PRIVACY NOTICE FOR CHILANGO WEB ORDERING SERVICE POWERED BY FLYT
This privacy notice provides information on how Flyt Limited (referred to in this notice as "Flyt") and CHILANGO(referred to in this notice as "CHILANGO" or the "Operatorr"), use personal data relating to users (referred to in this policy as "you") of the CHILANGO Web Ordering powered by Flyt (the "Application") and related services (together referred to in this policy as the "Services").
This notice is version 2.2 and was last updated on 21 May 2018.
1.Who are Flyt and the Operator?
Flyt Limited is a company registered in England and Wales with company number 08419148, and registered with the Information Commissioner's Office under number ZA015649.
CHILANGO Limited is a company registered in England and Wales with company number (COMPANY NUMBER)
Flyt runs the Application for the Operator. Flyt and the Operator each act as a data controller in their use of your personal data relating to the Application, as described in this privacy notice.
You can contact Flyt and the Operator using the contact details set out at paragraph 11 below.
2.Collection and use of data by Flyt
1. Registration details
If you install the Application, you will be asked to register with Flyt in order to create a profile and receive the related Services. Registration information will include:
§ the telephone number of the mobile device on which you have installed the Application. This will be used to deliver the Services and manage your PIN;
§ your email address, which will be used to send you receipts for bill payments; and
§ confirmation that you are 13 or over.
You will also be asked to set a four digit PIN to give access to your secure payment cards and other account details.
Your Flyt account can also be used in the main Flyt app and across other 'Powered by' Flyt apps.
Your registration information may be used to perform our obligations under the contract with you for the Services, in particular to:
• deliver the Services to you;
• send you confirmation of payments you have made using the Application or via the Website;
• send you receipts for bill payments; and
• verify your identity.
Your registration information may also be used by us for our legitimate business interests of promoting our business and services to users and developing new products and services, in particular:
• to improve and personalise your user experience within the Application or Website;
• with your opt-in permission (which may be sought in-App), to send you marketing communications (including in-App advertising) relating to our products and services, and, where you have separately consented to this, third party products and services, that we think may be of interest to you. You will of course be able to opt-out at any time by firstname.lastname@example.org or by changing your preferences.
2. Your payment card details
In order to order and collect, you will need to add credit or debit card details. Payment processing services are provided by a third party, VeriFone or any other third party payment provider selected by the Operator from time to time. The Application will transfer payment details directly from VeriFone (or other payment provider) to the Operator's point of sale system. By inputting payment card details, you are consenting to use of such details by VeriFone (or other payment provider), the Operator and Flyt for the purpose of paying your bill and processing the payment for your order.
Your card details will be securely stored by VeriFone (or other payment provider) for ease of use in future transactions using the Application. However, your CSC/CVV number is not stored by Flyt and must be entered each time you use a card for authentication. Flyt does not store your card details on its systems, although we hold a token which retains some of the digits. This enables you to identify the appropriate card in future transactions and on your payment receipt. You may remove payment cards from the Application at any time. Payment transactions are between you and the Operator. Flyt does not receive your payment.
3. Your take-away visits
The Application allows you to place orders for collection from CHILANGO. After placing an order you will "check out" and pay through Flyt. The details of your bill will be used to deliver the Services and generate your payment receipt in relation to your order. We use this for the purpose of performing the contract with you.
Flyt may also collect data relating to your visits (including the food you chose, the outlet you visited and when, bill amounts and your payments) for the future provision of a service to access past
receipts, and for analysis and statistical purposes (see paragraph 5 below). This data is collected through the Application and from the Operator's point of sale system.
We may also collect other data you provide us with in the course of providing the Services, for the purpose of providing the Services and, where this data is a special category of data, such as allergy or health related, with your consent.
4. Contacting Flyt
If you contact Flyt in relation to the Application (via email, telephone, post or otherwise), it may collect and retain your contact details and your communication for the purpose of handling your query and keeping records of communications. This is used for our legitimate business purposes of responding to your queries and record keeping which is necessary for the provision of quality assurance and customer services
3.Use of data by the Operator
Flyt runs the Application for the Operator and data collected through the Application may therefore be accessed by or disclosed to the Operator. As well as payment transaction data (see paragraph 2.2 above), this may include your Flyt user details, demographic information and details relating to your experience at CHILANGO. This data may be used by the Operator for:
o managing your payment with your consent (see paragraph 2.2);
o analysis and statistics (see paragraph 5 below) for our the Operator’s legitimate business interests in seeing how the App and the outlet are used; and
o subject to obtaining your consent (which is sought as an opt-in via the Application), sending you marketing communications by email.
The Operator may also combine your data with other data used in its business (including data collected from its point of sale system) for its legitimate business interests of improving its products and services and customer satisfaction.
4.Combining with data from other sources
Information collected using the Application and relating to your visits to CHILANGO may be combined by Flyt with data from other sources as follows.
o Data from the Operator's point of sale system may be used as referred to in paragraph 2.3 above;
o If you download or use (or have downloaded or used) another Flyt mobile application, Flyt may combine data obtained from this Application with data processed in relation to that application.
The combined data may be used by Flyt for its legitimate business interests of improving and developing its products and service offerings and customer experience and for the same purposes outlined in this policy.
5.Analysis and statistics
Flyt and the Operator may use the data they collect about you for analysis and statistical purposes, for example to analyse how many users are visiting particular outlets at particular times, food preferences, and the characteristics of such users, for example their age or gender.
Statistics and results of analysis (anonymised and without reference to your personal data) may also be shared with other partner restaurants, food outlets and their suppliers for the purpose of improving the customer experience within restaurants and food outlets. We use this for our and our partners’ legitimate business interests of improving our products and service offerings and customer experience.
6.Other use of your personal data
Flyt and/or the Operator may also use and disclose your personal data for our legitimate business interests for the purposes of:
o administration and maintenance of the Services;
o compliance with legal obligations, or protection and enforcement of legal rights (including Flyt's, the Operator's and those of their partners or other users); and/or
o managing actual or potential business transactions (e.g. in the case of an acquisition of Flyt's or the Operator's business).
In the course of providing telephone support to you in your use of the Application or Services, we or our service providers may record the calls for quality assurance purposes. This is in our legitimate interests for the purposes of quality assurance and customer services. Any data collected in this way will be retained for a period of 3 months, after which it will be deleted.
7.Disclosure of your personal data to third parties
Flyt and/or the Operator may disclose your personal data for the purposes outlined at paragraphs 2 to 6 above to third parties, including:
o service providers (see below) and professional advisers;
o governmental bodies and law enforcement authorities;
o any purchaser of Flyt's or the Operator's (as the case may be) business; and
o other third parties where required or permitted by law.
8.Storage and security of your personal data
Your personal data is stored in electronic and physical records maintained by Flyt, the Operator and/or their service providers such as Verifone, other payment providers, payment gateways, IT support providers and MailChimp. Whilst Flyt and the Operator are based in the UK, their service providers may have servers located overseas, where the laws may not give the same level of protection to personal data as within the UK. However, we have agreements in place with these service providers which limit their use of the data and place strict security obligations on the service providers with respect to how your data is used. In addition, where the service providers are based outside of the EEA, we rely on approved mechanisms such as Privacy Shield or the model contracts approved by the European Commission to provide safeguards for you. By submitting your personal data to us, you consent to the transfer, storing and processing of your personal data in countries outside of the UK (including countries located outside of the European Economic Area ("EEA").
9.Removal of your details
You may request removal of your live profile on the Application at any time by sending an email to Flyt at email@example.com
Flyt and the Operator may however retain certain aspects of your profile and other personal details for the purposes of maintaining records of their dealings with you, analysis and statistics and in the case of the Operator, subject to compliance with applicable law, its own marketing purposes.
Any call recordings made during the provision of IT support will be deleted after 3 months.
We will not keep your personal data for longer than we need it. We will keep under review the retention periods outlined above and change them as necessary.
10. Your rights
You have the right to request a copy of the personal data we hold about you. If you would like to access a copy of any personal data which Flyt or the Operator hold about you, or if you wish to change your consent regarding email marketing communications, please send a request by email or by post using the appropriate contact details in paragraph 11 below. We try to respond to 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.
You have the right, in certain circumstances, to object to Flyt or the Operator processing your personal data or to request that your personal data is corrected or deleted or that our processing of your data is restricted. Please contact them to discuss this as required.
In addition, where our processing is based on your consent, you have the right to withdraw consent at any time, but this will not affect any data we use for another purpose (as notified above). In addition we may still need to keep a copy of your data in order to maintain records or dealings with you (as above).
You also the right to complain to the data supervisory authority if you are unhappy with our processing of your personal data. The data supervisory authority in the UK is the Information Commissioner’s Office at www.ico.org.uk.
If you have any queries in relation to the processing of your personal data by Flyt Limited or the Operator (CHILANGO Limited), please contact them as follows: