Effective: September 27, 2026 · v8

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.

This version (v8) replaces v7 and, in addition to the changes described in Section 13, sets out in more detail how we handle Creator payout, tax, and compliance data (Sections 2.4, 5, 8 and 12).

2. Data We Collect

2.1 Information You Provide

2.2 Information Collected Automatically

2.3 Information from Third Parties

2.4 Creator Payout, Tax and Compliance Data

If you take part in the Creator Program and are eligible to receive payouts, we additionally collect and hold:

Two deliberate limits apply to this category. First, we do not collect or store identity documents (such as scans of a passport or driving licence) and we never store biometric templates. If we ever require an identity check before a payout (see our Terms, Section 7.4(c)), it will be run by a verification provider and we will keep the result and a minimal extract, not the underlying documents. Second, the most sensitive elements, full bank account numbers and taxpayer identification numbers, are encrypted at rest in a separate vault in the EU (Google Cloud, Frankfurt) rather than in the application database, which holds only masked references to them (such as the last digits, the account country, and the holder name needed to operate payouts and screening). They pass through our application servers in the United States in memory only, on their way into the vault. The rest of the information described above (your legal name, postal address, date of birth, tax residence and any VAT or registration number) is stored in our primary application database in the United States (Google Cloud, Iowa), with access limited to authorised administrators; you can also see and change the postal address you entered with your bank details in the app. See Sections 7 and 12.

Sanctions-screening records are held for compliance purposes, are visible only to authorised administrators, and are not shown in the Creator dashboard.

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
Calculating Creator earnings and settling them to a Creator's payout account Performance of a contract (Art. 6(1)(b)) — settlement of the Creator agreement in our Terms of Service
Checking that payout details are plausible and can receive payments (including asking our payout partner, when you enter them, whether it would accept them), confirming that changes to them come from you, and, where we require it, verifying the identity of a Creator we are paying Legitimate interest (Art. 6(1)(f)) — our interest in paying the right person and preventing payout fraud; and performance of a contract (Art. 6(1)(b))
Screening payees against applicable sanctions lists before each payout Legal obligation (Art. 6(1)(c)) — EU restrictive-measures rules bind all EU entities and prohibit making funds available to designated persons
Collecting taxpayer information and reporting Creator earnings to tax authorities Legal obligation (Art. 6(1)(c)) where a reporting regime applies to us; performance of a contract (Art. 6(1)(b)) where we collect the information in advance of a payout as a condition of settlement
Keeping accounting records of purchases, earnings and payouts Legal obligation (Art. 6(1)(c)) — Danish Bookkeeping Act (Bogføringsloven)
Analyzing usage trends to improve the Service Legitimate interest (Art. 6(1)(f))
Detecting and preventing fraud or abuse, security monitoring, and audit logging Legitimate interest (Art. 6(1)(f))
Complying with other 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.

Automated decision-making. We do not make decisions producing legal or similarly significant effects about you by automated means alone. Where a payout is automatically held, for example because a sanctions screening has flagged a potential match, a person reviews the hold before any final decision is taken, and you can contact us to have it reviewed.

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 categories of recipient set out below. Except where stated otherwise (in particular Apple and Google, which act as independent controllers for app-store purchases and sign-in, and the bank and payment providers that execute Creator payouts, which act as independent controllers), each acts as a processor on our behalf under a data processing agreement compliant with Article 28 of the GDPR. We maintain a register of our current processors and sub-processors; you can request the current list at privacy@rouxbarb.com.

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) and, for the Android application, Google (Google Play Billing) Transaction data, account identifiers, and (where you sign in with Apple or Google) your authentication identity token and name. In respect of app-store purchases and sign-in, Apple and Google act as independent data controllers for the data they collect and process for those purposes (including payment processing, billing, fraud prevention and authentication), under their own privacy policies, rather than as our processors. We are the controller only for the limited transaction and identity data they make available to us and which we then process in the Service
Payout validation and execution Our payout partners: Revolut (our corporate bank) and Airwallex (a regulated payment institution) The account holder's name, payout account details and postal address, and the payment instruction needed to settle a payout. When you enter or change your payout details, we also send the same details (without a payment) to the partner that will pay you, so that it can confirm it would accept them, and we may decline details it refuses. Revolut and Airwallex receive these details under their own terms and act as independent controllers for them, including for their own anti-money-laundering and sanctions obligations; they may process data outside the EU/EEA (see Section 7). Where your bank account is outside the EU/EEA, your bank receives the payment and your details in that country. End-User payment card data is never processed by them; all End-User purchases are handled by the applicable merchant of record
Former payout provider Stripe Stripe made Creator payouts for us until 25 September 2026. It continues to hold the data it received from Creators it paid, as an independent controller under its own terms, and receives no new Creator data from us
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:

7. International Data Transfers

Rouxbarb ApS is based in Denmark (EU/EEA). Some of our processors are located in the United States. Our starting principle is that sensitivity determines geography. For Creators this works as follows. Bank details and taxpayer identification numbers are encrypted at rest in an EU vault (Google Cloud, Frankfurt); they transit our application servers in the United States in memory only. Your legal name, address, date of birth and tax residence are stored in our primary database in the United States (Google Cloud, Iowa), under the EU–US Data Privacy Framework and the Standard Contractual Clauses described below. Our payout partners, Revolut and Airwallex, receive your name, bank details and address to validate and execute payouts, under their own terms and as independent controllers. Creators outside the EU are paid to banks in their own countries, which necessarily receive the payment and the details needed to credit it; sending your details to your own bank is necessary to perform our contract with you. For the remaining data, 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), 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. Where the data of UK or Swiss users is in scope, the UK Addendum or the Swiss annex applies.

7.3 Apple and Google (independent controllers). In respect of app-store purchases and sign-in with Apple or Google, those companies act as independent data controllers and any international transfer of the data they control is governed by their own privacy policies and transfer mechanisms, not by controller-to-processor Standard Contractual Clauses entered into by us. The same applies to our payout partners, Revolut and Airwallex, for the Creator data they receive to validate and execute payouts, and to the bank that holds a Creator's account.

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.

7.5 Creator payouts to banks outside the EEA. When we pay a Creator whose bank account is held outside the EEA (for example in the United Kingdom, the United States, Canada, Australia or New Zealand), the payout instruction carries the Creator's name, bank account details and postal address to that bank, because a bank transfer cannot be made without them. That transfer is necessary for the performance of our Creator agreement with you, and we rely on Article 49(1)(b) GDPR for it. Where the destination country benefits from a European Commission adequacy decision (for example the United Kingdom), we rely on that decision instead. The receiving bank and our payout partners act as independent controllers of the data they receive, as described in Section 7.3. We send nothing beyond what the transfer requires.

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. Where a legal obligation requires us to keep a record, deleting your account does not delete that record; the categories where this applies are listed below, so that our commitment to erasure is not stated more broadly than we can honour.

9. Your Rights Under the GDPR

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

If you are a Creator, note that we cannot settle payouts without the payout and tax information described in Section 2.4, and that sanctions screening before each payout is a legal obligation we cannot disapply at your request. Objecting to, or withdrawing, that processing means we are unable to make payouts to you; it does not affect your other rights.

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:

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.

Residents of other jurisdictions with comparable privacy legislation — including other US states, the United Kingdom, Canada, Australia, and New Zealand — may exercise equivalent rights available to them under their local law by contacting us at the same address; we apply the standards described in this policy to all users, regardless of where they live.

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. By joining the Creator Program, Creators confirm that they meet this requirement. We may ask for proof of age or identity before settling a payout (see our Terms, Section 7.4(c)); where we use a specialist verification provider for this, we receive the result rather than the underlying identity documents. 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, audit logging, regular security review, and employee training. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Protection proportionate to sensitivity. We hold different kinds of data with different levels of protection:

Incident response. 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. Where users in other jurisdictions are affected, we notify the relevant authority and affected users as required by the law applicable to them. We maintain internal incident runbooks so that these steps are carried out promptly.

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.

What changed in v8. This version describes in detail the payout, tax, and compliance data we process for Creators and the protections applied to it (Sections 2.4, 5, 12); states the legal bases for those activities, including sanctions screening and tax reporting (Section 3); sets out the retention periods that survive account deletion (Section 8); describes where Creator payout and tax data is stored and to whom it is disclosed (Sections 2.4, 7 and 12), including the postal address collected with bank details; and names our payout partners, Revolut and Airwallex, and our former payout provider, Stripe (Section 5). It does not change how we handle End-User data, declared interests, or personalised recommendations.

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.

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