Last updated
This Privacy Policy was last updated on 10th November 2021
1. Introduction
1.1 We are committed to safeguarding the privacy of our visitors and customers; in this policy we explain how we will handle your personal data.
1.2 This policy applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data. This policy applies to personal data collected by us or provided by you, whether in one of our restaurants, when you use our website or app, or in any other way (such as over the telephone).
1.3 We use cookies and similar technologies on our website and/or app. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website. Before you download or install our app on a mobile device, we will provide information about what the app does, and exactly how it uses your information.
1.4 In this policy, "we", "us" and "our" refer to Fuoco’s Group Ltd. For more information about us, see Section 17.
2. The personal data that we collect
2.1 In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
2.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number and postal address. The source of the contact data is you.
2.3 We may process your website and/or app user account data ("account data"). The account data may include your account identifier, name, email address, physical location, previous addresses, account creation and modification dates, website and/or app settings and marketing preferences. The primary source of the account data is you, although some elements of the account data may be generated by our website and/or app. If you log into our website and/or app using a third-party we will obtain elements of the account data from the relevant third party, for example, if you sign in using Facebook, Google or Apple accounts.
2.4 We may process information relating to our customer relationships ("customer relationship data"). The customer relationship data may include your name, your contact details, your classification / categorisation within our customer relationship management system and information contained in or relating to communications between us and you, such as customer feedback. The source of the customer relationship data is you.
2.5 We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website and/or app ("transaction data"). The transaction data may include your name, your payment card details (or other payment details) and the transaction details. Payment card details are passed directly to the payment services provider and are not collected by us. We collect aggregated transaction data, so that no individuals can be identified directly. The source of the transaction data is you and/or our payment services provider.
2.6 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website and/or app will generate the metadata associated with communications made using any contact forms.
2.7 We may process data about your use of our website and/or app and services ("usage data"). The usage data may include your app identifier, IP address, geographical location, browser and/or mobile device type and version, operating system, referral source, length of visit, page views, navigation paths as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
2.8 We may process technical data about the performance of our website and/or app ("diagnostic data"). The diagnostic data may include crash data and other diagnostic data. The source of this data is our crash monitoring system.
3. Purposes of processing and legal bases
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Operations - We may process your personal data for the purposes of operating our website and/or app, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, app, services and business.
3.3 Relationships and communications - We may process contact data, account data, customer relationship data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, app users, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, app, services and business.
3.4 Personalisation - We may process contact data, account data and/or usage data for the purposes of personalising the content and advertisements that you see on our website and/or app and through our services to ensure that you only see material that is relevant to you. The legal basis for this processing is consent.
3.5 Direct marketing - We may process contact data, account data, customer relationship data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, in-app push notifications, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent.
3.6 Research and analysis - We may process account data, usage data, transaction data and/or diagnostic data for the purposes of researching and analysing the use of our website, app and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, app, services and business generally.
3.7 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.8 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, app, services and business, and the protection of others.
3.9 Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.10 Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.11 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4. Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
4.3 Account data, contact data, communication data, customer relationship data, diagnostic data, transaction data and usage data will be stored on the servers of our hosting services provider Google Cloud Services. You can find information about our hosting services provider’s privacy policies and practices at https://cloud.google.com/privacy.
4.4 We may disclose transaction data to our suppliers or subcontractors insofar as reasonably necessary for operations and recording keeping. Aggregated transaction data will be stored on the servers of our accounting software provider Xero. You can find information about the accounting software provider’s privacy policies and practices at https://www.xero.com/uk/about/legal/privacy/.
4.5 Financial transactions relating to our website, app and services are handled by our payment services provider, Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services provider’s privacy policies and practices at https://stripe.com/gb/privacy.
4.6 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to a third country under UK data protection law.
5.2 We may transfer your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
5.3 The hosting facilities for our website and/or app are situated in the UK. You can obtain a copy of our hosting provider’s terms here: https://cloud.google.com/terms/data-processing-terms.
5.4 Where personal data is transferred from the UK to a third country or from a third country to the UK, transfers to each of these countries will be protected by appropriate safeguards to ensure your data receives the same level of protection as if it were processed in the EEA. For example, we may use standard data protection clauses adopted or approved by the competent data protection authorities.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. For example, we will retain your contact data, account data, customer relationship data and/or transaction data for 3 years for direct marketing purposes following the date of the most recent contact with you, before we anonymise your data.
6.3 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the nature of the data and the purposes for which it is kept.
6.4 We will securely dispose of your data by anonymising or deleting it.
6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. For example, we must keep certain tax records for 6 years from the end of the last company financial year they relate to or longer if necessary.
7. Security of personal data
7.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
7.2 We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
7.3 The following personal data will be stored by us in encrypted form: account data, communication data, contact data, customer relationship data, diagnostic data, transaction data and usage data.
7.4 Data relating to your enquiries and financial transactions that is sent from your web browser and/or app to our web server, or from our web server to your web browser and/or app, will be protected using encryption technology.
7.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
7.6 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website and/or app confidential and we will not ask you for your password (except when you log in to our website and/or app).
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;
(e) the right to object to processing - you can object to the processing of your personal data;
(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.3 You have the right to confirm as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.12 You are not required to pay a charge for exercising your rights. In certain limited circumstances, we may charge a reasonable fee. For example, the first copy of your personal data will be provided free of charge, but additional copies may be subject to a reasonable fee. If you make a request, we have one month to respond to you. You may exercise any of your rights in relation to your personal data by e-mailing us on dpo@fuocos.com. You can also contact us by written notice using the contact details in Section 17. We will need to see evidence of your identity before we are able to act on your request.
If you’re not happy with how we are using your personal data, please let us know by emailing us on dpo@fuocos.com. You can also contact us by written notice using the contact details in Section 17. You still have a legal right to lodge a complaint with a supervisory authority responsible for data protection.
8.13 If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. For complaints under UK data protection law, you should contact the Information Commissioner’s Office (ICO).
The ICO’s address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
9. Third party websites
9.1 Our website and/or app includes hyperlinks to, and details of, third party websites.
9.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
10. Personal data of children
10.1 Our website, app and services are targeted at persons over the age of 18.
10.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
11. Updating information
11.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
12. About cookies and similar technologies
12.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
12.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
12.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
12.4 When you download or use an app on a mobile device, the app may access or store information on your device using technology which works in a similar way to cookies.
13. Cookies and similar technologies that we use
13.1 We use cookies and/or similar technologies for the following purposes:
(a) authentication and status - we use cookies and/or similar technologies to identify you when you visit our website, use our app, as you navigate our website and/or app, and to help us determine if you are logged into our website and/or app;
(b) personalisation - we use cookies and/or similar technologies to store information about your preferences and to personalise our website and/or app for you;
(c) security - we use cookies and/or similar technologies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and/or app, and services generally;
(d) advertising - we use cookies and/or similar technologies to help us to display advertisements that will be relevant to you;
(e) analysis - we use cookies and/or similar technologies to help us to analyse the use and performance of our website and/or app, and services; and
(f) cookie consent - we use cookies and/or similar technologies to store your preferences in relation to the use of cookies and similar technologies more generally.
14. Cookies and similar technologies used by our service providers
14.1 Our service providers use cookies and similar technologies, and those cookies may be stored on your computer or other devices when you visit our website and/or use our app.
14.2 We use Google Analytics, which gathers information about the use of our app. For example, it records an event every time the user takes an action. The information gathered is used to create reports about the use of our app. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy.
15. Managing cookies and similar technologies
15.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(f) https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).
15.2 Blocking all cookies will have a negative impact upon the usability of many websites.
15.3 If you block cookies, you will not be able to use all the features on our website.
15.4 Most mobile devices allow you to refuse requests or disable technology similar to cookies, and to delete information stored on your device. The methods for doing so vary from device to device, and from version to version. For example, you can often change the privacy settings on your mobile device for location, tracking, advertising and analytics. You can often change privacy settings for specific apps or change your preferences in the app itself. If you have any privacy concerns, you can e-mail us on dpo@fuocos.com.
16. Amendments
16.1 We may update this policy from time to time by publishing a new version on our website and/or app.
16.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
16.3 We may notify you of significant changes to this policy by email.
17. Our details
17.1 This website and/or app is owned and operated by Fuocos Group Ltd.
17.2 We are registered in England and Wales under registration number 11908169 and our registered office is at Faulkner House, Victoria Street, St Albans, United Kingdom, AL1 3SE.
17.3 Our principal place of business is at 6 Amwell End, Ware, SG12 9HW.
17.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website or in-app contact form;
(c) by telephone, on the contact number listed on our website; or
(d) by email, using the email address dpo@fuocos.com.
