Welcome to Azumi Limited Group’s Privacy Policy.
What does this Privacy Policy Cover?
Azumi respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data in your dealings with us and your use of our websites (“Sites”) and tell you about your privacy rights and how the law protects you.
With that in mind, this Privacy Policy is designed to describe:
- Who we are and how to contact us.
- Your rights relating to your Personal Data.
- Marketing communications preferences.
- What Personal Data we collect.
- How we use your Personal Data and why.
- What happens when you do not provide necessary Personal Data?
- Personal Data from Third Party Sources.
- How we use cookies and other tracking or profiling technologies.
- Who we share your Personal Data with.
- How we keep your Personal Data secure.
- How long we store your Personal Data.
- Our policy on children.
- Third party links.
This Privacy Policy aims to give you information on how Azumi collects and processes your Personal Data through your use of our Sites, including any data you may provide through our Sites, and other dealings with us.
The Privacy Policy is intended to meet our duties of Transparency under the “General Data Protection Regulation” or “GDPR”.
We will post any modifications or changes to this Privacy Policy on this page.
Who we are and how to contact us.
Who we are.
Azumi Limited and its affiliates and associated companies is made up of different legal entities in different jurisdictions across the world (“Azumi Limited Group”). The Azumi Limited Group operates restaurants under the brands Zuma, ROKA, Inko Nito, Oblix and ETARU. More information on Azumi Limited Group is available by contacting us.
This Privacy Policy is issued on behalf of the entire Azumi Limited Group so when we mention “Azumi”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company(ies) in the Azumi Limited Group responsible for processing your Personal Data.
We will let you know which entity(ies) are the Controller(s) (for the purposes of the GDPR) of your Personal Data if you ask us to give you this information by contacting us at the details below.
How to contact us.
You can contact us by emailing: [email protected].
Your rights relating to your Personal Data.
Your rights in connection with your Personal Data
Under certain circumstances, by law you have the right to:
- Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
- Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing 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 Data for direct marketing purposes.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Sites. We will advise you if this is the case at the time you withdraw your consent.
How to exercise your rights
If you want to exercise any of the rights described above, please contact us using the contact details shown above in “Who We Are and How to Contact Us”
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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.
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.
Complaints
If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at: [email protected]
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
Marketing communications preferences.
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 (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or and/or by contacting us at any time using the contact details shown here “Who We Are and How to Contact Us”.
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of restaurant reservations and other interactions where we require your Personal Data to complete your booking or otherwise address your request.
What Personal Data we collect.
All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.
Before you read that table, it might be useful to explain what “Personal Data” is. The GDPR definition of Personal Data can be found here. Essentially, it boils down to: information about an individual, from which that individual is either directly identified or can be identified.
It does not include ‘anonymous data’ (i.e., information where the identity of individual has been permanently removed).
However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).
| Category of Personal Data collected | What this means |
| Identity Data | First name, surname, marital status, title, date of birth and gender. |
| Contact Data | Your home address, work address, billing address, email address and telephone numbers. |
| Financial Data | Your payment card details. Note that we pass any Financial Data we receive from you immediately to our third-party payment processors. We do not store any of your Financial Data. |
| Transaction Data | Details about payments to and from you in respect of meals and gift cards you have purchased from us. |
| Marketing and Communications Data | Your preferences in receiving marketing from us and our third parties and your communication preferences. |
| Profile Data | Includes your contract information, reservations and orders made by you, your interests, preferences, feedback and survey responses. |
| Behavioural Data | Inferred or assumed information relating to your behaviour and interests based on your online activity on our sites and third party platforms and/or based on your reservation and order history. |
| Usage Data | Includes information on how you use our website, products and services. |
| Technical Data | 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 this website or use our services. |
| Allergy and Preferences Data | Information about food allergies, intolerances and/or other health conditions, and information relating to any other preferences you may have. |
Aggregated Data
We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute considered Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Behavioural Data to calculate the percentage of users accessing a specific Site 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.
Special Categories of Personal Data
The GDPR defines “Special Categories of Personal Data” to include 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. As noted above, we may collect and use Allergy and Preferences Data that you provide to us, which may constitute Special Categories of Personal Data, in order to provide our services to you. We do not otherwise collect any Special Categories of Personal Data unless you provide your explicit consent to us to do so. We do not collect any information about criminal convictions or offences.
How we use your Personal Data and why.
We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.
What is our “legal basis” for processing your Personal Data?
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:
- Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
Generally we do not rely on your Consent as a legal basis for using your Personal Data other than in the context of direct marketing communications.
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.
| Purpose | Category(ies) of Personal Data involved | Why do we do this | Our legal basis for this use of data |
| Reservations/ Bookings | • Identity Data • Contact Data • Financial Data • Transaction Data • Marketing and Communications Data |
To secure and manage customer reservations. | Contractual Necessity. |
| Leads / Enquiry | • Identity Data • Contact Data |
To contact the person who has shown interest with us in booking a private dining event | Contractual Necessity. |
| Marketing | • Identity Data • Contact Data • Marketing and Communications Data |
To send you newsletters and offers which we think may be of interest to you. | Consent. We obtain opt-in consent to send marketing communications to you. |
| To process payments for gift cards | • Identity Data • Contact Data • Financial Data • Transaction Data |
To process and deliver your order. | Contractual Necessity. |
| To process advance payments for bookings | • Identity Data • Contact Data • Financial Data • Transaction Data |
To process your order to secure a reservation or to pay, or part pay, for a reservation in advance and allocate such payments correctly. | Contractual Necessity. |
| To improve our Sites | • Behavioural Data • Technical Data |
To monitor use of our Sites, to improve our Sites and to help operate our Sites more efficiently, and to improve your experience on our Sites. | Legitimate Interests. We have a legitimate commercial interest in ensuring that our Sites operate as efficiently as possible and that we improve our Sites based on information we learn from our users’ use of our Sites. |
| To provide your order to you, taking your food allergies, intolerances and preferences into account | • Allergy and Preferences Data | To ensure that we take into account information about your food allergies, intolerances and/or preferences, including when making your reservation and when preparing and delivering your order to you. | Explicit Consent. We obtain your explicit consent to use data relating to your food allergies and intolerances. Legitimate interests. We have a legitimate interest in taking your food preferences into account when preparing and delivering your order to you, to ensure that you are satisfied with the services you receive from us. |
| To manage our relationship with you including asking you to leave a review or take a survey | • Identity Data • Contact Data • Profile Data • Marketing and Communications Data |
To grow and develop our business and achieve high standards of customer satisfaction. | Legitimate interests. We have a legitimate interest in keeping our records updated and to study how customers use our products/services |
What happens when you do not provide necessary Personal Data?
Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Sites).
In this case, we may have to stop you using our Sites but we will notify you if this is the case at the time.
Personal Data from Third Party Sources
In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.
| Third party data source | Publicly available? | Category(ies) or other types of personal data received. |
| Online booking platforms | No | • Identity Data • Contact Data • Transaction Data |
| Gift card purchase platform | No | • Identity Data • Contact Data • Transaction Data |
| Analytics providers | No | • Behavioural Data • Technical Data |
How we use cookies & other tracking or profiling technologies.
Cookies.
What are cookies?
We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Sites.
We use two broad categories of cookies:
- first party cookies, served directly by us to your computer or mobile device; and
- third party cookies, which are served by our partners or service providers on our Sites.
Cookies we use
Our Sites use the following categories of cookies for the purposes set out in the Table A below. Table B details all cookies that can be utilised across our sites depending on the preferences set by you upon your first visit.
TABLE A
| Type of cookie | Purpose |
| Necessary Functional and performance related cookies | These cookies are essential to provide you with services available through our Sites and to enable you to use some of its features. These cookies allow our Sites to remember choices you make when you use our Sites, such as remembering your language preferences. |
| Not Necessary Statistics and Analytics | These cookies are used to collect information about traffic to our Sites and how users use our Sites. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Sites. The information collected is aggregated and anonymous. It includes the number of visitors to our Sites, the websites that referred them to our Sites, the pages they visited on our Sites, what time of day they visited our Sites, whether they have visited our Sites before, and other similar information. We use this information to help operate our Sites more efficiently, to gather broad demographic information and to monitor the level of activity on our Sites.
We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Sites work. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies You can find out more about how Google protects your data here: https://policies.google.com/privacy?hl=en |
| Not Necessary Social Media Cookies | These cookies are used when you share information using a social media sharing button or “like” button on our Sites or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this. |
| Meta Ad pixels | These cookies are used when you click an ad using Meta websites (Like Facebook and Instagram) These website will record your activity, visit & conversion if made. https://www.facebook.com/business/tools/meta-pixel You can find how Meta protects your data https://www.facebook.com/privacy/policy/ |
TABLE B
| Category | Name | Provider | Purpose |
|---|---|---|---|
| Essential | test_cookie | Used to check if the users browser supports cookies. | |
| CookieConsent | Cookiebot | Stores the users cookie consent state for the current domain | |
| SESS# | Sevenrooms | Preserves users states across page requests. | |
| __cf_bm | fonts.net | This cookie is used to distinguish between humans and bots | |
| Statistics | _ga | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | |
| _gat | Used by Google Analytics to throttle request rate | ||
| _gid | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | ||
| collect | Used to send data to Google Analytics about the visitors device and behaviour. Tracks the visitor across devices and marketing channels. | ||
| vuid | Vimeo | Collects data on the users visits to the website, such as which pages have been read. | |
| Marketing | Tr | Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. | |
| _fbp | Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. | ||
| pum_alm_first_activity | inkonitorestaurant.com | Used in context with pop-up advertisement-content on the website. The cookie determines which ads the visitor should be shown, as well as ensuring that the same ads does not get shown more than intended. | |
| pum_alm_last_activity | inkonitorestaurant.com | Used in context with pop-up advertisement-content on the website. The cookie determines which ads the visitor should be shown, as well as ensuring that the same ads does not get shown more than intended. | |
| pum_alm_pages_viewed | inkonitorestaurant.com | Used in context with pop-up advertisement-content on the website. The cookie determines which ads the visitor should be shown, as well as ensuring that the same ads does not get shown more than intended. | |
| pagead/landing [x2] | Collects data on visitor behaviour from multiple websites, in order to present more relevant advertisement - This also allows the website to limit the number of times that they are shown the same advertisement. | ||
| ads/ga-audiences | Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitors online behaviour across websites. | ||
| pagead/1p-user-list/# | Tracks if the user has shown interest in specific products or events across multiple websites and detects how the user navigates between sites. This is used for measurement of advertisement efforts and facilitates payment of referral-fees between websites. | ||
| _gcl_au | Google Tag Manager | Used by Google AdSense for experimenting with advertisement efficiency across websites using their services. | |
| ads/ga-audiences | Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitors online behaviour across websites. |
Disabling cookies
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Apart from those cookies that are necessary, all other cookies will only be deployed in accordance with the site you are visiting and the preferences that you have set.
If you reject all cookies via your browser, which includes the necessary cookies, you may experience some inconvenience in your use of our Sites. For example, our Sites not remembering your language setting.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk
You can also prevent the use of Google Analytics relating to your use of our Sites by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
Who we share your Personal Data with.
We may share your personal data with the parties set out below for the purposes set out in the table at “How we use your Personal Data and why.” above:
- Payment systems, to process payments via 3rd party platforms in a PCI compliant manner
- Reservations Platforms, to help manage our bookings and reservations process.
- Marketing Digital Platforms, to administer our marketing communications with customers who have opted-in to receive such communications from us
- Azumi Group Restaurants outside the UK and the Reservations Platforms they use, to further our business purposes
- Other service providers based in India and in the countries in which the Azumi Group operates restaurants who provide IT and other administration services.
- Professional advisers including lawyers, bankers, auditors and insurers based in India and in the countries in which the Azumi Group operates restaurants who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the countries in which the Azumi Group operates restaurants who require reporting of processing activities in certain circumstances.
Data transfers
We share your Personal Data with our affiliated companies within the Azumi Group and certain external third parties who are based outside of the UK. Any processing of your Personal Data by these parties will involve an export of your Personal Data outside of UK.
We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the UK and European Commission. For further details, see https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-transfers-after-uk-exit/
- Where we use service providers outside those countries that are not deemed as adequate, we may use specific contracts approved by the UK and European Commission, which give Personal Data the same protection it has in the UK. For further details, see https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-transfers-after-uk-exit/
How we keep your Personal Data secure.
We have put in place appropriate technical and organizational security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We store all the personal information you provide on secure password and firewall protected servers.
We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
How long we store your Personal Data.
We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above at “How we use your Personal Data and why.”, unless a longer retention period is required by law (for example for regulatory purposes).
We will only retain your personal data for as long as 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 in respect to our relationship with you.
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 or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting.
Our policy on children.
Our Sites are not intended for children below 16 and we do not knowingly collect data relating to children via our Sites.
However, you may provide us with Identity Data relating to children where, for example, you make a booking for a child’s birthday party, and we may store this information on your account. In providing us with this Identity Data, you are agreeing that you hold parental responsibility for that child or that you have been properly authorised by the holder of parental responsibility for the child to give us this Identity Data to use for these purposes.
Third party links.
Our Sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your Personal Data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every site you visit.
Azumi Limited
