This is the Privacy Policy of Santa’s Pizza (“Santa’s”, “we” or “us”).

We are committed to protecting your privacy and personal data.  This Privacy Policy informs you how we look after your personal data when you visit our websites at www.santaspizza.co.uk or www.santaspizza.com (“Websites”)

In this Privacy Policy, “you” means individuals who browse our websites, use our app or receive our goods and services from us. Santa’s Pizza is the controller of any personal data that you provide to us – this means that we are responsible for ensuring that your personal data is held and used in accordance with this Privacy Policy.

PURPOSE

Personal data includes any information you may provide to us when you visit our Websites, place an order, send us feedback, sign up to our mobile app or contact us for any other purpose.

It is important that you read this policy so that you are fully aware of how and why we are using your data and your rights in relation to your data. Our Websites and App are not intended for use by children and we do not knowingly collect data relating to children

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, username or similar identifier, title, date of birth, anniversaries and gender.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Audio and Visual Data includes images or video footage captured by our CCTV or other recording systems at our restaurants or otherwise for promotional purposes.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes 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 our Websites or App.

Profile Data includes your username and password on our Websites or App, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our Websites, App, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Health Data includes personal data about allergies or medical conditions.

Special Categories of Personal Data

The data protection laws recognise that some categories of personal data are more sensitive. This includes personal data which relates to your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions and health information (“Special Categories of Personal Data”). The only Special Category of Personal Data which we collect is Health Data which we will store and use in accordance with this Privacy Policy. If you provide us with any other personal information that falls within the Special Categories of Personal Data, we will keep such information confidential and not use or disclose it in any way unless we have your express consent.

Aggregated Data

We also collect, use and share aggregated data such as statistical or demographic data (“Aggregated Data”) for any purpose. Aggregated Data could be derived from your personal data but will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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.

HOW WE COLLECT YOUR INFORMATION

We use different methods to collect data from and about you including through direct interaction, automated technologies and from third parties.

Identity, Contact and Financial Data

You may give us your Identity, Contact and Financial Data by communicating with us via our Websites or by phone, email, post or otherwise. This includes personal data you provide when you:

• Fill in forms (including on our Websites and our App)
• Place an order via phone or our Websites
  
• Create an account on our Websites or App
• Register to receive our newsletter or updates from us
• Request information on our products or services to be sent to you;
• Enter a competition, promotion or survey; or
• Give us feedback or contact us for any other reason.

When you contact us (by phone, email or via our Websites or App), we may keep a record of your contact and what you say to us.

We may receive Contact and Identity Data about you from our providers of online reservations when you book a table.

We may receive Contact, Identity and Financial Data about you from our technical, payment and delivery services when you place an order for collection or delivery.

We may also receive Contact and Identity Data about you from social media platform providers (including Facebook, Twitter and Instagram) if you follow us, share our content or communicate with us via these platforms.

Audio and Visual Data

We may record images or video footage of you through our CCTV or other recording systems at our restaurants.

We may also take photos or record images for promotional purposes at special events provided we have informed you that we intend to do so and you have not objected to us doing so.

Health Data

You may give us details of your allergies or medical conditions when you place an order or make a reservation. We may also gather information in relation to your health as necessary health and safety purposes, including any information you provide or we gather as part of any log of an accident on our premises.

Usage and Transaction Data

We will collect details of orders you place via phone or our Websites and reservations you make. If you set up an account on our Websites, details of your previous orders will be stored.

Profile and Technical Data

As you interact with our Websites and App, we will automatically collect Profile and Technical Data about your orders, browsing actions, equipment and patterns. We may collect Technical Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy [LINK] for further details of the Cookies we use and how to change your cookie settings.

We may receive Technical Data about you from various third parties as set out below:

(a) analytics providers (such as Google);

(b) advertising networks; and

(c) social media platform providers (including Facebook, Twitter and Instagram) if you          follow us, share our content or communicate with us via these platforms.

We will also receive details of your experience with us and your preferences if you supply us with feedback.

Marketing and Communications Data

We will keep a record of your preferences in receiving marketing from us and our third parties and your preferences for how we communicate with you.

HOW WE USE YOUR INFORMATION

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Performance of Contract means using your data as necessary for us to provide a quote to you or fulfil a contract to provide our services to you.

Legitimate Interest means using your data as necessary for the commercial interests of our business, allowing us to conduct and manage our business to give you the best possible service and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.

Comply with a legal or regulatory obligation means using your personal data to the extent necessary for us to comply with a legal or regulatory obligation that we are subject to.

Type of Data

a) Identity b) Contact c) Profile d) Marketing & Communications

Lawful Ground for Proceeding
a) Perform our contract with you b) Necessary to comply with a legal obligation c) Necessary for our legitimate interests (to keep our records updated, maintain and develop our service provision and to understand how customers use our services)

5. To take photographs and record images for publicity purposes, including at special events we are hosting (e.g. charity fund-raising and opening events)

Type of Data
Audio & visual

Lawful Ground for Proceeding
Necessary for our legitimate interests (to promote our services and grow our business) provided you have been informed on arrival at the event that we are taking photographs for publicity purposes at the event and you have not objected to us doing so

6. To administer and protect our business, network and our Websites and App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of Data
a) Identity b) Contact c) Technical d) Usage

Lawful Ground for Proceeding
a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) b) Necessary to comply with our legal obligations

7. To deliver relevant Website and App content and advertisements in the most effective manner to you and measure or understand the effectiveness of our promotional campaigns and advertising

Type of Data
a) Identity b) Contact c) Profile d) Usage e) Marketing & Communications f) Technical

Lawful Ground for Proceeding
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

8. To use data analytics to improve our Websites and App, services, marketing, customer relationships and your experience with us

Type of Data
a) Technical b) Profile c) Usage

Lawful Ground for Proceeding
Necessary for our legitimate interests (to define types of customers for our services, to keep our Websites and App updated and relevant, to develop our business and to inform our marketing strategy)

9. To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of Data
a) Identity b) Contact c) Technical d) Usage e) Profile F0 Marketing & Communications

Lawful Ground for Proceeding
Necessary for our legitimate interests (to develop our products/services and grow our business)

10. To use information that you provide about your allergies, medical conditions or dietary requirements to fulfil your order

Type of Data
a) Health b) Identity

Lawful Ground for Proceeding
a) Perform our contract with you b) Necessary to comply with our legal obligations c) Necessary to for us to establish, exercise or defend our legal rights

11. To record any accident or injury on our premises

Type of Data
a) Health b) Identity

Lawful Ground for Proceeding
a) Necessary to comply with our legal obligations b) Necessary to for us to establish, exercise or defend our legal rights

12. To use our knowledge of your allergies or medical conditions in an emergency situation

Type of Data
a) Health b) Identity

Lawful Ground for Proceeding
Necessary for your vital interests where you are incapable of giving consent

Consent

Generally, we do not rely on consent as a legal basis for processing your personal data. However, we will obtain your consent before we:

• store any Health Data you give us for future use to allow us to fulfil your orders; or
• send third party direct marketing communications to you via email or text message.

You have the right to withdraw your consent at any time by contacting us.

Marketing and Email Newsletters

We may use your Identity, Contact, Technical, Usage and Profile 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 products, services and offers may be relevant for you.

You will receive details of our offers and promotions from time to time if you have requested information from us or purchased goods or services from us and you have not opted out of receiving these types of messages or if you have registered to use our App.

We may operate an email newsletter program through our Websites, the purpose of which is to inform subscribers about our products and services. You can subscribe through an online automated process should you wish to do so. Some subscriptions may also be manually processed with your prior agreement.

You can opt out of emails by checking the unsubscribe link in any email communication or opt out of App messages by changing your preferences within the App.

We will never share your personal data with any third parties for marketing purposes without your express consent.

Surveys

MOD Pizza may conduct online surveys of visitors. Your participation in a survey is voluntary and the information you provide will not be shared with third parties unless you have specifically consented upon the collection of your feedback.

WHO WILL WE DISCLOSE YOUR PERSONAL DATA TO?

• There are circumstances where we want to or are compelled to disclose your personal information to third parties. This will only take place in accordance with the applicable law and for the purposes listed above. Your personal information may, for the purposes set out in this privacy policy, be disclosed for processing to:
• our employees;
• our group companies and their employees;
• to another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your personal information will be permanently transferred to a successor company;
• third party consultants, contractors or other service providers who may access your personal information when providing services (including but not limited to IT support services) to us;
• government bodies and law enforcement agencies and in response to other legal and regulatory requests;
• auditors or contractors or other advisers auditing, assisting with or advising on any of our business purposes, in any jurisdiction where we operate;
• to public authorities where we are required by law to do so; and to any other third party where you have provided your express consent.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

WHERE WE STORE YOUR PERSONAL DATA

We may transfer and store your data outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• the country to which we are transferring your data has been deemed to provide an adequate level of protection for personal data by the European Commission (this includes companies based in the US if they are part of the Privacy Shield); or
• we use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when we transfer your personal data out of the EEA.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

RETENTION OF YOUR PERSONAL INFORMATION

Your personal information will be retained until your last use or purchase of our services or goods and normally for a period of two years thereafter, unless longer retention is required by applicable local law or where we have a legitimate and lawful purpose to do so. We will not retain beyond this period any of your personal information that is no longer required for the purposes set out in this privacy policy. The retention of your personal information will be subject to periodic review.
We may keep an anonymised form of your personal information, which will no longer refer to you, for statistical purposes without time limits.

YOUR RIGHTS

You have various rights in respect of the personal information we hold about you – these are set out in more detail below.  If you wish to exercise any of these rights, you can do so by contacting us at info@santaspizza.co.uk or by using the contact details at section 11 below.

Access: You can ask us to give you a copy of the personal information that we hold about you.

Correction: You can ask us to change or complete any inaccurate or incomplete personal information held about you.

Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.

Objection: You can object to our processing of your personal information where we are relying on a legitimate interest (or those of a third party) 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 information for direct marketing purposes.

Restriction: You can ask us to restrict our use of your personal information in the following circumstances: a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) if you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Transfer: You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.

Withdraw consent: If you have given us your consent to use personal information (for example, for marketing), you can withdraw your consent at any time.

Fee

We may charge a reasonable fee to provide you with a copy of your personal data if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you?

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.

Time limit to respond

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.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) if you believe that your personal information is not being processed in accordance with applicable data protection law. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

OTHER SITES

Our Website and App may contain links to third-party websites.  How your personal data is used by a third-party website that you link to from our Websites or App is governed by that website’s privacy policy. We cannot control and are not responsible for how your personal data is used by any third-party website.