TABERO LIMITED – Privacy & Cookies Policy
Version 1 – Dated November 6 2021
We are Tabero Limited, incorporated and registered in Ireland whose registered office is at 66 the Oaks, Keatingstown, Wicklow, Ireland (hereinafter referred to as “[Tabero]”, “we”, “us” or “our”, which terms shall also include our Affiliates. “Affiliates” means any entity that directly or indirectly controls, is controlled by, or is under common control with us. “Control” for purposes of this definition, means direct or indirect ownership or control of more than 50% of the voting interests of the subject entity). We are a company based in Ireland and we provide a technology platform to enable host restaurants and cooks connect with potential diners to create social dining experiences (the “Business”).]
We will handle your Personal Data in accordance with Data Protection Legislation. “Data Protection Legislation” means the Data Protection Acts 1988 to 2018, the General Data Protection Regulation (EU) 2016/679 (“GDPR”), and any other applicable law or regulation relating to the processing of Personal Data and to privacy, including the E-Privacy Directive 2002/58/EC and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (“E-Privacy Regulations”), as such legislation shall be supplemented, amended, revised or replaced from time to time.
[In some instances, we and certain Affiliates (“Participating Affiliates”) who are party to a data sharing agreement (“DSA”) may process certain Personal Data as joint controllers, meaning each party jointly determines: (i) the purposes; and (ii) the means, of processing the Personal Data. We and our Participating Affiliates shall be responsible, as joint controllers, for our own processing of the Personal Data and will fully comply with our respective obligations as joint controllers under Data Protection Legislation in respect of the Personal Data.]
You may be a data subject (as defined in Data Protection Legislation) or you may be a controller. When you are a controller in respect of the Personal Data of other data subjects, then you must comply with all of your controller obligations under Data Protection Legislation. When you are a controller, we and you act as independent controllers, unless agreed otherwise.
We fully respect your right to privacy in relation to your interactions with the Service and endeavour to be transparent in our dealings with you as to what information we will collect and how we will use your information. Also, we only collect and use individual’s information where we are legally entitled to do so. Information in relation to Personal Data collected by Irish entities is available on www.dataprotection.ie, the website of the Irish Data Protection Commission (“DPC”).
We may collect Personal Data from you in the course of your use of the Service. The information that we process includes:
Any Personal Data that we collect from you for these purposes is hereinafter referred to together as “Your Data”. Your Data is separate from and should be distinguished from User Uploaded Data (defined below).
We endeavour to keep Your Data accurate and up-to-date. As such, you must tell us about any changes to such information that you are aware of as soon as possible. You can change your stated interests in respect of whether or not you wish to receive direct marketing from us by clicking ‘unsubscribe’ on any direct marketing electronic communication which you receive from us.
If you are aged under 18, please get your parent/guardian’s permission before you provide Your Data to us/use the Service.
We may collect information from you as necessary in the course of providing our Service. We may collect your personal information while monitoring our technology tools and services, including our website and email communications sent to and from us. We gather information about you when you provide it to us, or interact with us directly.
We may use your Personal Data on any one or more of the following legal bases: (i) to perform a contract with you; (ii) for our legitimate business purposes in providing the Service to you (in which case, our legitimate interests will not override your fundamental privacy rights); and/or (iii) in limited circumstances, where you have given us your express consent.
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 legal basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your Personal Data where more than one ground has been set out in the table below.
Categories of data
Legal basis for processing and, where necessary, the basis of legitimate interest
To respond to an enquiry from you.
basic information, and
Necessary to take steps at your request prior to entering into a contract with you.
To register you as a customer of our website.
profile information, and
Performance of a contract with you.
Necessary for our legitimate interests in protecting our business from insolvent customers and fraud.
To register you as a customer of our website.
basic information, and
Performance of a contract with you.
To process [and deliver] your order.
contact information, and
Performance of a contract with you.
To make suggestions and recommendations to you about [goods or] services that may be of interest to you.
profile information, and
Necessary for our legitimate interests (to develop our products/services and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
newsletter information, and
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)
To provide and improve our Website, including auditing and monitoring its use, providing and improving our Service to you and managing and administering our relationship with you.
technical information, and
Necessary for our legitimate interests to provide and improve our website, including auditing and monitoring its use; providing and improving our Service to you; or managing and administering our relationship with you;
Necessary to fulfil our legal, regulatory and risk management obligations.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will receive marketing communications from us or a third party if you have requested information from us or purchased goods from us and have opted in to receiving that marketing. We will always get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any newsletter sent to you or by contacting us at any time.
Your Data is separate from and should be distinguished from User Uploaded Data. “User Uploaded Data” is data uploaded by you or others through your Account/your use of the Service when you use the comment function and the blog function on our website. We strongly recommend that you avoid uploading any Personal Data in any User Uploaded Data. We reserve the sole right to review, edit or delete User Uploaded Data. We also moderate all User Uploaded Data in order to ensure that it does not contain Personal Data. Notwithstanding this, we are a Processor and you are the Controller in respect of User Uploaded Data (to the extent that it includes Personal Data).
If you are a Controller in respect of any Personal Data of other data subjects contained in User Uploaded Data, then you must comply with all of your Controller obligations under Data Protection Legislation in that regard.]
[We use the following types of cookies:
You can find a list of cookies we use and the purposes for which we use them in the tables below.
[You can find a list of third party cookies we use and the purposes for which we use them in the tables below.
[Third party cookies]
[We do not share the information collected by the cookies with any third parties.] ]
[We use Google Analytics to obtain high-level “audience measurement” data such as the referral web domain, type of operating system/browser used, date and time of visit, and other information relating to activities on our Website to understand its usage better, analyse trends, and optimize the Website experience. To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.]
We use Google tracking cookies to understand if you complete certain actions on our website after you have seen or clicked through one of our adverts served via Google. Based on the content you have engaged with on our website, Google delivers some targeted advertisements across other Google partner websites. For more information, visit: https://support.google.com/ads/answer/2662922?hl=en.
The ‘Help Menu’ on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can also disable or delete similar data used by browser add-ons, such as flash cookies, by changing the add-on’s settings or visiting the website of its manufacturer.
For more information about cookies and managing them including how to turn them off, please visit www.cookiecentral.com. 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 fully experience the interactive features of our Service/Website or other related websites/applications which you visit/use.
We may contact you:
As a data subject, you have the following rights under Data Protection Legislation and we, as controller in respect of Your Data, will comply with such rights in respect of Your Data:
These rights are explained in more detail below, but if you have any comments, concerns or complaints about our use of your Personal Data, please contact us (see ‘How To Contact Us’ below). We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex or cumbersome, in which case we will respond within three months (we will inform you within the first month if it will take longer than one month for us to respond). Where a response is required from us within a particular time period pursuant to Data Protection Legislation, we will respond within that time period.
You may ask to see what Personal Data we hold about you and be provided with:
Requests for your Personal Data must be made to us (see ‘How To Contact Us’ below) specifying what Personal Data you need access to, and a copy of such request may be kept by us for our legitimate purposes in managing the Service. To help us find the information easily, please give us as much information as possible about the type of information you would like to see. If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person, if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person, if possible.
There are certain types of data which we are not obliged to disclose to you, which include Personal Data which records our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations. We are also entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the Personal Date requested, we may charge you a reasonable fee to account for administrative costs of doing so), or (ii) we are entitled to do so pursuant to Data Protection Legislation.
You can require us to correct any mistakes in your Personal Data which we hold free of charge. If you would like to do this, please:
If we are required to update your Personal Data, we will inform recipients to whom that Personal Data have been disclosed (if any), unless this proves impossible or has a disproportionate effort.
It is your responsibility that all of the Personal Data provided to us is accurate and complete. If any information you have given us changes, please let us know as soon as possible (see ‘How to Contact Us’ at Section 18 below).
We have a legitimate interest to send you electronic communications in connection with the Service and related matters (which may include but shall not be limited to newsletters, announcement of new features etc. and which may also appear on social media platforms such as Facebook, LinkedIn, Twitter or Instagram.). We may also ask you for your consent to send you direct marketing from time to time. You may be able to select your preferences with respect to direct marketing when registering Your Account. We may also ask you different questions for different services, including competitions. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please:
We will provide you with information on action taken on a request to stop direct marketing – this may be in the form of a response email confirming that you have ‘unsubscribed’. Unsubscribing from direct marketing does not unsubscribe you from essential electronic communications in respect of the administration of Your Account.]
You may ask us to ensure that, if we are evaluating you, we don’t base any decisions solely on an automated process and have any decision reviewed by a member of staff. Profiling may occur in relation to your Personal Data for the purposes of targeted advertising and de-targeting you from specified advertising. This allows us to tailor our advertising to the appropriate customers and helps to minimise the risk of you receiving unwanted advertising. These rights will not apply in all circumstances, for example where the decision is (i) authorised or required by law, (ii) necessary for the performance of a contract between you and us, or (ii) is based on your explicit consent. In all cases, we will endeavour that steps have been taken to safeguard your interests.]
In accordance with Data Processing Legislation, you may request that we stop processing your Personal Data temporarily if:
If you exercise your right to restrict us from processing your Personal Data, we will continue to process the Personal Data if:
In accordance with Data Protection Legislation, you may ask for an electronic copy of your Personal Data that you have provided to us and which we hold electronically, or for us to provide this directly to another party. This right only applies to Personal Data that you have provided to us – it does not extend to data generated by us. In addition, the right to data portability also only applies where:
In accordance with Data Protection Legislation, you can ask us (please see ‘How To Contact Us’ below) to erase your Personal Data where:
We may continue to process your Personal Data in certain circumstances in accordance with Data Protection Legislation (i.e. where we have a legal justification to continue to hold such Personal Data, such as it being within our legitimate business interest to do so (e.g. retaining evidence of billing information etc.). Where you have requested the erasure of your Personal Data, we will inform recipients to whom that Personal Data have been disclosed, unless this proves impossible or involves disproportionate effort. We will also inform you about those recipients if you request it.
We restrict access to Your Data to employees, contractors, and agents who need such access in order to operate, develop, or improve our Service. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, civil litigation and/or criminal prosecution, if they fail to meet these obligations. We may also share Your Data with our third party suppliers who assist us in the provision of the Service.
We also share Your Data with various third parties (subject to having appropriate contracts in place with such third parties).
All information you provide to us is stored on our (or contracted third party) secure servers. Where we have given you (or where you have chosen) a password which enables you to access any part of our Service, you are responsible for keeping this password confidential. We ask you not to share a password with any person not authorised to use the Service.
If Your Data contains any material which may reasonably be deemed to be offensive, inappropriate or objectionable or otherwise engage in any disruptive behaviour in relation to the Service, we may remove such content and/or suspend the use of Your Account. We may also remove any such material from any of our social media pages.
Where we reasonably believe that you are or may be in breach of any applicable laws, for example on hate speech, we may disclose your personal information to relevant third parties, including to law enforcement agencies or your internet provider. We would only do so in circumstances where such disclosure is permitted under applicable laws, including Data Protection Legislation.]
We do our utmost to protect user privacy through the appropriate use of security technology. We restrict access to Your Data to employees, contractors and agents who need to know Your Data in order to operate, develop or improve the services that we provide. We ensure that we have appropriate physical and technological security measures to protect your information; and we ensure that when we outsource any processes that the service provider has appropriate security measures in place. However, our Service may contain hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, including cookies. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
We will implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks that are presented by the processing of Your Data. In particular, we will consider the risks presented by accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Your Data transmitted, stored or otherwise processed.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect Your Data, we cannot guarantee the security of any data transmitted to us and any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. To the extent permitted by law, we are not responsible for any delays, delivery failures, or any other loss or damage resulting from (i) the transfer of data over communications networks and facilities, including the internet, or (ii) any delay or delivery failure on the part of any other service provider not contracted by us, and you acknowledge that our Service may be subject to limitations, delays and other problems inherent in the use of such communications facilities. You will appreciate that we cannot guarantee the absolute prevention of cyber-attacks such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorized disclosure, loss or destruction of Your Data arising from such risks.
We will notify serious data breaches in respect of Your Data to the DPC without undue delay, and where feasible, not later than 72 hours after having become aware of same. If notification is not made after 72 hours, we will record a reasoned justification for the delay; however, it is not necessary to notify the DPC where the Personal Data breach is unlikely to result in a risk to the rights and freedoms of natural persons. A Personal Data breach in this context means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.
We will keep a record of any data breaches, including their effects and the remedial action taken, and will notify you of any data breach affecting your Personal Data (which poses a high risk to you) when we are required to do so under Data Protection Legislation. We will not be required to notify you of a data breach where:
Your Data will be kept and stored for such period of time as we deem necessary taking into account the purpose for which it was collected in the first instance. This may include retaining Your Data as necessary to administer Your Account, comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Service.
Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Service, not to specifically analyse personal characteristics about you.
If you need to contact us with regard to any of your rights as set out in this Policy, all such requests should be made in writing by email to firstname.lastname@example.org