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Behind the Pass

Privacy Policy

Last updated 25th April 2025

APPETITE respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as  to how we look after your personal data when you visit our website and our app (regardless of where you visit it from)  and tell you about your privacy rights and how the law protects you. Please use the Glossary to understand the meaning  of some of the terms used in this privacy policy. 

1. Important information and who we are 

Purpose of this privacy policy 

This privacy policy aims to give you information on how APPETITE collects and processes your personal data through  your use of this website and mobile app, including any data you may provide through when you sign up to our newsletter  OR take part in a competition OR create an account to use the mobile app OR set up a user profile to use app features OR  purchase a product or service. 

Neither this website nor the app is intended for children, and we do not knowingly collect data relating to children. 

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may  provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware  of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not  intended to override them.  

Controller 

TOJA. TJ Limited of C/O MJB Avanti, Office 12 Epsilon House, West Road, Ipswich, Suffolk, England, IP3 9FJ, is the controller  and responsible for your personal data (referred to as “APPETITE,” "we", "us" or "our" in this privacy policy). 

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy.  If you have any questions about this privacy policy, including any requests to exercise your privacy rights, please contact  the data privacy manager using the details set out below.  

Contact details 

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in  the following ways: 

Email address: dataprotection@appetiteapp.uk 

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. 

Changes to the privacy policy and your duty to inform us of changes 

We keep our privacy policy under regular review. This version was last updated on 17 April 2025. Historic versions can  be obtained by contacting us. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal  data changes during your relationship with us. 

Third-party links including booking facility 

The website and the app include a link to the booking facility powered by Open Table and may include links to other third party websites, plug-ins, and applications. Clicking on the booking link will allow Open Table to collect data about you.

If you click on other links or enable those other connections this 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 the website you visit. 

2. The 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 may collect, use, store and transfer distinct kinds of personal data about you which we have grouped together as  follows:

Type of data
Description and examples
Identity
First name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact
Billing address, delivery address, email address and telephone numbers.
Financial
Payment card details.
Transaction
Details about payments to and from you and other details of products and services you have ordered or purchased from us including promotions and offers.
Technical
Internet protocol (IP) address, your login data, 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 the website or the app.
Profile
Username and password, purchases, bookings, or orders made by you, your interests, preferences, feedback, and survey responses.
Usage
Information about how you use our website, app, products, promotions, offers and services.
Marketing and
Communications
Preferences in receiving marketing from us and our third parties and your communication preferences.
Geolocation Data
Information about where you are when you are using the app which we collect if you select the option to allow us to do so. If you have selected ‘Always allow’, it includes the information about where you are at all times.
Special
Categories of
Personal Data
Details about your allergies, dietary requirements and restrictions and any other relevant information
concerning your health which we would otherwise not be aware of. These kinds of information may be or may
allow us or other users to infer information about your race or ethnicity, religious beliefs and health.

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 or app 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 do not collect any other Special Categories of Personal Data about you (this includes details about your race or  ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership,  information about your health, and genetic and biometric data). Nor do we collect any information about criminal  convictions and offences. 

If you fail to provide personal data 

Where we need to collect personal data to fulfil a contract we have with you, and you fail to provide that data when  requested, we may not be able to perform the contract we have or are trying to agree with you (for example, to provide  you with services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case  at the time.  

3. How is your personal data collected? 

We use different methods to collect data from and about you including through:

  • ‍Direct interactions. You may give us your Identity and Contact by filling in forms or by corresponding with us.  This includes personal data you provide when you: 
    • create an account on our platform; 
    • download the app; 
    • use app features; 
    • subscribe to our services or publications;  
    • request marketing to be sent to you; 
    • purchase products or services or engage with an offer or promotion; 
    • enter a competition, promotion, or survey; or 
    • give us feedback or contact us. ‍
  • Automated technologies or interactions. As you interact with our website or app, we will automatically collect  Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using  cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit  other websites employing our cookies. Please see our cookie policy for further details. ‍
  • Third parties or publicly available sources. We will receive personal data about you from various third parties  and public sources as set out below: 
    • Technical Data from the following parties: 

i. Analytics providers such as Google based inside and outside the UK; 

ii. Advertising networks such as Awin based inside and outside the UK; 

iii. Search information providers such as Google and Bing based inside and outside the UK; iv. Identity and Contact Data from publicly available sources such as Companies House and the  Electoral Register based inside the UK. 

4. How we use your personal data 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the  following circumstances: 

  • Where we need to carry out our contract with you or to provide you with a service, offer, promotion or product  that you have requested. 
  • 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. 

Please refer to the Glossary to find out more about the types of lawful basis that we will rely on to process your personal  data. 

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent  before sending third party direct marketing communications to you via email or text message. You have the right to  withdraw consent to marketing at any time by contacting us. 

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 customer
(a) Identity
(b) Contact
Performance of a contract with you
To provide you with a service that you
have requested, such as online booking,
including liaising with the service provider
(such as Open Table for online booking)
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
Communications
Performance of a contract with you
To provide you with a product, promotion
or offer such as Drops including:
(a) Manage payments, fees, and charges
(b) Collect and recover money owed to us
(c) liaise with the venue delivering the
product
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
Communications
(f) Geolocation
(g) Special Categories
of Personal Data
(details about your
allergies, dietary
requirements etc.
from which
information about
your race or ethnicity,
religious beliefs and
health may be
inferred).
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
(c) Consent (for geolocation and Special Categories of Personal Data)
To manage our relationship with you
which will include:
(a) Notifying you about changes to our
terms or privacy policy
(b) Asking you to leave a review or take a
survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Geolocation
(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)
(d) Consent (for geolocation)
To enable you to partake in a prize draw,
competition or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Geolocation
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how
customers use our products/services, to develop them and
grow our business)
(c) Consent (for geolocation)
To enable you to review places that you
book to eat at through our website or
application (including to tag cuisines, vibes
and allergies/dietary requirements that
are accommodated)
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Geolocation
(f) Special Categories
of Personal Data
(details about your
allergies, dietary
requirements etc.
from which
information about
your race or ethnicity,
religious beliefs and
health may be
inferred).
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business and to inform our marketing strategy)
(c) Consent (for geolocation and Special Categories of Personal Data)
To administer and protect our business,
the website, and the app (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 and app
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
(g) Geolocation
(e) Special Categories
of Personal Data
(details about your
allergies, dietary
requirements etc.
from which
information about
your race or ethnicity,
religious beliefs and
health may be
inferred).
(a) 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)
(b) Consent (for geolocation and Special Categories of Personal Data)
To use data analytics to improve our
website and the app, products/services,
marketing, customer relationships and
experiences
(a) Technical
(b) Profile
(c) Usage
(d) Geolocation
(e) Special Categories
of Personal Data
(details about your
allergies, dietary
requirements etc.
from which
information about
your race or ethnicity,
religious beliefs and
health may be
inferred).
(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website and the app updated and relevant, to develop our business and to inform our marketing strategy)
(b) Consent (for geolocation and Special Categories of Personal Data)
To make suggestions and
recommendations to you about goods or
services that may be of interest to you
(a) Identity
(b) Contact
(c) Transaction
(d) Technical
(e) Profile
(f) Usage
(g) Marketing and
Communications
(h) Geolocation
(i) Special Categories
of Personal Data
(details about your
allergies, dietary
requirements etc.
from which
information about
your race or ethnicity,
religious beliefs and
health may be
inferred).
(a) Necessary for our legitimate interests (to develop our products/services and grow our business)
(b) Consent (for geolocation and Special Categories of Personal Data)
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, Geolocation and Profile Data (which may include Special Categories  of Personal Data (in particular, details about your allergies, dietary requirements etc. from which information about your  race or ethnicity, religious beliefs and health may be inferred)) 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 products, 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 purchased goods or  services or participated in promotions or offers 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. 

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any  marketing message sent to you OR by contacting us at any time.  

Tagging is optional 

Optional tagging can be used on this website or the app to enable you to review places that you book to eat at (including  to tag cuisines, vibes and allergies/dietary requirements that are accommodated). 

Using diet tags may reveal personal information about you, for example, about your race or ethnicity, religious beliefs  and/or health (so-called Special Category data). Before you're able to use tags, we ask you to confirm that you understand  and accept this. If you don't, do not click to say you do nor use diet tags. 

If you start to use tags and change your mind and want to stop using them, simply don't use them as part of future reviews  and remove any tags that you used in the past. Please contact us at dataprotection@appetiteapp.uk if you would like our  support in removing past tags that you used. 

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 or the app may become inaccessible or not  function properly. For more information about the cookies we use, please refer to our Cookie Policy. 

Change of purpose  

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we  need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation  as to how the processing for the new purpose is compatible with the original purpose, please contact us.  

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which  allows us to do so. 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above  rules, where this is required or permitted by law. 

5. 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 Purposes for which  we will use your personal data above. 

  • External Third Parties as set out in the Glossary. 
  • Third parties identified in the table Purposes for which we will use your personal data above.
  • 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. 

6. International transfers 

We transfer your personal data outside the UK: 

  • to DigitalOcean who provide our servers and other cloud services and act as processors on our behalf, with  whom we have contractual arrangements in place to protect your personal data. DigitalOcean may transfer your  personal data on to its sub-processors who may be based anywhere in the world; those transfers take place  under the UK’s International Data Transfer Agreement which sets out the arrangements required to protect  your personal data. You can see full details of those arrangements in DigitalOcean’s Data Processing Agreement  here: https://www.digitalocean.com/legal/data-processing-agreement. 
  • to OpenTable International Limited, which provides our online booking facility, and is an English company based  in London that uses servers outside the UK. Its privacy policy, which states that it complies with the UK Extension  to the EU-U.S. Data Privacy Framework, is available here: https://www.opentable.com/legal/privacy-policy. Please  contact us if you want further information on the specific mechanism used by us when transferring your  personal data out of the UK. 
  • to our software developers in Nepal under the terms of an approved appropriate arrangement, known as an  International Data Transfer Agreement (or IDTA) to protect your personal data. 

7. Data security 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or  accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those  employees, agents, contractors and other third 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.  

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable  regulator of a breach where we are legally required to do so. 

8. 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. 

Details of retention periods for distinct aspects of your personal data are available in our retention policy which you can  request from us by contacting us. 

In some circumstances you can ask us to delete your data: see your legal rights below for further information. 

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research  or statistical purposes, in which case we may use this information indefinitely without further notice to you.  

9. Your legal rights 

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

  • Request access to your personal data. 
  • Request correction of your personal data.
  • Request erasure of your personal data. 
  • Object to processing of your personal data. 
  • Request restriction of processing your personal data. 
  • Request transfer of your personal data. 
  • Right to withdraw consent. 

Please consult the Glossary to find out more about these rights. If you wish to exercise any of the rights set out above,  please contact dataprotection@appetiteapp.uk. 

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.  

10. Glossary 

Lawful Basis  

Legitimate Interest includes: 

  • Supplying services to you and enabling you to use or receive third party services 
  • Protecting website and app users, employees, and other individuals and maintaining their safety, health, and  welfare 
  • Promoting, marketing, and advertising our products and services including promotions and offers that that we  run on behalf of third parties. 
  • Personalising communications or content within emails, on the website and in the app 
  • Understanding users’ behaviour, activities, preferences, and needs 
  • Improving existing and developing new products and services 
  • Complying with legal and regulatory obligations 
  • Preventing, investigating, and detecting crime, fraud, bullying, harassment, discriminatory or other anti-social behaviour and taking action against perpetrators, including working with law enforcement agencies • Protecting Appetite, its users, and partners, by taking appropriate legal action against third parties who have  committed criminal acts, or breach their legal obligations to Appetite 
  • Fulfilling our duties to our users, partners, colleagues, shareholders, and other stakeholders. 

Performance of Contract means carrying out our part of a contract to which you are a party or taking steps at your  request before we have agreed a contract. This includes arranging for a third party to deliver services to you. 

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to, such as keeping records and providing information to the tax authorities.

Third Parties  
External Third Parties 
  • Those parties listed under International Transfers 
  • Service providers acting as processors, based in the United Kingdom, the Netherlands, and India, who provide  IT and system administration services. 
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and  insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting  services. 
  • HM Revenue & Customs, regulators, and other authorities acting as processors or joint controllers based in the  United Kingdom. 
Your Legal Rights 

You have the right to: 

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive  a copy of the personal data we hold about you and to check that we are lawfully processing it. 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate  data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no  good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data  where you have successfully exercised your right to object to processing (see below), where we may have processed  your information unlawfully or where we are required to erase your personal data to comply with local law. Note,  however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be  notified to you, if applicable, at the time of your request.  

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and  there is something about your particular situation which makes you want to object to processing on this ground as you  feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your  personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate  grounds to process your information which override your rights and freedoms. 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your  personal data in the following scenarios:  

  • If you want us to establish the data's accuracy. 
  • Where our use of the data is unlawful, but you do not want us to erase it. 
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend  legal claims.  
  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds  to use it.  

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have  chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies  to personal information which you initially provided consent for us to use or where we used the information to perform  a contract with you.  

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not  affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we  may not be able to provide certain products or services to you. We will advise you if this is the case at the time you  withdraw your consent.

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TOJA. TJ LTD
Company No 12063786
© Appetite, 2025
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