigations.

9. Security

The security of your personal information and our Platform is a top priority for us.

We have put in place appropriate technical and organizational security measures to protect your personal information from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, the personal information transmitted, stored or otherwise processed by us.

We also only use suppliers that implement appropriate technical and organizational security measures in accordance with industry practices for good IT security.

10. Your rights

If you are in the EU/EEA, Switzerland or the UK, you have the following rights in relation to our processing of Personal Information about you, subject to the conditions and exceptions set out in applicable law:

• Right of access: you have a right to gain access to the information that we process about you.
• Right to rectification: you have a right to have incorrect information that we hold about you rectified.
• Right to erasure: you have the right to have information about you erased. However, please note that there may be limitations to exercising the right to erasure in accordance with applicable law.
• Right to restriction and objection: you have the right to ask us to restrict the processing of your information and similarly a right to object to processing.
• Right to data portability: you have the right to receive your personal information in a structured, commonly used and machine-readable format.
• Right to withdraw your consent: if processing of your personal information is based on consent, you have the right to withdraw your consent at any time. Please note that withdrawal of your consent will not affect the lawfulness of the processing carried out before you withdraw your consent.

Please note that certain personal data may be exempt from the above-mentioned rights pursuant to applicable data privacy laws, or other laws and regulations.

10.1 Easy access to exercise your rights directly in our App

Our App provides you with full control over your own personal information. We have incorporated privacy by design and privacy by default on our Platforms and have user-friendly features for you to be able to exercise your rights directly in the App, e.g. to delete your account (and thereby personal information) as well as an option to retrieve a copy of the personal information that we process about you. If you wish to exercise your rights directly in the App, please visit your account settings in the App.

You may also:

• unsubscribe from our newsletter
• request a copy of your data, or
• delete your account

by sending a request to us with your email address to: albert@usedash.io

10.2 Still have questions or wish to file a complaint

If the self-service that our App provides has not solved your query, or you wish to exercise other rights than provided for directly in the App or as set out above, you are welcome to contact us at: albert@usedash.io

We will make sure to answer your request without undue delay and in any event within one month of receiving your request. If your request is complex, we may need more time to process it, and can extend this deadline by two further months.

You always have the right to lodge a complaint with a data protection authority of competent jurisdiction, if you are not satisfied with our response. However, we encourage you to always reach out to us first so that we may have the opportunity to help you with your request.

The contact information for the Danish Data Protection Agency, which is the supervisory authority in Denmark where Dash’s headquarter is established, is:

Website: https://www.datatilsynet.dk
E-mail: dt@datatilsynet.dk
Address: Carl Jacobsens Vej 35, DK-2500 Valby, Denmark

11. Children's privacy

Our Platform is intended for Users 13 years of age or older, and we do not knowingly collect personal information from data subjects under the age of 13. When we become aware that personal information (or other information that is protected under applicable law) from a child under 13 has been collected, we will use all reasonable efforts to delete such information from our databases. If you believe we might have any personal information from or about a child under 13, please contact us by using the information in the section below titled “Contact information”.

12. Changes to the policy

You can stay updated on any changes to this Policy by visiting our Website and App. In case we make material changes to the Policy, we will notify you on the Platform or by using the email you provided when signing up to our Platform.