Privacy notice1

Introduction

1.1

This privacy notice (notice) applies to the processing of personal data by JKS
Restaurants Holdings Limited (company number 09667844) and member of the JKSGroup (as set out in Section 1.4) in connection with the processing of personal data on
this website, including any personal data you may provide though the use of thewebsite when you sign up to receive newsletters, make online booking reservations at
our restaurants, buy gift cards or use our contact forms (referred to through this noticeas this Website).

1.2

JKS Restaurants Holdings Limited is registered with the Information Commissioner's
Officer with registration number ZA243678.

1.3This Website is not intended for children and we do not knowingly collect personal data
relating to children.

1.4

References in this notice to “you” or “your” are references to individuals who use thisWebsite and references in this notice to “JKS”, “we”, “us” or “our” are references to
JKS Restaurants Holdings Limited and the other restaurants in our group. Our Group isdefined as the restaurants trading under the following names: Trishna, Gymkhana,
Hoppers, Motu Indian Kitchen, Brigadiers, Bubbledogs, Kitchen Table, BAO, Lyle's, XU
and Sabor (Group). A full list of the legal entity names and addresses are available
from info@jksrestaurants.com.

1.5

This notice is issued on behalf of JKS Restaurants Holdings Limited as controller.
Unless we notify you otherwise at the time your personal data is collected, JKS
Restaurants Holdings Limited is the controller for your personal data.

2

Purpose of this noticeThis notice aims to give you information about how JKS collects and processes yourpersonal data when you use this Website. It is important that you read this notice
together with any other notices we may provide on specific occasions when we arecollecting or processing your personal data, so that you are fully aware of how and why
we are using your personal data. This notice supplements the other notices and is notintended to override them.

3

How to make a complaint about the use of your personal data by us
If you have any concerns or questions about this notice, including any requests toexercise your rights, please contact us using the contact details set out below:
A: JKS Restaurants Holdings Limited, 67-69 George Street, London, W1U 8LT
E: info@jksrestaurants.com
T: +44 (0)20 3011 1021
If you are unhappy with how we process your personal data you can contact theInformation Commissioner's Office to make a complaint directly (www.ico.org.uk).
However, we would encourage you to contact us in the first instance so we may resolve
any issues you have.

4

Changes to the notice or to your personal data

4.1

This notice takes effect from 25 May 2018. We will inform you of any changes made tothis notice by posting these on this Website or emailing or posting a copy to you.

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4.2

It is important that the personal data we hold about you is accurate and current. Pleasekeep us informed if your personal data changes during your relationship with us. If you
wish to update your personal data, please contact us at info@jksrestaurants.com.

5

Third party links

5.1This Website may include links to third-party websites (including social media sites),plug-ins and applications. Clicking on those links or enabling those connections may
allow third parties to collect or share personal data about you. We do not control thesethird-party websites and are not responsible for their privacy statements. When you
leave this Website, we encourage you to read the privacy notice of every website you
visit.

6

The personal data we collect about you

6.1

Personal data includes any information about an individual from which that person canbe identified. It does not include personal data where the identity has been removed(anonymous data).

6.2

Please note that we may process your personal data without your knowledge orconsent where this is required or permitted by law.

6.3

We collect, use and share aggregated data such as statistical or demographic data forany purpose. Aggregated data may be derived from your personal data but is notconsidered personal data in law as this data does not directly or indirectly reveal youridentity. For example, we may aggregate your Usage Data to calculate the percentage
of users accessing a specific website feature. However, if we combine or connect
aggregated data with your personal data so that it can directly or indirectly identify you,we treat the combined data as personal data which will be used in accordance with thisnotice.

6.4

We do not collect any special categories of personal data about you through thisWebsite (this includes details about your race or ethnicity, religious or philosophicalbeliefs, 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.

6.5

We collect, use, store and transfer different kinds of personal data about you. We havegrouped together the following categories of personal data to explain how this type of
information is used by us. These terms are used throughout this notice:Contact Data

including your address, email address andtelephone numbers

Financial Data

includes bank account and payment card details

Identity Data

including your first name, last name and title

Marketing andCommunications Data

including your marketing and communicationpreferences

Profile Data

including your purchases or reservations made byyouTechnical Data

includes information collected when you access thisWebsite your internet protocol (IP) address, browser
type and version, time zone setting and location,browser plug-in types and versions, operating

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system and platform and other technology on thedevices you are using

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Transaction Data

includes details about payments from you and otherdetails of products you have purchased from us forexample, gift cards

Usage Data

information about how you use this Website

If you fail to provide personal data to us
Where we need to collect personal data by law, or under the terms of a contract wehave with you and you fail to provide that data when requested, we may not be able toperform the contract we have or are trying to enter into with you (for example, toprovide you with a gift card you have requested to purchase). In this case, we may
have to cancel your purchase with us or decline to enter into a contract with you but wewill notify you if this is the case at the time.

8

How your personal data is collected

8.1

We use different methods to collect personal data from and about you, including
through the channels set out below.
8.1.1

Direct interactions: You give us your Contact Data, Identity Data andProfile Data directly, for example, when you:(a)make a reservation for one or our restaurants who are part of our Group;(b)

submit a contact form on this Website; or(c)visit one of our restaurants and sign up to use the free Wifi provided(please note additional terms will also be provided at the point you sign-up
to use our Wifi); or(d)request marketing to be sent to you for example a newsletter or special
offers.

8.1.2

When you visit some of our websites you will have the ability to purchase agift card and /certain products and gifts through those websites. To theextent that you are purchasing any gift cards, products or services throughthis Website, we will also use your Financial and Transaction Data.

8.2

Automated technologies or interactions: We receive Technical Data about yourequipment, browsing actions and patterns. We collect this personal data by using
cookies, server logs and other similar technologies. Please see our Cookie Policy forfurther details of the information collected.

8.3

Third parties or publicly available sources: We receive Technical Data fromanalytics providers for example Google Analytics.

9

How we use your personal data

9.1

We will only use your personal data when the law allows us to. Most commonly, we will
use your personal data in the following circumstances:
9.1.1

Where we need to perform the contract we are about to enter into or
have entered into with you (for example to fulfil on the purchase of a giftcard through this Website or to book a table for you).

9.1.2

Where it is necessary for our legitimate interests (or those of a third
party) and your interests and fundamental rights do not override those46522267.1

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interests (for example it is within our legitimate interests to know who hasmade a booking at one of our restaurants).
9.1.3

Where we need to comply with a legal or regulatory obligation towhich we are subject.

9.1.4

In certain circumstances we may rely on your consent to process yourpersonal data, for example for certain email marketing.

9.2

Section 11 below sets out further information about the legal bases that we rely on toprocess your personal data.

9.3

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).

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How we use Cookies on this Website
More information about Cookies and how we use these on this Website can be found
here.

11

How we will use your personal data

11.1

We set out below, in a table format, a description of the ways in which we use yourpersonal data and the legal bases we rely on to do so. Where appropriate, we havealso identified our legitimate interests in processing your personal data.

11.2

We may process your personal data for more than one legal basis depending on thespecific purpose for which we are using your personal data. Please contact us at
info@jksrestaurants.com if you need further details about the specific legal basis weare relying on to process your personal data where more than one legal basis has been
set out in the table below.
Purpose and/or
activityType of data

Legal basis for processing

To notify you aboutchanges to thisWebsite, our terms andconditions or privacy
notice• Contact Data

• Necessary to comply with a legal
or regulatory obligation

To manage ourrelationship with you
which will include
notifying you of any
changes to terms andconditions or privacy
policy• Contact Data

• Identity Data
• Profile Data

• Identity Data
• Profile Data
• Technical Data
• Usage Data

To administer andprotect our businessand this Website(including
troubleshooting, data
analysis, testing,system maintenance,

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4• Necessary for our legitimate
interests: to ensure that you havethe most up-to-date terms
regarding the use of this Website
and to ensure that this Website isfunctioning as intended and if thiscan be improved• Necessary to comply with a legal
or regulatory obligation• Necessary for our legitimate
interests: ensuring the efficientand secure running of thisWebsite, including throughmaintaining information
technology services, network anddata security and improving

Purpose and/or
activityType of data

Legal basis for processing• Contact Data

• Necessary for our legitimate
interests: reviewing how visitorsand customers use this Website,
improving this Website andidentifying ways to grow ourbusiness

support, reporting andhosting of data)
To deliver relevant
website content to you
and measure orunderstand theeffectiveness of thecontent we serve to you• Identity Data
• Profile Data
• Technical Data
• Usage Data

To make suggestions
and recommendations
to you about services orcontent that may be ofinterest to you• Contact Data
• Identity Data

• Necessary for our legitimate
interests: developing our services
and growing our business• Marketing andCommunications
Data• Profile Data
• Technical Data
• Usage Data

To use data analytics to
improve this Website,
our services, marketing,customer relationships
and experiences• Technical Data

To process any
purchase from thisWebsite for example giftcards and products• Identity Data

• Usage Data

• Contact Data

• Necessary for our legitimate
interests: reviewing how visitorsand customers use this Website,
improving this Website andidentifying ways to grow ourbusiness• Necessary to perform a contract:
to provide you with a gift card or
products once purchased.

• Financial Data
• Transaction Data
• Profile Data
• Usage Data
• Marketing andCommunications
Data

To monitor and manage
any reservation you
make at one of ourrestaurants• Identity Data
• Contact Data
• Technical Data
• Profile Data
• Usage Data
• Marketing andCommunications
Data

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5• Necessary for our legitimate
interests: to make a reservation
for you at one of our restaurants
in line with your request andcontact you in regard to yourbooking.

Purpose and/or
activityType of data

Legal basis for processing

If you make areservation for one of
our restaurants for aGroup over 8 people,
we may require a
deposit from you, which
will include us collecting
your Financial Data andTransaction Data

• Identity Data

• Contractual Necessity

If you visit one of ourrestaurants, and sign up
to use the free Wifi
provided• Contact Data

• Contact Data
• Financial Data

• Identity Data
• Marketing andCommunications
Data• Necessary for out legitimate
interests: to monitor who isaccessing our free Wifi service,and how they are using suchservice.

• Technical Data
12

Change of purpose

12.1

We will only use your personal data for the purposes for which we collected it asdetailed in Section 9 and Section 11, unless we reasonably consider that we need touse it for another reason and that reason is compatible with the original purpose. If you
wish to receive an explanation as to how the processing for the new purpose iscompatible with the original purpose, please contact us at info@jksrestaurants.com.

12.2

If we need to use your personal data for an unrelated purpose, we will notify you andwe will explain the legal basis which allows us to do so.

13Marketing and exercising your right to opt-out of marketing

13.1

We strive to provide you with choices regarding certain personal data uses, particularlyaround marketing and advertising.

13.2

We may use your Identity, Contact, Technical Usage and Profile Data to form a view onwhat we think you may want or need, or what may be of interest to you. This is how we
decide which restaurants we believe will be of interest to you.

13.3

You will receive marketing communications from us if you have requested informationfrom us or purchased goods from us and, in each case, you have not opted out ofreceiving that marketing.

13.4

You can ask us to stop sending you marketing messages at any time by logging into
the website and checking or unchecking relevant boxes to adjust your marketing
preferences or by following the opt-out links on any marketing message sent to you.
You can also opt-out by contacting us at any time at info@jksrestaurants.com.Thirdparty marketing
We do not share your personal data with any organisations outside of the Group formarketing purposes. We will get your express opt-in consent before we share yourpersonal data with any company outside of the Group for marketing purposes.

14Disclosures of your personal data

14.1

We may have to share your personal data with the entities and persons set out below
for the purposes for which we collected the personal data, as detailed in Section 9 andSection 11.

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14.1.1

Your personal data will be shared within our Group. We share yourpersonal data between our Group to ensure the efficient operation of theGroup for instance, to provide the highest quality of service across our
restaurants.

14.1.2

Where required, we will disclose your personal data to:(a)any person or entity to whom we are required or requested to make suchdisclosure by any court of competent jurisdiction or by any governmental,
taxation or other regulatory authority, law enforcement agency or similar
body;

(b)

our professional advisers or consultants, including lawyers, bankers,
auditors, accountants and insurers providing consultancy, legal, banking,audit, accounting or insurance services to us; and(c)service providers who provide information technology and systemadministration services to us.

14.1.3

We may share your personal data with persons or entities outside of theGroup to whom we may sell or transfer parts of our business or assets.
Alternatively, we may seek to acquire other businesses or merge withthem. If a change happens to our business, the part of our business that is(as the case may be) sold, acquired or is the merged entity may use yourpersonal data in the same way as set out in this notice.

14.2

We require any person or entity to whom we disclose personal data pursuant to thisSection 14 to respect the confidentiality and security of your personal data and to treat
it in accordance with applicable laws and regulations. We do not allow such recipientsof your personal data to use it for their own purposes, and we only permit them toprocess your personal data for specified purposes and in accordance with our
instructions.

14.3

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

15International transfers

15.1

In some cases, the parties who we use to process personal data on our behalf are
based outside the European Economic Area (EEA), therefore their processing of yourpersonal data will involve a transfer of such data outside the EEA.

15.2

Whenever we transfer your personal data out of the EEA, we ensure a similar degree ofprotection is afforded to it by ensuring at least one of the following safeguards is
implemented:
15.2.1

we will only transfer your personal data to countries that have been
deemed to provide an adequate level of protection for personal data by theEuropean Commission;

15.2.2where we use certain service providers, we may use specific contracts
approved by the European Commission which gives personal data thesame protection it has within the EEA; and15.2.3where we use providers based in the US, we may transfer personal data tothem if they are certified under the EU-US Privacy Shield which requires
certified providers to have in place and maintain a similar level of protection
to the personal data as if it was processed within the EEA.

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15.3

Please contact us at info@jksrestaurants.com if you would like further information
about the specific mechanism used by us when transferring your personal data out of
the EEA.

16

Data security

16.1

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

16.2

We ensure that those who have permanent or regular access to personal data, or thatare involved in the processing of personal data, or in the development of tools used toprocess personal data, are trained and informed of their rights and responsibilities inwhen processing personal data.

16.3

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

17

Data retention

17.1

We will only retain your personal data for as long as necessary to fulfil the purposes wecollected it for. This includes for example the purposes of satisfying any legal,
regulatory, accounting, reporting requirements, to carry out legal work, for theestablishment or defence of legal claims.

17.2

To determine the appropriate retention period for personal data, we consider theamount, nature and sensitivity of the personal data, the potential risk of harm fromunauthorised use or disclosure of your personal data, the purposes for which we
process your personal data and whether we can achieve those purposes through othermeans, and the applicable legal requirements.

17.3

If we have your personal data, and you have not been active on our website for aperiod of 6 months, we will delete your personal data.

17.4

Details of retention periods for cookies on this website are set out in our Cookie Policy.
If you would like to know more about the retention periods we apply to your personaldata, please contact us at info@jksrestaurants.com.

17.5

In some circumstances we may anonymise your personal data (so that it can no longer
be associated with you) for research or statistical purposes in which case we may use
this information indefinitely without further notice to you.

18

Your legal rights

18.1

Under certain circumstances, you have rights under data protection laws in relation to
your personal data. It is the Group's policy to respect your rights and the Group will act
promptly and in accordance with any applicable law, rule or regulation relating to theprocessing of your personal data.

18.2

Details of your rights are set out below:
18.2.146522267.1

right to be informed about how personal data is used – you have aright to be informed about how we will use and share your personal data.
This explanation will be provided to you in a concise, transparent,
intelligible and easily accessible format and will be written in clear and plain
language;8

18.2.2

right to access personal data – you have a right to obtain confirmation ofwhether we are processing your personal data, access to your personal
data and information regarding how your personal data is being used byus;

18.2.3right to have inaccurate personal data rectified – you have a right tohave any inaccurate or incomplete personal data rectified. If we havedisclosed the relevant personal data to any third parties, we will takereasonable steps to inform those third parties of the rectification where
possible;

18.2.4right to have personal data erased in certain circumstances – youhave a right to request that certain personal data held by us is erased.
This is also known as the right to be forgotten. This is not a blanket right torequire all personal data to be deleted. We will consider each request
carefully in accordance with the requirements of any laws relating to theprocessing of your personal data;

18.2.5right to restrict processing of personal data in certain circumstances– you have a right to block the processing of your personal data in certain
circumstances. This right arises if you are disputing the accuracy of
personal data, if you have raised an objection to processing, if processingof personal data is unlawful and you oppose erasure and request restriction
instead or if the personal data is no longer required by us but you require
the personal data to be retained to establish, exercise or defend a legal
claim;

18.2.6right to data portability – in certain circumstances you can request toreceive a copy of your personal data in a commonly used electronic format.
This right only applies to personal data that you have provided to us (forexample by completing a form or providing information through a website).
Information about you which has been gathered by monitoring yourbehaviour will also be subject to the right to data portability. The right todata portability only applies if the processing is based on your consent or if
the personal data must be processed for the performance of a contract andthe processing is carried out by automated means (i.e. electronically);

18.2.7right to object to processing of personal data in certain
circumstances, including where personal data is used for marketing
purposes – you have a right to object to processing being carried out by
us if (a) we are processing personal data based on legitimate interests orfor the performance of a task in the public interest (including profiling), (b) if
we are using personal data for direct marketing purposes, or (c) if
information is being processed for scientific or historical research or
statistical purposes. You will be informed that you have a right to object at
the point of data collection and the right to object will be explicitly brought
to your attention and be presented clearly and separately from any otherinformation; and18.3

You may exercise any of your rights at any using the contact details set out in Section
3. 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.

18.4

We may need to request specific information from you to help us confirm your identityand ensure your right to access your personal data (or to exercise any of your otherrights). 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.

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18.5

We try to respond to all legitimate requests within one calendar month. Occasionally it
may take us longer than one calendar 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.
End of notice46522267.1

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