Privacy notice

This Privacy Notice explains how BatchRoute Ltd ("BatchRoute", "we", "us", or "our") handles personal information in connection with BatchRoute.

It covers our public verification and lookup pages, customer accounts, support interactions, website, and related services.

BatchRoute is designed to minimise personal information collected from consumers using public verification pages.

People who look up a lot code. You may scan a code on a package or enter a lot code into a verification page. You do not need a BatchRoute account to do this.

People who work for a brand. You may have a BatchRoute account and manage the product, batch, certificate, and consumer-facing information displayed by that brand.

When you perform a public lot-code lookup, BatchRoute records the lookup event so the relevant brand can understand whether its verification system is functioning.

The lookup record may contain:

• the product or product record looked up;
• the batch that matched, if one did;
• the text entered into the lookup field;
• a normalised version of that text; and
• the date and time of the lookup.

The lookup record is designed not to contain a direct or persistent identifier that BatchRoute uses to associate the lookup with a particular individual.

The lookup record does not intentionally contain:

• your full IP address;
• browser or device information;
• precise location information;
• referrer information; or
• a persistent consumer identifier used to connect lookups together.

Two lookups by the same person and two lookups by different people are therefore not recorded as a consumer history in the lookup data.

This description concerns the lookup record itself. It does not mean that BatchRoute never processes network information for security, abuse prevention, or infrastructure purposes.

To limit automated abuse and prevent large-scale enumeration of lot codes, BatchRoute may temporarily process a transformed or pseudonymised representation of the requesting IP address.

This information is kept separately from the lookup record and is not intentionally joined to a lookup event to create a consumer profile.

The current retention period for this security control is approximately one minute, after which the temporary value expires.

We do not use this short-lived security information for behavioural advertising or consumer profiling.

The public lookup and verification pages currently do not use advertising cookies, behavioural tracking scripts, or third-party analytics designed to create consumer profiles.

Those public pages also do not rely on third-party web fonts or third-party advertising resources.

Authenticated areas of BatchRoute may use strictly necessary technologies, such as session or security cookies, to provide authentication and protect the service.

When a public certificate is opened, we record that the certificate was opened and when.

The certificate-view event is designed to contain:

• the certificate or certificate version opened; and
• the time of the event.

The certificate-view event is not intentionally linked to a consumer identity or to a previous lookup.

If you work for a brand using BatchRoute, we may collect information necessary to create and manage the account, including:

• name;
• business email address;
• account credentials and password hash;
• role and permissions;
• account and billing information;
• support communications; and
• security and audit information associated with account activity.

Actions taken within a brand workspace may be recorded in an audit trail, including what changed, when it changed, and relevant information about the account user who made the change.

Audit records are intended to preserve trustworthy historical information and may therefore be protected against ordinary editing.

This does not mean that every piece of personal information in an audit record is exempt from applicable privacy law. Where a valid privacy right applies, BatchRoute will assess the request and apply appropriate deletion, restriction, anonymisation, retention, or other lawful handling.

BatchRoute staff may access a Customer workspace when reasonably necessary to provide support or investigate a security or operational issue.

Such access is read-only, restricted, and recorded in the applicable Customer audit trail where the system supports that audit event.

Support access is granted only for the period reasonably required for the task and should expire automatically where technically possible.

Customer-uploaded certificates and other files may be processed for malware scanning, storage, access control, delivery, and security.

Product images may be decoded and re-encoded before storage. Where this occurs, embedded image metadata such as camera-generated location metadata may be removed.

Customers remain responsible for ensuring that files uploaded to BatchRoute may lawfully be collected, processed, stored, and published.

We process information for purposes including:

• providing and operating BatchRoute;
• publishing Customer-authorised verification information;
• authenticating and administering Customer accounts;
• providing support;
• maintaining auditability and security;
• preventing fraud, abuse, and automated enumeration;
• protecting the service and its users;
• maintaining backups and operational resilience;
• improving the service using aggregated or de-identified information;
• complying with legal obligations; and
• establishing, exercising, or defending legal claims.

Where GDPR or a similar law requires a lawful basis, the basis will depend on the processing activity.

• Contract: where processing is necessary to provide or administer a service requested by a Customer.
• Legitimate interests: where necessary for security, fraud prevention, service operations, support, product improvement, or protection of legal rights, subject to the applicable balancing requirements.
• Legal obligation: where processing is required by applicable law.
• Consent: where we rely on consent and applicable law requires consent.

For information about our own business relationship with an individual, BatchRoute may act as a controller where we determine the purposes and means of processing.

Where a Customer uses BatchRoute to process personal data on the Customer's behalf, the Customer may act as controller and BatchRoute may act as processor.

The applicable Data Processing Addendum governs processor processing where required by applicable law.

Customers are responsible for determining the appropriate legal basis and notices for personal data they place into the service, unless BatchRoute expressly assumes a different role in a written agreement.

We may disclose information to service providers that help us operate BatchRoute, such as providers of:

• hosting and infrastructure;
• storage and file delivery;
• security and malware scanning;
• email and transactional communications;
• payment processing;
• monitoring and operational support; and
• professional, legal, accounting, or compliance services.

Our current material subprocessors and service providers are listed at https://batchroute.com/legal/subprocessors .

We may also disclose information where required by law, legal process, court or regulator, or where reasonably necessary to protect rights, safety, security, or the integrity of BatchRoute.

BatchRoute and its service providers may process information in countries other than the country in which you are located.

Where applicable data-protection law requires an approved transfer mechanism, we will use an applicable mechanism such as an adequacy decision, standard contractual clauses, or another lawful safeguard.

Where a specific transfer mechanism applies to Customer Data processed under a DPA, the DPA and its applicable transfer terms govern.

We keep information only for as long as reasonably necessary for the purpose for which it was collected, unless a longer period is required or permitted by law.

Current retention periods are maintained in our data retention schedule .

As a general rule:

• temporary security and rate-limiting data expires after the operational period for which it is needed;
• account data is retained while the account is active and for the period reasonably necessary after closure;
• Customer records may be retained for as long as necessary to maintain the Customer's verification service and fulfil the applicable contractual and legal requirements;
• audit records may be retained for the period stated in the retention schedule; and
• backups may remain for a limited period after primary deletion.

We do not retain personal information indefinitely merely because it may be useful.

Depending on where you live and which law applies, you may have rights including:

• access to personal information we hold about you;
• correction of inaccurate information;
• deletion or erasure;
• restriction of processing;
• objection to certain processing;
• data portability;
• withdrawal of consent where consent is the legal basis; and
• the right to complain to a competent privacy regulator.

These rights are subject to applicable legal exceptions and may not apply to every category of information.

If you performed a public lookup and ask us to identify or delete the lookup record associated with you, we may be unable to do so because the lookup record is intentionally designed not to contain a persistent identifier that allows us to reliably identify a particular person.

This is a consequence of our data-minimisation architecture, not a refusal to honour a valid privacy right.

Where California privacy law applies, California residents may have additional rights regarding their personal information, subject to statutory conditions and exceptions.

Depending on the circumstances, these may include rights to know, access, correct, delete, opt out of certain sale or sharing activities, limit certain uses of sensitive personal information, and receive equal treatment for exercising applicable rights.

BatchRoute does not sell or share public lookup information for cross-context behavioural advertising.

Requests may be submitted using the contact information in this notice. We may take reasonable steps to verify the identity of the requester before completing a request.

BatchRoute's public verification service is not directed to children and is not designed to create profiles about children.

We do not intentionally request personal information from children through a public verification lookup.

If you believe personal information relating to a child has been submitted to BatchRoute improperly, contact us using the address below so we can assess the situation.

We use technical and organisational measures appropriate to the nature and risk of the processing. Depending on the service area, these may include access controls, tenant isolation, encryption or secure transport, malware scanning, audit logging, short-lived access links, backups, and operational security controls.

No method of transmission, storage, or processing can be guaranteed to be completely secure.

If we determine that a security incident has resulted in unlawful access to or disclosure of personal information, we will respond in accordance with applicable law.

Where BatchRoute acts as processor, customer notification and cooperation obligations are governed by the applicable DPA.

We may communicate with affected individuals, customers, regulators, law-enforcement authorities, or other parties where required or reasonably necessary.

BatchRoute does not use public lot-code lookups to build a consumer profile or make decisions about a consumer based on the lookup.

We do not use those lookup events to determine eligibility for credit, insurance, employment, housing, or similar decisions.

BatchRoute may link to websites or services operated by third parties. Those services have their own terms and privacy practices.

A third-party service that is not controlled by BatchRoute is not governed by this Privacy Notice.

We may update this Privacy Notice to reflect changes in the service, technology, legal requirements, or how we process information.

The notice will carry a revision date. Where a change is material, we will use a reasonable method to provide additional notice where required by applicable law.

Questions, privacy requests, or complaints may be sent to:

privacy@batchroute.com

Postal address: 1 Example Street, London EC1A 1AA, United Kingdom

This Privacy Notice is effective from 24 August 2026.