Last modified: 14 August 2025

This privacy notice describes how we will collect, use, share and otherwise process your personal data in connection with your use of:

• Social Gems mobile application software (App)
• Any of our services that is accessible through the App (Services)

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important Information and Who We Are

TEK JUICE LIMITED is the controller and is responsible for your personal data (we, us or our in this notice).

As a member of a group of companies, we will share your personal data with other members of our group as set out below.

We have appointed a data privacy manager. If you have any questions about this privacy notice, please contact them using the details set out below.

Contact details

Our full details are:

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues.

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review.

This version was last updated on the date stated at the beginning of the policy. It may change and, if it does, those changes will be posted on this page and notified to you when you next start the App or log onto your account. You may be required to read and acknowledge the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you. Please visit the Profile section to update your details.

Third party links and sites

Our App and Services may, from time to time, contain links to and from the websites of third parties. Please note that these websites (and any services accessible through them) are controlled by those third parties and are not covered by this privacy notice.

You should review their own privacy notices to understand how they use your personal data before you submit any personal data to these websites or use these services.

The Data We Collect About You

We collect, use, store, and transfer different kinds of personal data about you.

For example, when you register with us and through your transactions and interactions with us.

We may also obtain additional information about you from other sources, such as social media and websites associated with you. The App also uses common automatic information collection and tracking technologies, such as cookies and beacons, to collect information about you.

Description of categories of personal data

• Identity Data:  first name, last name, title, date of birth and Profile Data.
• Contact Data:  first name, last name, contact address, email address and telephone numbers, your communication preferences, and copies of communications between you and us.
• Profile Data:  your email address, username and password.
• Transaction Data: billing and delivery addresses, payment card details, history of your payments, purchases, deliveries, returns and refunds and the applicable terms and conditions of your purchases.
• Device Data:  the type of device you use, your unique device identifier, mobile network information, your mobile operating system, the type of mobile browser you use, IP address, time zone setting.
• Content Data: information that you store or generate in the App, being [photos, videos and associated metadata, check-ins, posts and messages].
• Usage Data: logs and detail of your use of our Apps and Services, being the dates and times on which you download, access and update the App and our Services, any error or debugging information, and the resources that you access and the actions we and you take in relation to them and Cookies Data.
• Security Data: information we collect about your use of the App, our Services and our Sites in order to ensure your and our other users' safety and security, being Usage Data, the Cookies Data and the information provided to us by our payment processing provider.
• Cookies Data: the information collected through the cookies and similar technologies listed in our Cookies Notice.
• Direct Marketing Data: your direct marketing preferences, consents for receiving direct marketing from us and/or our third parties and the history of the direct marketing communications we have sent to you.
• Location Data: your current location as disclosed by GPS technology WiFi connections, your IP address for the time period where you have permitted us to collect it.
• Connected Data: information stored on your Device that you permit the App to connect to, being Contacts lists, login information, and camera data.
• Social Media Data: your social media account information.
• Feedback Data: your feedback and survey responses.
• Personalization Data: Cookies Data, Device Data, Content Data, Transaction Data, Connected Data, Social Media Data, Usage Data, Location Data, and the preferences we have inferred you have and use to personalize the App and Services, being the preferences noted in your account.
• Competition Data: information about the competitions you enter with us, being your competition history, the applicable terms and conditions, associated third parties and any additional privacy notices.

How We Collect Your Personal Data

We collect your personal data in the following ways:

Information we receive from third parties and publicly available sources

We will receive personal data about you from the third parties and public sources set out below:

• Device and Cookies Data from the following parties:  analytics providers, including Google Analytics; advertising networks; search information providers, including Google.
• Contact, Financial and Transaction Data  from providers of technical, payment and delivery services such as Stripe based inside the UK.S
• Identity and Contact Data  from publicly available sources such as Companies House and the electoral register based inside your jurisdiction; and
• Social media sites, including Facebook and Instagram;  When you log in using your Facebook or Instagram account, we collect data as permitted by your privacy settings and Facebook’s API, including Identity, Profile, and Social Media Data.
• Cookies;  we use cookies (small files placed on your device) and other tracking technologies on the App and in our direct marketing emails to improve your experience and our development of the App and our Services. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, (see our cookie notice).

How We Use Your Personal Data

We use your personal data to provide you with the services you request and other purposes, including:

• Service Delivery;  To operate the Social Gems App, process transactions, and provide customer support.
• Personalization: To tailor content and offers based on your Profile, Usage, and Social Media Data (e.g., suggesting friends’ content or location-based deals).
• Marketing: To send you updates or promotions, with your consent, using Marketing and Communications Data.
• Improvement:  To analyze Usage and Feedback Data to enhance app features.
• Security and verification:  To protect your account using Security and Device Data, and to verify user identities, especially for influencers claiming social media accounts.

Specific Use of Facebook and Instagram Data

• Collection:  When you (as an influencer or user) add your Facebook or Instagram account during registration or profile setup, we collect your name, email, profile details, verification status (e.g., whether the account is verified by the platform), follower count, and (with your consent) other Social Media Data (e.g., friends list, public posts). This is done via OAuth authentication to ensure secure access.
• Use for Verification:  We use this data to confirm that you own the social media account you claim, validate its verification status (e.g., blue checkmark or equivalent), and confirm your follower count. This helps prevent fraud, ensures authenticity in talent-business connections, and maintains the integrity of the platform. For example:
• Account Ownership:  By linking via OAuth, we verify that the login credentials match the claimed account.
• Verification Status:   We check platform-provided indicators (e.g., Instagram's verified badge) to confirm the account's legitimacy.
• Follower Count:  We access and store the public follower number to match it against your claims, aiding in influencer qualification for opportunities.
• Additional Uses:  Beyond verification, this data personalises your experience (e.g., tailored offers based on your profile) and enhances social interactions within the app, compliant with Facebook’s Platform Terms.
• Consent and Controls:  You provide explicit consent during the login process, where this privacy notice is displayed and a clear permission prompt explains the verification purpose. You can withdraw consent or unlink your account at any time via your profile settings, which will stop further data access from these platforms. If consent is withdrawn, we may retain minimal verification data (e.g., follower count snapshot) for record-keeping if required by our service contracts, but it will no longer be used for active personalization.
• Performance of a contract. Where we need to process your personal data to perform a contract with you or where you ask us to take steps before we enter into a contract with you. Where we rely on performance of a contract and you do not provide the necessary information, we will be unable to perform your contract.
• Legitimate interests. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Legal obligation. Where we need to use your personal data to comply with a legal or regulatory obligation. Where we rely on legal obligation and you do not provide the necessary information, we may be unable to fulfil a right you have or comply with our obligations to you, or we may need to take additional steps, such as informing law enforcement or a public authority or applying for a court order.

Delivery and improvement of our App and purchases  

Purpose or activity	Type of personal data	Lawful basis for processing
To permit you to install the App and register you as a new App user	Identity Contact Financial Device	Legitimate interests (delivering our App to you)
To take steps towards providing you with services at your request, to process and fulfil in-App campaigns and deliver services to you, including managing payments and sending you service communications	Identity Contact Transaction Device Location	Performance of a contract
To provide you with your membership benefits, fulfil campaigns or redemption of Gems within the App	Identity Contact Transaction	Performance of a contract
Enforce our terms and conditions, including to collect money owed to us by you	Identity	Legitimate interests (to recover debts due to us) and legal obligation

Account management and profiling  

Purpose or activity	Type of personal data	Lawful basis for processing
Combining the information we collect about you into a single customer account profile	Contact Direct Marketing	Legitimate Interests (to publicise and grow our business)

Direct marketing  

Purpose or activity	Type of personal data	Lawful basis for processing
To send you direct marketing communications via email, text and/or push notification	Contact Device Direct Marketing	Consent Unless we can rely on the soft opt-in and you have not opted out, in which case we rely on Legitimate Interest (to publicise and grow our business)
To send you direct marketing communications by telephone or post or email	Contact Device Direct Marketing	Legitimate interests (to publicise and grow our business) Unless you have opted out, in which case we rely on Consent

Troubleshooting, improvement and security  

Purpose or activity	Type of personal data	Lawful basis for processing
To administer, monitor and improve our business, Services and this App including troubleshooting, data analysis and system testing	Identity Contact Device	Legitimate interests (for running our business, provision of administration and IT services, network security, maintaining the security of our App and Services, providing a secure service to users and preventing fraudulent and other misuse of our App)
Applying security measures to our processing of your personal data, including processing in connection with the App	All personal data under this privacy notice	Legal obligation (applying appropriate technical and organisational measures under the GDPR)
Otherwise monitoring use of the App and deploying appropriate security measures	Contact Security Transaction	Legitimate interests (running our business, provision of administration and IT services, network security, maintaining the security of our App and services, providing a secure service to users and preventing fraudulent and other misuse of our App)

Rights and obligations  

Purpose or activity	Type of personal data	Lawful basis for processing
To comply with our other legal obligations, including compliance with tax legislation, judicial, law enforcement and government authorities' requests	All personal data under this privacy notice	Legal obligation (under laws of the UK, Uganda or relevant jurisdiction)

Cookies and personalisation  

Purpose or activity	Type of personal data	Lawful basis for processing
To deploy and process personal data collected via Cookies that are placed on your device, as set out in the cookies note.	Cookies	Legitimate interests (delivering and securing the App and our Services)
To deploy and process personal data collected via Cookies that are not strictly necessary, as set out in the cookies note.	Cookies	Consent
To deliver (personalised) advertisements to you	Personalisation	Consent

Other communications  

Purpose or activity	Type of personal data	Lawful basis for processing
To notify you of changes to the App, Services, your purchases and our terms and conditions for ongoing contracts	Contact	For ongoing or prospective contracts, Performance of a contract Otherwise, Legitimate interests (in servicing our users and prospective users)
To notify you of updates to this privacy notice	Contact Transaction	Legal obligation (to inform you of our processing under Articles 13 and 14 of the UK GDPR [and the EU GDPR])
To respond to your requests to exercise your rights under this notice	As relevant to your request	Legal obligation (complying with data subject requests under Chapter 3 of the UK GDPR and the EU GDPR)
To enable you to participate in a prize draw or competition (where applicable, please also see the separate prize or competition privacy notice)	Contact Direct Marketing Competition	Legitimate interests (in growing and publicising our business) Unless you have previously opted out, where we will rely on Consent Performance of a contract (once you have entered)
To ask you to complete a survey and process your response (where applicable, please also see the separate privacy notice)	Contact	Legitimate interests (to analyse how users use our products or Services and to develop them and grow our business) Unless you have previously opted out, where we will rely on Consent
To otherwise respond to your enquiries, fulfil your requests and to contact you where necessary	As relevant to your enquiry or request	Legitimate interests (service our users and prospective users) and legal obligation

Personal data sharing  

Purpose or activity	Type of personal data	Lawful basis for processing
Share personal data with our third-party providers for purposes not otherwise set out above	Identity Contact Transaction Device Location	Legitimate interests (for the purpose relevant to the recipient, as set out at "Disclosures of your personal data")

Business contacts  

Purpose or activity	Type of personal data	Lawful basis for processing
Process personal data relating to staff members of our business contacts, including suppliers, customers and prospects	Contact	Legitimate interests (servicing and receiving products or services, to or from our business contacts and carry out our B2B business)

Automated decision making and profiling  

We do not make decisions based solely on automated processing or profiling that produce legal effects concerning you (or have similarly significant effects).

Criminal offence data and special category data  

We do not intentionally collect criminal offence data about you. However we may process data relating to criminal offences in monitoring the use of our App for security purposes, where we suspect you may have committed a crime, such as attempting to make a fraudulent purchase or claim or circumvent the security of the App or Services. In such circumstances we will provide that information to law enforcement and/or use it to establish, exercise or defend a legal claim. In those circumstances, according to the type of activity and purpose, we will rely on legitimate interests (protecting our business, employees and other users) and legal obligation (where required by legal, judicial or law enforcement to disclose or process that information).

Special categories of personal data

We process the following special categories of personal data about you.

Sharing Your Personal Data

We may share your personal data with the following third parties:

Internal third parties;  other companies in the Tek Juice Group and other associated companies acting as processors who provide IT and system administration services and undertake leadership reporting.

External third parties;  Your Appstore Provider and mobile network operator to allow you to install the App.

• Service providers acting as processors based in the UK, Uganda and other jurisdictions who provide IT and system administration services, hosting services for our App, delivery and logistics services, payment processing, fraud and identity verification providers, customer service support, email delivery and administration, and data storage and analysis.
• Our professional advisors acting as controllers based in Uganda and the UK including lawyers, auditors, insurers, consultants and who provide legal, accounting, insurance and services
• Your service providers that you have appointed and we need to contact to fulfil your requests, such as your banking or payment card provider to process your transactions.
• Marketing and promotional partners and co-operatives acting as processors or joint controllers with whom we share data to enhance our offerings and identify prospective customers.
• Third party partners where you have subscribed to receive marketing from or with them.
• Specific third parties listed in the table [ Purposes for which we will use your personal data] above.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
• HM Revenue and Customs, regulators, law enforcement, public authorities or other third parties based in the UK , Uganda or relevant jurisdiction where necessary to exercise our rights or comply with a legal obligation.
• Facebook and Instagram: Data is shared back to these platforms as part of the authentication process, per their terms. Your Facebook and Instagram data may be included in these shares, with appropriate safeguards.

How we protect your data/Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer (SSL) technology and are stored on a secure server. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our App or Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to protect your personal data from loss, unauthorized use or access.

Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

We have put in place procedures to detect and respond to personal data breaches and notify you and any applicable regulator when we are legally required to do so.

Data Retention

In some circumstances you can ask us to delete your data: see below for further information.

Once we no longer have a legal right to hold your personal data, we will delete or, in some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

You have the following rights under data protection laws in relation to your personal data.

• Access. Request access to and/or a copy of the personal data we process about you (commonly known as a data subject access request). This enables you to check that we are lawfully processing it.
• Correction. Request correction of any incomplete or inaccurate data we hold about you. (We may need to verify the accuracy of the new data you provide to us.)
• Deletion. Request us to delete or remove personal data where there is no good reason for us continuing to process it. You also can ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we have processed your information unlawfully or where we need to erase your personal data to comply with law. (In some cases, we may need to continue to retain some of your personal data where required by law. If these apply, we will notify you at the time of our response.)
• Objection. Object to us processing your personal data where (a) we are relying on legitimate interests as the lawful basis and you feel the processing impacts on your fundamental rights and freedoms, or (b) the processing is for direct marketing purposes. In some cases, we may refuse your objection if we can demonstrate that we have compelling legitimate grounds to continue processing your information which override your rights and freedoms.
• Restriction. Request that we restrict or suspend our processing of your personal data:
  • if you want us to establish the data's accuracy;
  • where our use of the data is unlawful, but you do not want us to erase it;
  • where we no longer require it, but you need us to hold onto it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Data portability.  Request we transfer certain of your personal data to you or your chosen third party in a structured, commonly used, machine-readable format. This right only applies to information processed by automated means that we process on the lawful bases of consent or performance of a contract.
• Withdraw consent. Withdraw your consent at any time where we are relying on consent to process your personal data. Please know that this does not affect the lawfulness of any processing carried out before you withdraw your consent, and after withdrawal, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Complain to the relevant data protection regulator.  If you are unhappy with how we process your personal data, we ask that you contact us first using the details below so that we have the chance to put it right. However, you also have the right to make a complaint to the ICO or applicable data protection register at any time.

You can exercise any of these rights at any time by contacting us at Nobert@tekjuice.co.uk

Contact Details