PRIVACY POLICY

Last updated July 15, 2026

This Privacy Notice for PIM SYSTEMS GLOBAL LTD ('we', 'us', or 'our'), describes how and why we might access, collect, store, use, and/or share ('process') your personal information when you use our services ('Services'), including when you:

• Download and use our mobile application (pim), or any other application of ours that links to this Privacy Notice

• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hello@thepimsystem.com.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by using the table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered 'special' or 'sensitive' in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information beyond dietary preferences and requirements, which you provide voluntarily and which we process only to deliver the recipe suggestions feature.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

The personal information we collect may include the following:

• Names

• Email addresses

• Usernames

• Passwords

• Household inventory data (item names, categories, quantities, expiry dates)

• Shopping list data

• Dietary preferences and requirements (selected from a predefined set of options)

Sensitive Information: We do not process sensitive personal information as defined under UK GDPR beyond dietary preferences and requirements. Dietary data may, in certain jurisdictions, intersect with health or religious beliefs. We collect this data only to the extent you choose to provide it and only for the purpose of generating personalised recipe suggestions. You may update or remove your dietary preferences at any time in your account settings.

Social Media Login Data: We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in Section 6 below.

Application Data: If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Push Notifications: We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

• Log and Usage Data: Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports, and hardware settings).

• Device Data: We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. This may include information such as your IP address (or proxy server), device and application identification numbers, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts.

• To deliver and facilitate delivery of services to the user, including inventory management, expiry date estimation, shopping list management, household account functionality, and recipe suggestions.

• To identify usage trends so we can improve our Services.

• To process your subscription and manage billing through the applicable App Distributor (Apple or Google).

• To send transactional communications related to your subscription, including billing notifications.

• To save or protect an individual's vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. We may rely on the following legal bases:

• Consent: We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.

• Performance of a Contract: We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or processing your subscription.

• Legitimate Interests: We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information to analyse how our Services are used so we can improve them to engage and retain users.

• Legal Obligations: We may process your information where we believe it is necessary for compliance with our legal obligations.

• Vital Interests: We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

• Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Third-Party Service Providers: We share data with OpenAI for the purposes of expiry date estimation and recipe suggestions, and with DuckDuckGo for recipe image retrieval. Please see Sections 13 and 14 for full details.

• App Distributors: Subscription payments are processed by Apple App Store or Google Play Store. We do not receive or store your payment card details. These distributors process payment data subject to their own privacy policies.

• Household Members: If you participate in a Household Account, your inventory contributions and shopping list entries will be visible to all other members of that household. Please see Section 7 for full details.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics purposes. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using Apple or Google, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your Apple ID or Google account, in addition to standard email and password registration. Where you choose to sign in via Apple or Google, we will receive certain profile information about you from the relevant provider. The information received will typically include your name and email address, subject to your privacy settings with that provider and, in the case of Apple, whether you choose to share or hide your email address.

We will use the information we receive only for the purposes described in this Privacy Notice. We do not control, and are not responsible for, other uses of your personal information by Apple or Google. We recommend that you review Apple's and Google's respective privacy policies to understand how they collect, use, and share your personal information.

7. HOUSEHOLD ACCOUNTS AND SHARED DATA

In Short: Household Accounts allow multiple users to share inventory and shopping list data. Data contributed to a household is accessible to all members and remains in the household if a member leaves or is removed.

What data is shared within a household

When you participate in a Household Account, the following data is shared with all current members of that household:

• Household inventory items, including product names, categories, quantities, expiry dates, and associated metadata.

• Shopping list entries.

Your account-level personal data (name, email address, dietary preferences, and password) is not shared with other household members and remains private to your account.

Data contributed by you

Any inventory items or shopping list entries you add to a household become part of the shared household dataset. If you leave or are removed from the household:

• You will immediately lose access to all shared household data, including items you personally contributed.

• Your contributed items will remain in the household inventory and will continue to be accessible to remaining members.

• There is no mechanism to export your contributed data prior to leaving or being removed. We strongly recommend you make a personal record of any items you wish to retain before leaving a household.

Removal from a household

The household owner has the ability to remove any member at any time without notice. Upon removal, your account will revert to a standalone account immediately. You will not receive an in-app notification of removal. If you believe you have been removed in error, please contact the household owner directly or reach out to us at hello@thepimsystem.com.

Dissolution of a household

If the household owner deletes their account, the Household Account will be dissolved and all shared household data will be permanently deleted. All members will be returned to standalone accounts.

Third-party processing of shared data

Shared household data, including items contributed by any member, may be transmitted to the OpenAI API for the purposes of expiry date estimation and recipe suggestions. This processing may be triggered by any member of the household. By participating in a Household Account, you consent to your contributed data being processed in this manner. Please see Section 13 for full details of how OpenAI handles this data.

Legal basis for processing shared data

We process shared household data on the basis of performance of a contract (to deliver the household features you have signed up for) and, where applicable, consent.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than six (6) months past the termination of the user's account.

We recommend that you maintain your own backup copies of any inventory data or other information you consider important. We cannot guarantee the permanent availability of data stored within the App and are not liable for data loss resulting from technical failure, account termination, or other circumstances.

With respect to Household Account data: if you leave or are removed from a household, your contributed items remain in the household dataset and will be retained for as long as that household continues to exist, or until the household owner deletes them or dissolves the household. If the household is dissolved, all shared data will be permanently deleted. We are unable to delete individual contributed items from an active household on your behalf, as doing so would disrupt the household's shared inventory.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible, we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

10. DO WE COLLECT INFORMATION FROM MINORS?

In short: We do not knowingly collect data from or market to children under 13 years of age.

We do not knowingly collect, solicit data from, or market to children under 13 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 13 years old and, if you are under the age of majority in the jurisdiction in which you reside, you have obtained permission from your parent or legal guardian to use the Services. If we become aware that we have collected personal information from a child under the age of 13, we will take reasonable steps to delete such information and, where appropriate, any associated account, in accordance with applicable law. If you become aware that a child under the age of 13 has provided us with personal information, please contact us at hello@thepimsystem.com.

11. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Switzerland, you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided in Section 16 below.

Please note that in relation to data contributed to a Household Account, some rights may be limited. Specifically, we are unable to delete individual items from an active household inventory on your behalf where doing so would disrupt the household's operation for other members. If you have concerns about data you have contributed to a household, please contact us and we will advise on available options.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or the UK Information Commissioner's Office (ICO).

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us using the details provided in Section 16 below. Please note that this will not affect the lawfulness of the processing before its withdrawal.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements. Please note that termination of your account will also dissolve any Household Account you own, resulting in permanent deletion of all shared household data.

If you have questions or comments about your privacy rights, you may email us at hello@thepimsystem.com.

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

13. USE OF THIRD-PARTY APIS

OpenAI API

We have integrated the OpenAI API to provide enhanced functionality within our App. Specifically, we use the OpenAI API to:

• Provide automatic expiry date estimations for items in your inventory and shopping list.

• Generate personalised recipe suggestions based on your inventory, dietary preferences, and dietary requirements.

What data is shared with OpenAI:

• For expiry date estimation: product names, categories, and associated metadata.

• For recipe suggestions: inventory data, dietary preferences, and dietary requirements.

In Household Accounts, data contributed by any member of the household may be transmitted to OpenAI as a result of any member's use of these features. By participating in a Household Account, all members consent to their contributed data being shared with OpenAI as described above.

How OpenAI uses this data: We use OpenAI's API services in accordance with OpenAI's published API data handling policies. The data shared with OpenAI is used solely for the purpose of providing you with expiry date estimates and recipe suggestions. For current details on how OpenAI handles API data, please refer to OpenAI's Privacy Policy linked above.

Your control over data sharing: If you do not wish your data to be processed for AI-powered features, do not use those features. By using pim's AI-powered features, you consent to the sharing of relevant data with OpenAI as described above. For more information on how OpenAI handles data, please review their Privacy Policy: https://openai.com/en-GB/policies/privacy-policy/

DuckDuckGo API

We use the DuckDuckGo API to retrieve images relevant to recipe suggestions displayed within the App. When this feature is used, the name or title of a suggested recipe may be transmitted to DuckDuckGo for the purpose of image search. We do not share any personal data, inventory data, or dietary information with DuckDuckGo. Use of this service is subject to DuckDuckGo's own terms and privacy policy.

14. RECIPE SUGGESTIONS

Data Usage: We use your inventory data, dietary preferences, and dietary requirements to provide personalised recipe suggestions. This data is processed as described in Section 13 and is transmitted to the OpenAI API to generate recipe results.

Third-Party AI: Recipe suggestions are powered entirely by the OpenAI API. We are not responsible for inaccuracies, errors, allergen omissions, or unsatisfactory results generated by this service.

User Responsibility: You are responsible for verifying allergens, nutritional accuracy, and the suitability of any suggested recipe before preparation or consumption. AI-generated recipes should not be relied upon as the sole source of dietary or allergen information, particularly if you have a serious food allergy, intolerance, or medical dietary requirement.

User Consent and Control: By using the Recipe Suggestions feature, you consent to the use of your inventory data, dietary preferences, and dietary requirements for this purpose. You may update or remove your dietary preferences at any time in your account settings.

Feature Availability: The Recipe Suggestions feature is provided as-is and may be subject to limitations, technical issues, or changes in availability based on third-party service constraints.

15. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Last updated' date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at hello@thepimsystem.com or contact us by post at:

PIM SYSTEMS GLOBAL LTD

4th Floor, Silverstream House, 45 Fitzroy Street

London W1T 6EB

United Kingdom

17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law, including in relation to data contributed to Household Accounts as described in Section 11.

To request to review, update, or delete your personal information, please contact us at hello@thepimsystem.com or submit a data subject access request through our support channels.