Privacy Policy
SupaChefs Privacy Policy Effective Date: April 17, 2026 Last Updated: April 17, 2026 1. Introduction Welcome to SupaChefs. The SupaChefs platform (“Platform”) is owned and operated by Supa Labs, Inc. (referred
to
as
“we,”
“our,”
or
“us”),
a
corporation
incorporated
under
the
laws
of
the
Republic
of
the
Philippines.
SupaChefs
is
our
community-powered
food
marketplace
application
that
connects
home
chefs
with
customers
seeking
homemade
meals. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when
you
use
the
SupaChefs
mobile
application
and
website
(collectively,
the
“Platform”)
—
whether
you
are
a
customer
ordering
food
or
a
home
chef
selling
meals. By accessing or using SupaChefs, you acknowledge that you have read and understood this Privacy Policy
and
agree
to
its
terms.
If
you
do
not
agree,
please
do
not
use
our
Platform. 2. Who This Policy Applies To This Privacy Policy applies to all users of the SupaChefs Platform, including but not limited to: • Customers — any person who browses, orders, or purchases meals through the Platform • Home Chefs — any person who register to sell homemade meals through the Platform • Visitors — anyone who accesses the Platform through a website or mobile app without officialy registering 3. What Information We Collect We collect and process personal information in accordance with the principles of transparency, legitimate purpose
and
proportionality
under
the
Data
Privacy
Act
of
2012.
We
only
collect
data
that
is
necessary,
relevant
and
not
excessive
in
relation
to
the
declared
purposes
of
processing. Personal data collected may be classified as: ● Personal information; ● Sensitive Personal Information (e.g. government IDs, financial data, etc.) ● Privileged Information, if applicable. Provision of certain data may be mandatory for account creation and order fulfillment. Failure to provide the
required
data
may
result
in
inability
to
use
certain
features
of
the
Platform.
3.1 Information You Provide to Us When you register or use our Platform, you will be asked to provide the following: • Your full name, email address, and mobile number 1 • Delivery address and location details • Personal photo and bio (for chefs) as your profile information • Food menu listings, descriptions, photos, and pricing (for chefs) • Payment information — for cash-on-delivery orders, we record transaction confirmations. Future payment
methods
(GCash,
Maya,
credit/debit
card)
will
be
processed
through
secure
third-party
payment
providers. • Bank account or e-wallet details for chef payouts • Government-issued ID (for chef identity verification) • Communications you send us through customer support Certain information such as government-issued identification and financial account details are considered Sensitive
Personal
Information
under
applicable
laws
and
are
processed
with
heightened
security
and
confidentiality
safeguards,
and
only
upon
lawful
basis
such
as
consent
or
compliance
with
legal
obligations.
3.2 Information We Collect Automatically When you use our Platform, we automatically collect: • Device information — device type, operating system, unique device identifiers • App usage data — pages visited, features used, time spent, search queries • Log data — IP address, browser type, access times, referring URLs • Location data — general location to show nearby chefs (precise location only with your permission) • Cookies and similar tracking technologies — to remember your preferences and improve your experience 3.3 Information From Third Parties We may receive information about you from: • Google Sign-In, if you choose to log in using your Google account • Third-party delivery partners, when their services are used to fulfill your order (see Section 6.2) • Payment processors when transactions are completed • Analytics providers who help us understand how our Platform is used 4. How We Use Your Information 4.1 To Provide and Operate the Platform • Create and manage your account • Process and fulfill food orders • Connect customers with home chefs in their area • Facilitate order communication between chefs, customers, and delivery partners • Process chef payouts and platform fee deductions 4.2 To Ensure Safety and Trust 2 • Verify the identity of chefs before they go live on the Platform • Investigate complaints, disputes, and reports of misconduct • Monitor for fraud, abuse, and violations of our Terms and Conditions • Comply with food safety obligations and applicable Philippine laws 4.3 To Improve Our Services • Analyze usage patterns to improve app performance and features • Conduct internal research and development • Fix bugs, errors, and technical issues 4.4 To Communicate With You • Send order confirmations, updates, and delivery notifications • Respond to your customer support inquiries • Send you important policy updates or changes to our services • Send promotional messages and marketing communications — only with your consent, and you may
opt
out
at
any
time 4.5 Legal Compliance • Comply with applicable laws including the Philippine Data Privacy Act of 2012 (RA 10173) and the
Internet
Transactions
Act
of
2023
(RA
11967)
and
their
respective
Implementing
Rules
and
Regulations; • National Privacy Council (NPC) Circulars especially on consent, breach notification, and data subject
rights; • Respond to lawful requests from government authorities • Enforce our Terms and Conditions and other legal agreements 5. Legal Basis for Processing Your Data We process your personal data based on one or more of the following lawful criteria under the applicable laws: ● Consent – for optional processing activities such as marketing, location tracking, and profile enhancements.
Consent
may
be
withdrawn
at
any
time.
● Contractual Necessity – where processing is necessary for the performance of a contract (e.g. order
fulfillment,
account
management). ● Legal Obligation – where processing is required to comply with applicable laws, regulations or lawful
orders. ● Legitimate Interest – for fraud prevention, system security, service improvement, and analytics, provided
these
do
not
override
your
fundamental
rights
and
freedoms.
6. How We Share Your Information We do not sell your personal data. We only share your personal information: 3 ● With your consent; ● When necessary to fulfill a transaction; ● When required by law or regulation; ● Under lawful data sharing agreements ensuring adequate safeguards 6.1 Between Chefs and Customers To facilitate orders, we share limited information between parties: • Customers can see a chef’s name, profile photo, bio, food listings, and general location area • Chefs receive a customer’s name, delivery address, and order details to fulfill an order • We do not share full contact numbers directly — all communication is facilitated through the Platform
where
possible 6.2 With Third-Party Delivery Partners SupaChefs may integrate with third-party delivery service providers to offer delivery options for orders. When
a
delivery
partner
is
used
to
fulfill
your
order,
we
may
share
the
following
information
with
them: • Customer name and delivery address • Order details and pickup location (chef’s general area) • Contact information necessary to complete the delivery All third-party service providers, including delivery partners, are required to comply with applicable data privacy
laws
and
are
bound
by
data
processing
or
data
sharing
agreements
to
ensure
that
your
personal
data
is
protected
and
used
only
for
legitimate
purposes. Supa Labs, Inc. exercises reasonable diligence in selecting its partners but remains accountable for ensuring
that
personal
data
shared
is
protected
in
accordance
with
applicable
law.
6.3 With Technology Service Providers We share information with trusted third-party providers who help us operate the Platform, including: • Cloud hosting and data storage providers • Payment processing partners • Analytics and performance monitoring tools • Customer support tools All service providers are contractually bound to handle your data securely and only for the purposes we specify. 6.4 For Legal Reasons We may disclose your information if required to: • Comply with a legal obligation or court order • Protect the rights, property, or safety of Supa Labs, Inc., our users, or the public • Investigate or prevent fraud, security threats, or violations of our policies • Respond to lawful requests from the National Privacy Commission (NPC) or other government authorities 4 6.5 Business Transfers If Supa Labs, Inc. undergoes a merger, acquisition, or sale of assets, your personal information may be transferred
as
part
of
that
transaction.
We
will
notify
you
within
a
reasonable
time
and
before
your
data
is
transferred
and
becomes
subject
to
a
different
privacy
policy. 7. Data Retention We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy
Policy,
or
as
required
by
law. • Active account data — retained for as long as your account remains active • Order history — retained for a minimum of 3 years for tax, accounting, and dispute resolution purposes • Chef verification documents — retained for the duration of the chef’s active status plus 1 year • Communications and support records — retained for 2 years • Deleted accounts — personal data is removed within 30 days of account deletion, except where legal
retention
obligations
apply Further, we determine retention periods based on: ● Nature and sensitivity of the data; ● Purpose of processing; ● Legal and regulatory requirements; and ● Risk of harm from unauthorized use or disclosure. After the applicable retention period, personal data is securely deleted, anonymized or disposed of in a manner
that
prevents
further
processing.
8. Data Security and Breach Notification We implement reasonable and appropriate technical and organizational security measures to protect your personal
information
from
unauthorized
access,
disclosure,
alteration,
or
destruction.
These
include: • Encrypted data transmission (HTTPS/TLS) • Secure cloud storage with access controls • Limited internal access to personal data on a need-to-know basis • Regular review of our data handling practices However, no method of transmission over the internet or electronic storage is 100% secure. In the event of
a
data
breach
that
poses
serious
risk
to
your
rights,
we
will
notify
the
National
Privacy
Commission
(NPC)
and
the
affected
individuals
as
required
by
law. In the event of a personal data breach likely to result in a risk to the rights and freedoms of data subjects, we
shall: ● Notify the National Privacy Commission within 72 hours from knowledge of the breach; ● Notify the affected data subjects without undue delay when required under applicable regulations; and ● Take immediate steps to mitigate and prevent such recurrence. 5 9. Your Rights Under the Philippine Data Privacy Act As a user of SupaChefs, you have the following rights under Republic Act No. 10173 (Data Privacy Act of 2012): • Right to be informed — you have the right to know how your personal data is being collected and used • Right to access — you may request a copy of the personal data we hold about you • Right to correction — you may request correction of inaccurate or outdated information • Right to erasure or blocking — you may request deletion or blocking of your personal data under certain
conditions • Right to object — you may object to the processing of your personal data, particularly for direct marketing • Right to data portability — you may request your data in a structured, commonly used format • Right to damages — you may claim compensation if your data privacy rights have been violated • Right to file a complaint — you may lodge a complaint with the National Privacy Commission (NPC)
at
www.privacy.gov.ph To exercise any of these rights: ● Submit a request via email to our Data Protection Officer through admin@supachefs.com; ● Provide sufficient proof of identity; ● Specify the right you wish to exercise. We will respond within a reasonable period in accordance with applicable regulations. Certain requests may
be
denied
where
legally
justified
(e.g.
retention
required
by
law).
10. Children’s Privacy SupaChefs is not intended for use by individuals under the age of 18. We do not knowingly collect personal
information
from
minors.
If
we
become
aware
that
a
user
under
18
has
provided
us
with
personal
information,
we
will
take
steps
to
delete
that
information
promptly. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at admin@supachefs.com. If processing of minor data becomes necessary in the future, we will ensure verifiable parental consent in accordance
with
applicable
laws
and
regulations.
11. Location Data We use location data to connect customers with nearby home chefs. Specifically: • We request access to your approximate location to display relevant chefs in your area • Precise GPS location is only accessed if you explicitly grant permission through your device settings • You may disable location access at any time through your device settings, though this may limit certain
Platform
features • We do not share your precise location with other users — only general area information is displayed 6 12. Cookies and Tracking Technologies We use cookies and similar technologies to improve your experience on our Platform. These help us: • Remember your login and preferences • Understand how users navigate and use our Platform • Analyze performance and fix issues You may control cookie settings through your browser or device settings. Disabling cookies may affect some
features
of
the
Platform. Where required, we obtain your consent before placing non-essential cookies. You may withdraw consent at
any
time.
13. Third-Party Links and Services Our Platform may contain links to third-party websites or services, including delivery partner platforms. We
are
not
responsible
for
the
privacy
practices
of
those
third
parties.
We
encourage
you
to
review
their
privacy
policies
before
providing
any
personal
information. 14. Cross-Border Data Transfers Supa Labs, Inc. operates primarily in the Philippines. However, some of our service providers (such as cloud
hosting
platforms)
may
store
or
process
your
data
outside
the
Philippines.
Where personal data is transferred outside the Philippines, we ensure that: ● The recipient country has adequate data protection standards; or ● Appropriate safeguards are in place, including contractual obligations requiring compliance with Philippine
data
protection
laws. We remain responsible for ensuring that transferred personal data is protected. 15. Changes to This Privacy Policy We may update this Privacy Policy from time to time. When we make material changes, we will: • Post the updated Privacy Policy on our website and within the app • Update the “Last Updated” date at the top of this document • Notify you through the app or via email for significant changes Your continued use of the Platform after any changes constitutes your acceptance of the updated Privacy Policy. 16. Data Protection Officer In compliance with the Philippine Data Privacy Act, Supa Labs, Inc. has designated a Data Protection Officer
(DPO)
responsible
for
overseeing
our
data
privacy
practices
and
compliance. DPO Contact: • Name: Roxanne Fay Casio, Chief Operating Officer • Email: admin@supachefs.com 7 • Address: Unit 413, Building 12, Urban Deca Homes, Hernan Cortes St., Cebu City Phils 6000 The Data Protection Officer is responsible for: • Monitoring compliance with data privacy laws; • Handling data subject requests and complaints; • Coordinating with the National Privacy Commission. 18. Automated Decision-Making We do not use fully automated decision-making processes that significantly affect users. If such systems are
introduced,
we
will
ensure
transparency
and
provide
users
with
the
right
to
object. 17. Data Minimization and Accuracy We take reasonable steps to ensure that personal data is accurate, complete and up to date. Users are encouraged
to
update
their
information
when
necessary. 18. How to Contact Us If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please
contact
us: • Email: admin@supachefs.com • Website: www.supachefs.com • Address: For complaints related to data privacy, you may also contact the National Privacy Commission: • Website: www.privacy.gov.ph • Email: info@privacy.gov.ph Supa Labs, Inc. (SupaChefs) — Privacy Policy — DRAFT FOR LEGAL REVIEW — Not for public distribution until reviewed
and
approved. 8
to
as
“we,”
“our,”
or
“us”),
a
corporation
incorporated
under
the
laws
of
the
Republic
of
the
Philippines.
SupaChefs
is
our
community-powered
food
marketplace
application
that
connects
home
chefs
with
customers
seeking
homemade
meals. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when
you
use
the
SupaChefs
mobile
application
and
website
(collectively,
the
“Platform”)
—
whether
you
are
a
customer
ordering
food
or
a
home
chef
selling
meals. By accessing or using SupaChefs, you acknowledge that you have read and understood this Privacy Policy
and
agree
to
its
terms.
If
you
do
not
agree,
please
do
not
use
our
Platform. 2. Who This Policy Applies To This Privacy Policy applies to all users of the SupaChefs Platform, including but not limited to: • Customers — any person who browses, orders, or purchases meals through the Platform • Home Chefs — any person who register to sell homemade meals through the Platform • Visitors — anyone who accesses the Platform through a website or mobile app without officialy registering 3. What Information We Collect We collect and process personal information in accordance with the principles of transparency, legitimate purpose
and
proportionality
under
the
Data
Privacy
Act
of
2012.
We
only
collect
data
that
is
necessary,
relevant
and
not
excessive
in
relation
to
the
declared
purposes
of
processing. Personal data collected may be classified as: ● Personal information; ● Sensitive Personal Information (e.g. government IDs, financial data, etc.) ● Privileged Information, if applicable. Provision of certain data may be mandatory for account creation and order fulfillment. Failure to provide the
required
data
may
result
in
inability
to
use
certain
features
of
the
Platform.
3.1 Information You Provide to Us When you register or use our Platform, you will be asked to provide the following: • Your full name, email address, and mobile number 1 • Delivery address and location details • Personal photo and bio (for chefs) as your profile information • Food menu listings, descriptions, photos, and pricing (for chefs) • Payment information — for cash-on-delivery orders, we record transaction confirmations. Future payment
methods
(GCash,
Maya,
credit/debit
card)
will
be
processed
through
secure
third-party
payment
providers. • Bank account or e-wallet details for chef payouts • Government-issued ID (for chef identity verification) • Communications you send us through customer support Certain information such as government-issued identification and financial account details are considered Sensitive
Personal
Information
under
applicable
laws
and
are
processed
with
heightened
security
and
confidentiality
safeguards,
and
only
upon
lawful
basis
such
as
consent
or
compliance
with
legal
obligations.
3.2 Information We Collect Automatically When you use our Platform, we automatically collect: • Device information — device type, operating system, unique device identifiers • App usage data — pages visited, features used, time spent, search queries • Log data — IP address, browser type, access times, referring URLs • Location data — general location to show nearby chefs (precise location only with your permission) • Cookies and similar tracking technologies — to remember your preferences and improve your experience 3.3 Information From Third Parties We may receive information about you from: • Google Sign-In, if you choose to log in using your Google account • Third-party delivery partners, when their services are used to fulfill your order (see Section 6.2) • Payment processors when transactions are completed • Analytics providers who help us understand how our Platform is used 4. How We Use Your Information 4.1 To Provide and Operate the Platform • Create and manage your account • Process and fulfill food orders • Connect customers with home chefs in their area • Facilitate order communication between chefs, customers, and delivery partners • Process chef payouts and platform fee deductions 4.2 To Ensure Safety and Trust 2 • Verify the identity of chefs before they go live on the Platform • Investigate complaints, disputes, and reports of misconduct • Monitor for fraud, abuse, and violations of our Terms and Conditions • Comply with food safety obligations and applicable Philippine laws 4.3 To Improve Our Services • Analyze usage patterns to improve app performance and features • Conduct internal research and development • Fix bugs, errors, and technical issues 4.4 To Communicate With You • Send order confirmations, updates, and delivery notifications • Respond to your customer support inquiries • Send you important policy updates or changes to our services • Send promotional messages and marketing communications — only with your consent, and you may
opt
out
at
any
time 4.5 Legal Compliance • Comply with applicable laws including the Philippine Data Privacy Act of 2012 (RA 10173) and the
Internet
Transactions
Act
of
2023
(RA
11967)
and
their
respective
Implementing
Rules
and
Regulations; • National Privacy Council (NPC) Circulars especially on consent, breach notification, and data subject
rights; • Respond to lawful requests from government authorities • Enforce our Terms and Conditions and other legal agreements 5. Legal Basis for Processing Your Data We process your personal data based on one or more of the following lawful criteria under the applicable laws: ● Consent – for optional processing activities such as marketing, location tracking, and profile enhancements.
Consent
may
be
withdrawn
at
any
time.
● Contractual Necessity – where processing is necessary for the performance of a contract (e.g. order
fulfillment,
account
management). ● Legal Obligation – where processing is required to comply with applicable laws, regulations or lawful
orders. ● Legitimate Interest – for fraud prevention, system security, service improvement, and analytics, provided
these
do
not
override
your
fundamental
rights
and
freedoms.
6. How We Share Your Information We do not sell your personal data. We only share your personal information: 3 ● With your consent; ● When necessary to fulfill a transaction; ● When required by law or regulation; ● Under lawful data sharing agreements ensuring adequate safeguards 6.1 Between Chefs and Customers To facilitate orders, we share limited information between parties: • Customers can see a chef’s name, profile photo, bio, food listings, and general location area • Chefs receive a customer’s name, delivery address, and order details to fulfill an order • We do not share full contact numbers directly — all communication is facilitated through the Platform
where
possible 6.2 With Third-Party Delivery Partners SupaChefs may integrate with third-party delivery service providers to offer delivery options for orders. When
a
delivery
partner
is
used
to
fulfill
your
order,
we
may
share
the
following
information
with
them: • Customer name and delivery address • Order details and pickup location (chef’s general area) • Contact information necessary to complete the delivery All third-party service providers, including delivery partners, are required to comply with applicable data privacy
laws
and
are
bound
by
data
processing
or
data
sharing
agreements
to
ensure
that
your
personal
data
is
protected
and
used
only
for
legitimate
purposes. Supa Labs, Inc. exercises reasonable diligence in selecting its partners but remains accountable for ensuring
that
personal
data
shared
is
protected
in
accordance
with
applicable
law.
6.3 With Technology Service Providers We share information with trusted third-party providers who help us operate the Platform, including: • Cloud hosting and data storage providers • Payment processing partners • Analytics and performance monitoring tools • Customer support tools All service providers are contractually bound to handle your data securely and only for the purposes we specify. 6.4 For Legal Reasons We may disclose your information if required to: • Comply with a legal obligation or court order • Protect the rights, property, or safety of Supa Labs, Inc., our users, or the public • Investigate or prevent fraud, security threats, or violations of our policies • Respond to lawful requests from the National Privacy Commission (NPC) or other government authorities 4 6.5 Business Transfers If Supa Labs, Inc. undergoes a merger, acquisition, or sale of assets, your personal information may be transferred
as
part
of
that
transaction.
We
will
notify
you
within
a
reasonable
time
and
before
your
data
is
transferred
and
becomes
subject
to
a
different
privacy
policy. 7. Data Retention We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy
Policy,
or
as
required
by
law. • Active account data — retained for as long as your account remains active • Order history — retained for a minimum of 3 years for tax, accounting, and dispute resolution purposes • Chef verification documents — retained for the duration of the chef’s active status plus 1 year • Communications and support records — retained for 2 years • Deleted accounts — personal data is removed within 30 days of account deletion, except where legal
retention
obligations
apply Further, we determine retention periods based on: ● Nature and sensitivity of the data; ● Purpose of processing; ● Legal and regulatory requirements; and ● Risk of harm from unauthorized use or disclosure. After the applicable retention period, personal data is securely deleted, anonymized or disposed of in a manner
that
prevents
further
processing.
8. Data Security and Breach Notification We implement reasonable and appropriate technical and organizational security measures to protect your personal
information
from
unauthorized
access,
disclosure,
alteration,
or
destruction.
These
include: • Encrypted data transmission (HTTPS/TLS) • Secure cloud storage with access controls • Limited internal access to personal data on a need-to-know basis • Regular review of our data handling practices However, no method of transmission over the internet or electronic storage is 100% secure. In the event of
a
data
breach
that
poses
serious
risk
to
your
rights,
we
will
notify
the
National
Privacy
Commission
(NPC)
and
the
affected
individuals
as
required
by
law. In the event of a personal data breach likely to result in a risk to the rights and freedoms of data subjects, we
shall: ● Notify the National Privacy Commission within 72 hours from knowledge of the breach; ● Notify the affected data subjects without undue delay when required under applicable regulations; and ● Take immediate steps to mitigate and prevent such recurrence. 5 9. Your Rights Under the Philippine Data Privacy Act As a user of SupaChefs, you have the following rights under Republic Act No. 10173 (Data Privacy Act of 2012): • Right to be informed — you have the right to know how your personal data is being collected and used • Right to access — you may request a copy of the personal data we hold about you • Right to correction — you may request correction of inaccurate or outdated information • Right to erasure or blocking — you may request deletion or blocking of your personal data under certain
conditions • Right to object — you may object to the processing of your personal data, particularly for direct marketing • Right to data portability — you may request your data in a structured, commonly used format • Right to damages — you may claim compensation if your data privacy rights have been violated • Right to file a complaint — you may lodge a complaint with the National Privacy Commission (NPC)
at
www.privacy.gov.ph To exercise any of these rights: ● Submit a request via email to our Data Protection Officer through admin@supachefs.com; ● Provide sufficient proof of identity; ● Specify the right you wish to exercise. We will respond within a reasonable period in accordance with applicable regulations. Certain requests may
be
denied
where
legally
justified
(e.g.
retention
required
by
law).
10. Children’s Privacy SupaChefs is not intended for use by individuals under the age of 18. We do not knowingly collect personal
information
from
minors.
If
we
become
aware
that
a
user
under
18
has
provided
us
with
personal
information,
we
will
take
steps
to
delete
that
information
promptly. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at admin@supachefs.com. If processing of minor data becomes necessary in the future, we will ensure verifiable parental consent in accordance
with
applicable
laws
and
regulations.
11. Location Data We use location data to connect customers with nearby home chefs. Specifically: • We request access to your approximate location to display relevant chefs in your area • Precise GPS location is only accessed if you explicitly grant permission through your device settings • You may disable location access at any time through your device settings, though this may limit certain
Platform
features • We do not share your precise location with other users — only general area information is displayed 6 12. Cookies and Tracking Technologies We use cookies and similar technologies to improve your experience on our Platform. These help us: • Remember your login and preferences • Understand how users navigate and use our Platform • Analyze performance and fix issues You may control cookie settings through your browser or device settings. Disabling cookies may affect some
features
of
the
Platform. Where required, we obtain your consent before placing non-essential cookies. You may withdraw consent at
any
time.
13. Third-Party Links and Services Our Platform may contain links to third-party websites or services, including delivery partner platforms. We
are
not
responsible
for
the
privacy
practices
of
those
third
parties.
We
encourage
you
to
review
their
privacy
policies
before
providing
any
personal
information. 14. Cross-Border Data Transfers Supa Labs, Inc. operates primarily in the Philippines. However, some of our service providers (such as cloud
hosting
platforms)
may
store
or
process
your
data
outside
the
Philippines.
Where personal data is transferred outside the Philippines, we ensure that: ● The recipient country has adequate data protection standards; or ● Appropriate safeguards are in place, including contractual obligations requiring compliance with Philippine
data
protection
laws. We remain responsible for ensuring that transferred personal data is protected. 15. Changes to This Privacy Policy We may update this Privacy Policy from time to time. When we make material changes, we will: • Post the updated Privacy Policy on our website and within the app • Update the “Last Updated” date at the top of this document • Notify you through the app or via email for significant changes Your continued use of the Platform after any changes constitutes your acceptance of the updated Privacy Policy. 16. Data Protection Officer In compliance with the Philippine Data Privacy Act, Supa Labs, Inc. has designated a Data Protection Officer
(DPO)
responsible
for
overseeing
our
data
privacy
practices
and
compliance. DPO Contact: • Name: Roxanne Fay Casio, Chief Operating Officer • Email: admin@supachefs.com 7 • Address: Unit 413, Building 12, Urban Deca Homes, Hernan Cortes St., Cebu City Phils 6000 The Data Protection Officer is responsible for: • Monitoring compliance with data privacy laws; • Handling data subject requests and complaints; • Coordinating with the National Privacy Commission. 18. Automated Decision-Making We do not use fully automated decision-making processes that significantly affect users. If such systems are
introduced,
we
will
ensure
transparency
and
provide
users
with
the
right
to
object. 17. Data Minimization and Accuracy We take reasonable steps to ensure that personal data is accurate, complete and up to date. Users are encouraged
to
update
their
information
when
necessary. 18. How to Contact Us If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please
contact
us: • Email: admin@supachefs.com • Website: www.supachefs.com • Address: For complaints related to data privacy, you may also contact the National Privacy Commission: • Website: www.privacy.gov.ph • Email: info@privacy.gov.ph Supa Labs, Inc. (SupaChefs) — Privacy Policy — DRAFT FOR LEGAL REVIEW — Not for public distribution until reviewed
and
approved. 8