Dinabite Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits the dinabite website and / or uses the dinabite app. We will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
In this Policy the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of the dinabite website(s) and / or mobile apps;|
|“Supplier”||means any restaurant / bar / food delivery / catering establishment/ any person or business with which you have cause to interact as a result of your activity on the dinabite website and / or apps;|
|“Cookie”||means a small text file placed on your computer or device by our website or app, when you visit and /or use these URL’s or products. Details of the Cookies used are set out in Part 14, below; and|
|“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;|
The dinabite.ai website and any mobile device apps is / are owned by and published by Dinabite Ltd, a Limited Company registered in England under company number 09788163. Our registered address is 1 -75 Shelton Street, Covent Garden, London, WC2H 9JQ.
Our Data Protection Officer is Giuseppe Uslenghi, email address: firstname.lastname@example.org.
We are regulated by the Information Commissioner’s Office (ICO) in the United Kingdom.
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
Under the GDPR, you have the following rights, which we will always work to uphold:
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
For ‘end users’ of the website and apps (i.e. dining customers):
For ‘business users’ of the admin section of the website (i.e. restaurant managers):
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one or more of the following purposes:
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or SMS with information, news, and offers. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Third Parties, (including, for example, our partner Groupon) whose content appears on our website and app, may use third-party Cookies, as detailed below in Part 14.
Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties. We may, however, share certain data with those third parties as a result of you entering into a transaction with them as a ‘supplier’. In this case, the data that they may receive is outlined in more detail in section 10 below.
We use the following automated system for carrying out certain kinds of decision-making and / or profiling. If at any point you wish to query any action that we might take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us via email@example.com to find out more.
An algorithm or series of interconnected algorithms, which process such data as: known purchase history, geographic location history and real-time location, social media interaction with various other websites and / or apps (to the extent that you have made this ‘public’), your proximity to any of our member businesses and external factors such as weather, availability of produce, time of day, seasonal dietary fluctuations and many other considerations that are not connected directly to you. Such factors are then processed to form an offer to be sent to you, which we hope will provide you with an enjoyable experience at any of our member businesses.
In short, the automated decision making merely sends you an offer to consider, which we hope you will find appealing. The gravest consequence of us getting this wrong is probably that we offer you a discount on a restaurant dish that you might not like or in a location too far away from you. It’s not going to have a significant impact on your life, so please don’t be too concerned!
We may put you into categories of members who prefer certain styles of food (e.g. ‘likes sushi’ or ‘dislikes lasagne’ or ‘likes to eat in couples’ or ‘prefers groups of friends’). Our algorithms and / or data categories can change daily, so if you would like to learn more about these issues, please contact us with a request via firstname.lastname@example.org
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. As we collected with the intention of offering you pleasant experiences at advantageous prices in restaurants, we will assume that you wish to continue using restaurants for the span of your natural life. Therefore, we will continue to keep your data until you ask us to remove it from our systems, or if your legal next of kin informs us that you are no longer a living person.
We store data by renting server space from Amazon’s ‘AWS’ cloud storage; this may well mean that this data can be hosted and replicated for backup reasons in multiple locations anywhere in the world, perhaps outside the European Economic Area (EEA) (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein).
These locations are known under the GDPR as ‘third countries’ and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps, by checking Amazon’s policies, to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR. If you have any concerns about where and how Amazon store, backup and move data across their network, please visit:
Additionally we use Google Analytics to capture statistics about member usage, usage patterns, locations etc, so that we can analyse the performance of the Android and iOS applications. This data is stored in Google servers typically located both within and outside the EEA. Having read Google’s supplied information about this storage, we are satisfied that their procedures are sufficiently rigorous for our purposes under this policy document. However, if you have any concerns about Google’s data storage policies, please visit:
The process of you redeeming any offer or deal / contract with any catering establishment / restaurant / bar/ takeaway / food delivery partner (“supplier”) via our site and / or apps will involve that supplier receiving data from which you might be identifiable.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights and our obligations, and the third party’s obligations under the law, as described above in Part 9.
10.1 Custom Audience Advertisements
How we use Custom Audiences
When you use your email address to download dinabite vouchers, we may integrate this with
‘custom audience tools’ to display ads to you on certain external platforms. These tools allow us
to show you advertisements that are personalized to your dinabite history therefore, they are
more likely to be of interest to you.
Before your email address is shared by using these tools, we encrypt or hash your email
address to SHA256 standards. This generates a unique number that Facebook and Snapchat use
to match with unique codes representing the email addresses of its users. By using these unique codes instead of your email address, this ensures that your personal information is kept anonymous and secure and neither Facebook nor Snapchat are able to view it.
After 12 months of inactive use on the dinabite platform, we automatically remove hashed emails
from our custom audience tools.
How to opt-out of custom audiences
If you do not wish for your email address to be integrated with custom audience tools then you must
opt-out. To do this please fill in our secure form here.
Once we receive your request, if your hashed email address was already shared with custom
audience tools we will aim to remove it within 5 working days. Once we have removed your hashed
email address from our custom audience tools, or indeed, if it was never shared in the first place, we
will send you a confirmation of the removal email.
Once you opt-out we will never share your email address with custom audience tools at any
subsequent time, even if you use that same email address to download vouchers in the future.
In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via our website and / or app, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes; including the ability to opt-out of receiving emails from us, which you may do by unsubscribing using the links provided.
You may access certain areas of our website without providing any personal data at all, however, to use all the features and functions available, you may be required to submit or allow for the collection of certain data.
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made by email to email@example.com with the subject line “subject access request”. We will respond to the request as soon as reasonably possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date that we receive your request. You will be kept fully informed of this process.
Our websites and apps may place and access certain first-party Cookies (FPC’s) on your computer or device.
FPC’s are those placed directly by us and are used only by us. We utilize two types of these:
Session Cookies – for successful identification and navigation across site and app pages. These are only present during the session during which you are interacting with the site or app.
Permanent Cookies – to recognize registered users so that you can log on to the site or app without having to ‘re-register’ each time you access the interface in question.
By using our site and / or apps, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us.
Third-party Cookies are used on our site to perform statistical analysis WITHOUT any Personally Identifiable Information (PII) data, for technical implementation of exchange between your device / browser and our application server.
For more details on Cookies, please refer to the table below.
All Cookies used by us are in accordance with current Cookie Law.
You may, if you wish, deny consent to the placing of Cookies; however certain features of our site may not then function fully or as intended. Certain features of our site and / or apps depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them.
You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that the site / app may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
The following FPC’s may be placed on your computer or device:
|Name of Cookie||Purpose||Strictly Necessary|
|__cfduid||Logging in / recognition||Yes|
And the following third-party Cookies may be placed on your computer or device for analytics and associated purposes:
|Name of Cookie||Originator|
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
For the attention of Giuseppe Uslenghi. Email address: firstname.lastname@example.org.
Postal Address: C/O Dinabite Ltd, 1 -75 Shelton Street, Covent Garden, London, WC2H 9JQ.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
©2020 Dinabite Limited.