DRINKI LIMITED

DRINKI PRIVACY POLICY

UNITED KINGDOM

Please read this privacy policy carefully as it sets out how DRINKI LTD (“DRINKI” “we” or “us”) uses your personal information to provide you with the DRINKI mobile software application (the “App”) and websites (together with the App, collectively the “Services”). If you have any questions about this privacy policy, please contact us at info@drinki.com. We may change this policy from time to time so please check the the App or our website from time to time for any updates. If we make material changes in the way we use your personal information, we will notify you by posting a notice on the App and/or our website or sending you an email at the email address provided at the time of registration. Your continued use of any part of the Services following any update to this privacy policy will constitute your acceptance of any changes.

1. ABOUT US

1.1. We are DRINKI Limited, a company registered in England and Wales under company registration number 08704401 and have our registered office at St. John’s wharf, 104 Wapping Highstreet, E1W 2PR

1.2 We are a platform that provides information and promotions on behalf of venues, bars and FMCG brand owners to our members (the “Partners”).

2. OVERVIEW

2.1. DRINKI is a 'Data Controller' for the purposes of applicable data protection law.

2.2. This privacy policy explains how we use your personal information and other data we collect when you use the Services.

3. COLLECTED INFORMATION

3.1. All personal information you provide to us when registering with the Services, and any personal information generated by your navigation and use of the Services, will be processed and stored by DRINKI to manage registration and provide the Service. We also use this information to analyse trends in our users' behaviour to help us to determine your preferences, habits, tastes, geographic location in order to maximise your use and enjoyment of the Services. We have further listed the ways in which we use your personal information at Clause 5 below.

3.2. The types of personal information we collect may include:

4. COOKIES

4.1. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree. Cookies contain information that is transferred to your device hard drive.

4.2. Our App does not use cookies.

4.3. We use the following cookies on our website:

4.4. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

5. USE OF YOUR PERSONAL INFORMATION

5.1. As well as the purposes described above at Clause 3.1, we use the personal information we collect to:

5.2. We also use information that we collect about you to for operational purposes, including:

5.3. We use your personal data on the following legal basis:

5.4. Where we rely on your consent to process your personal data (e.g. marketing), you may withdraw your consent at any time by emailing us at info@drinki.com or via methods set out in this privacy policy. If you withdraw your consent, this will not affect the lawfulness of any processing which has taken place before you have withdrawn your consent.

6. MARKETING

6.1. We may send you marketing communications via email and push notifications. You are given the opportunity to opt in to marketing communications and push notifications on registration. If you change your mind and do not want to receive any marketing emails from us, you can unsubscribe from emails by following the unsubscribe directions provided in the footer of each one. If you do not want to receive push notifications from us you may opt out by changing the appropriate settings directly on your mobile device.

6.2. Where you opt out of receiving these marketing communications, we may still process your personal data for other required purposes, as specified in Clauses 4 and 5 above.

7. DISCLOSURE OF YOUR INFORMATION

7.1. We do not sell your personal information to anyone without your explicit consent, but we may share your personal information in the ways described below:

7.2. We may also provide our partners with anonymous information about how users, collectively, use the App and website so that they can understand how often people use their services, the App and the website.

8. SECURITY AND INTERNATIONAL TRANSFERS OF DATA

8.1 We are committed to ensuring that your information will be treated confidentially and securely, and we have put in place appropriate measures to ensure the security of your personal data.

8.2 The personal data that we collect from you may be transferred to, and stored at, destinations outside the European Economic Area (EEA) where the laws on processing personal data may be less stringent than in your country. It may also be processed by staff operating outside the EEA who work for us or for one of our agents or suppliers.

8.3 Presently personal data collected from you is stored in data centres as well as cloud networks.

8.4 When your personal data is transferred to parties located outside of the EEA we shall undertake an assessment and take appropriate measures to ensure such third party will provide adequate security of such personal data and respect your rights to privacy. These safeguards are intended to ensure a similar degree of protection is afforded to your data wherever it may be transferred and may include:

8.5 Although we take all steps reasonably necessary to ensure that your personal data is treated securely, you should be aware that the transmission of information via the internet is not completely secure and we cannot guarantee the security of your data during its transmission.

8.6 We may retain your personal data for as long as we require for the purposes for which it is processed or as is otherwise required by applicable law. If you terminate your account on the App and website, cease using the Services, or our agreement with you under the Terms of Use is terminated, we may continue to process your personal data for a reasonable period and as required under applicable law.

8.7 When calculating the appropriate retention period for your data, we consider the nature and sensitivity of the data, the purposes for which we are processing the data, and any applicable statutory retention periods. Using these criteria, we regularly review the personal data which we hold and the purposes for which it is held and processed. Once processing has been completed, we may securely delete or anonymise your personal data.

9. YOUR RIGHTS

9.1. You may request details of the personal information that we hold about you under data protection laws. If you would like a copy of the information held about you please write to us at info@drinki.com.

9.2. If you think any information we have about you is incorrect or incomplete, please write to us or email us at info@drinki.com as soon as possible. We will correct or update any information as soon as we can.

9.3 Under the EU General Data Protection Regulation and any equivalent rules in the UK, you are entitled to certain rights in relation to our handling of your personal data. For example, will have the right to have your personal data rectified or erased, the right to object to or restrict us from processing your personal data (including the right to object to profiling), and the right to data portability. If you would like to exercise these rights once they come into force, please write to us or email us at info@drinki.com.

9.4. Should you have any complaints about how we handle your personal information, please contact us at info@drinki.com. Should we be unable to resolve your complaint and you wish to take your complaint further, you may do so by contacting the UK Information Commissioner’s Office.