Privacy Policy
This policy explains how we, SMARTQ, a brand of Bottle Lab Technologies PVT LTD, use your personal information which you provide to us when using our service, via our website and mobile applications (apps).
Introduction
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About this Privacy Notice
This is the customer privacy notice of Bottle Labs Technologies Pvt Ltd India, a company incorporated.
SmartQrespects your privacy and is committed to protecting your personal data. This privacy notices.
Informs you of who we are, how we collect, share, use and protect your personal data, however, you provide it to us, and tells you about your privacy rights and legal protections.
Purpose of this Privacy Notice
This privacy notice tells you how SmartQcollects and processes your personal data through your provision of that data to us and the use of the SmartQ services and is supplemental to the SmartQ Privacy Notice.
It is important that you read this privacy notice together with any other information 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 notice is complementary to the other information which we might provide in specific circumstances and will not override it.
Contacts
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Who is the Controller and Data Protection Officer?
When we use "SmartQ", "we", "us" or "our" in this privacy notice, we are referring to Bottle Labs Technologies Pvt Ltd. This company is the “controller” for your personal data under the applicable legislation and it is primarily responsible for processing and ensuring proper protection of your data.
We have appointed an IT Risk and security officer who is responsible for overseeing questions in relation to this privacy notice and data protection issues in general. If you have any questions about this privacy notice, including in relation to your legal rights, please contact the IT Risk and SecurityOfficer using the details set out below.
Contact Details
Full name of legal entity: Bottle Labs Technologies Pvt Ltd, India
Name or title of IT Risk and Security: IT Risk and Security Officer
Email address: Support@thesmartq.com
Postal address: Opp: BDA Head Office, 1st Floor, Future Group, VK Kalyani Commercial Complex, Sankey Rd, Bengaluru, Karnataka 560051
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the SmartQ Indiasupervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO; so please contact using the first instance.
What personal data we use
Information that we collect directly from you
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Identity Data may include first name, last name, username, or similar identifier.
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Contact Data may include such things as billing address, delivery address, email address, and telephone numbers.
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Financial Data may include bank account and payment card details where this type of data is relevant to the reason underlying our relationship (usually so we can provide you with products and services).
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Transaction Data may include details about payments to and from you and other details of products and services you have purchased from us.
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Profile Data may include your username and password (in those circumstances where you might have a technological relationship with us through a smartphone or computer), purchases or orders made by you, your interests, preferences, feedback, and survey responses.
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Marketing and Communications Data may include your preferences in receiving marketing from us and our third parties and your communication preferences. You will not be contacted for marketing purposes unless you have given us your express consent to do so.
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Location data may include where the facility that serves you is located. You select the location that you wish to use.
Information that we collect from your use of the app
Technical Data may include internet protocol (IP) address, 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 any of our websites.
Usage Data may include information about how you use our websites and purchase our products and services.
We also collect, use, and share aggregated Data such as statistical or demographic data that may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users buying a product.
We do not collect any Special Categories of Personal Data about you through most of the standard ways in which we might collect your data (this includes details about, your health, genetic or biometric data), and please do not provide us with any.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of 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 enter into) with you (for example, to provide you with goods or services). In this case, we may have to cancel access to the product or service you wish to obtain from us, but we will notify you if this is the case at the time. Information that we obtain from a third party.
Information provided to us from someone else
In some circumstances, we may have received your personal data from another organization. For example, as part of an agreement to provide catering services with your organization. In this case, we will use that personal data to configure your user profile without unreasonable delay and will not use that data for any other purpose. Both parties have a lawful reason to share your personal data.
Why we collect your personal data
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Purpose of processing
Below we detail the elements of your personal data that we process and the lawful basis for doing so:
Type of data: Lawful basis for processing.
Name: Performance of, or leading to a contract & legitimate interest.
Email address: Performance of, or leading to a contract & legitimate interest.
Mobile number: Performance of, or leading to a contract & legitimate interest.
Payment information: Performance of a contract.
Location data: Legitimate interest.
Your requests: Legitimate interest.
The location data are selected by you so that we can offer you a relevant menu and booking information for the location of the services we offer. We have a legitimate interest to know the location of the service you want us to offer you. Where you opt into receiving marketing communications, we may use your contact information to market similar goods and services that you already used or purchased. You may object to us using your data for marketing purposes at any time by contacting us directly. If you contact us, we will use the information to give to manage your request.
We process payment information to receive payment for the goods or services you buy from us and, if you choose, to hold a credit balance on your account.
Change of purpose
We will only use your personal data for the purposes for which we have 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.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via e-mail or text message. You have the right to withdraw consent to marketing at any time by contacting us.
With whom we share your personal data
We share your personal data with the following recipients. Restaurants and food outlets that provide services to you.Google Cloud who processes your personal data. Mailgun Technologies Inc uses your email address to validate your account. Our services who support and develop the app.SmartQand/or affiliates for internal administration purposes. Other third parties we may appoint from time to time for the purposes of internal business Administration.
Whenever we share your personal data, we require that our partners offer similar levels of data protection as we apply to your personal data. We do this through our contracts with them and have Data Transfer or Processing Agreements in place stating how and why we share your personal data, and how we apply controls, appropriate to the risk, to safeguard the confidentiality, integrity, and availability of your personal data.
In addition, we may share your personal data with Any any law enforcement or regulatory body, government agency, court, or other third parties where we believe disclosure is necessary under applicable law or regulations or we have a statutory obligation to do so. New owners or re-organized entities in the event of a business restructuring, sale, purchase, or joint venture affecting our business.Any other person if you have given your consent.
We partner with Stripe Inc to process card payments. Stripe is PCI compliant and we have standard contractual clauses in place with them. Our systems do not process any payment information or card details. Your payment is processed by Stripe and the pseudonymized transactional data is then shared with us.
How long we store your personal data
You are in control of your personal data through your use of the theTime2Eat App. The retention period ofyour personal data may vary depending on the use of that personal data. The longest we would retain your transnational data will be 7 years. If we keep data for longer than that for further transnationalanalysis, for research or statistical purposes, the data will be anonymized and therefore we will not beable to identify you from that data.
We retain personal information we collect from you via the Time2Eat App for as long as you are auser of the app. If you no longer want to use the Time2Eat App you may delete your account at any time through your account section within the Time2Eat App. If the corporate email addressyouregistered your account with is no longer valid, the owner of that corporate email address may deleteyour Time2Eat App. If it is not possible to delete your user account, then we will securely store yourpersonal information and isolate it from any further processing until deletion is possible.
Your rights
You have rights under data protection laws in relation to your personal data. Under certain circumstances your rights are as follows:
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Request access to your personal data(commonly known as a "data subject access request" or “DSAR”). This enables you to receive a copy of the personal data we hold about you in order to check that we are processing it lawfully.
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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.
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Request erasure of your personal data. This enables you to ask us to delete or remove personal data where you believe we have no legitimate reason for 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 obliged to comply fully with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
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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 situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. In some cases, we might demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
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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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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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 automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Again, it is subject to any overriding legal, accounting, and reporting rights we might have to retain copies of your data; and
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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.
If you wish to exercise any of the rights set out above, please contact us.
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 chargea reasonable fee if your request is clearly unfounded, repetitive,orexcessive. Alternatively, we may 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 may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
International transfer of personal data
Your personal data is processed in India. This is necessary to provide support services for the application and process payment of our goods and services. SmartQ imposes contractual obligations on the recipient of your personal information to ensure that the recipients are subscribed to “international frameworks” that aim to ensure adequate protection. We have appropriate mechanisms for the transfer and processing of personal data outside of India. We have carried out a Data Protection Impacts assessment relating to this processing and have carried out an additional assessment to safeguard your personal data and assets that you have essentially equivalent protection to that offered in India.SmartQimplements a range of organizational and technical security measures, such as cybersecurity training, role-based access, and encryption, where appropriate, to ensure personal data is secure.
Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data strictly to those employees, agents, contractors, and other third parties who have a need to know that data in order to further the transaction in which were both concerned. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
Grievance Officer
The customer may contact Mr. Madhusudhan R ("Grievance Officer") in the event of any discrepancies or grievances concerning the processing of information and the Grievance Officer shall address all such discrepancies and grievances within 15 days of receipt of such grievances. Bottle Lab Technologies Pvt Ltd(SmartQ) acts as a "Data Controller" for the Personal Information it processes in the framework of this Privacy Policy.
In case of any questions or comments regarding this Privacy Policy or Bottle Lab Technologies Pvt Ltd(SmartQ) Personal Information collection practices, the Customer may contact Bottle Lab Technologies Pvt Ltd(SmartQ) by
Bottle Lab Technologies PVT LTD
SmartQ, Opp: BDA Head Office, 1st Floor,
Future Group, VK Kalyani Commercial Complex,
Sankey Rd, Bengaluru, Karnataka 560051
Contact Number: +91 8043758844
Email: support@thesmartq.com