Privacy Policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data.

Key Terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	Toast Portal LLC, Toast, Toast DXB
Personal data	Any information relating to an identified or identifiable individual
Data subject	The individual who the personal data relates to

Personal data we collect about you

We may collect and use the following personal data about you:

your name and contact information, including email address and telephone number
information to check and verify your identity, eg your date of birth
your gender
location data
your billing information, transaction and payment card information
purchase history and saved items
information from accounts you link to us, eg Facebook
information to enable us to undertake credit or other financial checks on you
Information about how you use our website, IT, communication and other systems
your responses to surveys, competitions and promotions.

We collect and use this personal data to provide services to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.

How your personal data is collected

We collect most of this personal data directly from you—in person, by telephone, text or email and/or via our website and apps. However, we may also collect information:

from publicly accessible sources;
directly from a third party, eg: customer due diligence providers;
from a third party with your consent;
from cookies on our website
via our IT systems, eg: through automated monitoring of our websites and other technical systems, such as our computer networks and connections.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, eg:

where you have given consent;
to comply with our legal and regulatory obligations;
for the performance of a contract with you or to take steps at your request before entering into a contract; or
for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
Providing services to you	To perform our contract with you or to take steps at your request before entering into a contract
Preventing and detecting fraud against you or us	For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for you and/or us
Conducting checks to identify our customers and verify their identity Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety law or rules issued by our professional regulator	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, eg policies covering security and internet use	For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures	For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price
Preventing unauthorised access and modifications to systems	For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for you and/or us To comply with our legal and regulatory obligations
Updating and enhancing customer records	To perform our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products
Marketing our services and those of selected third parties to: —existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, ie to promote our business to existing and former customers

Marketing

We may use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.
We may ask you to confirm or update your marketing preferences if there are changes in the law, regulation, or the structure of our business.

Who we share your personal data with

We routinely share personal data with:

third parties we use to help deliver our services to you, eg payment service providers and venues;
other third parties we use to help us run our business, eg marketing agencies or website hosts;
third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
our insurers and brokers;
our bank

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

We may also need to:

share personal data with external auditors, eg in relation to the audit of our accounts;
disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations;
share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

Where your personal data is held

Personal data may be held at our offices, third party agencies, service providers, representatives and agents.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you of a suspected data security breach where we are legally required to do so.

How to complain

Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

Changes to this privacy policy

This privacy notice was published on [insert date] and last updated on [insert date].

We may change this privacy notice from time to time.

How to contact us

You can contact us by email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Our contact details

Toast Portal LLC
info@toastdxb.com