This privacy policy relates to your use of this App and Web Ordering Tool (the Drink & Dine platform) and describes how we collect and use personal information about you during and after your relationship with us, in accordance with the General Data Protection Regulation (GDPR).
This policy applies to all users (whether venues or customers of those venues) of the Drink and Dine App and our Web Ordering Tool.
The Drink and Dine platform is provided and operated by LWC Drinks Limited, a company incorporated in England (registered number 7677007) with registered office at Unit 3, Stainburn Road, Openshaw, Manchester M11 2DN (“we”, “us”, “our”) and we are the "data controller" (registration number: Z308690X). This means that we are responsible for deciding how we hold and use personal information.
It is important that you read this policy, together with any other information we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
DATA PROTECTION PRINCIPLES
We comply with data protection law. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
HOW WE PROCESS YOUR PERSONAL INFORMATION
The kind of information we hold about you
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).
There are "special categories" of more sensitive personal data which require a higher level of protection.
We may collect, store, and use the following categories of personal information about you:
- Identity data (including name, title, account number, date of birth, gender and preferences when such information is linked to other personal information that identifies you).
- Contact data (including email addresses, telephone numbers and postal address).
- Technical usage data (including usernames, passwords, IP addresses, information about how you use our app, websites, browser type and version, the pages of the Platform that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data and other technical information about the devices you use when you access our app).
- Communications data (including emails, telephone calls and post which you receive from us or send to us, details of any feedback you give to us by phone, email, post or social media and your preferences in receiving information and being contacted by us).
- Financial data (including payment card or account details which is restricted to payment and gateway providers).
- Transaction data (including details about orders made by you, payments to and from you and other details of goods you have purchased from us and participating venues).
How is your personal information collected?
We collect personal information about you when using our Platform such as accessing the Platform, registering with us, contacting us via email, telephone, post or social media, when we contact you for or you send us feedback, make purchases via the Platform in participating venues (including communicating on updates to any order, replying to queries and resolve any problems), analysis of the Platform and complete customer surveys or participate in competitions via our Platform.
We may collect additional personal information in the course of trade-related activities throughout the period of you trading or otherwise dealing with us and our participating venues.
We collect this personal information from you either directly, such as when you register with us, contact us or purchase products or services via the Platform or indirectly, such as your browsing activity while on our Platform (see ‘Cookies’ below).
How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
1. Where we need to, to facilitate the orders you place through the Platform.
2. Where we need to comply with a legal obligation.
3. Where it is necessary for our legitimate interests or those of a participating venue and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:
1. Where we need to protect your interests (or someone else's interests).
2. Where it is needed in the public interest or for official purposes.
Generally, we rely on your consent as a legal basis for processing your personal data for marketing purposes. You have the right to refuse or withdraw consent to marketing communications at any time by contacting us.
The Platform is not intended for use by children and young adults under the age of 18, and we do not knowingly collect or use personal information relating to children.
Situations in which we will use your personal information
We need all the categories of information in the list above primarily to allow us to provide the Platform to you, to enable you to use the Platform for its intended purpose and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.
The situations in which we will process your personal information are listed below.
- Registering you as a new customer and the on-going management of the account.
- Providing ordering services at the participating venues you visit.
- Technical support with the Platform.
- Managing our relationship with you, responding to your queries and providing you with information about the Platform.
- Processing payments through the payment providers of the participating venues.
- Administration of competitions, promotions, surveys and events.
- Prevention of crime and fraud.
- Monitoring your use of our systems to ensure compliance with our IT policies.
- Monitoring network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
- Data analytics studies to review and improve the Platform and customer experiences.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you fail to provide Personal Information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as your use of the Platform).
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Data sharing
We may have to share your data with third parties, including third-party service providers and the participating venues.
We require third parties to respect the security of your data and to treat it in accordance with the law.
If you have given your consent to receiving promotional material from us and participating venues, then your data will be shared and used by us and participating venues for that purpose which may include sending you promotional offers and information about venues and special events.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you, or where we have another legitimate interest in doing so. For example, we will need to share your details with the participating venue when you place an order there.
HOW SECURE IS MY INFORMATION WITH THIRD PARTY SERVICE PROVIDERS AND PARTICIPATING VENUES?
All our third-party service providers and participating venues are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal information with other third parties to facilitate the orders you place, to perform Service-related services or to assist us in analysing how our Service is used, to ensure our compliance with legal obligations and to protect our legitimate interests, which may include (without limitation) HM Revenue & Customs, accountants and auditors, lawyers and debt collection agencies. The types of third parties we may share your information with include:
· Payment Processors
The Platform uses third-party services for payment processing (e.g. payment processors) and these are Global Pay and Optomony. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
· Participating venues
This is to allow them to provide you with the goods and services you order, deliver an order to you and be made aware of any essential information you have provided such as allergy information or specific delivery information. You may consent to receiving marketing and promotional material.
· Delivery partners
The participating venues may use a third party delivery agent to deliver your order to you.
· Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Platform. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. You can opt-out of having made your activity on the Platform available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms webpage.
· Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit.
We may also share your personal information with other third parties in the context of the possible sale or restructuring of the business.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
Data security
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
DATA RETENTION
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. We will retain your personal information in accordance with our Data Protection Policy and all applicable laws and regulations.
RIGHTS OF ACCESS, CORRECTION, ERASURE AND RESTRICTION
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. We will supply details of the personal information we hold, but not any document which contains that personal information.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact info@drinkanddine.co.uk.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact info@drinkanddine.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
COOKIES
Our website uses cookies to distinguish you from other users of our website and to enable certain functionality
You can block cookies by activating the setting on your browser
What are cookies and why do we use them?
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
We use cookies on website to distinguish you from other users of our website and to enable certain functional elements of the website to operate. This helps us to provide you with a good experience when you browse or order on the Platform and also allows us to improve our site.
The types of cookies we use
We use the following types of cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our Platform. They include, for example, cookies that enable you to log into secure areas of our Platform, use a shopping basket or make use of e-billing services.
- Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our Platform when they are using it. This helps us to improve the way our Platform works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our Platform or a particular participating venue. This enables us and participating venues to personalise our content for you, greet you by name and remember your preferences.
- Targeting cookies. These cookies record your visit to our Platform, the pages you have visited and the links you have followed. We will use this information to make our Platform and the advertising and information displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about certain individual cookies we may use and the purposes for which we use them in the table below:
_gat
(Google Analytics)
“Performance Cookie” used by Google Universal Analytics and limits the collection of data on high traffic sites.
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
ga
(Google Analytics)
“Performance Cookie” used by Google Universal Analytics and distinguishes unique users in order to calculate visitor, session and campaign data for the site’s analytics reports.
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
_fbp
(Facebook Pixel)
“Targeting Cookie” used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers
https://www.facebook.com/business/learn/facebook-ads-pixel
Cookies used by third parties
Where our Platform links to external content or social media, such as Facebook, Twitter, Instagram, LinkedIn and YouTube or where we use advertising networks and providers of external services like web traffic analysis services, these third parties may also use cookies over which we have no control.
Blocking or opting out of cookies
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Platform.
Marketing
We and the participating venues would like to send you information about products and services, competitions and special offers, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone, text message (SMS) or automated call.
You may give or remove your consent in the App’s settings.
If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:
- contacting us at info@drinkanddine.co.uk
- using the ‘unsubscribe’ link in emails
It may take up to 5 days for this to take place.
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
How to contact us
Please contact us, if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact, please send an email info@drinkanddine.co.uk