Terms of Use and Privacy Policy | The Initiative Group

Privacy Policy

Introduction

Welcome to our privacy policy.

There may be times when you trust us with personal data and we respect your privacy and are committed to protecting your personal data. This is why our policy is to take steps to ensure that your data and privacy rights are protected and to be clear about our personal data practices.

The purpose of this privacy policy is to explain what data we collect, how we use it and how you can control it.

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Les Betises Ltd (company number 11670558) collects, stores, uses, transfers and shares your personal data through your use of this website, or any data you may provide if you sign up to our newsletter or purchase a product or service.

We keep our privacy policy under regular review and reserve the right to update this privacy policy from time to time. If we make any material changes, we will notify you by email (sent to the email address if provided) or by presenting you with a new version of this privacy policy. If permitted by applicable law, your continued use of the website after the effective date of an updated version of the privacy policy will indicate your acceptance of the privacy policy as modified.

Please check our privacy policy posted on our website for the latest version with a new version of this privacy policy.

Our details

Les Betises Ltd is the controller and responsible for your personal data (collectively referred to as “Shaman”, “we”, “us” or “our” in this privacy policy). If you have any questions about this privacy policy or our data practices, you can contact us on the information below:

Email address: hello@shaman-coffee.com

Postal address: Flat 2, 8 Godson Street, London, N1 9GZ

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.

Personal 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 collect personal data about you in a variety of ways. Sometimes we collect the personal data directly from you and at times we may receive personal data about you from other sources and third parties. We also collect personal data automatically when you interact with our website.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes name, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Transaction Data includes details of reservations and services you have arranged through us.
Technical Data includes 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.
Profile Data includes reservations made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about the frequency of use of the website, areas and features that you access, visit or use and engagement with particular features.
Marketing and Communications Data includes any preferences you have for receiving marketing from us and our third parties.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. 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 this privacy policy.

We may collect minimal Special Category of Personal Data about you when you make a reservation with a particular restaurant and this information will be limited to (i) any allergy or dietary requirements you might have, and (ii) any access or seating requirements you might have (like disabled access or ramp access requirements). We do not knowingly collect any additional special category data.

Data from external sources. We may receive personal data about you from various third parties, like information to enhance or supplement existing user information or for statistical purposes and analytics. Additionally, we will receive Transaction Data from providers of technical and payment services we engage based inside the UK.

Children’s Data

This website and the services are not intended for children and we do not knowingly collect personal information about children under 13 years old. If you are aware of anyone under the age of 13 using the website or otherwise providing us with personal data, please contact us and we will take required steps to either delete such information or obtain appropriate approval from a parent or guardian.

How we use your personal data

We will not collect and use your personal data without letting you know. Our use of your data will be based on one of the following circumstances:

Where you have provided explicit consent.
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 obligation.

Principles of processing

We will not process personal data in a way that is incompatible with the purposes for which it has been collected or subsequently authorised by you. We also will not collect any personal data that is not needed for the mentioned purposes. For any new purpose of processing we will ask your approval before we begin that processing.

We will not sell or rent your personal data and will get your consent before giving your personal data to any third party for direct marketing communications.

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 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.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new user	(a) Identity (b) Contact	Performance of a contract with you
To process your booking	(a) Identity (b) Contact (d) Transaction	(a) Performance of a contract with you
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Providing service updates to you (c) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(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
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	(a) Necessary for our legitimate interests (to develop our products/services and grow our business)

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, 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 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 requested services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. We may provide you with details of any offers or discounts that we have negotiated with third parties but this will be optional for you to use, and we will not share any personal data with third parties for this purpose.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of use of a service or other transactions.

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 for more information (available through our website).

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

External Third Parties – we will share your personal data with service providers we have appointed to act as our processors, such service providers being based in the UK or EEA to provide web hosting and support services and marketing support services, and with relevant restaurants to enable your booking to be processed and honoured.
Where required by law or under any legal order.
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 policy.

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

Where we share your data with relevant restaurants, the restaurant shall be a controller of your data in line with their own privacy policy.

Aggregated Data. We may aggregate, anonymize or de-identify your personal data so that it cannot reasonably be used to identify you. Such data is no longer personal data but we will still take care of it. This is done for our legitimate interest as well as the wider societal interest. .

International transfers

We do not transfer your personal data outside the UK or the EEA. If there was any international transfers, we would ensure that a similar degree of protection is afforded to it by having appropriate safeguards in place prior to any international transfer taking place.

Data security

We have put in place reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We will limit access to your personal data to those 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.

Data retention

How long will you use my personal data for?

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.

Where we have anonymised your personal data (so that it can no longer be associated with you) for research or statistical purposes, we may use this information indefinitely without further notice to you.

Your legal rights

We are committed to providing you with privacy rights in relation to your personal data. Details of the rights you have are set out below. If you wish to exercise any of the rights set out above, please contact us.

Individual Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Your right to be informed: You have the right to understand how we collect and use your data. This privacy policy is our main way of giving you this information but you can also contact us for further information if required.
Your right of access: You have the right to ask us for copies of your personal information.
Your right of rectification: You have the right to ask us to rectify information you think is inaccurate.
Your right to erasure: You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing: You have the right to ask us to restrict the processing of your information in certain circumstances.
Your right to object to processing: You have the right to object to processing if we are able to process your information because the process forms part of our public tasks, or is in our legitimate interests.
Your right to data portability: This only applies to data you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated

You can read more about all of these rights at https://ico.org.uk/global/privacy-notice/your-data-protection-rights/.

Complaints

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 could 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 could 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.

Third-party links

Our 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 policy of every website you visit.