Privacy Statement for Business-to-business Marketing
This privacy statement (“Statement”) applies to the processing of personal data of prospective corporate customers’ employees, directors and where applicable other workers, such as independent contractors. This Statement covers how City Pantry Ltd T/A Just Eat for Business (hereinafter referred to as “JEfB”) handles their personal data to engage with them for the introduction and promotion of JEfB’s platforms and services for businesses (collectively, the “B2B Services”).
Unless otherwise stated or required by law, JEfB is responsible for the processing of personal data and will be the data controller for the personal data described in this Statement under the applicable data protection legislation.
This Statement does not apply to how third parties handle or use personal data. It is important that you read this Statement, together with any other privacy statement that may apply to you or that we may provide on specific circumstances or to specific services when we are collecting or processing personal data about you, so that you are aware of how, why we are using such data, your rights regarding your personal data and how to exercise them.
What Personal Data we process and why
To be able to interact with you, we collect and process your personal data. Personal Data, in this Statement also referred to as “your Data”, means any information or set of information from which we are able, directly or indirectly, to personally identify you, in particular by reference to an identifier, e.g. name and surname, email address, phone number, etc. It does not include data where the identity cannot be detected or has been removed (anonymous data such as business emails that do not allow identification of any individuals).
JEfB may process your Personal Data for the following purposes.
1. Marketing purposes
We collect and process the Personal Data that you provide to us or your publicly available business contact Data to be able to engage with you and introduce you to our B2B Services. With the collected business contact details, we can send marketing messages (emails, text messages and live calls) to you which may include the promotion of our B2B Services and may provide you with the latest news and updates about our B2B Services.
The legal basis for this processing is that it is needed in pursuing a legitimate interest of JEfB which is the promotion of B2B Services to our prospective corporate customers. To comply with the applicable direct marketing rules, JEfB takes commercially reasonable efforts to send marketing messages only to business addresses of individuals who are employed by or engaged with prospective corporate customers. JEfB also takes great care in sending the marketing messages to individuals who would expect to receive commercial messages from businesses such as JEfB and whose rights, interests and freedom would not be impacted by receiving such marketing communications.
Where obtaining the consent of such individuals is required to be able to send marketing messages, JEfB will ensure to obtain consent in accordance with the applicable laws.
Whenever you want to raise an objection with respect to receiving such marketing messages or usage of your Data for marketing purposes, you can unsubscribe by using the unsubscribe link in the messages or emailing dpo@citypantry.com.
You may also wish to sign up to one or more of the preference services operating in the United Kingdom: The Telephone Preference Service (“the TPS”) and the Corporate Telephone Preference Service (“the CTPS”). These may help to prevent you from receiving live calls related to marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
We process the following Personal Data for marketing purposes:
● Name
● Business Contact details
● Content of correspondences between you and JEfB
2. Analysing your interactions with our content and improving user experience
When you choose to interact with our marketing content that is sent to you via our marketing messages, we may process your Personal Data to analyse your engagement and interest in our content and to improve the content for a better user experience.
The legal basis for this data processing is your consent unless your consent is not necessary according to the applicable law. Before any Personal Data is collected, we obtain your consent via our content management platform. You are also free to interact with our content anonymously without giving consent in which case no Personal Data about you would be collected.
After you consent to the data processing, you can always withdraw your consent by contacting us by emailing dpo@citypantry.com.
Based on your consent, we process the below-stated Personal Data:
● Business email address
● IP address
● Content usage/viewing and interaction data, including information about which content, files or links you viewed or interacted with, for how long, which features have been used, the time and date of your visit, and the time spent with the content.
Additional purposes
We will only use your Personal Data for the purposes described above. If we want to use the data for a different purpose, we will take appropriate measures to inform you, consistent with the significance of the changes we make. Where required by applicable data protection law, we will obtain your consent.
How long we keep your data
We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including the purposes of satisfying any legal, tax, accounting, or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may anonymise your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Sharing of your Personal Data
JEfB may work and/or share data with other companies affiliated with Takeaway.com Group B.V. (hereinafter referred to as “JET Group” or “Group Companies”) and other third parties in order to carry out the processing described above.
These Group Companies and third parties will process your Personal Data on behalf of us (as data processors) or as autonomous data controllers and have access to your Personal Data for the purposes described in this Statement. We require Group Companies and third parties to protect it in accordance with the standards set out in this Statement and we take appropriate measures pursuant to the applicable data protection laws to guarantee the same level of protection and confidentiality of your Personal Data.
We will also share your Data with other third parties where appropriate or required by applicable law or regulation (including a court order) or where we believe disclosure is necessary to exercise, establish or defend legal rights or to protect the vital interests of any person. Such third-party controllers may include law enforcement agencies.
We may also disclose your Data to any company or prospective buyer of all or substantially all of our assets in connection with any sale or transfer of those assets.
Your Personal Data may be shared with the following parties:
● Affiliates, subsidiaries and/or group companies of JET Group
● Service providers such as providers for software, hosting, delivery, logistics, information security, marketing content management etc.
● Implementation partners
● Professional consultants
● Law enforcement, regulatory bodies and/or government agencies
● Prospective buyers
● Any other party provided that you have given your consent to the disclosure
Third-party websites
The communications you may receive from us may include links to third-party websites. When accessing such third-party websites, bear in mind that each of these websites has its own privacy statement. Although JEfB takes great care in selecting websites to link to, we cannot take responsibility for the way in which they handle your Personal Data.
Where your data gets sent
We may transfer your Personal Data outside the United Kingdom.This may include transferring it to or accessing it from other jurisdictions, including jurisdictions that may not provide a level of protection equivalent to your local data protection laws (“Third Countries”). While your Personal Data is processed in those Third Countries (for example, countries other than New Zealand, Canada, Israel or the EEA), it is also subject to the laws of the country in which it is held and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws in those jurisdictions.
Where we transfer Personal Data outside the United Kingdom, we will implement appropriate safeguards, including, when required, contractual restrictions regarding confidentiality and security in line with the applicable data protection laws and regulations. We have implemented similar appropriate safeguards with our third party service providers and further data can be provided upon request.
Personal Data rights, questions or complaints
We inform you that, with regard to Personal Data, you can exercise the rights provided for by applicable data protection laws, which may include:
● The right to be informed: Obtain information about our collection and use of your Personal Data.
● The right to access: Get access to the Personal Data we hold about you, gain information on how your Personal Data is being processed by us and under certain
conditions obtain a copy of your Personal Data undergoing processing.
● The right to verify the accuracy of your Personal Data: Request rectification if any of your Personal Data held by us is inaccurate, incomplete or requires an update.
● The right to be forgotten: Under certain circumstances you have the right to ask us to delete or otherwise dispose of any of your Personal Data that we hold.
● The right to restrict (i.e. prevent) the processing of your Personal Data: If the requirements are met, we will not process your Personal Data for any purpose other
than storing it.
● The right to object to us using your Personal Data for a particular purpose(s): We will stop processing your Personal Data upon your request if we process your Personal Data on another legal basis than consent.
● The right to withdraw consent: If we are relying on your consent as the legal basis for using your Personal Data, you are free to withdraw that consent at any time. Your
request will not prejudice the lawfulness of the processing based on the consent given prior to the withdrawal.
● The right to data portability: If you have provided Personal Data to us directly, we are using it with your consent or for the performance of a contract, and that data is
processed using automated means, you can ask us for a copy of that Personal Data in a structured, commonly used and machine-readable format (if technically feasible) to re-use with another service or business in many cases.
● Rights relating to automated decision-making and profiling.
● Lodge a complaint: You have the right to bring a claim before your competent data protection authority. We would welcome the opportunity to resolve your concerns
ourselves, however, so please contact us first.
To exercise your rights please contact us by emailing dpo@citypantry.com.
Please keep in mind that email communications are not always secure. Therefore, please do not include sensitive information in your emails to us.
We will do our best to address your request on time and free of charge, except where it would require a disproportionate effort. In certain cases, we may ask you to verify your identity before we can act on your request.
It is important that your Personal Data is kept accurate and up-to-date. If any of the Personal Data we hold about you changes, please keep us informed as long as we have that data. If you share with us the data of other people, it is your responsibility to collect such data in compliance with local legal requirements. For instance, you should inform such other people, whose data you provide to us, about the content of this Statement and obtain their prior consent.
If you have any other questions or complaints about the processing of your Personal Data, we will be happy to talk to you. We would also like to hear from you if you have tips or suggestions on how to improve our privacy policy. For more information about our use of your Personal Data or exercising your rights as outlined above, please contact us via emailing dpo@citypantry.com or the contact details set out below.
Security
JET takes Personal Data protection very seriously and we, therefore, take appropriate measures to protect your Personal Data against misuse, loss, unauthorised access, unwanted disclosure, and unauthorised alteration. If you feel that your Personal Data are not adequately protected or there are indications of misuse, please contact us via emailing dpo@citypantry.com.
Data Protection Authority
Besides the option of lodging a complaint with us, you have the right to lodge a complaint with the relevant supervisory authority for the protection of Personal Data. To do so, contact the supervisory authority directly.
How to contact us
If you have any questions or concerns about this Statement and/or our privacy practices, please contact us via emailing dpo@citypantry.com or the contact details set out below.
Just Eat Takeaway.com Data Protection Officer/ Privacy Council - Takeaway.com Group B.V.
Piet Heinkade 61
1019 GM Amsterdam
Netherlands
Updates to this privacy notice
We may update this Statement from time to time in response to changing legal, technical or business developments. When we update our Statement, we will take appropriate measures to inform you, consistent with the significance of the changes we make. Where required by applicable data protection law, we will obtain your consent to any material changes to this Statement.
We encourage you to periodically review this Statement for the latest information on our privacy practices.
This Statement may be updated and was last updated on 28th July 2022.
