Introduction

This privacy notice (“Notice”) contains important information on who we are, on how and why we collect, store, use and share personal data, and on your rights in relation to your personal data.

It is important that you read this Notice, together with any other privacy policy or fair-processing policy that we may provide on specific occasions, so that you are fully aware of how and why we use your personal data. This Notice supplements our other notices and policies and does not override them.

This Notice and our website,https://www.cando-restaurant.com  (“Website”), are not intended for use by children and we do not knowingly collect personal data in relation to children.

1. Who are we?

We are Cando Restaurant LLC (referred to from now as “we” and via similar words, such as “our”). We are a company incorporated in Dubai, UAE under company number 570274, and with our registered office address at Sheikh Rashid Bldg. Baniyas Road,Behind Twin Towers, Deira, DubaiUnited Arab Emirates

2. How can you get in touch?

If you would like to contact us in relation to this Notice or your personal data, you may do so by:

• sending an email to info@cando-restaurant.com
• submitting an enquiry at info@cando-restaurant.com 

3. Our key data principles

We live by the following principles:

• We do not collect more personal data than we need
• When we collect it, we do not use personal data more widely than is necessary
• We safeguard your personal data

 

4. What is “personal data”?

Any information that relates to an identified, or identifiable, living person is personal data.

You are identifiable if it is reasonably likely that your identity could be inferred from that data alone or from that data in combination with other information.

5. When do we collect personal data?

We collect personal data at the following times:

Direct interaction with you. For example, when you:

• make a booking
• visit and purchase items or services at or from our restaurants
• register to receive emails or newsletters from us (relating to our products, services, discounts, offers, competitions or events)
• take part in competitions or contact us via social media or other means
• connect to our Wi-Fi networks

• buy and/or use a Cando Restaurant Vouchers or Membership
• contact us (for example, with a question or to provide feedback)

 

Note on CCTV: for your safety, and for that of our other customers and our staff, we have CCTV at our restaurants. This is used proportionately, and naturally we do not make recordings in private places such as our washroom facilities. The CCTV data is deleted without undue delay, and we limit access to the data to a small number of people who have a legitamate reason to have such access.

 

From third parties. For example, when you:

• mention us in publicly available sources such as non-private Facebook, Twitter and Instagram posts
• are one of our business partners and we receive information, for example, when you are copied on an email. (Note: while this Notice will primarily be of interest to consumers, it is equally relevant to individuals working at our suppliers and at other businesses with which we have a relationship.)

 

From automated technologies. As you use the Website or our App, we automatically collect Technical Data (see definition in section 6 below) about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. 

6. What types of personal data do we collect?

It will depend on circumstances, but the types of personal data we may collect include:

• Identity Data - such as your name, title, date of birth, and gender and when you visit our premises, your image on CCTV
• Contact Data - such as your billing address, delivery address, email address, mobile number, current location (when you use the location function on our Website or App).
• Financial Data - namely your payment card details

• Transaction Data - namely details about payments you make to us (and any refunds given), products and services you have purchased from us, and the outstanding balance.
• Technical Data - including your internet protocol (IP) address, 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 the Website or App.
• Profile Data - including your purchases or orders, any feedback and survey responses that you provide, and in some cases biographical information that you provide
• Usage Data - including information about how you use our website, products and services
• Marketing Data - including your opt-in/opt-out preferences in relation to electronic marketing

 

We also collect Aggregated Data, which is large-scale statistical data. We use it for matters such as understanding what percentage of Website users look at a particular page. Aggregated Data is not personal data, as it will not reveal your identity. However, if we combine Aggregated Data with your personal data, so that you can be identified, we will treat the combined data as personal data and use it in accordance with this Notice.

We do not ordinarily collect any Special Categories of personal data about you (this is the legal term describing 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. If we ever do collect it – for example, if you make an accident report and provide health data to us – we will treat it lawfully. We may ask about allergies at a restaurant so that we can help safeguard customers, but we do not record such information in a way that would identify you.  

Note: do you have to provide personal data?

In general, no – although in some situations we may be unable to provide a service if you do not. If we need to collect personal data by law, or to perform a contract with you, and you do not provide it, we may be unable to proceed. An example of this would be where we need your delivery address or card details.

7. How do we use your personal data?

We use your personal data to perform contracts with you, when our legitimate interests allow us to, and to comply with the law.

Whenever we use your personal data, we need what is known as a “lawful basis”. These are prescribed by law and are limited in number. Please see the glossary below for more about lawful bases. Sometimes we may have more than one lawful basis for the same processing activity.

A summary of our use of your personal data, and the lawful bases on which we rely, is as follows:

Activity	Types of personal data	Lawful basis (or bases)
Providing you with products and services	Identity Contact	Performing a contract with you
Taking a pre-authorisation from your card when you make a booking, to cover “no-shows”	Identity Contact Financial	Performing a contract with you Legitimate interests
Processing payments and refunds	Identity Contact Financial Transaction	Performing a contract with you Legitimate interests
Registering, and processing information about, your Loyalty rewards	Identity Contact Financial Transaction	Performing a contract with you Legitimate interests
Communicating with you about this Notice	Identity Contact	Legal obligation Legitimate interests
Administering your involvement in competitions and special offers	Identity Contact Profile Usage	Performing a contract with you Legitimate interests
Asking and enabling you to leave a review or complete a survey	Identity Contact Profile Marketing	Performing a contract with you Legitimate interests Legal obligation
Sending marketing emails or SMS	Identity Contact	Consent
Responding to your questions or complaints	Identity Contact Financial Transaction Profile	Performing a contract with you Legitimate interests
Personalising your Website, App and in-restaurant experience	Identity Contact Profile Usage Marketing Technical	Legitimate interests
Operating, evaluating and improving our business and the Website or App	Technical Usage	Legitimate interests
Protecting against fraud and other criminal activity	Identity Contact Financial Transaction Technical Profile Usage	Legitamate interests Legal obligation
Participating in legal action	Identity Contact Financial Transaction Profile Usage Marketing	Legitimate interests Legal obligation
Evaluating your job application	Identity Contact Profile	Legitimate interests Legal obligation

Consent

We generally do not rely on consent as a legal basis for processing your personal data, although we will get consent before sending direct-marketing communications to you via email or SMS.  

You have the right to withdraw consent to such e-marketing at any time. This will not affect the lawfulness of marketing that took place prior to the time when we action your withdrawal of consent.

8. How do we share your personal data?

Business partners

Like most businesses, we rely on partners to provide some of the services that we offer to you. Our current partners include the following:

Partner name	Role	Date collected
Pixel Point POS	Electronic point-of-sale system, enabling us to sell to you	Name Customer ID Restaurant visited Date of visit Email address
Wireless Social	Wifi provider	Name Email address WiFi user ID Restaurant visited
Cyber Pixel	Provider of the Loyalty rewards pointing system on our App	Name Email address Gift card number Balance on the card
My Menu	Digital Menu and Feedback tool for customers	Name Email Contact No. Restaurant reviewed Date and time of visit Substance of your review

 

Other companies in our group

Your personal data may, where necessary, be collected, stored or used by other companies within our group. 

CCTV

We share CCTV data with our partner responsible for the maintenance and storage of the information (and where appropriate, with law-enforcement agencies)

Law-enforcement agencies

We may be required to share personal data with a law-enforcement agency (or similar regulatory body) in connection with an investigation.

Professional advisers

We may, where necessary, share your personal data with our lawyers, accountants or other professional advisers where we consider it necessary.

9. How long will your personal data be kept?

We retain your personal data for no longer than is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data (and whether we can achieve those purposes through other means), and the applicable legal, regulatory, tax, accounting and other requirements.

10. Marketing

We may store your contact details, and carry out marketing profiling activities, for direct electronic marketing purposes. If you have given your consent, we may contact you about our products or services that may be of interest to you.

If you prefer not to receive any direct electronic marketing communications from us, you can opt out at any time by sending an email to marketing@cando-restaurant.com. We will also give you the option to opt out each time we send a marketing communication by electronic means.

Opting out will not affect our ability to use your personal data for the other purposes set out in this Notice, and it will not affect the lawfulness of electronic marketing carried out prior to the time when we actioned you opt-out request.

11. 11. Keeping your personal data secure

We have appropriate security measures in place to prevent personal data from being accidentally lost or used or accessed in an unauthorised way.

12. 12. Your information rights

You have certain rights in relation to your personal data. Please see the “Your Legal Rights” section of the glossary below for more information.

We may first need to verify your identity (and, in certain cases, verify that you have authority to make the request on another person’s behalf).

In general, we try to deal with genuine requests within one month. Occasionally it may take longer, in which case we will let you know in advance.

You do not have to pay a fee to exercise these rights. However, if your request is excessive, repetitive or unfounded, we may charge a reasonable fee or refuse to comply with your request.

14. Cookies

Our website uses cookies. We use cookies to provide you with a great experience and to help our website run effectively.

15. Third-Party links

This Website or App may include links to websites, plug-ins and applications that are owned by someone other than us. Clicking on those links may allow the owner to collect or share your personal data. We have no control over other sites, are we not responsible for their privacy statements. We encourage you to read the privacy policy of every website you visit.

16. Changes to this Notice

We may change this Notice from time to time. Please check this Notice on our Website regularly to ensure you are aware of the most recent version.

17. How to complain

In the first instance, we hope you raise any issues with us directly – in almost all situations, matters can be resolved very simply. To do this, please use the details set out in section 2 above. 

GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best 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. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.