Bagel Factory Home Menu Orders Locations About Jobs Contacts Privacy Policy INTRODUCTION Welcome to the Great American Bagel Factory Limited privacy notice. The Great American Bagel Factory Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. This privacy notice is provided in a layered format so you can go to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice. 1 | IMPORTANT INFORMATION AND WHO WE ARE Purpose of this privacy notice This privacy notice aims to give you information on how The Great American Bagel Factory Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you make a booking, purchase a gift voucher, register to use our wireless broadband facility, opt in to receive email marketing from us, provide feedback or complete a survey. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. Controller The Great American Bagel Factory Limited is the controller and responsible for your personal data (collectively referred to as “The Great American Bagel Factory Limited”, “we”, “us” or “our” in this privacy notice). We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below. Contact details Our full details are: Full name of legal entity: The Great American Bagel Factory Limited Name or title of data privacy manager: Data Privacy Manager Email address: eat@Bagelfactory.co.uk Postal address: The Bagel Factory Ltd – 90A Tooley Street – London SE1 2TH Telephone number: 0207 407 7616 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Changes to the privacy notice and your duty to inform us of changes This is the first draw of the policy. It is important that the personal data we for nay reasons hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. Third-party links This website 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 data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. 2 | THE DATA WE COLLECT ABOUT YOU Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows: Identity Data includes first name, last name, title, date of birth and gender. Contact Data includes physical address, email address and telephone numbers. Financial Data includes payment card details. Transaction Data includes details about payments from you. Technical Data includes internet protocol (IP) address, your login data, 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. Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. 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 is not considered personal data in law as this data does not directly or indirectly reveal your identity. 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 notice. We do not collect any Special Categories of Personal Data about you (this includes 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 you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you or for the purposes of a contract to be entered into 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 our products or services or for the purposes of accepting a booking from you). In this case, we may have to cancel or decline a product or service you have ordered, or have attempted to order, from us, or a booking which you have made or attempted to make with us, but we will notify you if this is the case at the time. 3 | HOW IS YOUR PERSONAL DATA COLLECTED We use different methods to collect data from and about you including through: Direct interactions You may give us your Identity, Contact, Financial, Transactional and/or Profile Data when you: Make a booking directly with us; Correspond with us by phone, email or otherwise; Purchase our products and services; Request marketing to be sent to you; Give us feedback, complete a survey or make a complaint. Automated technologies or interactions As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details. Third parties We may receive personal data about you from various third parties as set out below: Technical Data from analytics providers such as ‘Google’ based outside the EU; Identity, Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as ‘PayPal’ based inside the EU; Identity and Contact Data from providers of other services and platforms such as ‘Uber Eats’, ‘Deliveroo’, ‘Just Eat’, ‘City Pantry’, ‘EatFirst’ and ‘Yoyo Wallet’’ in each case based inside the EU. Request marketing to be sent to you; Give us feedback, complete a survey or make a complaint. 4 | HOW WE USE YOUR PERSONAL DATA 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: Where we need to perform the contract, we are about to enter into or have entered into with you. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Where we need to comply with a legal or regulatory obligation. Please refer to the table below to find out more about the types of lawful basis that we will rely on to process your personal data. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message, whether sent from us directly or through a third party provider. You have the right to withdraw consent to marketing at any time by contacting us using the details shown further above. Purposes for which we will use your personal data We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the contact details shown further above if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. A. To process a booking made by you Type of data: (a) Identity (b) Contact Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary for our legitimate interests (to enable us to match you to your booking details, and/or to amend your booking details where requested by you) Retention Period: Until the contract with you is complete B. To process a gift voucher purchased by you Type of data: (a) Identity (b) Contact Lawful basis for processing including basis of legitimate interest: Performance of a contract with you Retention Period: Until the contract with you is complete C. To process and deliver your order including: (a) Manage payments and charges (b) Collect and recover money due to us Type of data: (a) Identity (b) Contact (c) Transaction Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover sums due to us) Retention Period: Until the contract with you is complete except for Financial and Transactional data which is retained for 6 years D. To manage our relationship with you which will include notifying you about changes to our terms or privacy policy Type of data: (a) Identity (b) Contact Lawful basis for processing including basis of legitimate interest: (a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests Retention Period: 6 years or, in the case of processing to comply with a legal obligation, for as long as the legal obligation continues if longer than 6 years E. Asking you to leave a review or take a survey To assess the information provided by you as part of a survey or any feedback you provide whether in response to our request or by you voluntarily leaving your feedback on our website. Type of data: (a) Identity (b) Contact (c) Profile (d) Marketing and Communications Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services, and to address complaints and monitor customer satisfaction) except that we will not approach you to take a survey unless you have provided your consent by opting in to direct marketing and have not yet opted out. Retention Period: 6 years except that we will not retain your data for the purposes of contacting you to take a survey if you have opted out of direct marketing F. To administer and protect our business and this website including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data Type of data: (a) Identity (b) Contact (c) Technical Lawful basis for processing including basis of legitimate interest: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation Retention Period: 6 years or, in the case of processing to comply with a legal obligation, for as long as the legal obligation continues if longer than 6 years G. To use data analytics to improve our website Type of data: (a) Technical Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to keep our website updated and relevant) Retention Period: 6 years H. To make suggestions and recommendations to you about products or services, promotions or offers that may be of interest to you Type of data: (a) Identity (b) Contact (c) Technical (d) Profile Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business) but subject to you providing your consent by opting in to direct marketing Retention Period: Until you opt out of direct marketing Marketing We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Promotional offers from us We may use your Identity, Contact, Technical 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 may receive marketing communications from us (via ‘Yoyo Wallet’,) if you have requested information from us or you have expressly opted in to receiving marketing communications from us and provided that, in each case, you have not opted out of receiving that marketing. Currently we use ‘Yoyo Wallet’ to deliver our marketing emails and we will get your express opt-in consent before we share your personal data with ‘Yoyo Wallet’ for these purposes. Third-party marketing We will get your express opt-in consent before we share your personal data with any company outside The Great American Bagel Factory Limited of companies for marketing purposes. Opting out You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out instructions on any marketing message or email sent to you or by contacting us using the details shown above at any time. Cookies You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy. Change of purpose We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the contact details shown further above. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 5 | DISCLOSURES OF YOUR PERSONAL DATA We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. Internal Third Parties as set out in the Glossary further below. ‘PayPal’, ‘Uber Eats’, ‘Deliveroo’, ‘Just Eat’ , ‘City Pantry’ ,’ EatFirst’, ‘Google’ and ‘Yoyo Wallet’. External Third Parties as set out in the Glossary further below. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. We require all third parties to whom we pass your personal data which we have collected from you, to respect the security of that personal data and to treat it in accordance with the law and do not allow such third-parties to use that personal data for their own purposes and only permit them to process that personal data for specified purposes and in accordance with our instructions. Please note however that where a third party collects your personal data directly from you as a data controller, you must check that third party’s privacy policy as it may allow for different or additional forms of processing by them over which we have no control. 6 | INTERNATIONAL TRANSFERS We may share your personal data (but only Technical Data which is collected via our Cookies) within the Google Group. If we do so, this will involve transferring your data to the United States, however in order to ensure a similar degree of protection is afforded to it we will only transfer your personal data to Google for as long as they remain part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. 7 | DATA SECURITY We have put in place appropriate security measures to prevent your personal data from being 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 of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 8 | DATA RETENTION How long will you use my personal data for? We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements. Details of retention periods for different aspects of your personal data are set out in the table in paragraph 4 above. In some circumstances you can ask us to delete your data. 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. 9 | YOUR LEGAL RIGHTS Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please refer to the Glossary at paragraph 10 below for more information about the following rights: Request access to your personal data Request correction of your personal data Request erasure of your personal data Object to processing of your personal data Request restriction of processing your personal data Request transfer of your personal data Right to withdraw consent If you wish to exercise any of the rights set out above, please contact us using the contact details shown further above. No fee usually required 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 may refuse to comply with your request in these circumstances. What we may need from you 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. Time limit to respond 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. 10 | 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 using the contact details shown further above. 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 or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. THIRD PARTIES Internal Third Parties Other companies in the The Great American Bagel Factory Limited acting as joint controllers or processors and who are based in the UK and provide IT and system administration services and undertake leadership reporting. External Third Parties Service providers acting as processors or joint controllers based in the UK who provide IT and system administration services. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services. HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances. YOUR LEGAL RIGHTS You have the right to: Request access to your personal data (commonly known as a “data subject access request”). 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 data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. 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 at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Follow the BAGEL Find out what’s new on our social! TWITTER FACEBOOK INSTAGRAM Get in on the latest Bagel Factory news and offers! Newsletter SIGN ME UP! We are happy to inform you that Bagel Factory sites are fully compliant with COVID-19 Government guideline & regulations. 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