Privacy Policy Effective as of September 18, 2023. Please click here to view the previous version of our Privacy Policy. European users: If you are located in the European Economic Area (the “EEA”) or the United Kingdom (the “UK”), please read the Notice to European Users below in addition to this Privacy Policy for information about your personal information and your privacy rights.
This Privacy Policy describes how ELOMI Corporation (d/b/a Dorsia) and our subsidiaries (“Dorsia,” “we”, “us” or “our”) processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, mobile application, social media pages, marketing activities, live events and other activities described in this Privacy Policy (collectively, the “Service”)). Dorsia may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information. Index Personal information we collect How we use your personal information How we share your personal information Your choices Other sites and services Security International data transfers Children Changes to this Privacy Policy How to contact us California privacy rights notice Notice to European users Personal information we collect Information you provide to us. Personal information you may provide to us through the Service or otherwise includes: Contact data, such as your first and last name, salutation, email address, professional title, industry, and company name, and phone number. Demographic data, such as your city, state, country of residence, postal code, gender, and age. Membership application data, such as who referred you to the Service and anything else you share with our membership team as part of the application process. Profile data,such as the username and password that you may set to establish an online account on the Service, date of birth, referral code, biographical details, photograph or picture, links to your profiles on social networks, interests, dietary restrictions, dining and restaurant preferences, and any other information that you add to your account profile. Reservation data, such as the details about the restaurants you visit including the dates, times, and order details. Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise. Transactional data, such as information relating to or needed to complete your reservations on or through the Service, including transaction history. Payment data needed to complete transactions, including payment card information or bank account number. Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them. Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection. Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as: Public sources, such as public records, social media platforms, and other publicly available sources. Private sources, such as restaurants where you have dined or made reservations, data providers, social media platformsand data licensors. Our affiliate partners, such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs. Marketing partners,such as joint marketing partners and event co-sponsors. Third-party services, such as social media services, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service. Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as: Device data,such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area. Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them. Precise geolocation data when you authorize our mobile application to access your device’s location. Communication interaction data suchas your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Notice. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service. Data about others. We may offer features that help users refer/invite their friends or contacts to use the Service or to share their reservation details, and we may collect contact details about these other individuals so that we can deliver their invitations and other Reservation data. Please do not share the contact details of others with us unless you have their permission to do so.
How we use your personal information We may use your personal information for the following purposes or as otherwise described at the time of collection: Service delivery and operations. We may use your personal information to:provide, operate and improve the Service and our business; personalize the Service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service; establish and maintain your user profile on the Service; facilitate your referrals/invitations to friends who you want to invite to join the Service or with whom you share your Reservation Data; enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in; communicate with you about the Service, including by sending push notifications and Service-related announcements, updates, security alerts, and support and administrative messages; communicate with you about events or contests in which you participate; understand your needs and interests, and personalize your experience with the Service and our communications; and provide support for the Service, and respond to your requests, questions and feedback.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business. Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes: Direct marketing. We may send you emails, push messages and other direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below. Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section of our Cookie Notice.
Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.
Compliance and protection. We may use your personal information to:comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); audit our internal processes for compliance with legal and contractual requirements or our internal policies; enforce the terms and conditions that govern the Service; and prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
Retention. We generally retain personal information to fulfill the purposes for which we collected it. The criteria we use to determine the retention period are whether those purposes are fulfilled and whether we need to retain it for purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.
How we share your personal information We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection. Affiliates. Our corporate parent, subsidiaries, and affiliates. Service providers. Third partiesthat provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics). Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy. Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above. Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so. For example, we may share your personal information with third-party advertisers with whom we are collaborating to offer you additional services such as sweepstakes, raffles, and promotions. We will share personal information that is needed for these other companies to provide the services that you have requested. Restaurants. We may share your personal information, such as Contact data and Reservation data, with the restaurants where you have booked a table through the Service. Business and marketing partners. Third partieswith whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you. Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service. Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us. Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above. Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Dorsia, financing of Dorsia, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares); for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Dorsia as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Your choices In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights in theNotice to European Users below. Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by contacting our support team. You can find contact information for our support team on your account page in our mobile application. Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. You may opt-out of mobile push messages by disabling them in your mobile device’s settings.If you receive text messages from us, you may opt out of receiving further text messages from us by replying STOP to our message. Note that carriers are not liable for delayed or undelivered messages. As always, message and data rates may apply for any messages sent to you from us and to us from you. Cookies. For information about cookies employed by the Service and how to control them, see our Cookie Notice. Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings. Mobile location data. You can disable our access to your device’s precise geolocation in your mobile device settings. Privacy settings. We make available certain privacy settings on the Service, including options to control email notifications. Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com. Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services. Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party. Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us. Other sites and services The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
Security We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International data transfer We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. Users in Europe should read the important information provided in theNotice to European Users below about the transfer of personal information outside of Europe.
Children The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
Changes to this Privacy Policy We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.
How to contact us Email: legal@dorsia.com Mail: 3921 Alton Rd Suite 413Miami Beach, FL 33140 California privacy rights notice Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. You may send us requests for this information to legal@dorsia.com. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
Notice to European Users General Where this Notice to European users applies. The information provided in this “Notice to European users” section applies where we are processing the personal information of individuals located in the EEA or the UK (EEA and UK jurisdictions are together referred to as “Europe”) as a controller. Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information about individuals from which they are either directly identified or can be identified. Controller. Dorsia is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (including the EU GDPR and the so-called ‘UK GDPR’ (as and where applicable, the “GDPR”)). See the ‘How to contact us’ section above for our contact details. Our GDPR Representative. Pursuant to Article 27 of the UK GDPR, we have appointed EDPO UK Ltd as our UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR: • by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/ • by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom
Our legal bases for processing In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use. Our legal bases for processing your personal information described in this Privacy Policy are listed below.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 information 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”).
We have set out below the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see How we use your personal information above.
1. Service Delivery and Operations Information Involved: Contact data Demographic data Membership application data Reservation data Profile Data Communications data Transactional data Payment data Data from third-party servicesDevice data Legal Basis: Contractual Necessity
2. Research and Development Information Involved: Contact data Demographic data Membership application data Reservation data Profile dataDevice data Online activity data Precise geolocation data Communication interaction data Legal Basis: Legitimate Interests (Improving Service, adding new features)
3. Marketing and Advertising Information Involved: Contact data Communications data Marketing data Legal Basis: Consent
4. Service Improvement and Analytics Information Involved: Contact data Demographic data Membership application data Reservation data Profile data Device data Online activity data Precise geolocation data Communication interaction data Legal Basis: Legitimate Interests (Providing good service, understanding usage) Consent (for optional cookies)
5. Compliance and Protection Information Involved: Contact data Demographic data Legal Basis: Compliance with Law Legitimate Interests (Participating in, supporting, and following legal processes; protecting rights, property, and safety)
6. Further Uses Information Involved: Any and all data types relevant in the circumstances Legal Basis: Original legal basis, if compatible with initial purpose Consent, if not compatible with initial purpose
Retention We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for Compliance and protection purposes. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. When we no longer require the personal information, we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you. Other info No obligation to provide personal information. You do not have to provide personal information to us. However, where we need to process your personal information either to comply with applicable law or to deliver our Service to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Service to you. We will notify you if this is the case at the time (for example, by using a prompt in our App). No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics (other than details of your dietary requirements), criminal background or trade union membership) on or through the Service, or otherwise to us. If you provide us with any sensitive personal information to us when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Service. No Automated Decision-Making and Profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects. Security. We have put in place procedures designed to deal with breaches of personal information. In the event of such breaches, we have procedures in place to work with applicable regulators. In addition, in certain circumstances (including where we are legally required to do so), we may notify you of breaches affecting your personal information.
Your rights General. European data protection laws give you certain additional rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold: Access. Provide you with information about our processing of your personal information and give you access to your personal information. Correct. Update or correct inaccuracies in your personal information. Delete. Delete your personal information 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 information where you have exercised your right to object to processing (see below). Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it. Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes. Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time. Exercising These Rights. To exercise any of these rights, please contact us using the contact details provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.
Your Right to Lodge a Complaint with your Supervisory Authority. Although we urge you to contact us first to find a solution for any concern you may have, in addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.
For users in the EEA – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en For users in the UK – the contact information for the UK data protection regulator is below: The Information Commissioner’s Office Water Lane, Wycliffe House Wilmslow - Cheshire SK9 5AF Tel. +44 303 123 1113 Website: https://ico.org.uk/make-a-complaint/
Data processing outside Europe We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe. It is important to note that that the US is not the subject of an ‘adequacy decision’ under the GDPR – basically, this means that the U.S. legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal information, which is equivalent to that provided by relevant European laws. Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented: Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time). Transfers to territories without an adequacy decision. We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S., see above). However, in these cases: we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.
You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.
