Effective: July 17, 2026 · v7

Privacy Policy

1. Introduction

Rouxbarb ApS ("Rouxbarb ApS," "we," "us," or "our") operates the Rouxbarb application and related services (collectively, the "Service"). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you use our Service.

Rouxbarb ApS is a company registered in Denmark, CVR no. 46028244, and acts as the data controller for personal data processed through the Service.

By using the Service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use the Service.

2. Data We Collect

2.1 Information You Provide

• Account information: name and email address when you create an account. Sign-in is handled via Apple, Google, or a one-time email sign-in link (passwordless) — we do not collect or store a password.

• Profile information: handle, display name, profile photo, optional bio, and other optional details you choose to share.

• User-generated content: recipes, Experiences, ratings, comments, photos, and shopping lists you create or upload.

• Communications: messages you send to us through support channels or feedback forms.

• Declared interests (optional): you may choose to tell us which kinds of food content you want to see more of by selecting interest tags in Settings → My Interests (for example, cuisines, meal types, or dietary styles). Providing interests is entirely optional, is never required to use the Service, and is collected only through that dedicated screen — we do not infer or auto-populate declared interests from your behaviour. Some interest tags may reveal, or be capable of suggesting, special categories of personal data — for example, religious or philosophical beliefs (such as Kosher, Halal, or Vegan) or health information (such as allergy-related or medically-associated diets). We collect and use such tags only with your explicit consent, which you give by selecting them on the My Interests screen after being informed of this use (Art. 9(2)(a) GDPR). We use declared interests for one purpose only: personalising the content shown to you. You can change or remove your declared interests at any time in Settings; removing a tag deletes it and immediately stops its use in personalisation.

2.2 Information Collected Automatically

• Usage data: pages viewed, features used, search queries, recipes saved, and interaction patterns.

• Personalisation data: to recommend content you are likely to enjoy, we derive a numerical representation of your engagement patterns (an "affinity profile") from the content you view, save, like, and cook from. This profile is a mathematical pattern used solely to measure similarity between content you have engaged with and other content on the Service; it is computed from your recent activity when your feed is generated and is not stored as a lasting record (see Section 8). It is not a set of labels or categories about you, and we do not use it to derive, record, or act on conclusions about your beliefs, health, or other special categories of personal data. See Section 3 for how this works and how to object.

• Device information: device type, operating system, app version, language settings, and unique device identifiers.

• Log data: IP address, access times, and crash reports.

• Location data: we do not collect your device’s GPS location, and the app does not request location permissions. A coarse, approximate location (such as country or region) may be derived from your IP address. When you tag a place on an Experience, we store the location of the place you select (for example, a restaurant) — not your own position.

2.3 Information from Third Parties

• Social login providers: if you sign in using a third-party account (e.g., Google or Apple), we may receive your name, email address, and profile picture as permitted by your settings with that provider.

3. How We Use Your Data

We process your personal data for the following purposes and legal bases under the GDPR:

Purpose | Legal Basis

Providing and maintaining the Service | Performance of a contract (Art. 6(1)(b))

Personalising recipe and content recommendations based on how you interact with the Service | Legitimate interest (Art. 6(1)(f)) — our interest in operating a useful, relevant discovery experience; you may object at any time (see Section 9)

Personalising recommendations based on interests you declare in Settings → My Interests | Consent (Art. 6(1)(a)); where a declared interest may reveal special categories of personal data (beliefs or health), your explicit consent (Art. 9(2)(a)) — withdrawable at any time by removing the interest or clearing your interests (see Section 9)

Communicating with you about your account or support requests | Performance of a contract (Art. 6(1)(b))

Sending service (transactional) emails — account verification, sign-in links, security notices, purchase receipts, and payout notices | Performance of a contract (Art. 6(1)(b)) and, for certain records, legal obligation (Art. 6(1)(c)) — these emails are necessary to provide the Service and cannot be unsubscribed from

Sending lifecycle emails related to your use of the Service (for example, a welcome email or onboarding tips shortly after you join) | Legitimate interest (Art. 6(1)(f)) — our interest in helping you get started with the Service you signed up for; every lifecycle email contains an unsubscribe link and you can opt out at any time

Sending our email newsletter, promotional emails, and push notifications | Consent (Art. 6(1)(a)) — withdrawable at any time via the unsubscribe link in any email or the Newsletter toggle in Settings

Analyzing usage trends to improve the Service | Legitimate interest (Art. 6(1)(f))

Detecting and preventing fraud or abuse | Legitimate interest (Art. 6(1)(f))

Complying with legal obligations | Legal obligation (Art. 6(1)(c))

Where we rely on your explicit consent to use declared interests that may reveal special categories of personal data, that consent is separate from your acceptance of our Terms of Service and from any other consent. It is given through the dedicated My Interests screen in Settings, is limited to the single purpose of personalising the content shown to you, and may be withdrawn as easily as it was given — remove a tag or clear your interests in Settings at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. Accepting our Terms of Service does not constitute consent to this processing.

Emails we send. We send three kinds of email. Service (transactional) emails — such as sign-in links, account verification, security notices, purchase receipts, and payout notices — are necessary to operate the Service; because the Service cannot function without them, they cannot be unsubscribed from and are not affected by any marketing opt-out. Lifecycle emails — such as a welcome email or a small number of onboarding tips after you join — relate to your use of the Service; each one contains an unsubscribe link, and opting out stops all future lifecycle emails immediately. Newsletter and marketing emails are sent only with your consent; each one contains an unsubscribe link, and you can also opt out at any time using the Newsletter toggle in Settings. Opting out of lifecycle or marketing emails never affects service emails or your use of the Service.

How our recommender system works. When you use the Service, our recommender system suggests recipes and Experiences by comparing content: it converts each post into a numerical pattern, builds an affinity profile from the patterns of content you have engaged with (viewed, saved, liked, cooked from), and surfaces other content whose pattern is similar. Your personalised feed is regenerated regularly based on your recent activity. The most significant factors determining what you are shown are: (a) the similarity of a post to content you have recently engaged with; (b) the type and strength of your engagement (for example, cooking from a recipe weighs more than viewing it); (c) the recency and popularity of the post; and (d) if you have declared interests in Settings → My Interests, how well a post matches those interests. The behavioural part of the system matches content to content: it is not designed to identify, categorise, or record your religious or philosophical beliefs, health, or other special categories of personal data, and we do not query or analyse affinity profiles to draw such conclusions. As a safeguard, content categories whose inference could reveal such data (for example, religious dietary practices, belief-based diets, or allergy- and health-associated diets) are excluded from behavioural inference entirely: the system will never learn or score them from your viewing, saving, liking, or cooking activity. The only way such a category can influence your recommendations is if you explicitly declare it yourself in My Interests, with the consent described in Section 2.1.

You may object to this personalisation at any time, free of charge, by contacting us or using the feed-mode control in Settings (see Section 9). If you object, we stop generating personalised recommendations for you and discard any cached affinity data; you will see non-personalised content instead, and the Service remains fully usable.

4. Cookies and Similar Technologies

Rouxbarb is a native mobile application and does not use cookies. Our website at rouxbarb.com, which hosts these legal documents, does not set cookies either. We do not use analytics, advertising, or other tracking technologies.

5. Third-Party Service Providers

We share personal data with the following third parties. Except where stated otherwise below (in particular Apple, which acts as an independent controller for App Store purchases and Sign in with Apple), each acts as a processor on our behalf under a data processing agreement compliant with Article 28 of the GDPR:

Category | Provider | What they process

Cloud infrastructure, database, authentication, AI processing, push notifications, AI language model, place search & bot detection | Google (GCP, Firebase, Vertex AI, Gemini, FCM, Google Places, reCAPTCHA Enterprise) | All user data, content, logs, identity tokens, usage behaviour, user photos, recipe text, voice transcripts, device tokens, conversational query text, place search queries, sign-up bot-detection signals

Error monitoring | Sentry | Crash reports, error diagnostics, device and app state, IP address, user IDs

In-app purchases & authentication | Apple (App Store IAP, Sign in with Apple) | Transaction data, Apple ID, and (where you sign in with Apple) your authentication identity token and name. In respect of App Store purchases and Sign in with Apple, Apple acts as an independent data controller for the data it collects and processes for those purposes (including payment processing, billing, fraud prevention and authentication), under Apple’s own privacy policy, rather than as our processor. We are the controller only for the limited transaction and identity data Apple makes available to us and which we then process in the Service

Payout processing | Stripe (Stripe Connect) | Creator identity and bank account data collected for KYC verification and payout disbursement. Stripe processes Creator payout data only. Stripe does not process End-User payment card data — all End-User purchases are handled by Apple IAP

Voice AI — Kitchen Assistant (STT & TTS) | ElevenLabs | Voice input, synthesised voice output

Email delivery | Resend | Your email address and the content of account verification, sign-in link, notification, support, and lifecycle emails, and — where you have opted in — our email newsletter and other marketing emails

Operational alerting | Slack | The content of any bug report or support message you submit from the app

Firebase is used solely for authentication and push notification delivery (FCM); we do not use the Firebase Analytics SDK. reCAPTCHA Enterprise runs only on our website for bot detection at sign-up and does not store or read information on your device.

Wake-word detection for the Kitchen Assistant ("Hey Rouxbarb") is performed entirely on your device using a local model. No audio is transmitted to Rouxbarb ApS, ElevenLabs, Google, or any other third party unless and until the wake word is detected on your device. Once activated, your spoken input is transmitted to ElevenLabs for transcription and to Google (Gemini) for generating a response, and the response is converted to speech by ElevenLabs and streamed back to your device.

These providers are contractually obligated to process your data only as instructed by us and in compliance with applicable data protection laws.

6. Data Sharing and Disclosure

We do not sell your personal data. Neither your declared interests nor your affinity profile is visible to other users, and neither is shared with any outside party for that party's own purposes; they are stored securely and used only to personalise the content shown to you. We may disclose personal data in the following circumstances:

• With your consent: when you direct us to share information with a third party.

• Service providers: as described in Section 5 above.

• Legal requirements: when required by law, regulation, legal process, or governmental request.

• Business transfers: in connection with a merger, acquisition, or sale of assets, in which case you will be notified of any change in data controller.

• Safety and rights: to protect the rights, property, or safety of Rouxbarb ApS, our users, or others.

7. International Data Transfers

Rouxbarb ApS is based in Denmark (EU/EEA). Some of our processors are located in the United States. We rely on the following transfer mechanisms under Chapter V of the GDPR:

7.1 EU–US Data Privacy Framework. For transfers to Google (Google LLC), Stripe (Stripe, Inc.), Sentry (Functional Software, Inc.), Slack (Salesforce, Inc. / Slack Technologies, LLC), ElevenLabs (US entity) and Resend, we rely on their certification under the EU–US Data Privacy Framework, which the European Commission has recognised as providing an adequate level of protection. Before relying on a provider's certification we verify that the correct legal entity is actively certified for the relevant category of data (non-HR data). Where a certification lapses or ceases to cover a transfer, we rely on the Standard Contractual Clauses described in Section 7.2 as a fallback.

7.2 Standard Contractual Clauses. As a fallback for any processor not covered by the Data Privacy Framework, we rely on the Standard Contractual Clauses adopted by the European Commission under Commission Implementing Decision (EU) 2021/914 of 4 June 2021, supported by a documented transfer impact assessment and, where appropriate, supplementary technical and organisational measures.

7.3 Apple (independent controller). In respect of App Store purchases and Sign in with Apple, Apple acts as an independent data controller and any international transfer of the data Apple controls is governed by Apple’s own privacy policy and transfer mechanisms, not by controller-to-processor Standard Contractual Clauses entered into by us.

7.4 Continuity of safeguards. If any transfer mechanism on which we rely is invalidated, suspended, or otherwise ceases to be available, we will identify and implement an alternative lawful transfer mechanism to ensure your personal data continues to receive an adequate level of protection.

A copy of the applicable safeguards is available on request by contacting us at privacy@rouxbarb.com.

8. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

• Account data: retained for the lifetime of your account. When you delete your account, your personal data is deleted immediately, except: (a) records we are required to retain by law — such as the payment and payout records described below, which are pseudonymised (the link to your identity is severed) and retained; (b) a short period needed to purge data from routine backups; and (c) if you were a Creator, your Creator credit — your Creator name and profile image, as they appeared at the time of sale — on content you sold to End-Users. This credit is preserved as attribution on those End-Users' purchases, as a fixed record detached from any active profile, so that buyers keep access to the recipe they paid for *by you*. It is limited to content that was actually purchased or accessed under a subscription, we make no new use of it, and it is not a live or updatable profile. We retain it on the legal bases of: performing our contract with those buyers; your agreement to this under the Creator Program (Terms Section 7.9); the legitimate interests of buyers and of Rouxbarb ApS in the integrity of purchased content; and the establishment or exercise of legal claims. See Terms Sections 7.5 and 7.9.

• Personalisation data: your behavioural affinity profile is not stored as a lasting record. It is recomputed from your recent activity each time your feed is generated and held only in a short-lived cache (approximately 30 minutes) before it expires; your generated recommendation feed is likewise held in a short-lived cache. The underlying interaction events are retained for the lifetime of your account and deleted when you delete your account.

• Declared interests: retained until you remove them in Settings → My Interests (removal takes effect immediately) or delete your account, whichever comes first. Withdrawing consent for a declared interest deletes it; withdrawal does not affect the lawfulness of personalisation carried out before withdrawal.

• Voice input and transcripts: voice input for the Kitchen Assistant is processed in real time and the resulting transcripts are not retained beyond the active session — they are purged when the session ends.

• Usage and analytics data: retained in an aggregated or anonymized form for up to 26 months.

• Communications: retained for up to 24 months after the inquiry is resolved.

• Email preferences and consent records (newsletter, marketing, and lifecycle emails): your subscription status and the record of when and how you gave or withdrew consent are retained for as long as you hold a Rouxbarb account, to evidence consent and to keep honouring your preferences. When your account is deleted, these records are deleted with it. We retain only a minimal suppression entry (your email address and the fact that it must not be contacted) after account deletion, so that your opt-out continues to be honoured. Unsubscribing takes effect immediately for future sends, though you may occasionally receive a message that was already in transit.

• Suppression list: we maintain a suppression list of email addresses that must not be contacted — addresses that have opted out, hard-bounced, generated a spam complaint, or been suppressed manually. Each entry contains only the email address and the reason it must not be contacted. Suppression entries are retained for as long as necessary to prevent unwanted contact, which in practice means they are not deleted, on the basis of our legitimate interest in honouring opt-outs and maintaining email deliverability (Art. 6(1)(f)) and, for opt-outs, our legal obligation to respect them (Art. 6(1)(c)). Because deleting a suppression entry would defeat its purpose — it exists to ensure we do not contact you — an erasure request does not extend to the suppression entry itself.

• Payment and payout records (Creator transaction history, payout records, Stripe Connect data) | 5 years from the end of the relevant financial year | Required under the Danish Bookkeeping Act (Bogføringsloven). This retention period applies regardless of account deletion and overrides any shorter preference expressed by the Creator.

9. Your Rights Under the GDPR

If you are in the EU/EEA, you have the following rights regarding your personal data:

• Access: request a copy of the personal data we hold about you.

• Rectification: request correction of inaccurate or incomplete data.

• Erasure: request deletion of your data ("right to be forgotten"), subject to the limited exceptions in Section 8 — including records we must keep by law, suppression entries (which exist to ensure we do not contact you), and, if you were a Creator, the retained Creator credit on content you have sold to End-Users.

• Restriction: request that we limit how we process your data.

• Data portability: receive your data in a structured, machine-readable format.

• Objection: object to processing based on legitimate interest, including personalised recommendations (via the feed-mode control in Settings or by contacting us — if you object to personalisation, we stop generating personalised recommendations, discard any cached affinity data, and serve you non-personalised content), lifecycle emails (via the unsubscribe link in any lifecycle email), and to direct marketing.

• Withdraw consent: withdraw consent at any time where processing is based on consent (for example, marketing communications (unsubscribe link in any email, or Profile > Settings > Account > Newsletter), or interests you have declared in Settings → My Interests — remove a tag or clear your interests there, and it is deleted and no longer used). Withdrawal does not affect the lawfulness of processing carried out before withdrawal. Service (transactional) emails, such as sign-in links, security notices, and receipts, are necessary to provide the Service and are not affected by marketing opt-outs.

To exercise any of these rights, contact us at the address provided in Section 15. We will respond within one month of receipt of your request. That period may be extended by up to two further months where necessary, taking into account the complexity and number of requests, in which case we will inform you within one month of the reasons for the delay. You also have the right to lodge a complaint with the Danish Data Protection Agency (Datatilsynet) or another relevant supervisory authority.

10. Your Rights Under the CCPA/CPRA (California Residents)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the "CCPA/CPRA"), grants you additional rights, to the extent it applies to Rouxbarb ApS:

• Right to know: you may request details about the categories and specific pieces of personal information we have collected about you, the sources of that information, our business purposes for collecting it, and the categories of third parties with whom we share it.

• Right to delete: you may request that we delete the personal information we have collected from you, subject to certain exceptions.

• Right to correct: you may request that we correct inaccurate personal information we hold about you.

• Right to opt out of sale or sharing: Rouxbarb ApS does not sell or share personal information as those terms are defined under the CCPA/CPRA. If this changes, we will provide a "Do Not Sell or Share My Personal Information" link.

• Right to limit use of sensitive personal information: you may request that we limit the use of any sensitive personal information to that necessary to provide the Service.

• Right to non-discrimination: we will not discriminate against you for exercising any of your CCPA/CPRA rights.

To exercise these rights, contact us at the address provided in Section 15. We will verify your identity before processing your request and respond within 45 days.

11. Children's Privacy

The Service is not directed at children under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have collected personal data from a child under 16, we will take steps to delete that information promptly.

Where a user is aged 16 or 17, they may use the Service on the basis set out in our Terms of Service (which requires the consent of a parent or legal guardian). We process the personal data of users aged 16 and 17 on the same bases described in this Privacy Policy, apply data minimisation, and do not direct marketing specifically at them.

Creators who apply to receive payouts through the platform must be at least 18 years of age. Payout-related identity verification is processed by Stripe under Stripe's own terms and privacy policy. Stripe's KYC process requires Creators to provide government-issued identification; this data is collected and held by Stripe directly and is not stored by Rouxbarb ApS. If you believe we may have collected data from a child under 16, please contact us.

12. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption in transit and at rest, access controls, regular security assessments, and employee training. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

In the event of a personal data breach, we will notify the Danish Data Protection Agency (Datatilsynet) without undue delay and, where feasible, within 72 hours of becoming aware of it, in accordance with Article 33 of the GDPR. Where the breach is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay in accordance with Article 34 of the GDPR.

13. Changes to This Privacy Policy

Where we make material changes to this policy — including changes to what data we collect, how we use it, or who we share it with — we will update the "Effective" date at the top of this policy and post the revised version at rouxbarb.com/legal/privacy. We may also post a notice on the Platform to draw your attention to significant changes.

Where a change affects processing that relies on your consent (for example, marketing communications, or your explicit consent to the use of declared interests), we will obtain your fresh consent before the change takes effect for that processing; continued use of the Service alone does not constitute acceptance of such changes. For changes that do not rely on your consent, your continued use of the Platform following the update constitutes your acceptance of the revised policy.

14. Beta Signup Privacy Notice

If you applied to join the Rouxbarb closed beta program, your signup data was collected and processed separately under our Beta Signup Privacy Notice, available at rouxbarb.com/legal/beta-privacy. That notice governs data collected during the beta application process only. This Privacy Policy applies once you become a registered user of the Platform, whether through beta conversion or direct signup at full launch. If you converted from a beta tester to a registered user, your data handling transitions to this Privacy Policy from the date your account was activated on the live Platform.

15. Contact Us

If you have questions about this Privacy Policy or wish to exercise your data protection rights, please contact us:

Rouxbarb ApS | privacy@rouxbarb.com | rouxbarb.com

Vesterbrogade 74, 1620 København V, Denmark | CVR: 46028244

For complaints, you may also contact the Danish Data Protection Agency (Datatilsynet) at datatilsynet.dk.