1. ABOUT THIS POLICY

We are committed to safeguarding the privacy of the personal information that we process in the course of our business, including the personal information we receive from you. This Privacy Policy describes how and why we collect, store, and use personal information, and it provides information about your rights as a Data Subject.

2. WHAT IS PERSONAL DATA?

Personal data is any data relating to an identified or identifiable natural person who can be directly or indirectly identified from that data, for example, information such as your name, identification number, or location data.

3. SCOPE OF POLICY

This policy applies to personal data that we collect from visitors and customers through our website https://www.mrmiyagis.xyz/venue/studioone, our in-restaurant Wi-Fi, or communications that we receive from you via telephone, email, face-to-face, or in writing at our registered address.

4. CONSENT

When you access or use the above platforms or provide us with your personal data, you are accepting and, consenting to us collecting and processing your personal data. If you do not consent you may discontinue use of our platforms.
We may update this Privacy Policy from time to time by posting the amended terms on the platforms mentioned in the above “Scope” section.

5. HOW DO WE COLLECT YOUR PERSONAL DATA?

We may collect and process the following information about you including but not limited to:

·         Identity data: Your title, full name, and date of birth (for any birthday promotions);

·         Contact details: contact information such as your address details, your mobile number and email address;

·         Behavioural & Allergy data: Your food preferences and dietary requirements including information about allergies;

·         Transactional/Financial data: Payment information for confirming reservations

·         Contact data: Information you provide to us when you contact us by email, telephone, or face-to-face (in the context of making a reservation for example);

·         Responses you provide us in our surveys;

·         Behavioural & Lifestyle data: Data from social media profiles and preferences such as:

o    Lifestyle information such as seating preferences, ages of children, and other information necessary to fulfill special requests; and

o    Photographs taken of you at our events or when you dine in at our restaurant.

We may source such data when you:

·         Subscribe to a newsletter with your email address;

·         Make an online inquiry;

·         Make a reservation with us on our website, over the phone;

·         Voluntarily complete a customer comments card/survey;

·         Get in touch with us via email to contact us or provide any feedback;

·         Connect to our guest Wi-Fi portal;

·         Send us a letter, email, or social media message;

·         Book any of our events;

·         Attend events that we host;

·         From publicly available sources including information from your social media profile when you like or share our content or when you access our in-restaurant Wi-Fi (please note that the information we receive will depend on the privacy preferences you have set on your social media platforms).

What information is automatically collected by us?

There is “Device Information” about your computer hardware and software that is automatically collected by us, this information can include but is not limited to:

·         Device type (e.g. mobile, computer, laptop, tablet);

·         Cookies;

·         Operating system;

·         IP address;

·         Browser type;

·         Browser information (e.g., type, language, and history);

·         Domain names;

·         Access times;

·         Settings;

·         Referring the website addresses;

·         Location information.

6. HOW IS YOUR DATA USED?

We require the information outlined in the previous section for the following reasons:

·         To provide you with our goods and services;

·         To understand and cater to your dietary requirements and to ensure that we take into account information about your food allergies, intolerances, and/or preferences when preparing your order;

·         To process advance booking payments;

·         Send you newsletters with updates;

·         Send you communications we think will be of interest to you including emails with special offers & other promotions on our goods and services;

·         To notify you of changes to our services;

·         To improve our goods and services;

·         For internal record keeping.

Our use of your personal data will always have a lawful basis, either because it is necessary to complete a booking, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests.

7. ‘SPECIAL CATEGORY’ PERSONAL DATA

Special Category Personal Data is personal data revealing or concerning (directly or indirectly) data that is sensitive in nature (e.g. biometric data pertaining to your religion or health).
We may use certain sensitive (or “special category”) personal data where you have given your explicit consent to us doing so, to better serve and meet your needs. Examples of sensitive personal data we may collect and process include, but are not limited to:

·         Information about food allergies or food intolerances;

·         Dietary requirements, which may imply or suggest your religion, health, or other sensitive personal data; and

·         Information about any mobility requirements.

8. SHARING YOUR PERSONAL DATA

We will not sell, distribute, or lease your personal information to third parties. Any personal information we request from you will be safeguarded.

We will only share your personal data if we are required to do so by law or with the following entities:

Our third-party service providers, who help deliver services to you on our behalf including but not limited to our payment processor, email verification, email marketing services, SMS campaign, customer relationship management system, and guest Wi-Fi;
Our partner companies within the Forefront Group, so you can be offered related goods and services, which we think may be of interest to you.
Your explicit consent will be obtained should your data be shared with any other entity not specified above.

9.  CUSTOMER PROFILING

We may analyze (or appoint a third party to analyze) your personal information to create a profile of your interests and preferences so that we can contact you with relevant information. Please note that we may also make use of additional information about you when it is available from external sources to help us do this effectively.

However, you do have the right to object to us carrying out this type of automated processing.  If you wish to do so please get in touch with us in writing – please refer to the “Contact Details” section to obtain the relevant contact information.

10. DATA SECURITY

 Data security is very important to us, and to protect your personal data we have taken suitable measures to safeguard and secure data collected about you.

We train people who work for us on how to handle personal data appropriately and we restrict access to what is necessary for specific job functions. In addition, our employees and third-party service providers are subject to confidentiality and may not disclose your personal data unlawfully or unnecessarily.

Whilst we take all measures to protect your personal data, we cannot warrant or guarantee the security of your personal data and in agreeing to this privacy policy, you understand that you provide us with your personal data at your own risk.

11. DIRECT MARKETING

We will send you the latest updates and promotions on our goods and services, which we think may be of interest to you. This information will be sent to you via email or SMS.

If you wish to opt out of our promotional emails, please click on the unsubscribe link, which can be found at the bottom of each promotional email. Similarly, if you wish to opt out of our SMS campaigns, please send us a text message with the opt-out code, which will be detailed in any SMS received from us.

Please note that opting out of our email and SMS marketing campaigns only removes you from future marketing, but the personal data collected for the purpose of providing you with our goods and services will remain in our systems.

If you no longer wish to be contacted for marketing purposes, you can also email us at the following address: sm@forefrontgroup.co

12.  HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will retain your personal data for as long as necessary for the purpose for which we obtained it unless you explicitly request for us to erase your personal information, or we are required by law to keep the data for longer.

13. YOUR DATA PROTECTION RIGHTS

You have certain rights over the personal information that we hold about you. Here is a summary of your rights:

·         Obtain access to, and copies of, the personal data that we hold about you;

·         Require us to correct the personal data we hold about you if it is incorrect;

·         Require us to erase your personal data;

·         Object at any time to the processing of your personal data;

·         Require us to restrict our data processing activities;

·         Require that we cease processing your personal data if the processing is causing you damage or distress;

·         Withdraw the consent you have previously given us to process your personal data if your consent was the basis under which your personal data was processed;

·         We will inform all third parties to whom we sent your personal data of your request to access, rectify, erase, and restrict data processing activities or objections to the way your data is being processed, to the best of our abilities. We can inform you, if you so request, who the recipients of your personal data are;

·         Ask us to transfer your personal data directly to you or to another company.

Please note that the above rights are not absolute, and we may be entitled to refuse certain requests where exceptions apply.

You also have the right to raise a complaint regarding non-compliance with our privacy policy where you have made a request to remove or delete your personal data from specific processing (for example; marketing communications).

14. HOW TO EXERCISE YOUR RIGHTS?

If you would like to exercise any of the above rights, you can contact us in writing – please refer to the “Contact Details” section to obtain the relevant contact information. We will endeavour to get back to you as soon as possible but not later than within 28 days. In the event your request is particularly complex, we will notify you and keep you updated should it take longer than 28 days to process your request.

Please note: 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.

15. COOKIES

Like many other websites, we use cookies. We use them to help you personalize your online experience.

A cookie is a text file that is placed on your hard disk by a web page server which allows the website to recognise you when you visit. Cookies only collect data about browsing actions and patterns and do not identify you as an individual.
We use cookies for some of the following reasons:

·         To verify your account and device and determine when you log in, so we can make it easier for you to access the services and provide the appropriate experiences and features; and

·         To assist with analyzing performance, we may use third-party cookies, such as Google Analytics.

Please note that you can set your browser to not accept cookies, but this may limit your ability to use the services. If you would like more information on cookies, we encourage you to visit www.aboutcookies.org/.

16.  PRIVACY POLICIES OF OTHER WEBSITES

Our website may contain links to other websites. Our privacy policy applies only to our website, so if you click on a link to any other website, you should read their privacy policy. We will not be responsible for any loss or damage arising out of your visit to these websites and you visit these sites at your own risk.

17. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy at any time.  When we do, we will revise the date at the top of this page.  We encourage you to check this page from time to time for any changes. This policy was last updated in December 2023.

18.  OUR CONTACT DETAILS

If you have any questions about how we use your personal data, or you wish to exercise any of your data protection rights as provided by the law and described in this policy, please contact us by email at: sm@forefrontgroup.co