Basket Privacy Policy

Effective date: 18 August 2026 Last updated: 9 September 2026 Version: 1.1

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1. Introduction

This Privacy Policy explains how BASK3T International B.V. ("Basket", "we", "us" or "our") collects, uses, shares and protects personal data when you use the Basket mobile applications for iOS and Android, our website at https://bask3t.app, and any related features and services (together, the "Services").

Basket is a shopping layer for the internet. It helps you discover, save, organise, compare and buy products across online stores. To do that, we necessarily process some information about you and about the products you save. This document sets out exactly what we process, why, and what control you have.

We have written this policy to be readable. Where a term has a specific legal meaning under the EU General Data Protection Regulation (Regulation (EU) 2016/679, the "GDPR"), we use it in that sense.

If you do not agree with this Privacy Policy, please do not use the Services.

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2. Who is responsible for your data (data controller)

For the purposes of the GDPR and equivalent laws, the data controller for the personal data described in this policy is:

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3. Summary at a glance

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4. The personal data we collect

We collect personal data in three ways: data you give us, data generated when you use the Services, and data we receive from third parties.

4.1 Data you provide to us

4.2 Data generated when you use the Services

We do not collect your general browsing history. Basket's apps do not read the websites you visit outside the Basket app. We only receive information about a product page when you deliberately save or share it with Basket — for example through the system share sheet or by pasting a link.

4.3 Data we receive from third parties

• Product and retailer data sources — primarily Shopify Inc. (including the Shopify Global Catalog and merchant storefronts via the Universal Commerce Protocol) and the online stores whose products you view or save. This is product data (titles, prices, availability, images and links), not personal data, but it becomes associated with you once you save an item.
• Infrastructure providers — hosting and related technical processing as listed in Section 9.

4.4 Data we do not collect

We do not knowingly collect special categories of personal data under GDPR Article 9 (such as data revealing health, religious beliefs, political opinions, trade union membership, sexual orientation, or biometric data used to identify you). Please do not include such information in basket names, notes or support messages.

We do not collect payment card data. Basket does not currently process payments — see Section 12.

We do not collect Sign in with Apple or Google sign-in identifiers. Accounts are created with email and password only.

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5. Account requirement

The Basket mobile apps require an account. There is no guest mode: you cannot create baskets, sync content or receive alerts without registering. You may browse the public website at https://bask3t.app without an account; in that case we still process the limited device, technical and log data described in Section 4.2 and any cookies covered by Section 8.

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6. Why we use your data, and our legal basis

Under the GDPR we must have a lawful basis for each purpose. The table below sets these out. Where we rely on legitimate interests (Article 6(1)(f)), we have carried out a balancing assessment and you may object at any time (Section 11).

6.1 To provide the Services — legal basis: performance of a contract (Art. 6(1)(b))

Creating and authenticating your account; storing and syncing your baskets and saved products; enabling sharing; providing search, comparison and price information; providing customer support.

6.2 To send you the alerts and notifications you ask for — legal basis: performance of a contract (Art. 6(1)(b)), or consent (Art. 6(1)(a)) for the device permission

Price-drop alerts, back-in-stock alerts and other notifications about items you have saved. Push notifications require your operating system permission, which you can withdraw at any time in device settings.

6.3 To keep the Services secure and prevent abuse — legal basis: legitimate interests (Art. 6(1)(f)) and legal obligation (Art. 6(1)(c))

Detecting and preventing fraud, spam, scraping, credential stuffing and other misuse; enforcing our Terms; protecting our users and systems. Our legitimate interest is the security and integrity of a service that many people rely on.

6.4 To improve, measure and develop the Services — legal basis: legitimate interests (Art. 6(1)(f)), or consent where required by local law for analytics

Understanding which features are used and where users encounter problems; diagnosing crashes; measuring the performance of new features; improving product matching, price accuracy and recommendation quality. Wherever it is possible to do so without loss of accuracy, we use aggregated or de-identified data for this purpose.

6.5 To produce aggregated retailer insights — legal basis: legitimate interests (Art. 6(1)(f))

We provide retailers with aggregated and statistical insight into demand for their products — for example, how often a product is saved or compared. No insight is shown to a retailer unless it is derived from at least 50 distinct users

We do not provide retailers with your identity, your email address, your individual baskets, or any information that identifies you as an individual, unless you have given separate, explicit consent.

6.6 To communicate with you — legal basis: performance of a contract (Art. 6(1)(b)) for service messages; consent (Art. 6(1)(a)) or legitimate interests (Art. 6(1)(f)) for marketing, depending on your country

Service messages (security alerts, changes to these documents, account notices) are not optional while you hold an account. Marketing emails are sent only where permitted, and every marketing message contains an unsubscribe link.

6.7 To comply with law — legal basis: legal obligation (Art. 6(1)(c))

Responding to lawful requests from authorities, meeting accounting and tax obligations, and handling data subject requests.

6.8 Automated decision-making and profiling

Basket uses automated processing to rank, group, match and recommend products, and to decide which alerts to send you. This is profiling in the GDPR sense, but it does not produce legal effects concerning you or similarly significantly affect you within the meaning of GDPR Article 22. We do not use automated decision-making to make credit, pricing, employment, insurance or eligibility decisions about you, and prices shown in Basket are not personalised to your individual profile.

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7. Advertising and paid placements

Basket does not currently display advertising. If we introduce sponsored or promoted placements in future, they will be clearly labelled as such, they will never alter the neutrality of our rankings or price comparisons, and this Privacy Policy will be updated before any such feature goes live

We do not use your personal data to build advertising profiles for third parties, and we do not participate in real-time bidding or data broker arrangements.

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8. Cookies, analytics and similar technologies

8.1 On our website

Our website uses cookies and similar technologies:

Where consent is required, we ask for it through our cookie banner before any non-essential cookie is set, and you can change or withdraw your choices at any time via https://bask3t.app/cookies. Details of individual cookies, their providers and their lifespans are listed at https://bask3t.app/cookies#overview.

8.2 In our mobile apps

Our apps do not use browser cookies. They use device-level storage for session tokens, preferences and similar functional data. The shipping apps do not currently include third-party analytics or crash-reporting SDKs. If we add such SDKs later, we will update this policy and the App Store / Play privacy labels before release.

8.3 Apple App Tracking Transparency

Basket does not track you across apps and websites owned by other companies, and therefore does not request permission under Apple's App Tracking Transparency framework. If we ever enable advertising-identifier collection or cross-app tracking, we will request ATT permission where required and update this policy.

8.4 Do Not Track

Our website does not currently respond to browser "Do Not Track" signals, because no common standard for interpreting them has been agreed. We do honour Global Privacy Control signals where legally required

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9. Third-party services and recipients of your data

We share personal data only with the following categories of recipients, and only to the extent necessary.

9.1 Processors acting on our instructions

These providers process personal data on our behalf under a written data processing agreement that meets GDPR Article 28. They may not use your data for their own purposes.

We do not currently use a separate third-party transactional email provider, push-notification delivery provider, customer-support platform, or crash/error monitoring SDK. Account, alert and support messages are handled by Basket systems or by direct email to our @bask3t.app addresses. When we introduce any of those processors, we will add them to this table before they process personal data.

This table must stay accurate. Apple and Google compare the third-party SDKs in the app binary against this policy and the store privacy labels. A mismatch is a common rejection reason.

9.2 Independent controllers

• Apple Inc. and Google LLC act as independent controllers for app store distribution and the platform services they provide when you download or use Basket through the App Store or Google Play. Their handling of your data is governed by their own privacy policies.
• Shopify Inc. and online stores / retailers. When Basket retrieves catalogue data from Shopify or another merchant, and when you follow a link from Basket to a retailer's website or app (including checkout), you deal with that party as an independent controller and its own privacy policy applies to the data it processes. Basket has no control over, and accepts no responsibility for, the data practices of third-party stores.

9.3 Other disclosures

We may disclose personal data where necessary to: comply with a legal obligation, court order or valid request from a public authority; establish, exercise or defend legal claims; protect the rights, safety or property of Basket, our users or the public; or enforce our Terms and Conditions.

9.4 Corporate transactions

If Basket is involved in a merger, acquisition, financing, reorganisation or sale of assets, personal data may be transferred as part of that transaction. We will notify you before your personal data becomes subject to a materially different privacy policy, and you will retain the right to delete your account.

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10. International data transfers

Our primary hosting region is the European Union. Some of our providers are established outside the European Economic Area, including in the United States.

Where personal data is transferred outside the EEA or the UK, we rely on one or more of the following safeguards under Chapter V of the GDPR:

• an adequacy decision of the European Commission for the destination country, or the UK equivalent;
• the European Commission's Standard Contractual Clauses (Decision (EU) 2021/914), together with the UK International Data Transfer Addendum where relevant, supported by a transfer impact assessment; or
• certification under the EU–US Data Privacy Framework and its UK extension, where the recipient participates.

You can obtain a copy of the safeguards we rely on, with commercially confidential terms redacted, by writing to [email protected].

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11. Your rights

Subject to the conditions and exceptions in applicable law, you have the following rights.

Our response times. We respond to requests without undue delay and in any event within one month of receipt. Where a request is complex or you have made several requests, we may extend this by up to two further months and will tell you why within the first month.

Verification. To protect your data, we may need to verify your identity before acting on a request. We will not ask for more information than is necessary to do so.

Cost. Exercising your rights is free. We may charge a reasonable fee, or refuse to act, only where a request is manifestly unfounded or excessive — and we will explain our reasoning if that ever happens.

11.1 Additional rights for residents of certain jurisdictions

If you are a California resident, you have rights under the California Consumer Privacy Act as amended, including rights to know, delete, correct, and to opt out of the "sale" or "sharing" of personal information. Basket does not sell or share personal information as those terms are defined under the CCPA, and does not knowingly do so for consumers under 16. We do not discriminate against you for exercising your rights.

If you are in another jurisdiction with comparable legislation, we will honour equivalent rights to the extent that law applies to us. Basket launches first for users in the European Union / EEA and comparable European markets. If we expand to jurisdictions that require additional disclosures (for example Brazil's LGPD, Canada's PIPEDA, or further US state privacy laws beyond the CCPA statement above), we will update this section before that launch.

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12. Payments and subscriptions

Basket is currently free to use and does not charge consumers. We do not process, store or have access to payment card details.

If we introduce paid features in future, purchases made through the iOS or Android apps will be processed by Apple or Google under their own terms, and we will receive only the transaction confirmation and subscription status necessary to activate your entitlement — never your full payment card number. This Privacy Policy will be updated before any paid feature launches.

Retailers and merchants who enter into a paid agreement with us are handled under a separate commercial contract. We do not currently use a third-party billing processor for merchant invoicing; if we introduce one, we will name it in Section 9 before it processes personal data.

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13. Data retention and deletion

We keep personal data only for as long as we need it for the purposes described in this policy, or for as long as the law requires.

13.1 How to delete your account

You can permanently delete your Basket account and its associated personal data:

1. In the app — open Settings → Account → Delete account and confirm. This route is available in both the iOS and Android apps, as required by Apple App Store Review Guideline 5.1.1(v).
2. By email — write to [email protected] from the address associated with your account.

Deletion removes your profile, your baskets and saved products, your preferences and your alert subscriptions. We may retain a minimal record of the deletion itself, and any data we are legally required to keep, as set out above. Deletion cannot be undone.

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14. How we protect your data

We implement appropriate technical and organisational measures under GDPR Article 32, including:

• encryption of data in transit using TLS, and encryption of data at rest;
• passwords stored only as salted hashes using a modern password-hashing algorithm — never in plain text;
• role-based access control and the principle of least privilege for employee access;
• logging and monitoring of access to production systems;
• segregation of production, staging and development environments;
• regular backups, with restore testing;
• security review of code changes and of third-party dependencies;
• contractual security obligations on all processors.

No system can be guaranteed to be completely secure. If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority within 72 hours where required (GDPR Art. 33) and inform affected users without undue delay where the risk is high (GDPR Art. 34).

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15. Children's privacy

The Services are not directed to children. You must be at least 16 years old to create a Basket account.

• In the EU/EEA, the GDPR sets the age of consent for information society services at 16, with Member States permitted to lower it to no less than 13. In the Netherlands the applicable age is 16.
• In the United States, our minimum age is 13, in line with the Children's Online Privacy Protection Act.

We do not knowingly collect personal data from children below the applicable age. If we become aware that we have done so, we will delete the data promptly. If you believe a child has provided us with personal data, contact [email protected].

Basket is not submitted to Apple's Kids Category or Google Play's Designed for Families. If that ever changes, this section will be rewritten before release.

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16. Links to other websites and services

The Services contain links to retailers, brands and other third-party websites and apps. Following such a link takes you outside Basket. We do not control those destinations, and this Privacy Policy does not apply to them. We encourage you to read the privacy policy of any site you visit.

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17. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes to the Services, to our data practices, or to the law. When we do:

• we will update the "Last updated" date at the top of this page;
• we will keep the previous version available at https://bask3t.app/privacy-policy/archive;
• where the change is material — for example a new purpose of processing, a new category of recipient, or a change in legal basis — we will notify you in advance by email or through an in-app notice, and where the law requires it we will ask for your consent.

Continued use of the Services after a change takes effect means you have read the updated policy.

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18. How to contact us

You also have the right to lodge a complaint with your local data protection supervisory authority at any time. In the Netherlands this is the Autoriteit Persoonsgegevens, Postbus 93374, 2509 AJ The Hague, autoriteitpersoonsgegevens.nl.

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Prepared for BASK3T International B.V. Not legal advice. Before App Store submission, have qualified Dutch counsel review this policy against the shipping build, App Store privacy labels, and signed processor agreements.