Privacy Notice

We care about your privacy and the security of your personal data. When processing personal data, we comply with the requirements of the European Union General Data Protection Regulation (GDPR) and other applicable legal acts.

Personal Data (hereinafter – Personal Data) means any information or set of information by which we may directly or indirectly identify you, primarily by reference to an identifier such as name, surname, email address, telephone number, etc.

The Data Controller is:

  • Inga Bartkevičiūtė
  • Individual Activity Certificate No. 571212, issued by Republic of Lithuania
  • info@smartsourdough.com

This Privacy Notice explains how we collect and use your Personal Data when you:

  • use the Smart Sourdough application;
  • subscribe to Smart Sourdough news, consent to receive direct marketing communications or such communications are sent to you on other lawful grounds;
  • contact us and submit an inquiry, request, complaint or feedback.

Certain services in the Smart Sourdough application may be provided by third parties, or you may be redirected to such third-party websites (for example, in order to make a payment for the Smart Sourdough application subscription). When using these services, third-party data protection policies apply together with this Privacy Notice. We kindly ask you to read them and ensure that the conditions for the processing of your Personal Data specified therein are acceptable to you.

1. What Data We Collect and How Long We Retain It

Registered User Account and Application Data

  • Your email address when registering using email and password
  • Your Google account email address and name when registering and logging in via your Google account
  • Your subscription status and data: active subscription plan, duration, price
  • Payment data: payer’s name, surname, payment status, amount paid, payment date and time.
  • Your recipes
  • Baking log entries
  • Starters and their feeding history
  • Planned bakes
  • Photos that you upload to the application (the application stores only those photos that you choose to upload; the application does not scan your gallery and does not have access to other files)
  • Technical data: unique User ID (a randomly generated server code consisting of numbers and letters), device type, browser, error logs (log), notification settings, Application version

The legal basis for the processing of Personal Data is the conclusion and performance of a contract (GDPR Article 6(1)(b)) – provision of services and ensuring application functionality (account creation, storage of your data, sending selected functional notifications).

Registered user account and application data are retained until the account is deleted, and upon deletion of the account, Personal Data associated with it are removed or anonymised, except where legal acts require us to retain the data for a longer period.

Payment accounting data are retained as required by accounting legislation, usually 10 years.

Technical log data are retained for 6 months.

Direct Marketing

For the purpose of direct marketing, we may process the following Personal Data: name, email address.

We also collect statistical information about newsletters and marketing messages sent by email: we monitor whether you have read the newsletter or message, when and how many times you have read it or opened links, whether you forwarded it to others, which operating system and email server (its location) you used.

For direct marketing purposes, we process Personal Data when we receive your consent for such processing. In this case, the legal basis for processing Personal Data is your consent (GDPR Article 6(1)(a)) and the data are processed until you withdraw your consent or for 5 years.

You may at any time unsubscribe from our newsletters or other marketing information and/or withdraw your consent for the processing of Personal Data for direct marketing purposes by simply clicking the unsubscribe link in the newsletter or email.

Administration of User Inquiries

When receiving, examining and responding to your inquiries, requests, applications, proposals, complaints, feedback, etc. (hereinafter collectively – Inquiry), we may process the following data:

  • Your identification and contact information as indicated by you: name, surname, email address;
  • The content of your Inquiry: the question you address to us, your request, claim or feedback, other information provided in or together with the Inquiry;
  • Information collected by us that is necessary to examine the Inquiry and make a decision, e.g., purchase data, etc.

The purpose of processing Personal Data is to properly and objectively examine your Inquiry, provide you with the necessary information, answer your questions, resolve your requests or claims. We may also analyse Inquiry data in order to improve the quality of our activities and/or services, taking into account your opinion and suggestions.

The legal basis for data processing is the performance of our legal obligation to examine and respond to consumer Inquiries (GDPR Article 6(1)(c)), as well as our legitimate interest in evaluating user feedback for the purpose of improving the quality of our activities and/or services (GDPR Article 6(1)(f)).

Your Inquiry and related Personal Data are processed and retained until we examine the Inquiry, provide you with a response and implement adopted decisions, and also for 6 (six) months after the Inquiry is resolved.

Cookies and Tracking

The application:

  • does not use advertising cookies;
  • does not use tracking technologies for advertising or content personalisation;
  • uses only necessary technical cookies required for login and application functionality and analytical cookies for anonymous browsing statistics collection.

More information about cookies and how they are used is provided in the Cookie Notice.

2. Data Storage Location

Registered user data are stored in the “Google Firebase” infrastructure (EU servers). Google’s privacy policy applies. Data are not transferred outside the EEA.

3. Data Transfer

Your data are not sold and are disclosed to other parties only to:

  • “Google Firebase”, which provides cloud infrastructure
  • “Stripe”, which administers and manages all payments and settlements
  • State authorities and institutions when they perform functions assigned by law, in accordance with the procedure established by legal acts.

4. Your Rights

You may at any time:

  • access your Personal Data and information about how they are processed;
  • download (export) your data (recipes, starters, product list) in JSON format;
  • withdraw your consent for the processing of Personal Data where data are processed on the basis of consent (e.g., opt out of notifications by disabling them);
  • object to the processing of your Personal Data where they are processed on the basis of our legitimate interest, except where there are legitimate grounds for such processing or for the establishment, exercise or defence of legal claims;
  • request deletion of your account and all related data;
  • request rectification of incorrect, inaccurate or incomplete Personal Data, or restriction of the processing of your Personal Data where they are processed in violation of legal requirements or where there is another legal basis.

To exercise your rights, contact us at info@smartsourdough.com.

If you believe that your data are processed unlawfully or your rights are violated, you have the right to contact the local data protection authority (in Lithuania – the State Data Protection Inspectorate https://vdai.lrv.lt/) and lodge a complaint. However, before submitting a formal complaint, we kindly ask you to contact us at info@smartsourdough.com so that an appropriate solution to the issue can be found.

5. Amendments

This Privacy Notice may be updated and amended. The current version of the Privacy Notice is always available on our website https://smartsourdough.com and in the application https://app.smartsourdough.com.

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