Privacy Policy

1. Scope of this Privacy Policy

This Privacy Policy describes how Foodfe AS collects, uses, shares, stores and protects personal data when you use the Foodfe Services.

The Foodfe Services covered by this policy include:

This policy does not replace a separate privacy notice from your employer, a meal provider, Dintero or another organisation that independently decides how it uses your personal data.

2. Who is responsible for your personal data?

Foodfe AS is generally the data controller for user accounts, authentication, meal orders, Foodfe payment administration, platform security, technical operation, customer support and the development of the Foodfe Services.

3. Roles of employers and meal providers

Your employer or workplace organisation

Your employer or workplace organisation may give Foodfe your name, contact details, workplace, programme eligibility and subsidy or allowance information. The employer is responsible for its own use of employee information and for explaining the legal basis for that use.

Depending on the customer agreement, Foodfe may process some workplace administration data on the employer's documented instructions as a data processor, while acting as an independent controller for the core Foodfe account, ordering, payment, security and support functions described in this policy.

Kitchens, caterers and other meal providers

A meal provider acts as Foodfe's data processor when it uses order information solely to prepare and fulfil meals on Foodfe's instructions. A provider may also act as an independent data controller for its own legal duties or independently determined purposes, such as accounting, food-safety obligations, handling a complaint or defending a legal claim. When acting independently, the provider is responsible for its own privacy information and legal basis.

4. Personal data we process

The categories of personal data depend on how you use Foodfe.

Account and contact data

Name, email address, telephone number, employer or workplace, language, account identifier and account status.

Authentication data

Login identifier, encrypted or securely managed credentials, one-time-code status, authentication tokens, login time and failed-login information. Authentication is provided through Amazon Cognito.

Workplace programme data

Workplace, programme eligibility, subsidy or allowance level, price category and programme start or end information.

Order data

Meal selection, portion size, scheduled date, workplace or pickup location, order number, status, price and order history.

Dietary data

Dietary preferences, allergy and intolerance information, ingredient exclusions and free-text meal instructions that you choose to provide.

Payment data

Dintero payment token or reference, card brand, last four card digits, payment and refund status, transaction amount and billing address. Foodfe does not store your full card number or card security code.

Technical data

Essential session information and operational logs, such as timestamps, request or error identifiers, app or browser version and network metadata that may include an IP address when generated by the hosting infrastructure.

Support data

Emails, requests, complaints, feedback and information needed to investigate and answer your enquiry. Support emails are stored in Microsoft 365/Outlook.

Business contact data

Name, role, organisation, business contact details and correspondence for employer administrators, kitchens, caterers, suppliers and other business contacts.

5. Where personal data comes from

Foodfe may receive personal data:

• directly from you when you register, update your profile, place an order, provide dietary information, make a payment or contact support;
• from your employer or workplace administrator when they enrol you or manage programme eligibility and subsidies;
• from a kitchen or meal provider when it updates fulfilment or order information;
• from Amazon Cognito when it authenticates your login;
• from Dintero and participating financial institutions when they process a payment or refund; and
• automatically from essential technical systems when you use the Foodfe Services.

6. Why we process personal data

Foodfe only processes personal data for identified purposes and where a legal basis under applicable data-protection law applies.

When Foodfe relies on legitimate interests, it assesses whether the processing is necessary and balances Foodfe's interests against your rights and reasonable expectations.

7. What your employer can see

Depending on the workplace programme and your employer's permissions, an authorised employer or canteen administrator may see:

• your name and contact details;
• whether you are registered with Foodfe;
• your meal-programme eligibility;
• your subsidy or allowance level;
• your individual meal orders; and
• the prices associated with your individual orders.

Foodfe does not provide employers with behavioural advertising profiles. Employers must use information available through the employer portal only for legitimate workplace meal-programme administration and related billing or support.

8. Allergies and dietary information

Providing dietary preferences, allergy information or intolerance information is optional. Some of this information may reveal health, religion or beliefs and may therefore be special-category personal data under the GDPR.

Before Foodfe stores special-category dietary information, the app asks for your separate and explicit consent. The consent notice explains the purpose, the relevant recipients and how you can withdraw consent.

Foodfe uses this information only to:

• help display or prepare appropriate meals;
• communicate relevant preparation instructions to the kitchen or meal provider;
• respond to questions or complaints concerning the relevant order; and
• protect or defend legal claims where legally necessary.

Foodfe does not use allergy or sensitive dietary information for advertising, marketing segmentation, employee monitoring or employment decisions.

You can edit or remove allergy and dietary information through your profile or settings. To formally withdraw consent or request deletion from systems not directly controlled through the app, email support@foodfe.app. Withdrawal does not affect processing that was lawful before withdrawal, but it stops future consent-based processing.

9. Payments

User payments are processed by Dintero. Card information is entered directly into the payment provider's secure payment flow. Foodfe does not receive or store your full card number or card security code.

Foodfe may receive and retain:

• a payment token or transaction reference;
• the card brand and last four card digits;
• payment, failure and refund status;
• transaction amount; and
• billing address.

Dintero, banks and payment networks may act as independent controllers for payment authorisation, fraud prevention, anti-money-laundering duties and other regulatory purposes. Their own privacy notices apply to those activities.

10. Who receives personal data

Foodfe shares personal data only when needed for the purposes described in this policy.

Foodfe does not sell or rent personal data.

11. Cookies, local storage and technical logs

Foodfe uses only technologies that are necessary to provide and secure the Services. These may include essential session cookies, secure authentication tokens and equivalent local-storage technologies.

Necessary technologies are used to:

• keep you signed in and maintain a secure session;
• complete authentication and prevent unauthorised access;
• remember essential service or privacy settings;
• process an order or payment flow; and
• detect and troubleshoot operational errors.

Foodfe does not use optional analytics cookies, advertising or retargeting cookies, advertising identifiers, behavioural advertising, precise location tracking or optional push-notification tracking.

Amazon CloudWatch is used for essential operational logging and error monitoring. Foodfe retains these records only for the operational and security purposes described in this policy, not for advertising or cross-service tracking.

Because Foodfe currently uses only strictly necessary technologies, no optional cookie-consent platform is used. Blocking necessary cookies or local storage may prevent login or other core functions from working.

12. International data transfers

Foodfe's primary production environment is hosted in Ireland, within the European Economic Area (EEA). Foodfe currently configures its services so that personal data is intended to be processed in Norway or elsewhere in the EEA.

Some suppliers are international organisations. If supplier support, subprocessors or another arrangement results in personal data being accessed from or transferred to a country outside the EEA, Foodfe will ensure that a lawful transfer mechanism and appropriate safeguards are in place before the transfer, such as an adequacy decision or the European Commission's Standard Contractual Clauses.

You may contact the DPO for information about the transfer safeguards applicable to a particular service provider.

13. How long we keep personal data

Foodfe keeps personal data only as long as needed for the relevant purpose, subject to legal requirements and legitimate needs relating to security, complaints, audits and legal claims.

When a retention period expires, Foodfe deletes or anonymises the information. Data may be retained longer where required by law, necessary to resolve an outstanding dispute or needed to establish, exercise or defend a legal claim.

14. How we protect personal data

Foodfe uses technical and organisational safeguards appropriate to the information and relevant risks. These may include:

• role-based access controls and least-privilege access;
• secure authentication through Amazon Cognito;
• encryption during transmission and encryption at rest where appropriate;
• logging, monitoring and incident-response procedures;
• backup, restoration and business-continuity measures;
• separation of production and development environments;
• confidentiality obligations for authorised personnel; and
• contractual and security requirements for data processors.

No internet service can guarantee absolute security. Contact Foodfe immediately if you believe your account or personal data has been compromised.

15. Children and young users

Foodfe does not apply a fixed minimum age because employees and apprentices under 18 may be eligible to use Foodfe through their workplace. Foodfe handles children's and young people's information with additional care and provides information in clear language appropriate to the user.

Where Foodfe relies on consent to provide an online service directly to a child under 13 in Norway, consent must be given or authorised by the person with parental responsibility.

Allergy and health-related information receives stronger protection. Foodfe requires verifiable consent from a parent or guardian before relying on consent to process this type of information for a user under 18, unless another valid legal basis for the special-category processing clearly applies.

A parent or guardian may contact support@foodfe.app or the DPO to ask about a young user's information or to exercise applicable rights on the young user's behalf.

16. Automated decisions

Foodfe does not make decisions based solely on automated processing that produce legal effects or similarly significant effects for users.

Technical systems may automatically validate a login, check order rules, process a payment response or flag unusual activity. Where a decision could materially restrict your account or access to the Services, Foodfe provides appropriate human review.

17. Your data-protection rights

Subject to the conditions in applicable law, you may have the right to:

• receive confirmation of whether Foodfe processes your personal data and obtain access to it;
• correct inaccurate or incomplete information;
• request deletion of personal data;
• request restriction of processing;
• receive eligible information in a structured, commonly used and machine-readable format;
• object to processing based on legitimate interests;
• withdraw consent at any time for future processing; and
• complain to a data-protection authority.

You can correct profile information and edit or remove dietary information in the app. Data download, full account deletion and formal withdrawal requests are not currently available as self-service functions. Send these requests to support@foodfe.app with the subject Privacy request, or contact the DPO at anika@dcx.no.

Foodfe may request information reasonably necessary to verify your identity. Foodfe will normally respond within one month. The period may be extended where permitted by law for complex or numerous requests, and Foodfe will explain any extension.

Where Foodfe processes information solely on an employer's documented instructions, Foodfe may forward the request to the employer or assist the employer with its response.

18. Complaints

Please contact Foodfe or the DPO first so the concern can be investigated. You also have the right to complain to the Norwegian Data Protection Authority:

You may also complain to the supervisory authority in the EEA country where you live, work or believe an infringement occurred.

19. Changes to this Privacy Policy

Foodfe may update this policy when the Services, data-processing activities, providers, legal requirements or organisational arrangements change. The date at the top of the page shows when the policy was last updated.

Foodfe will provide an appropriate notice before a material change takes effect. When a new purpose requires consent, Foodfe will request new consent rather than treating continued use as consent.

20. Contact Foodfe

Questions about this policy or Foodfe's use of personal data can be sent to: