Privacy policy.
KINEYA RESTAURANT Privacy Notice
Last Updated [05.12.2020]
We respect the privacy of every person who visits or registers with www.Kineya.co.uk (the “Site”) and uses the services made available by us from the Site or in our restaurants (the “Service”) and we are committed to ensuring a safe online experience.
1.Purpose of this notice
This privacy notice explains our approach to any personal information that you might supply to us (or that might be collected from you) in connection with your use of the Service and sets out your rights in respect of our processing of your personal information.
This privacy notice will inform you how you can verify which of your personal information is collected by us through the Service and how you can request that we delete, update or transfer it.
This privacy notice is intended to assist you in making informed decisions when using the Service. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Terms and Conditions and Cookie Policy.
Please also note that this privacy notice only applies to the use of personal information collected by us from your use of the Service or during your communications with us. It does not apply to personal information collected during your communications with third parties.
2.Who are we and what do we do?
The Site and ours Services are operated by the [Kineya Ltd.] trading as Kineya Restaurant (“we” “us” or “our”).
[Kineya Co. Ltd] is the data controller responsible for your personal information. [Kineya Co. Ltd] is registered at the UK Information Commissioner’s Office with registration number: [ZA827573].
[Kineya Co. Ltd] is an English company with registered company number: 1981361 and whose principal address is 22 Great James St, WC1N 3ES.
3.How to contact us?
If you have any questions about this privacy notice or want to exercise your rights, please contact us by:
sending an e-mail to: marketing@kineya.co.uk
or writing to us at: Kineya – Unit 27B, The Circle, St Pancras Station, London, N1C 4QP
4.What personal information do we collect?
Personal information may be collected from you in the following ways:
A. Information you voluntarily provide to us
We collect and maintain personal information that you voluntarily submit to us during your use of the Site and/or Service. For example, when registering with us, setting up an account for collection and delivery of our food, purchasing a gift card or voucher, making a booking, entering a competition, signing up to our loyalty programme, or paying for your food using our online platform
For example, in order to sign up and create an account for online ordering, we request the following personal information from you:
name
company name
date of birth
job title
office location
e-mail address
payment information
social media handle (if relevant)
address (if relevant)
phone number
If you contact us, we may collect additional personal information from you such as your opinion on our service.
B. Information we collect through your use of the Site and Service
Through our use of cookies, log files and other technologies, we may collect personal information regarding your mobile device or the computer hardware and software used to access the Site and Service. This may include the following:
IP address of device(s) used;
browser type;
operating system and device type;
approximate location (e.g. London);
access times and dates; and
referring website addresses.
We also collect personal information regarding your use of and activity on the Site and Service.
This personal information allows us to deliver more helpful information, services and tools. Please see our Cookie Policy for further information.
C. Information we collect from third parties
We may also combine personal information that we collect through your use of the Site and Service with personal information that: a) you have provided to third parties and in respect of which you have given the third party permission to share with us; and/or b) we have obtained from a public record.
5.How do we use your personal information?
Our primary goal in collecting personal information from you is to: (i) carry out our Services; (ii) verify your identity (if necessary); (iii) help us improve our restaurant services and help to develop and market new services; (iv) carry out any requests made by you on the Site; (v) investigate or settle enquiries or disputes; (vi) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vii) enforce our agreements with you; (viii) protect the rights, property or safety of us or third parties, including our other customers and users of the Site and at our restaurants; (ix) provide support for the provision of our Services; (x) carry out recruitment for our restaurants; and (xi) use as otherwise required or permitted by law.
In particular, we may use your personal information for the following purposes:
A. Provision of the Service
We use this information to communicate with you and to carry out actions you request on the Site, such as requests for support, orders placed and to track the transactions that are performed.
In addition, we may use the information and payment details you have provided to us so that we can fulfil the supply of products and services you have ordered from our Site.
Who do we share your personal information with for these purposes?
We will share your personal information with the following categories of third parties:
To verify card payments and process refunds – credit card companies and other payment providers; and
To deliver products and process returns – delivery and courier companies (e.g. Deliveroo) or click and collect providers.
What is our legal basis?
It is necessary for us to use your personal information to provide the Service to you and perform our obligations in accordance with any contract that we may have with you. It is also in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can to you.
B. Information Requests and Feedback
Our Service contains various user interfaces to allow visitors to request more information about our products and services, to use the functionalities of the Site, or to provide us with feedback about them. Contact information may be requested in each case, along with information about your computing environment and/or industry, and details of your request or reported feedback. This information is used in order to allow us to respond to your requests, to assure that our software and services work correctly.
What is our legal basis?
It is in our legitimate business interests to respond to any requests you make to us or use the information you provide to us in your feedback in order to improve our products and services.
C. Profiling
We may use your information for customer profiling to ensure that we market the most suitable products and services to you.
What is our legal basis?
It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can to you.
D. Service administration
We may use your personal information to:
develop and improve the Service;
send you administrative e-mails about the Service; and
contact you to answer any queries you may have.
What is our legal basis?
It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can to you.
E. Customer Insight and Analysis
Our web pages and e-mails may contain “web beacons” or “pixel tags.” Web beacons and pixel tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. By using this information, we are able to measure the effectiveness of our content and how visitors use our Site. This allows us to learn what pages are most attractive to our visitors, which parts of our Site is the most interesting and what kind of offers our registered users like to see.
Some of the web beacons that are placed on our Sites are used only by us, and other web beacons are used by our service providers on our behalf to analyse how our Sites are used. Once you click on an e-mail that contains a web beacon, your contact information may subsequently be cross-referenced to the source e-mail and the relevant web beacon or pixel tag information.
In some of our e-mail messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.
Who do we share your personal information with for these purposes?
We share your personal information with a variety of third party service providers to assist us with customer insight analytics.
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis as the information will no longer constitute personal information.
However where your personal information is not in an anonymous form, it is in our legitimate interest to continually evaluate that personal information to ensure that the products and services we provide are relevant to the market.
We will only use your location data for customer insight purposes where we have your consent to do so.
F. Internal record keeping and legal compliance
We may use your personal information for internal record keeping purposes and to check you comply with the Site and our Terms and Conditions.
What is our legal basis?
It is in our legitimate interest to ensure that we keep our records up-to-date in order to monitor who uses the Service, to comply with our legal obligations and to monitor your compliance with the relevant Terms and Conditions.
G. Marketing by us
We carry out the following marketing activities using your personal information:
Email marketing
We may send you marketing communications by email (including details of our offers, newsletters and events), where you have consented to receive such marketing communications or where we have another lawful basis to do so.
Our email marketing will include personalised and non-personalised email marketing. Personalised email marketing is marketing which has been specifically tailored to you. For example, our personalised email marketing will feature our products and services that we think are most likely to appeal to you. Non-personalised marketing is marketing about our products and services generally and is not tailored to any particular individual.
Where we are sending you personalised email marketing, we will also use information that we observe about you from your interactions with our Site, and our email communications to you and/or with our products and services in our restaurants (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected).
Who do we share your personal information with for these purposes?
We share your personal information with a variety of third party email marketing providers who assist us in delivering our email marketing campaigns to you.
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.
We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have an alternative lawful right to do so.
H. Business administration and legal compliance
We use your personal information for the following business administration and legal compliance purposes:
to comply with our legal obligations;
to enforce our legal rights;
protect rights of third parties; and
in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
Who do we share your personal information with for these purposes?
We will share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.
What is our legal basis?
Where we use your personal information in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.
Where we share your sensitive personal information, we shall obtain your consent to do so. we share your sensitive personal information, we shall be relying on your consent to do so.
I. Competitions and games
From time to time we run prize draw promotions or competitions either online or in our restaurants which you can enter or games or quizzes on our Site or in our restaurants that you can play.
Who do we share your personal information with for these purposes?
We share your personal data with any third party providers that assist us with the administration of any prize draws, competitions, games or quizzes.
What is our legal basis?
It is in our legitimate interest to use your personal information to enable you to participate in any prize draws, competitions, games or quizzes and where it is necessary for the performance of any contract that we may have with you.
J. Recruitment
We use your personal information (e.g. name, job title, contact information including email address, curriculum vitae, your education, employment history and similar matters and similar information that you may provide to us and any other information relevant to potential recruitment) for the following recruitment purposes:
to assess your suitability for any position for which you may apply to us whether such application has been received by us online, via email or by hard copy or in person application or through a third party recruitment agency.
to review our equal opportunity profile in accordance with applicable legislation, and we do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment related decisions are made entirely on merit.
Who do we share your personal information with for these purposes?
We will share your personal information with external recruiters where we have engaged them to find a candidate for a specific role with us.
What is our legal basis?
Where we use your personal information in connection with recruitment it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make the best recruitment decisions. We will not process any special data except where we are able to do so under applicable legislation or with your explicit consent which shall be obtained at the time we collect your personal information following the instructions provided.
K. Other
Any other purposes for which we wish to use your personal information will be notified to you either by updating our privacy notice or otherwise from time to time including the legal basis of such use.
6. How do we obtain your consent?
Where our use of your personal information requires your consent, you can provide such consent:
at the time we collect your personal information following the instructions provided; or
by informing us by e-mail, post or phone using the contact details set out in this privacy notice.
7.Use of cookies
Our Service may use certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.
8.Third Party Links and Services
Our Service may contain links to third party websites and services. Please remember that when you use a link to go from our Site or Service to another website or you request a service from a third party, this privacy notice no longer applies.
Your browsing and interaction on any other website, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.
We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.
This privacy notice applies solely to personal information collected by us through our Site and Service and does not apply to these third party websites and third party service providers.
9.Transfers outside the EEA
Where necessary in order to deliver our services, we will transfer personal information to countries outside the EEA. When doing so, we will comply with our legal and regulatory obligations in relation to the personal information including having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information
10.How long do we keep your personal information for?
We do not keep your personal information for any specific period but we will not keep it for longer than is necessary for our purposes. In considering how long to keep it, we will take into account its relevance to our business and our legal and regulatory obligations.
If your information is only useful for a short period e.g. for specific marketing campaigns we may delete it.
11. Confidentiality and security of your personal information
We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.
We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
unauthorised access;
improper use or disclosure;
unauthorised modification; and
unlawful destruction or accidental loss.
All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of the Service.
12. How to access your information and your other rights?
You have the following rights in relation to the personal information we hold about you:
A. Your right of access
If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
B. Your right to rectification
If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
C. Your right to erasure
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
D. Your right to restrict processing
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
E. Your right to data portability
With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.
F. Your right to object
You can ask us to stop processing your personal information, and we will do so, if we’re:
relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing;
processing your personal information for direct marketing; or
processing your personal information for research unless such processing is necessary for the performance of a task carried out in the public interest.
G. Your rights in relation to automated decision-making and profiling
You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
H. Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
I. Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
13. Change to this privacy notice
We may make changes to this privacy notice from time to time.
To ensure that you are always aware of how we use your personal information we will update this privacy notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We may notify you by e-mail of any significant changes. However, we encourage you to review this privacy notice periodically to be informed of how we use your personal information.