PRIVACY POLICY

• This Privacy Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer it and/or provide you with access to it.
• This Privacy Policy is intended to help you make informed decisions when using the Site and our Services. Please take a moment to read and understand it. Please note that it should be read in conjunction with our website Terms and Cookie Policy.
• Please also note that this Privacy Policy only applies to the use of your personal information obtained by us, it does not apply to your personal information collected during your communications with third parties who collect it for their own purposes.

ASK Italian Restaurants Limited is the data controller responsible for your personal information and is registered at the UK Information Commissioner’s Office with registration number: ZA840237.

ASK Italian Restaurants Limited is an English company with registered company number: 10406599 and whose registered office is at 3rd Floor Capital House, 25 Chapel Street, London NW1 5DH.

ASK Italian Restaurants Limited is a trading brand of Azzurri Central Limited which is an English Company with registered company number 12457130 and whose registered office is at 3rd Floor, Capital House, 25 Chapel Street, London NW1 5DH.

Azzurri Central Limited provides business services to ASK Italian Restaurants Limited.

We collect and maintain personal information that you voluntarily submit to us during your use of the Site and/or our Services. For example, when you request to book a table, purchase a gift card, download a voucher, log on to our Wi-Fi in our restaurants, order a food collection, or pay for your table bill using a mobile app.

In providing the Services, we may collect the following types of personal information:

• Title, first name and surname
• Email address
• Contact telephone number
• Number of children aged under 12
• Address or geographic location
• Payment information
• Gender
• Device used and basic Facebook profile (where logging onto Wi-Fi)
• Birthday

What is our legal basis?

It is in our legitimate interest to use your personal information to provide the services you have requested from us and where it is necessary for the performance of any contract that we have with you.

Our Site and our restaurants allow you to request information about our products and Services or make a complaint about any of the Services. Your name and contact information may be requested in each case, together with details of other personal information that is relevant to your customer service enquiry. This information is used in order to enable us to respond to your request or complaint.

What is our legal basis?

It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best customer service we can to you.

From time to time we will ask you to provide feedback about our products and services in the form of a survey. We collect the following types of personal information:

• First name and surname
• Email address
• Telephone number
• Address

We use this information to help us improve the quality of service provided by our staff and in our restaurants. We also use your feedback to monitor the quality of our products and services and to assist with the selection of future product and services.

What is our legal basis?

It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.

We analyse your contact details with other personal information that we observe about you from your interactions with our Site, our email communications to you and/or with our products and services in our restaurants, such as the products and services you have purchased or viewed, or from your use of our restaurant Wi-Fi.

We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across ASK Italian Restaurants, for example your past restaurant bookings and information requests. For this purpose we may also combine the data that we collect directly from you with data that we obtain from third parties.

Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile. This includes the following:

• An IP address to monitor Site traffic and volume
• A session ID to track usage statistics on our Site
• Information regarding your personal or professional interests, demographics, buying habits, experiences with our products and contact preferences
• Technology providers you use to see what email systems our customers use to read our emails, so that we can make sure they receive the best experience
• Location and how often our emails are opened. This enables us to measure how our restaurants are performing in relation to where our customers are based

Our web pages and e-mails contain certain Tags such as “cookies” “web beacons” or “pixel tags” (“Tags”). Tags allow us to track receipt of an e-mail to you, and/or to view your web page and email interactions. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag.

In some of our e-mail messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

To provide you with more choice about your Tag preferences, we are using Civic. You can ‘Allow All’, or ‘Manage Settings’ based on their categories:

• Essential Cookies (Can not be blocked as required for the website to function)
• Performance/Analytics Cookies
• Targeting Cookies

For more information on these choices, please visit our Cookie Policy.

We also use this information for marketing purposes (see the Marketing section below for further details).

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other customers.

We will only use your location data for customer insight purposes where we have your consent to do so.

We use your personal information (including details of our offers, newsletters and events), where you have consented to receive such marketing communications or where we have another lawful basis to do so.

Our email marketing will include personalised and non-personalised email marketing. Personalised email marketing is marketing which has been specifically tailored to you. For example, our personalised email marketing will feature our products and services that we think are most likely to appeal to you. Non-personalised marketing is marketing about our products and services generally and is not tailored to any particular individual.

Where we are sending you personalised email marketing, we will also use information that we observe about you from your interactions with our Site, and our email communications to you and/or with our products and services in our restaurants (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected).

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have an alternative lawful right to do so.

We use your email address to serve you with online advertising (including on social media channels) operated by Facebook, Instagram, Google, TikTok, Twitter, Snapchat, LinkedIn and Pinterest where you are a registered user of such services.

Our online and social advertising will include personalised and non-personalised remarketing. Personalised advertising is marketing which has been specifically tailored to you. For example, our personalised remarketing will feature our products and services that we think are most likely to appeal to you. Non-personalised advertising is marketing about our products and services generally and is not tailored to any particular individual.

Where we are undertaking personalised online advertising, we will also use information that we observe about you from your interactions with our Site, and our email communications to you and/or with our products and services in our restaurants (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected).

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

Where you are a registered user of Facebook, Instagram or of a Google service, we will use your email address in an encrypted format to enable Facebook and Google to find other registered users of their services that share similar interests to you based on:

• information that we observe from your interactions with our Sites, our email communications to you and/or with our products and services in our restaurants (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected); and
• the information Facebook and/or Google hold about you.

We do this using Facebook Lookalike Audiences and Google Similar Audience respectively. Please note that such activity is subject to the privacy choices you have elected to make on such services.

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes

From time to time we run prize draw promotions or competitions either online or in our restaurants which you can enter or games or quizzes on our Site or in our restaurants that you can play. We may collect the following types of personal information:

• Title, first name and surname
• Email address
• Social media handle (if relevant)
• Contact telephone number
• Number of children aged under 12
• Address
• Information on any of your personal preferences that we may ask you about
• Birthday

What is our legal basis?

It is in our legitimate interest to use your personal information to enable you to participate in any prize draws, competitions, games or quizzes and where it is necessary for the performance of any contract that we may have with you.

From time to time we offer a refer friend scheme online. This allows you to earn rewards when you refer a friend. Please note that you should only refer friends who are happy to hear from us and have confirmed that to you. We collect the following personal information about you when you register to refer a friend:

• First name and surname
• Email address
• Postcode

What is our legal basis?

We process your personal information where you have consented to us using such information for the purpose of your participation in the “Refer a Friend” scheme.

We use your personal information for the following business administration and legal compliance purposes:

• To comply with our legal obligations;
• To enforce our legal rights;
• Protect rights of third parties; and
• in connection with a business transition such as a merger, acquisition by another company or sale of all portion of our assets.

What is our legal basis?

Where we use your personal information in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.

Where we share your sensitive personal information, we shall obtain your consent to do so.

We use your personal information (e.g. name, job title, contact information including email address, curriculum vitae, your education, employment history and similar matters and similar information that you may provide to us and any other information relevant to potential recruitment) for the following recruitment purposes:

• To assess your suitability for any position for which you may apply to us whether such application has been received by us online, via email or by hard copy or in person application or through a third party recruitment agency.
• To review our equal opportunity profile in accordance with applicable legislation, and we do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment related decisions are made entirely on merit.

What is our legal basis?

Where we use your personal information in connection with recruitment it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make the best recruitment decisions for ASK Italian Restaurants. We will not process any special data except where we are able to do so under applicable legislation or with your explicit consent which shall be obtained at the time we collect your personal information following the instructions provided

REASON: Fulfilment of services (e.g. to enable you to book a restaurant table, verify any card payments, deliver products, provide you with WiFi in our restaurants, send to you any purchased gift cards or provide the Site).

REASON: Customer services (e.g. if you send us a query or make a complaint or if we ask for your feedback on our products or services).

REASON: Customer insight and analysis (e.g. to analyse your interactions with our Site, email communications to you and/or with our products and services in our restaurants).

REASON: Marketing (e.g. to send you email marketing or serve you with online advertisements).

REASON: Competitions and games (e.g. running prize draws or competitions for you to enter).

REASON: Refer a friend (e.g. where you can spread our offers).

REASON: Business administration and legal compliance (e.g. the boring, but important stuff such as complying with any legal obligations we may have).

REASON: Recruitment (e.g. to hire great people to join our team).

Your browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.

We do not monitor, control, or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.

This Privacy Policy applies solely to personal information collected by us through our Service and does not apply to these third party websites and third party service providers.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

• unauthorised access;
• improper use or disclosure;
• unauthorised modification; and
• unlawful destruction or accidental loss.

All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.

If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

You can ask us to stop processing your personal information, and we will do so, if we are:

• relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing;
• processing your personal information for non-personalized direct marketing.

You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.