Privacy & Cookie Policy

Updated: May 11, 2018


1. What does this Privacy Policy Cover?

Rosa’s Thai Café respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data which we collect via our website, www.rosasthaicafe.com, via feedback cards and feedback devices in our restaurants and via third party feedback apps (“Site”). We also want to tell you about your privacy rights and how the law protects you.

With that in mind, this Privacy Policy is designed to describe:

  • Who we are and how to contact us.
  • Your rights relating to your Personal Data.
  • Marketing communications preferences.
  • What Personal Data we collect.
  • How we use your Personal Data and why.
  • What happens when you do not provide necessary Personal Data?
  • Personal Data from Third Party Sources.
  • How we use cookies and other tracking or profiling technologies.
  • Who we share your Personal Data with.
  • How we keep your Personal Data secure.
  • How long we store your Personal Data.
  • Our policy on children.
  • Third party links.

This Privacy Policy aims to give you information on how Rosa’s Thai Café collects and processes your Personal Data through your use of this Site, including any data you may provide through this Site.

The Privacy Policy is intended to meet our duties of Transparency under the “General Data Protection Regulation” or “GDPR”.

We will post any modifications or changes to this Privacy Policy on this page.


2. Who we are and how to contact us.

Who we are.

ROSA’S LONDON LIMITED is the Controller (for the purposes of the GDPR) of your Personal Data (referred to as either [“Rosa’s Thai Cafe”], “we”, “us” or “our” in this Privacy Policy).

Our address is: 3-7 Temple Avenue, Temple Chambers Suite 215, London, EC4Y 0HP, England.

How to contact us.

You can contact us by emailing: privacy@rosaslondon.com


3. Your rights relating to your Personal Data.

By law you have the right to:

  • Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Data 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 Data. This enables you to ask us to delete or remove Personal Data 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 Data where you have exercised your right to object to processing (see below).
  • Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing 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 Data for direct marketing purposes.
  • Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.

4. How to exercise your rights

If you want to exercise any of the rights described above, please contact us using the contact details shown here Who we are and how to contact us.

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


5. Complaints

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at: privacy@rosaslondon.com

We will reply to your complaint as soon as we can.

If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, the Information Commissioner’s Office.


6. Marketing communications preferences.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you AND/OR by contacting us at any time using the contact details shown here Who we are and how to contact us.


7. What Personal Data we collect.

All the Personal Data we may collect, both from you and from third parties about you, is outlined in the table below.

Category of Personal Data collected What this means
[Identity Data] [First name and last name]
[Contact Data] [Your physical address including postcode, email address and telephone numbers.]
[Marketing and Communications Data] [Your preferences in receiving marketing from us and our communication preferences.]
[Behavioural Data] [Inferred or assumed information relating to your behaviour and interests, based on your online activity. This is most often collated and grouped into “segments” (e.g., there may be a segment for men, living in London and aged under 25, who like eating out).]
[Technical Data] [Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or use our services.]
[Food Order Data] [What food you have ordered for delivery or collection]
[Financial Data] [Your payment card details]
[Booking Data] [Details of when and in which restaurant your booking is]
[Job Application Data] [CV, work history, qualifications, skills and experience]
[Feedback Data] [Your comments on your dining experience at Rosa’s Thai]

8. Aggregated Data

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute considered Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

No Special Categories of Personal Data

We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.


9. How we use your Personal Data and why.

We will only use your Personal Data for the purposes for which we collected it as listed below, 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 Data for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.


10. What is our “legal basis” for processing your Personal Data?

In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:

  • Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
  • Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”)

Generally we do not rely on your Consent as a legal basis for using your Personal Data other than in the context of direct marketing communications.

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.

Purpose Category(ies) of Personal Data involved Why do we do this Our legal basis for this use of data
[Registration] ·       [Identity Data

·       Contact Data]

[To register you as a friend of Rosa’s Thai.] [Contractual Necessity.]
[To process payments for food order deliveries or collections] ·       [Identity Data

·       Contact Data

·       Financial Data

·       Food Order Data]

[To process and deliver your order including manage payments, fees and charges.] [Contractual Necessity.]

 

 

[Troubleshooting] [Technical Data] [To track issues that might be occurring on our systems.] [Legitimate Interests.

It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Sites and associated systems and services.]

[Marketing] ·       [Identity Data

·       Contact Data

·       Marketing and Communications Data]

[To form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.] [Legitimate Interests.

We have a legitimate interest in providing you with updates on our Sites and related offers where you have purchased or shown interest in similar services from us.]

[Table Reservations] ·       [Identity Data

·       Contact Data]

[To reserve a table for you in a Rosa’s Thai restaurant] [Contractual Necessity.]
[Recruitment] ·       [Identity Data

·       Contact Data

·       Job Application Data]

[To consider your application for employment with Rosa’s Thai] [Contractual Necessity.]
[Improving our service to customers] ·       [Feedback Data

·       Identity Data

·       Contact Data]

[To consider your feedback on your dining experience at Rosa’s Thai and to improve our service to future customers] [Legitimate Interests.

We have a legitimate interest in receiving your feedback so that we can improve our service to future customers.]


11. What happens when you do not provide necessary Personal Data?

Where we need to process your Personal Data either to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Site).

In this case, we may have to stop you using our Site have with us but we will notify you if this is the case at the time.


12. Personal Data from Third Party Sources

In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not

Third party data source Publicly available? Category(ies) or other types of personal data received.
[Social Media sites] [Yes] ·       [Identity Data

·       Contact Data]

[Recruiters, CV search companies, background check providers and referees] [No] ·       [Identity Data

·       Contact Data

·       Job Application Data]

[Analytics Providers] [No] ·       [Behavioural Data

·       Technical Data]

[Collectors of feedback via apps] [No] ·       [Feedback Data]

13. How we use cookies & other tracking or profiling technologies.

What are cookies?

We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.

We use two broad categories of cookies:

  • first party cookies, served directly by us to your computer or mobile device; and
  • third party cookies, which are served by our partners or service providers on our Site.

Cookies we use

Our Site uses the following types of cookies for the purposes set out below:

Cookie Name Description Expiry
NID, ga, gat, gid, _gali These cookies are used to collect information about how visitors use our website and WordPress blog. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited.
Read Google’s overview of privacy and safeguarding data
Various
rosa_analytics This cookie is used to remember a user’s choice about cookies on rosasthaicafe.com. Where users have previously indicated a preference, that user’s preference will be stored in this cookie. 180 Days
messenger_accepted This cookie is used to remember a user’s choice about whether they accept using Facebook Messenger Chat Facility 180 Days
wordfence_verifiedHuman This cookie is used by Wordfence – this manages site security preventing hacking and blocking access from suspicious IP addresses. 24 hours
fr Cookies needed for the Facebook social plugin. These cookies are set when explicit consent is given and the user is logged in to Facebook. 30 days
wordpress_test_cookie WordPress sets this cookie when you navigate to the login page. The cookie is used to check whether your web browser is set to allow, or reject cookies. Session Based

If you would like to update your cookie preferences, click the button below

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility).  Many browsers are set to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.

In particular, you can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.

You can also prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB]

Please confirm these descriptions (once populated) are exhaustive. If not, please let us know about any other tracking/profiling practices you, or any third parties, may engage in on your Sites (such as flash cookies, pixel tags, mobile advertising identifiers, cross-device tracking etc.). In particular, please consider whether any information collected in furtherance of such practices will, or could potentially be, linked to any Personal Data.


14. Who we share your Personal Data with.

The table below describes who we share your Personal Data with, what we share and why we share it.

Recipients Category(ies) of Personal Data we share. Why we share it Location(s)
[Service Providers] ·       [Identity Data

·       Contact Data

·       Technical Data]

[Our service providers provide us with IT and system administration services.] ·       [Within Europe]

 

[Professional advisers] ·       [Identity Data

·       Contact Data]

[Our lawyers, bankers, auditors and insurers provide consultancy, banking, legal, insurance and accounting services.] ·       [Within Europe]
[HM Revenue & Customs, regulators and other authorities] ·       [Identity Data

·       Contact Data]

[Authorities may require reporting of processing activities in certain circumstances] ·       [Within Europe]

Data transfers

As you can see from the above, we do not transfer your Personal Data to any parties located outside the European Economic Area. This includes our staff, representatives and advisors.


15. How we keep your Personal Data secure.

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.


16. How long we store your Personal Data.

We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above How we use your Personal Data and why, unless a longer retention period is required by law (for example for regulatory purposes).

The table below shows our standard retention practices:

Category of Personal Data Retention period
[Behavioural Data] For so long as retention is necessary to fulfil the Purposes/Use for which it is used (see How we use your Personal Data and why.
[Marketing and Communications Data] [Nine months from the date on which we collected or received it.]
[Identity Data]
[Contact Data]
[For so long as retention is necessary to fulfil the Purposes/Use for which it is used (see How we use your Personal Data and why). If there is inactivity from the customer within nine months, the data is automatically deleted.
[Job Application Data] [Six months from the date on which we received it.]
[Food Order Data] [Nine months from the data on which we collected or received it.]
[Technical Data] [For so long as retention is necessary to fulfil the Purposes/Use for which it is used (see How we use your Personal Data and why).]
[Booking Data] [Nine months from the data on which we collected or received it.]
[Feedback Data] [Nine months from the data on which we collected or received it.]

17. Our policy on children.

This Site is not intended for children below 16 and we do not knowingly collect data relating to such children.



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