Privacy Policy
Welcome to Identifyi Limited’s privacy policy.
We own and operate online data storage platform (“Platform”) which can be accessed via a mobile application.
Genie Vault is a digital personal data storage platform that helps people take control of their shopping data and turn it into something useful for them. We operate Genie Vault to securely store, process, and help you use that data according to your instructions. You are in full control of your data and you determine who may access your data, and when the data is erased from Genie Vault.
Genie Vault works like a personal data vault for your shopping history. It allows you to collect and manage information about what you buy, where you buy it, and how much you pay — for example through scanned paper receipts, forwarded electronic receipts, or direct connections with participating retailers.
To help you make sense of this data, Genie Vault uses an AI-powered assistant (“Genie”). Genie helps you organise your data, understand your spending, and access practical benefits based on the information stored in your Vault.
Genie Vault may be made available either as a standalone mobile application or, in future, through applications operated by retail, loyalty programme or other partners where Genie Vault is made available as an embedded feature.
During the Open Beta, Genie Vault is currently made available primarily as a standalone mobile application for approved Open Beta participants. You choose whether to create a Genie Vault, what data you add to it, and how you use the features made available during the Open Beta.
Where partner offers or partner offer testing are made available, selected structured or derived information from your Genie Vault may be used in a controlled environment to help create, deliver, test, measure and improve relevant offers. Partners do not receive direct access to your full Genie Vault, raw receipt images, forwarded emails, digital receipt files or full purchase history through campaign discovery. If you choose to redeem an offer with a partner, that partner may be able to identify you within its own checkout, loyalty, account, payment or point-of-sale environment.
We do not sell your personal data. Any partner-related data use is designed to support features, benefits, offer testing, campaign measurement or services made available through Genie Vault and is subject to your choices, the permissions you have given, this Privacy Policy and any applicable feature-specific notice or consent flow.
We share personal data only as described in this Privacy Policy. If you were recruited to the Genie Vault Open Beta by People for Research Ltd on or after 13/07/2026, we may provide People for Research with your email address as confirmation that you have activated your Genie Vault account. This allows People for Research to reconcile its recruitment records and follow up with invited participants who have not completed activation
We do not share your receipts, purchase data, Vault contents, Genie conversations, Discord status, Hub activity or any other information about how you use Genie Vault for this purpose.
We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains what personal data we process when you use Genie Vault, why we process it, how we keep it secure, and what rights you have in relation to your data.
Important information about who we are
Identifyi Limited, a company incorporated in England and Wales under company number 16017432 whose registered office address is at 25 Cabot Square, Canary Wharf, London, United Kingdom, E14 4QZ is the controller and responsible for your personal data (collectively referred to as " Identifyi", "we", "us" or "our" in this privacy policy).
If you have any questions about this privacy policy, please contact us using the details set out below.
Contact Details
Full name of legal entity: Identifyi Limited
Email address: contact@genievault.com
Postal address: 25 Cabot Square, Canary Wharf, E14 4QZ London, United Kingdom
UK’s Information Commissioner’s Office Registration Number ZC094325
Complaints
You will always have the right to lodge a complaint with a supervisory body. The relevant authority in the UK (where we are based) is the Information Commissioner’s Office (www.ico.org.uk). If you do have a complaint, we would appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance, if possible, at the email address above. If you are based in another jurisdiction, you may have additional rights or ability to refer matters to an alternative supervisory body.
Changes to the privacy policy
We keep our privacy policy under regular review and reserve the right to update this privacy policy from time to time. This privacy policy was last updated on 13 July 2026. Please check our privacy notice posted on the Platform for the latest version.
Third-party links
Our Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Platform, we encourage you to read the privacy policy of every website you visit.
1. The data we collect about you
General
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Categories of personal data
Depending on how you use Genie Vault, we may collect and process the following categories of personal data.
a. Account and Identification Data
This includes information you provide when creating or using your Genie Vault account, such as:
- name or username,
- email address,
- unique user or account identifiers,
- authentication and security-related information.
b. Contact and Communication Data
This includes information used to communicate with you, such as:
- email address,
- in-app messages or support communications,
- preferences related to notifications or communication settings.
c. Device and Technical Data
When you access Genie Vault through a mobile application or other interfaces, we may collect technical information, such as:
- device type, operating system, and app version,
- IP address and general location data derived from it (e.g. country or region),
- log files, timestamps, and error reports,
- information about how you interact with the app (for example, features used or actions taken).
d. Purchasing Data
If you choose to add shopping data to your Genie Vault by scanning paper receipts, uploading or forwarding digital receipts, or connecting supported retailers or services, we may process purchasing data contained in those receipts or purchase confirmations.
Purchasing data may include, where available:
- total value of a transaction,
- total number of items purchased,
- individual product or service descriptions,
- individual product or service prices,
- applied offers, promotions, or discounts,
- name of the retailer or issuer,
- store name and store address,
- contact details of the retailer or issuer (where shown on the receipt),
- date and time of the purchase,
- last four digits of a payment card (where displayed),
- loyalty or membership card number (where displayed).
We process purchasing data solely to provide the Genie Vault service to you and according to the choices you make within the app. You decide whether and how this data is added to your Vault.
e. Insights and Derived Data
Based on the data stored in your Genie Vault, we may generate insights or summaries for your personal use, such as:
- spending summaries or trends,
- categorisation of purchases,
- aggregated or calculated values created to help you better understand your data.
These insights are derived from your data and do not introduce new personal data from external sources. This aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
f. Partner Interaction Data
If you choose to share parts of your Genie Vault data with a specific retail or loyalty partner, we may process information related to that interaction, such as:
- the partner you have chosen,
- the scope and purpose of data sharing,
- confirmation that data has been shared based on your instruction.
g. Support and Feedback Data
If you contact us for support or provide feedback, we may process:
- the content of your messages,
- any information you choose to share to help us resolve an issue or improve the service.
We do not intentionally collect special category data under data protection laws. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information or genetic and biometric data. However, some purchasing data you choose to upload (for example, from certain types of retailers) may indirectly reveal sensitive information. We do not require you to provide such data, and you remain in control of what information is added to your Genie Vault.
The Genie Vault Open Beta is available only to approved participants aged 18 or over. We do not knowingly allow children or anyone under 18 to create or use a Genie Vault account during the Open Beta.
We do not knowingly collect data relating to children under 13 years old, special category data or information relating to criminal convictions. However, if we become aware that a person under 18 has created an Open Beta account, we may close the account and delete or restrict the relevant data in accordance with this Privacy Policy and applicable law.
h. Open Beta Participation Data
If you take part in the Genie Vault Open Beta, we may process information connected with your Open Beta participation, such as:
- Open Beta sign-up information;
- eligibility confirmations, such as age and UK residency confirmations;
- approved participant records;
- invitation, approval and activation status;
- device type and app access information;
- referral source, creator code, campaign code or other attribution information;
- onboarding status;
- beta activity records;
- microquest, task, challenge or survey participation;
- feedback, issue reports, screenshots, screen recordings or other materials you choose to provide as part of beta testing;
- support channel participation and beta community participation status.
i. Free Prize Draw Data
If you choose to take part in the Genie Vault Open Beta Free Prize Draw, we may process information needed to administer the Free Prize Draw, such as:
- confirmation that you wish to take part in the Free Prize Draw;
- confirmation that you have read and accepted the Free Prize Draw Rules;
- Discord handle, Discord display name, Discord ID or other beta community identifier;
- information needed to match your Discord or beta community account with your approved Genie Vault Open Beta participant record;
- Prize Draw Dashboard identifiers or display names;
- entry records;
- referral records;
- activity records relevant to entry validation;
- winner status;
- winner notification records;
- prize fulfilment status;
- fraud prevention, audit and compliance records relating to the Free Prize Draw;
- payment details or payment identifiers where needed to verify, administer or fulfil a prize.
j. Partner Offer and Campaign Data
Where partner offers or partner offer testing are made available, we may process limited partner offer and campaign-related information, such as:
- partner name or partner identifier;
- campaign name or campaign identifier;
- offer details;
- offer eligibility indicators derived from structured Genie Vault data;
- internal campaign IDs or pseudonymous campaign user IDs;
- offer delivery status;
- offer interaction data, such as whether an offer was shown, saved, accepted, declined, ignored or expired;
- discount code assignment data;
- redemption confirmation data;
- receipt confirmation data;
- partner redemption status or campaign code status, where provided by a partner;
- campaign reporting metrics.
Partner Offer and Campaign Data is separate from your full Genie Vault. Unless we explain otherwise in a specific notice or consent flow, partners do not receive direct access to your raw receipt images, forwarded emails, digital receipt files, full Vault interface or full purchase history through campaign discovery.
Keeping data up to date
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 your relationship with us. You can do this by logging into your account on our Platform and updating certain information or contacting us directly to update on your behalf.
If you fail to provide personal data
Where we need to collect personal data by law or contractual terms, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
2. How is your personal data collected?
We collect personal data in a limited number of clearly defined ways, all of which are connected to your decision to use Genie Vault and the choices you make within the service. The main way we will collect your personal data is through your direct interactions with us, but we will also collect data through automated technologies and third parties or other publicly available sources.
a. Data you provide directly to us
You provide certain personal data directly when you:
- create or manage a Genie Vault account,
- communicate with us (for example through customer support),
- configure your preferences or settings within the app,
- scan paper receipts,
- upload or forward digital receipts or online purchase confirmations,
- connect supported retailers or services or
- otherwise interact directly with us through Genie Vault.
This typically includes account, identification, contact information, and purchasing data and any related information contained in those materials. You can decide whether to add, remove, or stop adding such data at any time.
b. Data provided by our partners with your consent
Genie Vault may also be accessed, including in future, through applications operated by retail or loyalty programme partners. If you choose to create or connect a Genie Vault through such an application, and you give your explicit consent, the partner may share certain personal data with us to enable your account and the proper functioning of the service.
This data may include, where applicable:
- first and last name,
- email address,
- gender,
- age or date of birth,
- address or general location information,
- loyalty or membership identifiers.
Partners only share this data with us based on your instructions and in accordance with their own privacy policies.
c. Automated and technical data
When you use Genie Vault through a mobile application or other interfaces, certain technical data is collected automatically to ensure the service works securely and reliably. This includes:
- device and application information,
- log data, timestamps, and error reports,
- information collected through cookies or similar technologies (where applicable).
This data is used only for technical, security, and performance purposes and not to collect information unrelated to your use of Genie Vault.
d. No data collection without your involvement
We do not collect personal data about you from third-party sources unless you have chosen to connect or authorise such a source within Genie Vault.
We do not intentionally collect personal data that you have not provided, authorised, or chosen to store in your Genie Vault. If, in limited circumstances, additional data is processed to comply with legal obligations or to protect the security and integrity of the service, we will do so in accordance with applicable data protection laws.
e. Data collected through Open Beta, beta community and Free Prize Draw participation
If you take part in Open Beta activities, join an official beta community, complete a Free Prize Draw confirmation form, use the Prize Draw Dashboard or interact with beta support channels, we may collect personal data through those interactions.
This may include Open Beta Participation Data, Free Prize Draw Data, Support and Feedback Data, Discord or beta community identifiers, entry records, activity records, referral records, winner records and prize fulfilment information.
Where a third-party platform such as Discord is used, your use of that platform is also subject to that platform’s own terms and privacy policy.
f. Data collected from partners in connection with offer redemption or campaign measurement
If you choose to redeem a partner offer, the partner may provide us with limited campaign, code, redemption or transaction confirmation information. This may include whether a code was used, whether an offer was redeemed, redemption date, store or channel, campaign identifier, code status or other information needed to confirm, reconcile, measure or report campaign outcomes.
We use this information only for the purposes described in this Privacy Policy, such as offer delivery, redemption confirmation, campaign measurement, fraud prevention, support, audit and compliance.
3. How we collect and use your personal data
Genie Vault is a data-driven service. Processing your personal data is necessary for us to operate Genie Vault and to provide you with the services you choose to use. We will only use your personal data when the law allows us to. This includes UK data protection rules (under the UK GDPR and Data Protection Act 2018) and other applicable laws in countries where we collect and process information.
We will not collect and use your personal data without letting you know. The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
Where you have provided consent. We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose.
Where we need to perform the contract, we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party). We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Where we need to comply with a legal obligation.
We process your personal data only for clearly defined purposes as described below. We will not process personal data in a way that is incompatible with the purposes for which it has been collected or subsequently authorised by you. We also will not collect any personal data that is not needed for the mentioned purposes. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful basis we are relying on to process your personal data, where more than one lawful basis has been set out in the list below.
a. To provide and operate the Genie Vault service
We process your Account and Identification Data, Contact and Communication Data, and Purchasing Data to enable you to create, use, and manage your Genie Vault. This includes:
- creating and maintaining your account,
- securely storing the data you choose to add to your Vault,
- processing purchasing data from receipts and purchase confirmations,
- structuring, organising, and categorising your data so it can be understood and used,
- enabling core Genie Vault features and functionality; and
- liaising with you in relation to our Platform, Services or wider business.
Legal basis: Performance of a contract (the Genie Vault Terms of Service or Genie Vault Terms of Use for Open Beta Participants).
Without this processing, we would not be able to provide the Genie Vault service to you.
b. To generate insights and benefits for you
We process Account and Identification Data, Contact and Communication Data, Purchasing Data, and Insights and Derived Data stored in your Genie Vault to generate insights, summaries, and other outputs designed to help you better understand and benefit from your data. This may include:
- spending summaries and trends,
- categorised views of your purchases,
- AI-assisted insights delivered through the Genie assistant,
- personalised recommendations or benefits made available to you through the service.
These outputs are generated based on the data you have chosen to store in your Vault and are intended to provide you with practical value.
Legal basis: Performance of a contract; Legitimate interests (providing value-added features that form part of the service you expect to receive).
c. To administer the Open Beta, beta activities and Free Prize Draw
We process Account and Identification Data, Contact and Communication Data, Device and Technical Data, Open Beta Participation Data, Support and Feedback Data and Free Prize Draw Data to administer the Open Beta and, where applicable, the Genie Vault Open Beta Free Prize Draw.
This may include:
- checking Open Beta eligibility;
- approving, inviting and activating Open Beta participants;
- managing beta onboarding and beta participation;
- recording beta activities, microquests, surveys, feedback, issue reports and support requests;
- managing referral attribution and activated referral records;
- matching your Genie Vault Open Beta participant record with your Discord or beta community account where needed for Free Prize Draw participation;
- validating, publishing, correcting, rejecting or voiding Free Prize Draw entries;
- operating or supporting the Prize Draw Dashboard;
- selecting, notifying and verifying winners;
- administering and fulfilling prizes;
- preventing fraud, misuse, duplicate accounts, artificial activity or unfair participation;
- keeping records needed for audit, compliance, legal, accounting, dispute resolution and prize draw administration.
Legal basis: Performance of a contract; Legitimate interests; Consent where required; Legal obligation where applicable.
d. To enable, deliver, test and measure partner offers and partner-related features
Where partner offers, partner-related features or partner offer testing are made available, we may process Account and Identification Data, Contact and Communication Data, Purchasing Data, Insights and Derived Data, Partner Offer and Campaign Data, Device and Technical Data and relevant Open Beta Participation Data to enable, deliver, test, measure and improve partner-related features and offers.
This may include:
- preparing and structuring relevant information derived from your Genie Vault;
- identifying whether an offer may be relevant to you based on structured Vault data or derived insights;
- creating controlled, de-identified or pseudonymous campaign views for selected partners;
- enabling partners to create or test offers based on structured shopping behaviour;
- assigning, importing or managing individual campaign codes;
- delivering offers to you through Genie Vault, Genie or another official Genie Vault interface;
- explaining why an offer may be relevant;
- recording whether an offer was shown, saved, accepted, declined, ignored, expired or redeemed;
- confirming redemption through user-submitted receipts, digital order confirmations, partner redemption data, campaign code status files or reconciliation processes;
- measuring campaign performance;
- reporting campaign performance in a controlled and proportionate way;
- preventing fraud, abuse, duplicate redemption or misuse;
- improving campaign relevance and the partner offer testing model.
Unless we explain otherwise in a specific notice or consent flow:
- partners do not receive direct access to your full Genie Vault;
- partners do not receive your raw receipt images, forwarded emails, digital receipt files or full purchase history through campaign discovery;
- partners do not browse your Vault;
- partners do not receive your name, email address or personal account data through campaign discovery;
- offers are delivered through Genie Vault or Genie rather than through unrestricted partner access to your Vault;
- you can ignore, decline or redeem offers;
- if you choose to redeem an offer with a partner, that partner may be able to identify you within its own checkout, loyalty, account, payment, online store or point-of-sale environment;
- redemption with a partner does not give that partner access to your full Genie Vault.
Legal basis: Performance of a contract; Legitimate interests; Consent where required.
Where we rely on consent for partner offer testing or a particular partner-related feature, the relevant consent flow or notice will explain what you are consenting to and how you can withdraw that consent.
e. To enable offers, benefits, and information from partners at your request
This section applies to partner-application or user-connected partner contexts. It is separate from the Open Beta partner offer testing described above, where partner-related features or offers may be tested through the standalone Genie Vault environment.
Where Genie Vault is made available through a retail or loyalty partner, or where you choose to connect any further retail or loyalty partners to your existing Genie Vault, you will receive offers, benefits, or information from that partner based on data derived from your Genie Vault.
In such cases, we process Account and Identification Data, Contact and Communication Data, and Purchasing Data to:
- prepare and structure relevant information derived from your Vault,
- enable the delivery of offers, benefits, or messages from the selected partner through the application you are using,
- ensure that any such delivery reflects your choices and permissions.
In this partner-application or user-connected partner context, we do not independently decide which partner content is made available by that partner.
In this context:
- partner-related offers and benefits are an integral feature of the service you access through the partner application,
- delivery of such offers is based on information derived from your Genie Vault and structured to support the service,
- Genie Vault enables the technical processing and delivery of these offers but does not independently create or promote partner content.
Legal basis: Legitimate interests (to develop and grow our business by enabling our partners to provide offers, benefits, and information to you).
f. To maintain security, integrity, and compliance
We process Device and Technical Data to:
- protect the security and integrity of the platform,
- prevent fraud or misuse,
- troubleshoot errors and maintain performance,
- comply with legal and regulatory obligations.
Legal basis: Legitimate interests; Legal obligation (where applicable).
g. To manage our relationship with you which will include:
We process certain Account and Identification Data, Contact and Communication Data, and Support and Feedback Data to:
- Notifying you about changes to our terms or privacy policy;
- Asking you to leave a review or take a survey; and
- Responding to a request for support or information.
Legal basis: Performance of a contract with you, Necessary to comply with a legal obligation, Necessary for our legitimate interests (to keep our records updated and to study how customers use our platform, and services displayed to enable us to develop our relationships and grow our business)
h. To use data analytics
We process certain Account and Identification Data, Contact and Communication Data, Device and Technical Data, Purchasing Data, Insights and Derived Data, Support and Feedback Data, Open Beta Participation Data, Free Prize Draw Data and Partner Offer and Campaign Data to improve our platform, services, customer relationships and experiences.
Legal basis: Necessary for our legitimate interests (to keep our platform updated and relevant, to develop our business).
We do not use your personal data for independent advertising networks, data brokerage, or the sale of personal data. Any partner-related offers, benefits, or messages are delivered as part of the Genie Vault service and only in accordance with your choices and the permissions you have given.
During the Open Beta, this may include analysis of onboarding, receipt processing, Genie interactions, beta activities, microquests, feedback, referral performance, Free Prize Draw participation, offer interaction, campaign performance and product quality. We use this analysis to improve Genie Vault, understand product performance, prevent misuse, improve receipt recognition, improve Genie’s responses and improve the overall Open Beta experience.
Where possible, we use aggregated, de-identified or pseudonymous information for analytics and reporting. We do not use your personal data for independent advertising networks, data brokerage or the sale of personal data.
i. Marketing Communications from Genie Vault
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving the marketing. We will process your Account and Identification Data, Contact and Communication Data and Purchasing Data to form a view on what we think you may want or need or what may be of interest to you.
j. No independent third-party marketing
We do not share your personal data with unrelated third parties, which are not partners with whom you have chosen to connect your Genie Vault, for their own marketing purposes, and we do not sell personal data.
k. To reconcile Open Beta recruitment and account activation
If you were recruited to the Genie Vault Open Beta by People for Research Ltd, we may use your Account and Identification Data and Contact and Communication Data to provide People for Research with a list of participants who have activated their Genie Vault accounts. People for Research may compare this list with its own recruitment records in order to identify and follow up with invited participants who have not completed account activation.
For this purpose, we share only your email address and confirmation that your Genie Vault account has been activated. We do not share information about your receipts, purchases, use of Genie, Discord participation, Hub activity, onboarding activity or any other activity within Genie Vault.
Legal basis: Legitimate interests. Our legitimate interests are to administer Open Beta recruitment efficiently, maintain accurate project participation records and avoid unnecessary activation reminders being sent to participants who have already activated their accounts.
You may object to this processing by contacting us at contact@genievault.com
Opting out
You can ask us to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of use of the Platform, you will still receive service-related communications that are essential for administrative or customer service purposes.
If you no longer wish to receive partner-related offers, partner offer testing messages or partner-related communications, you can use the relevant preference, account, consent, opt-out or support route made available in Genie Vault. During the Open Beta, if an in-app preference setting is not yet available, you can contact us using the official support route and ask to stop receiving partner-related offers or to stop taking part in partner offer testing.
Stopping partner-related offers will not prevent you from receiving essential service-related communications, security messages, account messages, Open Beta administration messages or Free Prize Draw administration messages where these are necessary.
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