Data Retention Policy

Last Updated: June 23, 2022

1. Introduction

This policy has been implemented to set guidelines to ensure that Blank Street Inc and its subsidiaries (collectively, “Blank Street”, “we” or “us”) complies with applicable data protection and privacy laws and regulations with respect to its retention of personal data.

For the purposes of this policy, unless expressly stated otherwise, reference to “personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

2. Scope

Blank Street does not retain personal data for longer than is necessary for the purpose for which the personal data was collected.

3. Retention of Data

Electronic and paper data, including those holding Personal Data, will be retained in line with retention periods set out in the schedule below. When data needs to be deleted in accordance with the schedule, deletion shall occur in compliance with Blank Street’s then-current policies and practices for secure disposal.

Schedule by Category of Data A) Account Registration Data Including: • email address; • first name and last name; • phone number; • delivery address; • credit card details, specifically (i) the last 4 digits of the credit card; (ii) the expiry date; (iii) the card issuer; (iv) the name of the cardholder; and (v) billing address postcode); and • user password.

Purpose of Collecting this Data

In order to create an account within the Blank Street App, for customers to make online orders of coffees to either be collected in store or delivered.

Purpose for Retaining this Data

In order to facilitate online orders through the Blank Street App.

Retention Period In the case of account deletion: 90 days from the date of deletion request. In the case of inactivity of the Blank Street App: 3 years from the date of last session

B) Zip or Postcode of User Purpose of Collecting this Data

In order to deliver orders made via a customer account.

Purpose for Retaining this Data To assist a customer in making repeat orders. On an anonymized basis, for statistical and analytical purposes.

Retention Period In the case of account deletion: 90 days from the date of deletion In the case of inactivity of the Blank Street App: 3 years from the date of last use ZIP or postcode data will be retained on a fully anonymised basis after the above periods.

C) Transaction data (products ordered, date and value of order, associated store) Purpose of Collecting this Data In order for the customer to accrue points for the loyalty programme and save favourite orders.

Purpose for Retaining this Data To create a functioning customer account within the Blank Street App.On an anonymised basis, for statistical and analytical purposes.

Retention Period In the case of account deletion: 90 days from the date of deletion In the case of inactivity of the Blank Street App: 3 years from the date of last use Transaction data will be retained on a fully anonymised basis after the above periods.

D) Cookies Purpose of Collecting this Data To review how customers engage with the Blank Street website

Purpose for Retaining this Data To analyse user interaction with the Blank Street website in order to improve customer’s experience of it.

Retention Period Please refer to the Cookies Policy.

D) Email and in-app (marketing) Purpose of Collecting this Data To provide promotional offers to customers who have consented to receiving email and in-app marketing communications.

Purpose for Retaining this Data To provide regular marketing to customers.

Retention Period Until a customer withdraws consent, either through unsubscribing to a marketing email, or amending their preferences within the App.Or 3 years after signing up to receive email marketing.