Frinkl

I.Personal Data Controller

Controller of your personal data is frinkl Ltd with its registered office at Suite 18 Equity Chambers 249 High Street North, Poole, BH15 1DX, e-mail address to contact the controller:
II.Purposes, methods, legal grounds and period of data processing.

APPLICATION
By creating an individual account in our application, you provide us with the following data:
(•) contact details, e.g. name, e-mail address, telephone number; (•) user profile name; (•) data provided in the user's profile (•) other data that you provide voluntarily, also with separate consents.

When using our application, we collect the following data:
(•) data about your account (e.g. account ID) and behavior (•) your IP address; (•) data on your activity collected using cookies and similar technology. (•) approximate data on your location, or precise location using GPS (with your separate consent); (•) private messages, questions and comments to support.
The data is processed for the following purposes:

• 1. enabling the use of the service - on the basis of an agreement concluded by accepting the Regulations (Article 6 (1) (b) of the GDPR), in particular:
  (a.) ensuring the operation of the application, updates, (b.) user service - adjusting personal settings, making payments; (c.) monitoring user behavior in terms of compliance with the Service Regulations.
2. performance of accounting and tax obligations in the event of payment - based on the legal obligation imposed on us (Article 6 (1) (c) of the GDPR);
3. consideration of complaints / defense against claims and asserting your rights - based on our legitimate interest (Article 6 (1) (f) of the GDPR);
4. sending marketing content regarding our products and services by electronic means (email, sms, telephone, social media, push messages on your device) - based on our legitimate interest (Article 6 (1) (f) of the GDPR);
5. collecting and analyzing information about our customers (profiling), such as identification data and behavior on our website or in the application, including by transferring data to websites and social media in order to better adapt the targeted marketing information to the interests of customers and to quality control of our services and the development of our products - based on our legitimate interest (Article 6 (1) (f) of the GDPR);

Your personal data may be entrusted for processing or made available:
(1.)our employees, associates and external entities performing specific services for us (e.g. IT support) - on the basis of appropriate authorizations or processing agreements (2.)websites and social media platforms (Facebook, Google) - in accordance with the regulations and privacy policies of the websites concerned. (3.)authorities authorized to request access to data if, on the basis of a ruling or decision of an authorized body or provisions of generally applicable law, we are obliged to disclose them.

Time during which we will process your data (data retention):
(1.)In the case of data processed on the basis of your consent - until you withdraw your consent to processing, without affecting the lawfulness of the processing carried out before its withdrawal. (2.)Data related to the implementation of payments will be processed for a period of 5 years from the end of the year in which the payment was made. (3.)The data necessary to prepare or conclude and perform the contract will be processed until the contract is performed. (4.)In the case of data processed on the basis of our legitimate interest - until the purpose of processing is achieved or until you submit an objection

ORDERING AND BOOKING PROCESS As part of the ordering and booking process, we process the following data:
(•) contact details, e.g. name, e-mail address, telephone number; (•) user profile name; (•) data provided in the user's profile; (•) order; (•) payment data; (•) other data that you provide voluntarily, also with separate consents.

Personal data is processed in order to fulfill the order, on the basis of (Article 6 (1) (b) of the GDPR) and for the purpose of reporting restaurant reviews based on your consent (Article 6 (1) (a) of the GDPR).

Your personal data may be entrusted for processing or made available:
(1.) the restaurants you have chosen to fulfill your order or reservation; (2.) our employees, associates and external entities performing specific services for us (e.g. IT support) - on the basis of appropriate authorizations or processing agreements; (3.) websites and social media platforms - in accordance with the regulations and privacy policies of the websites concerned. (4.) authorities authorized to request access to data if, on the basis of a ruling or decision of an authorized body or provisions of generally applicable law, we are obliged to disclose them.

Time during which we will process your data (data retention):
(1.) The data necessary to prepare or conclude and perform the contract will be processed until the contract is performed. (2.) In the case of data processed on the basis of your consent - until you withdraw your consent to processing, without affecting the lawfulness of the processing carried out before its withdrawal.

USER SERVICE Your personal data obtained in connection with the letter, inquiry, request addressed to us, both in public and private information, as well as via e-mail address or contact form, are processed for the purpose of:
(1.) maintaining contact and responding to the addressed letter / application / inquiry / request - based on your consent expressed by providing data in the text of the letter / application / inquiry / request (Article 6 (1) (a) of the GDPR); (2.) defense against claims and asserting your rights - based on our legitimate interest (Article 6 (1) (f) of the GDPR);

Your personal data may be entrusted for processing or made available:
(1.) our employees, associates and external entities performing specific services for us (e.g. IT support) - on the basis of appropriate authorizations or processing agreements; (2.) authorities authorized to request access to data if, on the basis of a ruling or decision of an authorized body or provisions of generally applicable law, we are obliged to disclose them.

Time during which we will process your data (data retention):
(1.) In the case of data processed on the basis of your consent - until you withdraw your consent to processing, without affecting the lawfulness of the processing carried out before its withdrawal. (2.) In the case of data processed on the basis of our legitimate interest - until the purpose of processing is achieved or until you submit an objection.

CONTACT Your personal data obtained in connection with the establishment and maintenance of business relationships, presentation of a commercial offer, contract service or ongoing negotiations are processed in order to:
(1.) establish and maintain business contact through electronic (email, telephone) and traditional (paper) communication - based on your consent expressed directly or by making contact by you (Article 6 (1) (a) of the GDPR); (2.) start and conduct business talks, negotiating, accepting and performing an order - on the basis of a concluded contract or in order to conclude such a contract (Article 6 (1) (b) of the GDPR); (3.) performance of accounting and tax obligations in the case of payment or issuing an invoice / invoice / other document related to accounting obligations - on the basis of our legal obligation (Article 6 (1) (c) of the GDPR); (4.) consideration of complaints / defense against claims and asserting your rights - based on our legitimate interest (Article 6 (1) (f) of the GDPR); (5.) send marketing content regarding our products and services by electronic means (email, telephone) - based on our legitimate interest (Article 6 (1) (f) of the GDPR);

Your personal data may be entrusted for processing or made available to:
(1.) our employees, associates and external entities performing specific services for us (e.g. IT support) - on the basis of appropriate authorizations or processing agreements; (2.) external operators - on the basis of relevant agreements. (3.) authorities authorized to request access to data if, on the basis of a ruling or decision of an authorized body or provisions of generally applicable law, we are obliged to disclose them.

Time during which we will process your data (data retention):
(1.) In the case of data processed on the basis of your consent - until you withdraw your consent to processing, without affecting the lawfulness of the processing carried out before its withdrawal. (2.) Data related to the implementation of payments will be processed for a period of 5 years from the end of the year in which the payment was made. (3.) The data necessary to prepare or conclude and perform the contract will be processed until the contract is performed. (4.) In the case of data processed on the basis of our legitimate interest - until the purpose of processing is achieved or until you submit an objection.

SOCIAL MEDIA When you follow, leave comments or otherwise interact with our accounts maintained on various social networking sites, we become the controller of personal data visible to us in accordance with the terms of the given social platform.
We process your personal data that you use in accordance with the privacy rules established by the website on which you have an account. They can be, among others. name and surname, date of birth, photo, information about where you live and work, and other information assigned to your account, as well as any personal data that you voluntarily make public on a specific social media platform or provide us in a private message.

Your data is processed for the purpose of:
(1.) keeping an account on a social network in accordance with the regulations and privacy policy of a given website, including interacting with other users - based on our legitimate interest (Article 6 (1) (f) of the GDPR); (2.) defense against claims and asserting your rights - based on our legitimate interest (Article 6 (1) (f) of the GDPR); Your personal data may be entrusted for processing or made available: (1.) our employees, associates, companies from our capital group and external entities performing specific services for us (e.g. IT support, courier services) - on the basis of appropriate authorizations or processing agreements; (2.) authorities authorized to request access to data if, on the basis of a ruling or decision of an authorized body or provisions of generally applicable law, we are obliged to disclose them. Your personal data may also be used for other purposes and made available to other entities, based on the regulations of a given social networking site, over which we have no influence.

Time during which we will process your data (data retention):
(1.) In the case of data processed on the basis of our legitimate interest - until the purpose of processing is achieved or until you submit an objection. However, the exercise of this right on the social media website may be limited by the website regulations in accordance with its privacy policy (e.g. rules regarding deleting comments or deleting the history of private messages).

CONTEST Your personal data obtained during the application for participation in the competition are processed in order to:
(1.) taking part in the competition and its implementation (including awarding the prize) - on the basis of the competition regulations (Article 6 (1) ( b) of the GDPR); (2.) fulfillment of accounting and tax obligations in the case of awarding a prize in cash or in kind, the implementation or delivery of which is related to accounting obligations - on the basis of our legal obligation (Article 6 (1) (c) of the GDPR); (3.) collecting and analyzing information about our customers (profiling), such as identification data and behavior on our website or in the online store, including by transferring data to websites and social media in order to better adapt the targeted marketing information to the interests of customers and in the purpose of controlling the quality of our services and developing our products - based on our legitimate interest (Article 6 (1) (f) of the GDPR); (4.) defense against claims and asserting your rights - based on our legitimate interest (Article 6 (1) (f) of the GDPR); (5.) sending marketing content regarding our products and services by electronic means (email, telephone, social media) - based on our legitimate interest (Article 6 (1) (f) of the GDPR); (6.) sending marketing content regarding our products and services by traditional (paper) method - based on our legitimate interest (Article 6 (1) (f) of the GDPR).

Your personal data may be entrusted for processing or made available to:
(1.) our employees, associates and external entities performing specific services for us (e.g. IT support) - on the basis of appropriate authorizations or processing agreements; (2.) websites and social media platforms - on the basis of appropriate entrustment agreements in accordance with the regulations and privacy policies of the websites concerned. (3.) authorities authorized to request access to data if, on the basis of a ruling or decision of an authorized body or provisions of generally applicable law, we are obliged to disclose them. Time during which we will process your data (data retention): (1.) In the case of data processed on the basis of your consent - until you withdraw your consent to processing, without affecting the lawfulness of the processing carried out before its withdrawal. (2.) Data related to the implementation of payments will be processed for a period of 5 years from the end of the year in which the payment was made. (3.) The data necessary to prepare or conclude and perform the contract will be processed until the contract is performed. (4.) In the case of data processed on the basis of our legitimate interest - until the purpose of processing is achieved or until you submit an objection.

III. Your rights You have the right to:
(1.) request access to personal data concerning you, including information on their processing (Article 15 of the GDPR); (2.) rectify or supplement data if they are incorrect or incomplete (Article 16 of the GDPR); (3.) deletion requests (the right to be forgotten / forgotten), in the case where there is no basis for their treatment or withdrawn consent to the processing (Art. 17 of the GDPR); (4.) requests to limit processing if they are incorrect, unnecessary, processed without a legal basis or an objection to processing has been made based on the legitimate interest of the Controller (Article 18 of the GDPR); (5.) receiving and transferring personal data in a structured, commonly used format, in the case of data provided to the controller and processed on the basis of consent (Article 20 of the GDPR);

Withdrawal of consent You have the right to withdraw your consent to processing at any time. Withdrawal of consent does not affect the lawfulness of the processing of your data, which was made on the basis of the consent granted before its withdrawal.

Objection You have the right to object at any time to the processing of your personal data based on our legitimate legal interest (Article 6 (1) (f) of the GDPR), including profiling based on this provision (if it occurs). In such a situation, we will not process your personal data for these purposes, unless there are valid legitimate grounds for such processing, superior to your interests, rights and freedoms, or there are grounds for establishing, investigating or defending claims.
You also have the right to bring at any time object to the processing of your personal data, in a situation where your personal data are processed for direct marketing via traditional (paper) - in which case we will not process your personal data for such purposes.
Office for the protection of personal data You also have the right to lodge a complaint with the supervisory authority if you believe that the processing of your personal data violates the provisions of the GDPR.
Exercise of rights If you want to exercise your rights regarding the processing of personal data, please contact us at [ ] All requests regarding the protection of personal data will be implemented immediately, but within a period not longer than one month from their submission. This period may be extended by another two months in the event of a complex nature of the request.

IV. Data transfer to third countries and international organizations
In the case of personal data obtained and processed in the European Union or the area where the GDPR operates, we would like to inform you that some of the tools or solutions we use require the transfer of personal data outside the European Economic Area to third countries (e.g. some cloud services or marketing tools). If such a data transfer is necessary, we make every effort to ensure the highest possible standards of security for the processing of your data and the protection of your privacy, and we select only service providers that ensure such protection.
All data transfers take place on the basis and within the limits of the law, in particular with regard to Chapter V of the GDPR, which provides for the conditions for the transfer of data to third countries with appropriate safeguards (in particular, Standard Contractual Clauses).

V. Profiling and automated decision making
Some of our services may involve data processing consisting in profiling in order to better adapt our offer to your needs and interests. The consequence of profiling will be the assignment of a profile to you in order to conduct analyzes or predict your preferences, behaviors and attitudes.
As part of the contract performance and in order to improve our platform, controller uses automatic decision-making and profiling. We may use your location data, for example, to select restaurants in your area.
If such automated decision-making or profiling leads to a negative decision, and you do not agree, you can contact us by writing to us at the following address: [ ]. In this case, we will arrange for the situation to be re-assessed.

VI. Use of cookies
Our websites use cookies . Personal data collected by cookies make it possible to monitor user behavior on the web and are used based on your consent when entering the website or by setting the browser.

What are cookies ?
Cookies are small files that are stored on your terminal device (eg. Mobile, tablet) record information about your behavior when you visit our website and use our online store. The cookies we use are safe for your device. In particular, it is not possible for viruses or other unwanted software or malware to enter this way.

What are cookies used for ?
We use cookies to enable the use of our services ( cookies necessary to maintain the session ), remember your preferences when using our website (e.g. type of software you use, font, resolution, etc.), collect information necessary to improve the quality of our services ( e.g. observing what content is of great interest), as well as to better adapt advertising content to your interests.

Cookies Policy
More information on the cookies we use and how to configure the settings can be found in our Cookies Policy.

VII. Changes to the Privacy Policy
We reserve the right to change the Privacy Policy presented by publishing new content on our website. After making the change, the Privacy Policy will be published on the website with a new date.
In the event of a change in the Privacy Policy requiring the fulfillment of the information obligation, in accordance with the law on the protection of personal data, we will inform you directly about such change through traditional or electronic correspondence or by displaying the announcement at the entrance to the website or in another way ensuring the easiest access to this information.
Privacy Policy version 1.0 published [date]