Privacy Policy

Welcome to GinoRestaurants.com (the “Site”), a website operated in the United Kingdom by Upmarket Leisure Ltd, a company incorporated in England and Wales with company registration number 13017028, VAT number 375 4607 75 and whose registered office is located at Upmarket Leisure Ltd, Ridgefield House, 14 John Dalton Street, Manchester, M2 6JR United Kingdom. (“Upmarket Leisure Ltd”, “we”, “us” or “our”).

Upmarket Leisure Ltd values its customers and respects their privacy. Any information we collect about you is held with the utmost care and security. Your visit to our Site and your use of any of the services or features we provide, including the Gino Rewards Programme is subject to our terms and conditions of which this Privacy Policy forms part. This policy (together with our Cookie Policy and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting this Site or using any services or features offered on this Site you are freely accepting and consenting to the practices described in this Privacy Policy, in particular:
1) The processing of your personal data in accordance with this Privacy Policy as described in Section 3 of this Privacy Policy; and
2) The transfer of your personal data outside of the EEA or the UK as described in Section 5 of this Privacy Policy.

If you choose to decline to have your personal data processed or transferred in accordance with this Privacy Policy you may not be able to enjoy all the services and features we provide on our website.

We do not knowingly or intentionally collect any information from children under the age of 13. If you are under the age of 13 you may look at our Site but you may not make a purchase, register or submit any personal information to us. If we become aware that we have inadvertently received personal information from a visitor under the age of 13 on the Site, we will delete the information from our records.

For the purposes of applicable laws, the data controller is Upmarket Leisure Ltd, a company incorporated in England and Wales with company registration number 13017028, VAT number 375 4607 75 and whose registered office is located at Upmarket Leisure Ltd, Ridgefield House, 14 John Dalton Street, Manchester, M2 6JR

This Privacy Policy does not cover information that you submit on other websites, even if we communicate with you on those websites. For example, if you post something on Facebook, Twitter, Instagram or YouTube, that information is governed by the privacy policies on those websites and is not governed by this Privacy Policy.

Information we collect from you
1.1 Information you give to us. You may give us information about you by filling in forms on our Site during visits to our stores and events or by corresponding with us by telephone, e-mail, post or otherwise. This includes information you provide when you register to use our Site (which you must do if you would like to use some of the services and features we offer), subscribe to our services (such as our loyalty programme, “Gino Rewards Programme”), or place an order on our Site. This information may include: your name, age, date of birth and sex; your contact details (e.g. address, telephone number, e-mail address); debit or credit card information (if you wish to place an order on our Site); where you have registered a user or Gino Rewards Programme account with us, your user name and password; your communication and shopping preferences and interests; feedback and survey responses; correspondence with us; if you enrol in our Gino Rewards Programme information relating to your transactions, purchases and participation in the Gino Rewards Programme including Member rewards, and other personal information (such as enquiries, feedback, suggestions, ideas, photographs, messages or other information) that you may post, share, reproduce or otherwise make available to us. We may record or monitor calls that you receive from us or make to us. We do this for security and training purposes, and to improve the services we provide to you. When you register with us you can view your personal information in ‘My Account’. You can access ‘My Account’ directly to amend any personal details, for example if you change your address. If you forget your password, simply click on the ‘forgotten password’ link on the register or login page and an e-mail containing your decrypted password will be sent to the e-mail address that you originally provided

1.2 Information we collect about you. With regard to each of your visits to our Site, we may automatically collect the following information:
technical information including the Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
information about your visit including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any telephone number used to call our customer service number.

1.3 Information we receive from other sources. We may receive information about you if you use any of the other websites we (or any member or brand within our Group (as defined below)) operate or other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this Site. We are also working closely with third parties (including, for example sub-contractors in technical, payment and delivery services, advertising networks, marketing services, analytics providers, search information providers, and credit reference agencies) and may receive information about you from them.

Cookies
Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site.
For detailed information on the cookies we use and the purposes for which we use them, please see our detail below.

Use made of the information
We use information held about you in the following ways:
3.1 Information you give to us. We will use this information in relation to:
(a) Administration of our Site and performance of our contract with you: The information you give to us is necessary to enable us to (i) fulfil your order (including acknowledging your order and communicating with you if there is any issue regarding the fulfilment of your order); (ii) to make sure your order is delivered correctly; (iii) to maintain your account; (iv) accounting, billing, reporting and audit;(v) credit checking or screening (vi) authentication and identity checks (vii) credit, debit or other payment card verification and screening; (viii) debt collection; (ix) safety, security, health, training, legal and administrative purposes;

(b) Operate our loyalty programme: Gino Rewards: The information you give to us is necessary to enable us to: (i) enrol you in the Gino Rewards Programme; (ii) create a new, or link your existing, online user account to your Gino Rewards Programme account, enabling you to check your points balance on our Site, collect points when shopping on our Site and redeem points on our Site; (iii) administer the Gino Rewards Programme (including the provision of Member rewards), which may include the sharing of information with carefully selected third party partners to assist with the operation of the Gino Rewards programme; (iv) where you has provided your consent, offering products and services that are likely to be of interest including special events, offers, promotions, publications and catalogues by post, email and/or phone; and (v) market research and statistical analysis;

Providing customer service in pursuit of our legitimate interest as a retailer: We ask for your contact details such as your e-mail address and telephone number and order details to enable us to answer any questions you have about using our Site; to notify you about the status of your order or whether you have left a shopping basket with a product in it, and other customer care services such as identifying your requirements and shopping preferences. To provide those customer care services we may use your data for statistical and market analysis; studies, research and development by us, or a third party we appoint as a data processor pursuant to applicable laws.

Direct Marketing: In order to improve your shopping experience with us we want to keep you up-to-date on our latest products, promotional offers and events. If you are an existing customer, we may contact you by electronic means (email or text) about goods and services similar to those which were the subject of a previous sale or negotiations for a sale. We may do so by using your email address to match you on social media for the purposes of showing you direct marketing.

We may contact you as an existing customer by direct postal mail as it is in our legitimate interests to do so as a retailer seeking to market similar products or products we think you may be interested in. If you are a new customer, and where we permit selected third parties to use your personal information, we (or they) will contact you by electronic means only if you have expressly consented to this or we are otherwise permitted to do so in accordance with applicable laws.
We may use the information you provide and the information we collect about you to build a picture of your interests so that we may tailor our communications to you to ensure they are relevant and of interest to you and so that when you visit our site we can tailor your experience so that it is easier to shop with us.

Opt-out of Direct Marketing : You can at any time tell us not to send you marketing communications (i) by e-mail by clicking on the unsubscribe link within the marketing e-mails you receive from us; or(ii) by SMS by following the “STOP” instructions provided with the message or (iii) by postal mail by following the instructions that may be included in a particular promotion.. If you have registered with us, you may also opt out of receiving postal mail from us by logging into your account and amending your preferences.

(c) Our service: To notify you about changes to our service.
(d) Our Site: To ensure that content from our Site is presented in the most effective manner for you and for your computer, and so that we can enhance your experience of using our Site.

3.2 Information we collect about you. We will use this information in relation to:
(a) Administration of our Site: To administer our Site and for internal operations including troubleshooting, data analysis, testing, research, statistical and survey purposes. We may collect information from visitors to our site and analyse it to build up a picture of how people use our website. This helps us to improve the service we offer you.
(b) Site improvement: To improve our Site to ensure that content is presented in the most effective manner for you and your computer.
(c) Providing customer service in pursuit of our legitimate interest as a retailer: The information we collect from you will (i) allow you to participate in interactive features of our service when you choose to do so; (ii) allow us to measure or understand the effectiveness of advertising we serve to you and others; and (iii) allow us to make suggestions and recommendations to you and other users of our Site about goods or services that may be of interest to you or them when we are legally permitted to do so or with your prior consent.
(d) Security of our Site: As part of our efforts to keep our Site safe and secure.

3.3 Information we receive from other sources. We may combine the information we collect from you and the information you provide to us with information we receive from other sources. We may use this combined information for the purposes set out above (depending on the types of information we receive).

Disclosure of your information
4.1 We may share your personal information with any member or brand within our Group. Please visit www.manzanitacapital.com for more information about which members and brands constitute our Group. They may use the information in accordance with their privacy policies for purposes such as: financial reporting and analysis; strategic planning; the development of customer segmentation and metrics to provide a consistent view of our customer base; the creation of inspiring content and editorial features, and the development and sale of new products and collaborations to enhance your experience as a customer of Upmarket Leisure Ltd or other brands in the Group.

4.2 From time to time we retain the services of other carefully selected and monitored companies and individuals to perform functions on our behalf in connection with the successful operation and continuous improvement of this Site. These companies and individuals are appointed as data processors or as joint controllers. We may share your information with such third parties including:
(a) Suppliers and sub-contractors for the performance of any contract we enter into with them or you (e.g. in order to process your order and maintain your account, including the authorisation and validation of credit or debit card transactions, the provision of delivery services, the analysis of data.). These companies or individuals may be provided with access to your personal details in order to fulfil their function but may not use such information for any other purpose.
(b) Advertisers and advertising networks we appoint to assist us and who require the data to select and serve relevant adverts to you on our behalf including our third-party advertising partners and their service providers in order to deliver to you banner advertisements and other advertising tailored to your interests when you visit certain websites. Our advertising partner will make the data we provide it pseudonymous. To learn more about this information or to make choices about receiving personalised advertising provided by third parties, please visit the European Digital Interactive Advertising Alliance by clicking here: http://www.youronlinechoices.eu. We may also work with third parties (such as Facebook, Tik Tok and Instagram) to serve ads to you as part of a customized campaign on their platforms. If you prefer not to see customized ads from us, you can opt out by changing your account settings or preferences on such platforms.
(c ) Analytics and search engine providers that assist us in the improvement and optimisation of our Site.

4.3 We do not provide your personal details to other companies or individuals for their marketing purposes unless you have indicated that you wish to receive information about other companies’ products, offers and services.

4.4 We may disclose your personal information to other third parties:
(a) In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
(b) If Upmarket Leisure Ltd (or its ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006) or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
(c) If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use or terms and conditions of supply and other agreements; or to protect our rights, property, or safety (or the rights, property, safety of our customers, or others). This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store and process your personal data
5.1 The data that we collect from you may be transferred to and stored at a destination outside of the country in which it was originally collected. This may include transfers outside of the European Economic Area (“EEA”) or the UK (including to the USA) .The reason for this transfer is that some of the operations we need managed in order to complete our contract with you or to enhance your experience with us are located outside of the EEA or the UK, for instance it may be processed by staff working outside of the EEA or the UK who work for us or for one of our suppliers or service providers. Such staff may be engaged in, amongst other things, the fulfilment of your order, the processing of your payment details and the provision of support services including marketing and analytics. We may also transfer your data outside of the EEA or the UK when we transfer your data to any service provider or brand within our Group specified in Section 4.1, 4.2 and 4.4. of this Policy which may be required to exercise our legitimate interests as a retailer or to conclude our contract with you. You should be aware that personal information stored outside the country where it was collected may be available to government authorities of the countries where it is stored, under applicable data disclosure laws of those countries. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and applicable laws. We use the latest strong encryption technology to ensure that all transactional information is protected to the highest standard. Transactional information includes any credit or debit card details, your personal contact information together with any other names and addresses you provide when you place an order for delivery to another address, and your purchasing history. If you have given your consent prior to entering the details required for the ordering process, our Site will retain your Upmarket Leisure Ltd account details such as your name, address, e-mail address and purchasing history. Each time you log into your Upmarket Leisure Ltd account to create a new order you must re-enter your credit card details. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

5.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any 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.

Third party websites
Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Data Retention and Destruction
We store data for as long as it is necessary to provide products and services to you and others and so long as we are legally required to do so. Information associated with your account will be kept until your account is deleted, unless we no longer need the data to provide products and services, or until any legal requirement to keep it no longer exists. When we no longer need personal data, we securely delete and destroy it.

Rights of Data Subjects
As a data subject and in accordance with applicable laws you have the right to the following:
a right of access to a copy of the information comprised in their personal data;
a right to object to processing that is likely to cause or is causing damage or distress;
a right to prevent processing for direct marketing;
a right to object to decisions being taken by automated means;
a right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed; and
a right to claim compensation for damages caused by a breach of applicable laws.

Accessing and modifying your personal information
Applicable laws on data protection in the UK give you the right to access information held about you in accordance with applicable laws. We will respond to your access request within one month, in accordance with applicable laws. Subject to applicable laws, you also have the right to update and correct inaccuracies in your personal data, and have the information blocked or deleted, as appropriate. You may request to change your personal information by sending a written request by e-mail to [email protected] or by post to – The Company Secretary Upmarket Leisure Ltd, Ridgefield House, 14 John Dalton Street, Manchester, M2 6JR

Right to erasure
Requests for the deletion or removal of your personal data, including information published or processed online, should be sent by email to [email protected] or by post to – The Company Secretary Upmarket Leisure Ltd, Ridgefield House, 14 John Dalton Street, Manchester, M2 6JR

Right to data portability
If you would like access to any personal data which you have provided to us in a machine-readable format, or if you would like your data to be transferred directly to another data controller, please direct your request by email to [email protected] or by post to –
The Company Secretary Upmarket Leisure Ltd, Ridgefield House, 14 John Dalton Street, Manchester, M2 6JR

Changes to our Privacy Policy
Any changes we may make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Policy.

Contact
Questions, comments or requests regarding this Privacy Policy are welcomed and should be addressed by email to [email protected] or by post to –
The Company Secretary Upmarket Leisure Ltd, Ridgefield House, 14 John Dalton Street, Manchester, M2 6JR

Non-waiver
No failure to exercise and no delay on the part of Upmarket Leisure Ltd in exercising any right, remedy, power or privilege of Upmarket Leisure Ltd under this Privacy Policy and no course of dealing between us shall be construed or operate as a waiver, nor shall any single or partial exercise of any right, remedy, power or privilege preclude any other or further exercise thereof or the exercise of any other right, remedy, power or privilege on the part of Upmarket Leisure Ltd.

Law, jurisdiction and language
This Site, any content contained herein, and any contracts entered into as a result of usage of this Site are governed by English law. The parties to any such contract agree to submit to the exclusive jurisdiction of the courts of England and Wales. All contracts are concluded in English.

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