Last Updated: January 24, 2019
TABLE OF CONTENTS:
- INFORMATION WE COLLECT
- HOW WE USE THE INFORMATION WE COLLECT
- SHARING & DISCLOSURE
- OTHER IMPORTANT INFORMATION
- YOUR RIGHTS
- OPERATING GLOBALLY & INTERNATIONAL TRANSFERS
- CONTACT US
Thank you for using Restaurome! Your trust is important to us and we’re committed to protecting the privacy and security of your personal information. The information that’s shared with us helps us to provide a great experience with Restaurome.
2. INFORMATION WE COLLECT
There are three general categories of information we collect.
2.1 Information You Give to Us.
2.1.1 Information that is necessary for the use of the Restaurome Platform.
We ask for and collect the following personal information about you when you use the Restaurome Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.
- Account Information. When you sign up for an Restaurome Account, we require certain information such as your first name, last name and email address.
- Profile and Listing Information. To use certain features of the Restaurome Platform (such as creating a Listing), we may ask you to provide additional information, which may include your address, phone number, and a profile picture.
- Identity Verification Information. To help create and maintain a trusted environment, we may collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information.
- Communications with Restaurome and other Members. When you communicate with Restaurome or use the Restaurome Platform to communicate with other Members, we collect information about your communication and any information you choose to provide.
2.1.2 Information you choose to give us.
You may choose to provide us with additional personal information in order to obtain a better user experience when using Restaurome Platform. This additional information will be processed based on our legitimate interest or when applicable, your consent.
- Additional Profile Information. You may choose to provide additional information as part of your Restaurome profile (such as city, and a personal description). Some of this information as indicated in your Account settings is part of your public profile page, and will be publicly visible to others.
- Other Information. You may otherwise choose to provide us information when you fill in a form, update or add information to your Restaurome Account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team, share your experience with us or use other features of the Restaurome Platform.
2.1.3 Information We Automatically Collect from Your Use of the Restaurome Platform.
When you use the Restaurome Platform, we automatically collect personal information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Restaurome Platform.
- Geo-location Information. When you use certain features of the Restaurome Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. Restaurome may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
- Usage Information. We collect information about your interactions with the Restaurome Platform such as the pages or content you view, your searches for Listings and other actions on the Restaurome Platform.
- Log Data and Device Information. We automatically collect log data and device information when you access and use the Restaurome Platform, even if you have not created an Restaurome Account or logged in. That information includes, among other things: details about how you’ve used the Restaurome Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Restaurome Platform.
2.1.4 Information We Collect from Third Parties.
Restaurome may collect information, including personal information, that others provide about you when they use the Restaurome Platform, or obtain information from other sources and combine that with information we collect through the Restaurome Platform. We do not control, supervise or respond for how the third parties providing your information process your Personal Information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
- Third Party Services. If you link, connect, or login to your Restaurome Account with a third party service (e.g. Google, Facebook), the third party service may send us information such as your registration, friends list, and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
- Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Restaurome Platform through partnerships, or about your experiences and interactions from our partner ad networks.
3. HOW WE USE INFORMATION WE COLLECT
We may use, store, and process personal information to (1) provide, understand, improve, and develop the Restaurome Platform, (2) create and maintain a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with Restaurome Policies) and (3) provide, personalize, measure, and improve our advertising and marketing.
3.1 Provide, Improve, and Develop the Restaurome Platform. We may use the personal information to provide, improve, and develop the Restaurome Platform such as to:
- enable you to access and use the Restaurome Platform,
- enable you to communicate with other Members,
- operate, protect, improve, and optimize the Restaurome Platform and experience, such as by performing analytics and conducting research,
- provide customer service,
- send you service or support messages, updates, security alerts, and account notifications,
- to operate, protect, improve, and optimize the Restaurome Platform and experience, and personalize and customize your experience
- enable your use of our enterprise products.
We process this personal information for these purposes given our legitimate interest in improving the Restaurome Platform and our Members’ experience with it, and where it is necessary for the adequate performance of the contract with you.
3.2 Create and Maintain a Trusted and Safer Environment. We may use the personal information to create and maintain a trusted and safer environment such as to:
- detect and prevent fraud, spam, abuse, security incidents, and other harmful activity,
- conduct security investigations and risk assessments,
- verify or authenticate information or identifications provided by you (such as to compare your identification photo to another photo you provide),
- conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required,
- comply with our legal obligations,
- Resolve any disputes with any of our Members and enforce our agreements with third parties,
- enforce our Terms of Service and other policies, and
- in connection with the activities above, we may conduct profiling based on your interactions with the Restaurome Platform, your profile information and other content you submit to the Restaurome Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Restaurome Platform if such processes detect activity that we think poses a safety or other risk to the Restaurome Platform, our community, or third parties. If you challenge the decisioning based on the automated process, please contact us as provided in the Contact Us section below.
We process this personal information for these purposes given our legitimate interest in protecting the Restaurome Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.
3.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing.
We may use the personal information to provide, personalize, measure, and improve our advertising and marketing such as to:
- send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Restaurome or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google),
- personalize, measure, and improve our advertising,
- conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Restaurome Platform, information obtained from third parties, and your search history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you,
- enrolling in an email subscription will not affect the frequency of administrative emails that we may send in connection with any Restaurome Account. No fee is charged for sending promotional emails to you, but third-party data rates may apply. Note that you may not be able to take advantage of certain promotions if you do not have an Restaurome Account, and
We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.
3.4 Your Choices
You have choices on the promotional messages that you choose to receive.
- You can limit the information you provide to Restaurome. Participation in promotions and marketing programs is voluntary.
- You can limit the communications that Restaurome
sends to you.
- To opt-out of marketing emails, simply click the link labeled “unsubscribe” at the bottom of any marketing email we send you or access the notification settings in your Restaurome Account.
- You can always update your notification settings within your Restaurome Account by visiting the Notifications section of your Restaurome Account. Please note that even if you opt-out of marketing communications, we may still need to contact you with important transactional information about your account. For example, even if you opt-out of emails, we may still send you activity confirmations or fraud alerts.
4. SHARING & DISCLOSURE
4.1 Advertising and Social Media; Sharing With Your Consent.
Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your Restaurome Account or when you participate in promotional activities conducted by Restaurome partners or third parties.
Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Restaurome Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.
The social media platforms with which we may share your personal information are not controlled or supervised by Restaurome. Therefore, any questions regarding how your social media platform service provider processes your personal information should be directed to such provider.
Please note that you may, at any time ask Restaurome to cease processing your data for these direct marketing purposes by sending an e-mail to opt-out@Restaurome.com.
4.2 Sharing between Members.
To help facilitate interactions between Members, we may need to share certain information, including personal information, with other Members, as it is necessary for the adequate performance of the contract between you and us, as follows:
- When you as a Guest submit a request, certain information about you is shared with the Host, including your profile, and other information you agree to share.
4.3 Profiles, Listings, and other Public Information.
The Restaurome Platform lets you publish information, including personal information, that is visible to the general public. For example:
- Parts of your public profile page, such as your first name, username and your description are publicly visible to others.
- Listing pages are publicly visible and include information such as the approximate location or precise location ( depending on the information you gave us), Listing description, availability, your public profile photo, and any additional information you choose to share.
- Guests may write Reviews and rate. Reviews and Ratings are a part of your listing page and may also be surfaced elsewhere on the Restaurome Platform
- If you submit content in a community or discussion forum, blog or social media post, or use a similar feature on the Restaurome Platform, that content is publicly visible.
Based on our legitimate interest to promote the Restaurome Platform we may display parts of the Restaurome Platform (e.g., your Listing page) on sites operated by Restaurome’s business partners, using technologies such as widgets or APIs. If your Listings are displayed on a partner’s site, information from your public profile page may also be displayed.
Information you share publicly on the Restaurome Platform may be indexed through third party search engines. In some cases, you may opt-out of this feature in your Account settings. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
4.4 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.
Restaurome may disclose your information, including personal information, to courts, law enforcement, governmental authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Restaurome, (iii) to respond to valid requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service or other agreements with Members, or (v) to protect the rights, property or personal safety of Restaurome, its employees, its Members, or members of the public. For example, Host tax information may be shared with tax authorities or other governmental agencies.
These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person’s vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Restaurome Platform secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.
Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Restaurome’s property, its Members and the Restaurome Platform. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Member about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
4.5 Service Providers.
Restaurome uses a variety of third-party service providers to help us provide services related to the Restaurome Platform. Service providers may be located inside or outside of the European Economic Area (“EEA”). In particular, our service providers are based in Europe, India, Asia Pacific and North and South America.
For example, service providers may help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Restaurome Services through third party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service or advertising, , or (vii) process, handle or assess insurance claims or other similar claims. These providers have limited access to your personal information to perform these tasks on our behalf, and are contractually bound to protect the personal information and only use the personal information in accordance with our instructions .
Restaurome will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.
4.6 Business Transfers.
4.7 Aggregated Data.
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.
5. OTHER IMPORTANT INFORMATION
5.1 Analyzing your Communications.
We may review, scan, or analyze your communications on the Restaurome Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.
These activities are carried out based on Restaurome’s legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
5.2 Linking Third Party Accounts.
You may link your Restaurome Account with your account at a third party social networking service. Your contacts on these third party services are referred to as “Friends.” When you create this link:
- some of the information you provide to us from the linking of your accounts may be published on your Restaurome Account profile;
- your activities on the Restaurome Platform may be displayed to your Friends on the Restaurome Platform and/or that third party site;
- a link to your public profile on that third party social networking service may be included in your Restaurome public profile;
- other Restaurome users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;
- other Restaurome users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking service;
- the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and
- the publication and display of information that you provide to Restaurome through this linkage is subject to your settings and authorizations on the Restaurome Platform and the third party site.
We only collect your information from linked third party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.
5.3 Third Party Partners & Integrations
The Restaurome Platform may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). Restaurome doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, Restaurome, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
6. YOUR RIGHTS
You may exercise any of the rights described in this section before your applicable Restaurome Data Controller by sending an email to firstname.lastname@example.org. Please note that we may ask you to verify your identity and request before taking further action on your request.
6.1 Managing Your Information.
You may access and update some of your information through your Account settings. If you have chosen to connect your Restaurome Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.
6.2 Rectification of Inaccurate or Incomplete Information.
You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your Restaurome Account).
6.3 Data Access and Portability.
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
6.4 Data Retention and Erasure.
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely.” Please note that if you request the erasure of your personal information:
- We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Restaurome Account for fraud or safety reasons, we may retain certain information from that Restaurome Account to prevent that Member from opening a new Restaurome Account in the future.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Restaurome may keep some of your information for tax, legal reporting and auditing obligations.
- Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the Restaurome Platform, even after your Restaurome Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
- Because we maintain the Restaurome Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
6.5 Withdrawing Consent and Restriction of Processing.
If we are processing your personal information based on your consent you may withdraw your consent at any time by sending a communication to Restaurome specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of Restaurome override your own.
6.6 Objection to Processing.
In some jurisdictions, applicable law may entitle you to require Restaurome not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Restaurome will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
Where your personal information is processed for direct marketing purposes, you may, at any time ask Restaurome to cease processing your data for these direct marketing purposes by sending an e-mail to opt-out@Restaurome.com.
6.7 Lodging Complaints.
You have the right to lodge complaints about our data processing activities by filing a complaint with our Data Protection Officer who can be reached by the “Contact Us” section below or with a supervisory authority.
7. OPERATING GLOBALLY & INTERNATIONAL TRANSFERS
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Restaurome Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Restaurome Account, please contact us following the instructions in the Contact Us section below.
10. CONTACT US
Restaurome UG, Schillerstr. 41a, 84544 Aschau, Germany