Azumi respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data in your dealings with us and your use of our websites (“Sites”) and tell you about your privacy rights and how the law protects you.
- Who we are and how to contact us.
- Your rights relating to your Personal Data.
- Marketing communications preferences.
- What Personal Data we collect.
- How we use your Personal Data and why.
- What happens when you do not provide necessary Personal Data?
- Personal Data from Third Party Sources.
- Who we share your Personal Data with.
- How we keep your Personal Data secure.
- How long we store your Personal Data.
- Our policy on children.
- Third party links.
Who we are and how to contact us.
Who we are.
Azumi Limited and its affiliates and associated companies is made up of different legal entities, details of which can be found here (“Azumi Limited Group”).
We will let you know which entity(ies) are the Controller(s) (for the purposes of the GDPR) of your Personal Data if you ask us to give you this information by contacting us at the details below.
How to contact us
You can contact us by emailing: [email protected].
Your rights relating to your Personal Data.
Your rights in connection with your Personal Data
Under certain circumstances, by law you have the right to:
- Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
- Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data. 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.
- Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Sites. We will advise you if this is the case at the time you withdraw your consent.
How to exercise your rights
If you want to exercise any of the rights described above, please contact us using the contact details shown here “Who We Are and How to Contact Us”.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.
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.
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 a number of requests. In this case, we will notify you and keep you updated.
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
Marketing communications preferences.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or and/or by contacting us at any time using the contact details shown here “Who We Are and How to Contact Us”.
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of restaurant reservations and other purchases where we require your Personal Data to complete your order.
What Personal Data we collect.
All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.
Before you read that table, it might be useful to explain what “Personal Data” is. The GDPR definition of Personal Data can be found here. Essentially, it boils down to: information about an individual, from which that individual is either directly identified or can be identified.
It does not include ‘anonymous data’ (i.e., information where the identity of individual has been permanently removed).
However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).
|Category of Personal Data collected||What this means|
|Identity Data||First name, surname, marital status, title, date of birth and gender.|
|Contact Data||Your home address, work address, billing address, email address and telephone numbers.|
|Financial Data||Your payment card details. Note that we pass any Financial Data we receive from you immediately to our third party payment processors. We do not store any of your Financial Data.|
|Transaction Data||Details about payments to and from you in respect of meals and gift cards you have purchased from us.|
|Marketing and Communications Data||Your preferences in receiving marketing from us and your communication preferences.|
|Behavioural Data||Inferred or assumed information relating to your behaviour and interests based on your online activity on our Sites.|
|Technical Data||Internet protocol (IP) address, 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 this website or use our services.|
|Allergy Data||Information about food allergies, intolerances and/or preferences you have.|
Special Categories of Personal Data
The GDPR defines “Special Categories of Personal Data” to include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. As noted above, we may (with your explicit consent) collect and use Allergy Data that you provide to us, which may constitute health data, in order to provide our services to you. We do not otherwise collect any Special Categories of Personal Data unless you provide your explicit consent to us to do so. We do not collect any information about criminal convictions or offences.
How we use your Personal Data and why.
We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
What is our “legal basis” for processing your Personal Data?
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:
- Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
Generally we do not rely on your Consent as a legal basis for using your Personal Data other than in the context of direct marketing communications.
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.
|Purpose||Category(ies) of Personal Data involved||Why do we do this||Our legal basis for this use of data|
|Reservations/ Bookings||• Identity Data
• Contact Data
• Transaction Data
|To secure and manage customer reservations.||Contractual Necessity.|
|Marketing||• Identity Data
• Contact Data
• Marketing and Communications Data
|To send you newsletters and offers which we think may be of interest to you.||Consent.
We obtain opt-in consent to send marketing communications to you.
|To process payments for gift cards||• Identity Data
• Contact Data
• Financial Data
• Transaction Data
|To process and deliver your order.||Contractual Necessity.|
|To process advance payments for bookings||• Identity Data
• Contact Data
• Financial Data
• Transaction Data
|To process your order to secure a reservation or to pay, or part pay, for a reservation in advance and allocate such payments correctly.||Contractual Necessity.|
|To improve our Sites||• Behavioural Data
• Technical Data
|To monitor use of our Sites, to improve our Sites and to help operate our Sites more efficiently, and to improve your experience on our Sites.||Legitimate Interests.
We have a legitimate commercial interest in ensuring that our Sites operate as efficiently as possible and that we improve our Sites based on information we learn from our users’ use of our Sites.
|To provide your order to you, taking your food allergies, intolerances and preferences into account||• Allergy Data||To ensure that we take into account information about your food allergies, intolerances and/or preferences when preparing and delivering your order to you.||Explicit Consent.
We obtain your explicit consent to use data relating to your food allergies and intolerances.
We have a legitimate interest in taking your food preferences into account when preparing and delivering your order to you, to ensure that you are satisfied with the services you receive from us.
What happens when you do not provide necessary Personal Data?
Where we need to process your Personal Data either to comply with law, or to perform 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 the functionalities of the Sites).
In this case, we may have to stop you using our Sites but we will notify you if this is the case at the time.
Personal Data from Third Party Sources
In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.
|Third party data source||Publicly available?||Category(ies) or other types of personal data received.|
|Online booking platforms||No||• Identity Data
• Contact Data
• Transaction Data
|Gift card purchase platform||No||• Identity Data
• Contact Data
• Transaction Data
|Analytics providers||No||• Behavioural Data
• Technical Data
What are cookies?
We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Sites.
We use two broad categories of cookies:
- first party cookies, served directly by us to your computer or mobile device; and
- third party cookies, which are served by our partners or service providers on our Sites.
Cookies we use
Our Sites use the following types of cookies for the purposes set out below:
|Type of cookie||Purpose|
|Essential Cookies||These cookies are essential to provide you with services available through our Sites and to enable you to use some of its features.|
|Functionality Cookies||These cookies allow our Sites to remember choices you make when you use our Sites, such as remembering your language preferences. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Sites.|
|Analytics and Performance Cookies||These cookies are used to collect information about traffic to our Sites and how users use our Sites. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Sites. The information collected is aggregated and anonymous. It includes the number of visitors to our Sites, the websites that referred them to our Sites, the pages they visited on our Sites, what time of day they visited our Sites, whether they have visited our Sites before, and other similar information. We use this information to help operate our Sites more efficiently, to gather broad demographic information and to monitor the level of activity on our Sites.
We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Sites work. You can find out more information about Google Analytics cookies here:
You can find out more about how Google protects your data here:
|Social Media Cookies||These cookies are used when you share information using a social media sharing button or “like” button on our Sites or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.|
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
If you do not accept our cookies, you may experience some inconvenience in your use of our Sites. For example, our Sites not remembering your language setting.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.
You can also prevent the use of Google Analytics relating to your use of our Sites by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
Who we share your Personal Data with.
The table below describes who we share your Personal Data with, what we share and why we share it.
|Recipients||Category(ies) of Personal Data we share.||Why we share it||Location(s)|
|Payment systems||• Financial data||To process payments via 3 rd party platforms in a PCI compliant manner.||• Within Europe|
|Reservations Platforms||• Identity Data
• Contact Data
|Our service providers provide us with IT systems that help manage our bookings and reservations process.||• Within Europe|
|Marketing Digital Platforms||• Identity Data
• Contact Data
|Our service providers administer our marketing communications with customers who have opted-in to receive such communications from us.||• Within Europe|
|Azumi Group Restaurants outside Europe & the Reservations Platforms they use||• Identity Data
• Contact Data
|We only share data with our restaurants outside Europe where a customer has requested that we do so to, for example, to make a reservation.||• Global|
As you can see from the above, we share your Personal Data with our affiliated companies within the Azumi Group and certain external third parties who are based outside the European Economic Area (“Europe”). Any processing of your Personal Data by these parties will involve an export of your Personal Data outside of Europe.
We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries.
- Where we use service providers outside Europe, we may use specific contracts approved by the European Commission, which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries.
- Where we use service providers based in the U.S., we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Data shared between Europe and the U.S. For further details, see European Commission: EU-U.S. Privacy Shield.
How we keep your Personal Data secure.
We have put in place appropriate technical and organizational security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We store all the personal information you provide on secure password and firewall protected servers.
We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
How long we store your Personal Data.
We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above “How we use your Personal Data and why.”, unless a longer retention period is required by law (for example for regulatory purposes).
The table below shows our standard retention practices:
|Category of Personal Data||Retention period|
|Identity Data||Where you have not opted in to receive marketing communications from us or for your data to be held on our customer database, your Identity Data will be deleted after two (2) years from the date of your last visit.|
|Contact Data||Where you have not opted in to receive marketing communications from us or for your data to be held on our customer database, your Contact Data will be deleted after two (2) years from the date of your last visit.|
|Financial Data||We pass any Financial Data we receive from you immediately to our third party payment processors. We do not store any of your Financial Data.|
|Transactions Data||We store Transactions Data for a period of two (2) years from the date of your last visit.|
|Marketing and Communications Data||We store Marketing and Communications Data until you unsubscribe from our marketing communications.|
|Behavioural Data||We anonymise Behavioural Data almost immediately following collection. We then retain Behavioural Data in anonymised form for thirty-eight (38) months.|
|Technical Data||We anonymise Technical Data almost immediately following collection. We then retain Technical Data in anonymised form for thirty-eight (38) months.|
|Allergy Data||We store Allergy Data for a period of two (2) years from the date of your last visit.|
Our policy on children.
Our Sites are not intended for children below 16 and we do not knowingly collect data relating to children via our Sites.
However, you may provide us with Identity Data relating to children where, for example, you make a booking for a child’s birthday party, and we may store this information on your account. In providing us with this Identity Data, you are agreeing that you hold parental responsibility for that child or that you have been properly authorised by the holder of parental responsibility for the child to give us this Identity Data to use for these purposes.
Third party links.
Azumi Limited, 2018
STATEMENT PURSUANT TO THE MODERN SLAVERY ACT 2015
FOR FINANCIAL YEAR 2018/19
This document has been published in accordance with the Modern Slavery Act 2015 and constitutes the modern slavery and human trafficking statement for Azumi Ltd and its relevant subsidiaries.
We have zero tolerance to slavery and human trafficking of any kind in our operations and supply chain. We are proud of the steps we have taken to date in order to combat slavery and human trafficking and we are committed to improving our practices to combat slavery and human trafficking wherever required in the future.
We are a luxury global restaurant group in the hospitality sector. Azumi Ltd, headquartered in London trades under the restaurant brands Zuma, Roka, Oblix, Etaru and Inko Nito.
Azumi Ltd has over 2,000 employees worldwide and owns and operates restaurants in Europe, the United States of America, Middle East and South East Asia. Azumi Ltd has suppliers in the UK and internationally.
As a responsible business, we recognise our responsibility to ensure that our business activities are guided by the careful balance of the interests of our stakeholders and it is our responsibility to promote high standards of ethical behaviour across our supply chain.
Our policies on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Our supply chains
Our supply chains include suppliers from across the world. We require all of our direct suppliers to share our commitment to tackling modern slavery and human trafficking and expect that they will work closely with their own suppliers, distributors and producers to promote total transparency and knowledge of operations within our supply chain.
Due diligence processes for slavery and human trafficking
As part of our initiative to identify and mitigate risk we have in place systems to:
• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.
• Protect whistle blowers.
The steps we have taken include:
• Appointing an appropriate Compliance Officer with responsibility, together with the Group HR Director, for overseeing the implementation and application of policies and procedures to prevent modern slavery and the annual preparation of our Slavery and Human Trafficking Statement.
• The Compliance Officer and Group HR Director will report annually to the Board of Directors on slavery and human trafficking issues. Notes of all relevant meetings will be taken and retained to evidence this.
• The Company has a whistle blowing policy which ensures there are adequate procedures for staff to report modern slavery issues in the firm and its supply chain. A copy can be found within the Employee Handbook.
• We are prepared to respond to enquiries and challenges from inside and outside of the organisation on slavery and human trafficking within the firm and its supply chain. Any such enquiries will be handled as soon as possible and confirmed in writing.
• We have instigated a comprehensive firm-wide risk assessment, charting the firm’s supply chains across the Company in order to identify potential modern slavery risk areas.
• We rigorously check that all our employees have the right to work in this country and we ensure pay at or above the national minimum wage.
• We apply the same rigorous checks to ensuring that any agency workers are similarly checked by their respective employer and that no bonded labour is supplied.
• All our employees are paid by bank transfer and we do not allow payment to be made into third party bank accounts therefore minimising the risk of forced labour. However we do employ family members and where possible we avoid this being a direct reporting relationship. In the event that this is the case, line managers are aware and monitor the situation.
OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
We will continue to keep under review and make all efforts to identify any significant risks in our business activities and supply chain and implement any actions appropriate or necessary directly with suppliers.
The Company and its Directors will review and update this policy on an annual basis and signed off as required.
This statement is made pursuant to section 54(6) of the Modern Slavery Act 2015.
Chief Executive Officer