Privacy Policy

Six By You for both iOS & Android devices (the app) is provided by Six By Nico (Holdings) LTD, trading as Six By Nico (‘we’, ‘our’ or ‘us’). 

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 any information relating to you (your information).

It also explains your rights in relation to your information and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your information is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).

We are the controller of your information obtained via the app, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

The app is solely intended for use by people in the UK + IE who are Six By Nico Customers.

This privacy policy is divided into the following sections:

  • What this policy applies to
  • Information we collect about you
  • Location services/data
  • How your information is collected
  • How and why we use your information
  • Marketing
  • Who we share your information with
  • How long your information will be kept
  • Transferring your information out of the UK
  • Your rights
  • Keeping your information secure
  • How to complain
  • Changes to this privacy policy
  • How to contact us

 

What this policy applies to

This privacy policy relates to your use of the app only.

The app links to Sevenrooms to facilitate restaurant booking functionality, and Zonal Loyalty in order to track your restaurant rewards. These other apps, websites or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate.

 

Information we collect about you

The information we collect about you depends on the particular activities carried out through the app. We will collect and use the following information about you:

Category of data

In more detail

Identity and account data you input into the app

Registration is mandatory in order to use  the app

—your name, contact information, including email address and telephone number.

—information to check and verify your identity, eg date of birth

—your account details, such as username and password

—your replies to security questions

Data collected when you use specific functions in the app

—data you store online with us using the app including bookings and preferences (while such data may not always be protected by UK GDPR we will assume it is and treat it in accordance with this policy)

Data collected when you permit the collection of location data

—details of your location with a high degree of precision, see the section ‘Location services/data’ below

Other data the app collects automatically when you use it

—your activities on, and use of, the app which reveal your preferences, interests or manner of use of the app and the times of use

You must provide that information to use the app and its services unless we tell you that you have a choice. 

Sometimes you can choose if you want to give us your information and let us use it. Where that is the case we will tell you and give you the choice before you give the information to us. We will also tell you whether declining to share the information will have any effect on your use of the app or our services.

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

 

Location services/data

The app will request your consent to use location services to precisely identify your location each session (ie each time the app is opened or has been placed in the background. We require access to that data in order to identify Six By Nico restaurants and events near you.

If you do not provide your consent, you may use the app but that will mean the ‘find a restaurant’ feature on the app will not be available. To withdraw your consent at any time you can disable the geo-location permissions from within the settings area (that will not affect the lawfulness of our use of that data in reliance on the consent before it was withdrawn).

We will not process your location data other than strictly required to enable the ‘find a restaurant’ feature on the app, and to suggest local upcoming events.

The location services in the app will not operate unless location services/data are generally enabled on your device. You may disable such functionality at any time by references to device settings.

 

How your information is collected

We collect information from you directly when you input it into the app or indirectly, such as your activity while using the app.

 

How and why we use your information

Under data protection law, we can only use your information 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. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

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

What we use your information for

Our reasons

Create and manage your account with us

For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you 

Providing services and/or the functionalities of the app to you

Depending on the circumstances:

—to perform our contract with you 

—for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you 

Conducting checks to identify you and verify your identity or otherwise to help prevent and detect fraud against you or us

For our legitimate interests, ie to minimise the risk of account or identity theft or fraud that could be damaging for you, a third party or us

To enforce legal rights or defend or undertake legal proceedings

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests, ie to protect our business, interests and rights

Communications with you not related to marketing, including about changes to our terms or policies or changes to the app or service or other important notices

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests, ie to provide the best service to you

Protect the security of systems and data used to provide the app and its services

To comply with our legal and regulatory obligations

We may also use your information to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

Operational reasons, such as improving efficiency, training and quality control or to provide support to you

For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you 

Statistical analysis to help us understand our customer base

For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you 

Updating and enhancing customer records

Depending on the circumstances:

—to perform our contract with you 

—to comply with our legal and regulatory obligations

—where neither of the above apply, for our legitimate interests, eg making sure that we can keep in touch with our customers about existing orders and new products

Disclosures and other activities necessary to comply with legal and regulatory obligations, eg to record and demonstrate evidence of your consent to our use of your information where relevant 

To comply with our legal and regulatory obligations

Marketing our services to existing and former customers 

For our legitimate interests, ie to promote our business to existing and former customers

See ‘Marketing’ below for further information.

To share your information with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency

In such cases, information will be anonymised where possible and only shared where necessary

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets

 

How and why we use your information—in more detail

More details about how we use your information and why are set out below:-

Purpose

Processing operation

Lawful basis relied on under UK GDPR

Relevant categories of your information

Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices 

Addressing and sending communications to you as required by data protection laws, i.e.: UK GDPR or Data Protection Act 2018

Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b))

—your name and contact information, including email address and telephone number 

—your account details (username)

   

Addressing and sending communications to you about changes to our terms or policies or changes to the products or other important notices

Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you

—your name and contact information, including email address and telephone number

—your account details (username)

 

How and why we use your information—sharing

See ‘Who we share your information with’ for further information on the steps we will take to protect your information where we need to share it with others.

 

Marketing

We will use your information to send you updates (by email, text message, telephone or post) about our app including exclusive offers, promotions or new features.

We have a legitimate interest in using your information for marketing purposes (see above ‘How and why we use your information’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that 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:

  • contacting us at app@sixbynico.co.uk
  • using the ‘unsubscribe’ link in emails
  • updating your marketing preferences on our app

We will always treat your information with the utmost respect and never sell or share it with other organisations outside of Six Company for marketing purposes unless you specifically agree.

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

 

Who we share your information with

We routinely share your information with:

  • service providers we use to help us run our business or provide the services or functionalities in the app: Amazon Web Services (AWS) for storing app data and files, Sevenrooms with our restaurant reservations and surrounding  information, Airship .co.uk  as our CRM, and AndersenLab as our development partners.

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 occasionally may also need to share your information with:

  • our external auditors, e.g. in relation to our accounts—the recipient of the information will be bound by confidentiality obligations
  • our professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
  • law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
  • other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your information will be bound by confidentiality obligations

 

Who we share your information with—further information

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

 

How long your information will be kept

We will keep your information in relation to the App for as long as you remain a user of the app. If you wish for your information to be deleted then contact us at app@sixbynico.co.uk and we will delete or anonymise your information.

 

Transferring your information out of the UK

Countries outside the UK have differing data protection laws, some of which may provide lower 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.

Occasionally we may transfer your information from the UK to our Six By Nico located outside the UK in Dublin.

Under data protection laws, we can only transfer your information to a country outside the UK 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 UK GDPR
  • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
  • a specific exception applies under relevant data protection law

We transfer your information outside the UK to the following countries based on adequacy regulations: Ireland.

In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your information outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law. 

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

 

Transferring your information out of the UK—in more detail

More details about the countries outside the UK to which your information is transferred are set out below:

Recipient country

Recipient

Processing operation (use) by recipient

Lawful safeguard

Ireland

Six By Nico (Dublin) Fd Limited (Rbk House, Irishtown, Athlone, Westmeath N37 XP52)

Shared mailing database between our UK and Dublin restaurants.

Legally-approved standard data protection clauses for transfers from a controller to processor recognised or issued further to Article 46(2) of UK GDPR

 

Transferring your information out of the UK—further information

If you would like further information about data transferred outside the UK, please contact app@sixbynico.co.uk. (see ‘How to contact us’ below).

 

Your rights

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

Access to a copy of your information

The right to be provided with a copy of your information

Correction (also known as rectification)

The right to require us to correct any mistakes in your information

Erasure (also known as the right to be forgotten)

The right to require us to delete your information—in certain situations

Restriction of use

The right to require us to restrict use of your information in certain circumstances, eg if you contest the accuracy of the data

Data portability

The right to receive your information that 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 information being used for direct marketing (including profiling)

—in certain other situations to our continued use of your information, eg where we use your information for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims

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 the app

The right to withdraw consents

If you have provided us with a consent to use your information, you have a right to withdraw that consent easily at any time

You may withdraw consents by emailing us at app@sixbynico.co.uk

Withdrawing a consent will not affect the lawfulness of our use of your information in reliance on that consent before it was withdrawn

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under UK GDPR. 

If you would like to exercise any of those rights, please email or write to us—see below: ‘How to contact us’. When contacting us please:

  • provide enough information to identify yourself (eg your full name, email address and account number)] and any additional identity information we may reasonably request from you, and
  • let us know which right(s) you want to exercise and the information to which your request relates

 

Keeping your information secure

We have appropriate security measures to prevent your information from being accidentally lost, or used or accessed unlawfully. We limit access to your information 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.

 

How to complain

Please contact us if you have any queries or concerns 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.

You also have the right to lodge a complaint with the Information Commissioner. 

The Information Commissioner can be contacted using the details at https://ico.org.uk/make-a-complaint or 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 the app or by other means, such as email.

 

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.

Our contact details are:

Six by Nico Holdings Ltd (1st Floor, Pavilion 2. Junction 24 Business Park Glasgow G51 3AD)

app@sixbynico.co.uk