This Privacy Policy covers the services provided by Fesvi.Co Ltd, a company registered in United Kingdom under company UEN number 15253172 and having its registered address at 85 Great Portland Street, London, W1W 7LT, United Kingdom.
This Privacy Policy provides details of the way in which we process personal data in line with our obligations under the Personal Data Protection Act (PDPA) and any other laws which apply to us in relation to the processing of personal data (collectively referred to as “Data Protection Laws”).
In this Privacy Policy, “controller”, “personal data” and “process” (and its derivatives) have the meanings given to those terms in Data Protection Laws. Personal data generally means information that can be used to individually identify a person, and processing generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.
MenuHub will be the controller of your personal data processed in connection with our services. We process your personal data across a range of systems and tools, including our end-user management system, our customer management system and communications platforms.
The MenuHub Platform is the technology solutions developed by Fesvi.Co and made available to you, including our technology solution which enables you to order products from Businesses. MenuHub and the businesses who operate on the MenuHub Platform (“Business” or “Businesses”) are joint controllers in respect of any personal data that is processed for placing and completing orders made with a Business via the MenuHub Platform.
If you are a customer of a Business and have queries how your personal data is processed by the Business or wish to address your rights, please contact the Business. The purpose of this Privacy Policy is to explain MenuHub’s data processing activities, including how and why we process personal data.
We collect personal data in relation to you when you provide it directly to us through the MenuHub Platform, when third parties such as Businesses provide us with personal data about you, or when personal data about you is automatically collected in connection with your use of the MenuHub Platform.
If you are acting on behalf of a Business or are an MenuHub corporate customer, we collect personal data through the Business’s or corporate customer’s engagement with MenuHub, including personal data that is collected from you and from the Business or corporate customer or through an account created on the MenuHub Merchant Website (the dedicated micro-site hosted and managed by Fesvi.Co which enables the Business or corporate customer to access their MenuHub account).
In providing our services, we may collect and process the following information:
Biographical and contact information. Information such as name, email address, telephone number.
Third Parties may provide us with personal data. For example, a Business may provide us with personal data about you in order for us to fulfill food orders placed with the Business through the MenuHub Platform. This includes biographical and contact information, order information, and special category order information.
Some personal data is automatically collected when you use the Website, such as:
This information is collectively referred to as “automatically collected information”.
The below table sets out how and why we process your personal data as described above, the legal justification that supports this processing and the categories of personal data processed.
| Why we process your personal data | Legal justification | Categories of personal data |
|---|---|---|
Administration purposes To:
| Such processing is necessary for the performance of a contract between you and a Business. Where you choose to provide special category data order information, the legal justification is your explicit consent | Biographical and contact information, order information, automatically collected data and in certain cases, special category data order information |
| Personalization services, troubleshooting, data analysis, and survey purposes | We have a legitimate interest to personalize our services to ensure you are provided with the best possible service. We have a legitimate interest in operating and maintaining the Website and to manage, monitor, and improve our services. We sometimes use surveys to assist with this | Biographical and contact information, order information, automatically collected data and in certain cases, special category data order information |
| Training, quality monitoring, or evaluating the services we provide | Such processing is necessary for the legitimate interests pursued by us in monitoring and improving our services and their usage and ensuring that our users use the Website and the MenuHub Platform and/or MenuHub Merchant Website, as applicable, in accordance with our terms and conditions and policies | Biographical and contact information, order information, automatically collected data and in certain cases, special category data order information |
| Statistical information that is not related back to individuals to help us improve the services we offer | We have a legitimate interest in carrying out certain analytics to ensure the services we provide to Businesses are effective and operate appropriately | User activity on the MenuHub Platform (e.g. duration on a particular page, most popular choices etc). This data is aggregated so that it is not referable to any individual user |
Corporate purposes To:
| If you are acting on behalf of a Business or a MenuHub corporate customer and we are provided with personal data, we will process that as necessary including to perform the MenuHub Terms & Conditions and/or other applicable contractual terms as necessary. Such processing is in our legitimate interests of managing customer relationships | Biographical and contact information, including the name of the Business or MenuHub corporate customer on whose behalf you act and the role you occupy in respect of such an entity |
Legal and contractual matters
| We have a legitimate interest in ensuring that our services and the Website are used in accordance with our terms and conditions of use and policies and to protect against or deter fraudulent, illegal, or harmful actions. Where necessary for the purpose of complying with our legal obligations such as in respect of taxation, accounting, payment card rules and standards, data protection, consumer, public health laws or adhering to court orders. We have legitimate interests in establishing, exercising or defending a legal claim, a prospective legal claim, legal proceedings or prospective legal proceedings and in resolving disputes | Biographical and contact information, order information, automatically collected data and in certain cases, special category data order information |
Corporate matters
| Such processing is in MenuHub’s legitimate interest to ensure prudent and effective management of its business and to scale and develop our business. MenuHub also has legal obligations in respect of legal and financial matters under company law and accounting regulations | Biographical and contact information, order information, and automatically collected data |
Disclosure requests
| We will disclose personal data where we receive a legally binding request to disclose personal data from law enforcement or other bodies or where we have a legitimate interest in assisting law enforcement or other agencies in respect of an investigation | Biographical information, contact information, reward information, and employment information |
Data Protection Laws provide certain rights in favor of data subjects (the “<strong>Data Subject Rights</strong>”). Data Subject Rights include the right to:
These Data Subject Rights will be exercisable by you subject to limitations as provided for under Data Protection Laws. If you require more information about how a Business processes your personal data or you wish to exercise any of your data subject rights in respect of the processing of your personal data by a Business you should contact the Business directly. You may contact us or make a request to exercise any Data Subject Right by contacting [email protected]. Your request will be dealt with in accordance with Data Protection Laws.
MenuHub may engage other companies and people to perform tasks on our behalf and may need to share personal data with them to enable us to provide you with our services. These other companies and people include:
MenuHub may also disclose personal data to Businesses. As part of the food ordering process, a Business may obtain from MenuHub biographical and contact information, order-related information, and special category data order information. MenuHub may disclose personal data in some scenarios e.g. when you violate our terms and conditions or other policies. MenuHub may disclose such personal data, at our sole discretion, if we believe it necessary or appropriate in connection with the investigation of fraud, IP infringement, piracy, or other unlawful activity. This may require disclosure of biographical and contact information and automatically collected data, amongst other personal data.
As noted above, as part of the food ordering process, a Business may obtain from MenuHub biographical and contact information, order information, special category data order information or other personal data. Where you consent to direct marketing, your consent is provided directly to the Business. MenuHub, acting as a processor, may assist Businesses in managing its users’ consent preferences. You may unsubscribe from direct marketing through the unsubscribe link included in marketing communications. MenuHub also acts as processor when it assists Businesses with managing their analytics. The Business’s Privacy Policy and notices will govern in respect of marketing activities and analytics conducted by MenuHub acting as a processor.
We will keep personal data only for as long as the retention of such personal data is deemed necessary for the purposes for which that personal data are processed (as described in this Privacy Policy) unless we are required to retain your personal data for a longer period (e.g. in the event of legal proceedings or investigations).
Certain information, such as biographical and contact details and order details have to be provided to enable us to provide our services to you. If you do not provide this information, it will mean that we are not able to provide our services to you.
On occasion, we include links to third parties on the Website. Where we provide a link it does not mean that we have any control over the linked website or its privacy policy or that we endorse, or approve that website’s policy towards visitor privacy. You should review the linked website’s privacy policy before sending them any personal data.
MenuHub may send you MenuHub Platform service-related announcements. You may not opt-out of service-related communications.
For further information about this Privacy Policy or the processing of your personal data by or on behalf of MenuHub, please contact us at [email protected]. While you may make a complaint in respect of MenuHub’s compliance with Data Protection Laws to any competent data protection supervisory authority or MenuHub’s lead supervisory authority, the Personal Data Protection Commission, we ask that you contact us in the first instance to give us the opportunity to address your concerns.
The manner in which we process personal data will evolve and we will update this Privacy Policy from time to time to reflect changing practices. We will update the “Last Modified” date accordingly at the end of this Privacy Policy. We will notify you of material updates but please review this Privacy Policy from time to time.