- Before or at the time of collecting personal information, Merchant will identify the purposes for which information is being collected.
- Merchant will collect and use personal information solely with the objective of fulfilling those purposes specified by Merchant and for other compatible purposes, unless Merchant obtains the consent of the individual concerned or as required by law.
- Merchant will only retain personal information as long as necessary for the fulfilment of those purposes.
- Merchant will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.
- Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
- Merchant will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
- Merchant will make readily available to customers information about our policies and practices relating to the management of personal information.
“Non Personal Information” is information that is not personally identifiable to you and that we automatically collect when you access our Site with a web browser. It may also include publicly available information that is shared between you and others.
“Personally Identifiable Information” is non-public information that is personally identifiable to you and obtained in order for us to provide you within our Site. Personally Identifiable Information may include information such as your name, email address, and other related information that you provide to us or that we obtain about you.
Information We Collect
Generally, you control the amount and type of information you provide to us when using our Site. As a user, you can browse our Site to find out more about our Site. You are not required to provide us with any Personally Identifiable Information as a user.
We collect personal information whenever you provide it to us. This personal information may include the following:
- full name;
- delivery address;
- e-mail address;
- contact number;
Computer Information Collected
When you use our Site, we automatically collect certain computer information by the interaction of your mobile phone or web browser with our Site. Such information is typically considered Non Personal Information. We also collect the following:
- Geographical Information. When you use the mobile application, we may use GPS technology (or other similar technology) to determine your current location in order to determine the city you are located in and display information with relevant data or advertisements. We will not share your current location with other users or partners. If you do not want us to use your location for the purposes set forth above, you should turn off the location services for the mobile application located in your account settings or in your mobile phone settings and/or within the mobile application.
- Automatic Information. We automatically receive information from your web browser or mobile device. This information includes the name of the Site from which you entered our Site, if any, as well as the name of the Site to which you’re headed when you leave our Site. This information also includes the IP address of your computer/proxy server that you use to access the Internet, your Internet Site provider name, web browser type, type of mobile device, and computer operating system. We use all of this information to analyze trends among our Users to help improve our Site.
- Log Data. Like many Site operators, we collect information that your browser sends whenever you visit our Site (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics.
How We Use Your Information
We use the information we receive from you as follows:
- Enhancing the quality of our customer services;
- Processing of inquiries by Merchant(s);
- Further improvements to our services and Site;
- Helping resolve any disputes;
- Carrying out troubleshooting activities;
- Conducting surveys for the purpose of market research; and
- Supplying our customers with information on our products and services.
How We Share Information
We may disclose your personal information to:
- our employees, consultants and service providers;
- our infrastructure providers;
- law enforcement and regulatory agencies in connection with any investigation to help prevent unlawful activity or as otherwise required by law.
Reasons We Collect and Use Your Personal Information
We may use your information in the following ways:
- where it is necessary to perform our contract with you;
- where it is required by law;
- where you have provided consent, provided that you can withdraw this consent at any time; and
- where it is necessary for our legitimate interests as a business.
Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)
The Merchant may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it’s not overridden by your rights
- For payment processing purposes
- To comply with the law
Your Data Protection Rights Under General Data Protection Regulation (GDPR)
Where the European Union’s General Data Protection Regulation 2016/679, or GDPR, applies, in certain circumstances and subject to data processing agreements, you have rights in relation to the personal information we hold about you. We set out below an outline of those rights and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by providing details only known to the account holder. To exercise any of your rights, please send an email to email@example.com. Please note that for each of the rights below we may have valid legal reasons to refuse your request and, in such instances, we will let you know if that is the case. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information we have on you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where the Merchant relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
Links to Other Website
Do Not Track Disclosures
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. There is no industry consensus as to what Site and app operations should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals.
California Online Privacy Protection Act
According to CalOPPA, Merchant agrees to the following:
- Users can visit our site anonymously.
By logging in to your account
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. Merchant do not specifically market to children under the age of 13 years old.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
- Merchant/hotefy will notify you within 7 business days
- Merchant/hotefy will notify the users via in-site notification within 7 business days
Merchant also agrees to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
The Data of the users of hotefy is securely protected from unauthorized access. The measures Merchants take to guarantee that your Data is protected from any alterations, accidental or unlawful destruction, and accidental loss. The merchant always exerts reasonable efforts in order to ensure the protection of your Data against misuse, loss or alteration by third parties. But you should also be aware that when information is transmitted over the Internet, transmissions are subject to a certain amount of risk. The security tools employed and the procedures implemented to ensure the limitation of any access to personal and private information. With these tools and procedures, access by unauthorized users is located to prevent it. We are proud to offer security measures that abide by high industry standards. That is why we have not yet received complaints regarding cases of penetration of our security system. But there is always a certain amount of risk of thieves who may thwart the security system we implement.
Please note that subscribers receive email messages from hotefy informing them of products, improvements, new services offered, notices of scheduled services, etc. Should you choose to opt-out of receiving such emails, you can suspend your subscription.
Retention of Information
Merchant retains personal data for as long as you are a User in order to meet the contractual obligations to you, and for such longer period as may be in legitimate interests and to comply with legal obligations. Our data deletion process is Merchant enabled and Merchant is able to remove customer data on request. They capture the customer details via the hotefy digital menu. Customer when served, their data is moved to the archive. From the Archive, the Merchant is able to delete at any time. The Merchant may also remove their entire menu at any time thereby removing all their data.