River Exe Café Privacy Policy

Who we are

https://www.riverexecafe.com/ (our website) is provided by River Exe Cafe Ltd (‘we’, ‘our’ or ‘us’). We are a custom-built barge and floating restaurant that floats well off shore in the Exe Estuary. We provide a water taxi service, and we offer a wide range of locally-sourced food.

We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

Your Privacy

We take your privacy very seriously and this privacy policy contains important information about how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

Our company is based in the UK as is our website and our on-shore shop. When we collect, store, use and share certain personal data about you, we do so in accordance with the UK General Data Protection Regulation (which is the Retained Regulation (EU) 2016/679), as tailored by the Data Protection Act 2018 (UK GDPR Regime).

Minors

Given the nature of our website, we do not expect to collect the personal data of anyone under 18 years old. If you are aware that any personal data of anyone under 18 years old has been shared with our website please let us know so that we can delete that data.

What this policy applies to

This privacy policy relates to:

your use of our website when you make a booking/reservation for our café restaurant and/or water taxi, when you make a venue private hire booking for a wedding or other occasion, when you purchase a product from us online (eg gift vouchers or River Café Exe Gin) or when you simply visit our website and have a look around;
when you visit our on-shore store and/or your make a booking there for our café restaurant and/or water taxi or venue private hire or you make an in store purchase; and/or
when you telephone or email us to make an enquiry or to make a café restaurant and/or water taxi booking or venue private hire booking.

We use Stripe Payments UK Limited to facilitate online purchases of goods by customers. Stripe is a provider of online secure and compliant integrated payment platforms for use by businesses. When you make a payment on our website the payment page is hosted by Stripe. For privacy information relating to how Stripe handles personal data please refer to their privacy policy here: https://stripe.com/en-gb/privacy.

We use Access Collins Hospitality Reservations and Bookings to facilitate café restaurant and water taxi bookings and reservations. Access Collins is an integrated booking management system provided by The Access Group for business use. The system enables you to make a booking/reservation with us, and it allows us to manage that booking efficiently. When you make a booking on our website the booking page is hosted by Access Collins and it is a part of a central booking system for River Exe Café provided by The Access Group but controlled by us, which allows us to take and manage bookings made by you online, in-store and via telephone. For privacy information relating to how Access Collins handles personal data please refer to their privacy policy here: https://www.theaccessgroup.com/en-gb/privacy-notice/.

We also use point of sale systems (POS) in-store and in-restaurant including Clover POS (customer card payments) and ICR Touch EPOS (restaurant transactions). When you pay for goods or services in-store (Clover) or in-restaurant (ICR Touch) these systems allow you to pay by card quickly and efficiently and allow us to manage the transaction. For privacy information relating to how Clover and ICR Touch handle personal data please refer to their respective privacy policies here: https://www.clover.com/privacy-policy and https://www.icrtouch.com/apple-privacy-policy; https://www.icrtouch.com/google-play-store-privacy-policy.

Throughout our website we will have links to some of the above companies. We may also have links that refer you to other websites owned and operated by other trusted third parties eg courier and delivery companies (we currently use Royal Mail), and links to certain social media platforms such as Facebook and Instagram. Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.

Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out by you through our website and/or when you visit our on-shore store and/or when you telephone us. It may include information necessary to process your restaurant (and/or water taxi) booking, your venue hire booking, your order for a product(s), about your interaction with the website, information about your device. We may also collect additional information if you contact us for customer support.

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

Booking and Order information, such as:
- Identity & contact information: name, title, billing address, shipping address, email address, phone number and company details (if you are a business customer), account details (if you register for an online account with us)
- Payment information: debit/credit card numbers, Paypal details or other payment method details;
- Profile information: booking history, purchase history, and saved items.
Customer support information, such as:
- Identity & contact information: name, address, telephone number and email address.
Device information, such as:
- Technical information: version of web browser, IP address, time zone, cookie information, what products you view, search terms, your contact history, how you interact with the website and what activities you undertake on it.

If you do not provide personal data we ask for where it is required (such as billing address, telephone number and name), it may delay or prevent us from fulfilling the order for you.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

How your personal data is collected

We collect personal data from you:

directly, when you enter or send us information, such as when you contact us (online, in-store or via telephone) to make a booking, when you contact us for any enquiries (including in store and via email or telephone) or for customer support, when you send us feedback, when you create an online account with us, when you subscribe to our mailing list for updates and offers, when you submit an order online to purchase a product or when you purchase a product in-store; and
automatically, when you access our website using cookies (please see our Cookie Policy).

How and why we use your personal data

Under the UK GDPR, we can only use your personal data if we have a lawful basis for doing so, 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 (see below)

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
Create and manage your online account with us	To perform our contract with you or to take steps at your request before entering into a contract.
To facilitate, create and manage your restaurant (and/or water taxi) booking with us – this includes online bookings, in-store bookings and telephone bookings.	To perform our contract with you or to take steps at your request before entering into a contract.
To provide our restaurant services and water taxi services to you.	To perform our contract with you or to take steps at your request before entering into a contract.
To provide products to you, to fulfill our contract with you, to process your payment information, arrange for shipping, and provide you with invoices and/or order confirmations, and communicate with you.	To perform our contract with you or to take steps at your request before entering into a contract.
To provide customer support to you	To perform our contract with you or to take steps at your request before entering into a contract. For our legitimate interests or those of a third party (to ensure best service or enhance service)
To screen reservations and orders for goods for potential risk or fraud	For our legitimate interests (to protect our business from risk)
To enforce legal rights or defend or undertake legal proceedings	Depending on the circumstances: to comply with our legal and regulatory obligations for our legitimate interests or those of a third party (to protect our business, interests and rights or those of others from risk)
To load the website accurately for you, and to perform analytics on the website usage to optimize our website (depending on your cookie preferences)	Where you have given consent For our legitimate business interests (ensure best customer experience/ enhance customer experience)
Marketing our products to you and on occasion those of selected third parties (depending on your marketing preferences)	Depending on circumstances: Where you have given consent For our legitimate interests (promoting our brand and services and products to increase sales) See further ‘Marketing’ below.
Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or services etc	To comply with our legal and regulatory obligations
Operational reasons, such as improving efficiency of service and quality control of products.	For our legitimate interests (managing quality of service and products)
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 (managing business information with view to improving)
Updating customer records	Depending on the circumstances: 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 where neither of the above apply, for our legitimate interests or those of a third party (ensuring accurate customer information).
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, eg to record and demonstrate evidence of your consents where relevant and to provide information on a Subject Access Request, request for erasure of personal data, right to rectify or right to object.	To comply with our legal and regulatory obligations

Marketing

We may use your personal data to send you information and updates (by email and by telephone and on occasion by text message) about our products and/or, including exclusive offers, promotions or new products.

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 will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the UK GDPR Regime and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

You have the right to opt out of receiving marketing communications at any time by:

emailing us at [email protected];
writing to us at
Unit 1, The Point, Pierhead
Exmouth
Devon
EX8 1FE
United Kingdom
using the ‘unsubscribe’ link within our emails or texting ‘STOP’ in response to marketing texts; or
updating your marketing preferences in your online account with us.

We may ask you to confirm or update your marketing preferences if you ask us to provide further products in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect, and we will never share it with other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

Who we share your personal data with

We routinely share personal data with trusted third party service providers to help us operate and manage our business and to provide our products and services to you and to fulfill our contracts with you. These include various technology providers, software programmes and IT systems, such as:

Digital Ocean (cloud hosting) to host our website;
Stripe to enable online payments for goods and services;
Access Collins to facilitate and enable restaurant and water tax reservations, and bookings management (online, instore and via telephone)
BCG Retail Ltd/ICR Touch EPOS system for restaurant transactions including customer order and pay
Fiserve/Clover POS system for in-store transactions – customer purchase and pay
Google and Gmail to manage and store customer data securely
IT specialists for occasional website support
Delivery and courier companies (we currently use Royal Mail) in the fulfilment of customer orders (we use Gmail to fulfil orders for gift vouchers)

We only allow the companies referred to above, to handle your information if we are satisfied they take appropriate measures to protect your information. We also impose contractual obligations on service providers to ensure they can only use your information to provide services to us and to you.

We or the third parties mentioned above may also need to share personal data with:

Companies in a transaction processing chain in connection with processing a payment transaction, such as merchants, banks or other card issuers, card associations, debit network operators and their members
external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used. Different retention periods apply for different types of personal data.

If you no longer have an account with us, or we stop supplying you products, we will delete or anonymise your account data after 6 years.

Transferring your personal data out of the UK

Countries outside the UK have differing data protection laws, some of which may provide different levels of protection of privacy. It is sometimes necessary for us to transfer your information to countries outside the UK. In those cases, we will comply with applicable UK laws designed to ensure the privacy of your information.

We may transfer your information from the UK to our service providers who are based outside the UK, including within the EEA and the USA.

If/when we transfer your information outside the UK we will only transfer to countries where:

the UK government has decided the particular country ensures an adequate level of protection of your information (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you
a specific exception applies under relevant data protection law

Any changes to the destinations to which we send personal data or in the transfer mechanisms we use to transfer personal data internationally will be notified to you in accordance with the section on ‘Change to this privacy policy’ below.

Cookies and other tracking technologies

A cookie is a small text file that is downloaded to your computer or device when you visit our website. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor. For more information on the cookies we use please refer to our cookie policy.

Your rights

You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your personal data	The right to be provided with a copy of your personal data
Correction (also known as rectification)	The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data—in certain situations
Restriction of use	The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object to use	The right to object: at any time to your personal data being used for direct marketing (including profiling) in certain other situations to our continued use of your personal data, eg where we use your personal data for our legitimate interests.
Not to be subject to decisions without human involvement	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not make any such decisions based on data collected by our website.

A more detailed explanation of your rights can be found on the Information Commissioners Office website at https://ico.org.uk/ on your rights under the UK GDPR.

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

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

We constantly seek to improve and maintain the highest level of service to our customers. But in the event you think that more could have been done, please contact us with your concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner in the UK. The UK’s Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

Changes to this privacy policy

We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example via email or by notification on our website.

How to contact us

You can contact us by post, 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 as follows:

By emailing us at [email protected];
By writing to us at
Unit 1, The Point, Pierhead
Exmouth
Devon
EX8 1FE
United Kingdom
By calling us on +44 1395 620022

Thanks for reading

River Exe Cafe Ltd

This revision was published 7th March 2022