Privacy Policy (2020)

Privacy Policy (2020)

GLOBAL PRIVACY POLICY
Welcome to Dorsia’s privacy policy. Dorsia is operated by ELOMI CORPORATION (hereinafter, "we", "our", "us" or “Dorsia”). We respect your privacy and are committed to protecting your information. This privacy policy applies to visitors and users (individually, "you") and describes our practices regarding personal information collected to operate our websites, systems, applications, social media accounts, and other services (collectively, the "Services"). Your use of our Services is also subject to the Dorsia Terms of Service (“TOS”). It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing information about you so that you are fully aware of how and why we are using your data. Capitalized terms that are not defined below shall have the meanings attributed to them under the TOS.

INFORMATION COLLECTION
We may collect the following types of information about you:
Identity Data, which includes name or other similar identifiers.
Contact Data, which includes address, email address and telephone numbers.
Financial Data, which includes credit card, debit card or other payment card details.
Technical Data, which includes internet protocol (IP) address, location data, your login data, and device and browser information.
Profile Data, which includes your username and password, your dining interests, food allergies and preferences.
Usage Data, which includes information about how you use our Services and partner sites and advertising we serve on those sites.
Marketing and Communications Data, which includes your preferences in receiving marketing.

IF YOU ARE IN THE EU OR THE UK, PLEASE SEE THE SECTION "ADDITIONAL DISCLOSURES FOR THE EU AND THE UK" THAT PERTAIN TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.

We may collect information about you in various ways, including through:Direct interactions: You may give us your information by registering or contacting us. This includes information you provide when you:create an account with us;subscribe to our Services or publications; make a reservation through our Services; submit a request to Dorsia, whether related to the Services or otherwise;claim a promotional offer from us;request marketing to be sent to you; orgive us feedback.

USING OUR SERVICES
As you interact with our Services, we may automatically collect Technical Data and Usage Data about your use of our Services. Some of the ways in which we may collect information are further described below:
Cookies and other technologies: The Services may use cookies, a type of technology that installs a small amount of information on a website user’s computer or other device to permit a website to, for example, recognize future visits using that computer or device. The Services may use other similar technologies (including, without limitation, tracking pixels, as described further below, and other anonymous identifiers) to gather information about you, such as IP addresses and location data, to customize your visit, to enable us to enhance our Services, or for other purposes. Please see our Cookie Policy for further details.
Interest-Based Advertising: We may engage third-party vendors to use your information in connection with their own information to deliver targeted advertising to you when you visit our website or other websites. Cookies, described above, may be used in this process. For example, if you are searching for information on a particular product, our vendor may cause an advertisement to appear on other websites you view with information on that product. This form of advertising is called "Behavioral Advertising." We believe that such advertising is helpful because you will see ads that are relevant to your interests. However, if you would like to opt out of these interest-based advertisements, please see the "CUSTOMER CHOICES" section below.
Clickstream Data: When you use the internet, websites collect information about the type of computer and browsing software you use and the address of the website from which you linked to the website. The Services may collect and use clickstream data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our website, how visitors navigate throughout the website and how we may tailor our website to better meet the needs of visitors. This information may be used to improve our Services. Any collection or use of clickstream data will be anonymous and aggregated and will not intentionally contain any information about you.
Location Data: When you give us consent, we will collect the latitude and longitude coordinates of your device once you are awarded a Reservation to assist you with providing directions to the Restaurant within such Reservation. We use this information to help us improve the relevance of search results and streamline the Restaurant processes. This information is only collected while the app is running. We also use general geographic data to identify the city a user is in at the time such user submits an offer via the Dorsia Services. If you would like to opt out of location tracking, please see the "CUSTOMER CHOICES" section below. We may also collect personal information/personal data about you from various third parties and public sources--If you register for our Services using Facebook, Twitter or other social media sites, we will import your information from those social media sitesWhen a new Restaurant joins us, we will collect any information that Restaurant has about prior guests and import it into the Restaurant's guestbook on our Services.We also obtain information about you from Restaurants that join the Dorsia Services, including notes, tags, and other metadata about your dining habits and experiences.

INFORMATION USE AND SHARING
We use information held about you to perform our services and for other purposes outlined below. Specifically, we use your information for a variety of purposes:
To perform a contract with you;
To perform specific services that you have requested;
To respond to your direct inquiries;
For our affiliates’ everyday business purposes;
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests;
To send you Dorsia marketing materials;
To send you marketing materials for our affiliates’ products and services;
Where we need to comply with a legal or regulatory obligation; and in other ways as required or permitted by law or with your consent. We will only disclose information that we collect about you to third parties with your consent or as provided below:
In addition to the foregoing, we will share your information with Restaurants and their affiliates as and when your Reservation request is submitted via the Dorsia Services. We will provide the Restaurant certain categories of your information including: your name, dining profile, date and time of visit, your contact details, dining preferences, party size and any other information you provide at the time of your reservation or feedback. We or the Restaurant may share your information with their affiliates (e.g., other restaurants in the same Restaurant group) to enhance the hospitality such restaurant group provides you when you dine with them. By interacting with you, the Restaurant and their affiliates may, as permitted by applicable law, share your information with their partners to support operations, such as to perform analytics and tailor marketing to you.
To use certain Services, payment card information may be requested. We may ask you for credit card, debit card, or other payment information. By submitting your payment information through our Services, to the extent permitted by applicable law, you expressly consent to the sharing of your information with restaurants, third-party payment processors, and other third-party service providers.
To third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them, if we are part of a bankruptcy proceeding or other change in control.
To third parties to whom we need to share your information to investigate suspected fraud, abusive or unlawful uses or activities, harassment or other violations of any law, rule or regulation, or the policies for the Services, or to protect the security or integrity of the Services.
To third-party service providers to provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to or process your information as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.
To respond to requests from law enforcement authorities and our regulators, or to respond to requests if we are involved in a legal proceeding.
To third parties as necessary to investigate and correct technical problems and malfunctions in the Services.
If you are an individual that resides in the European Union, please see the “ADDITIONAL DISCLOSURES FOR EU RESIDENTS” section below.

THIRD-PARTY LINKS AND SOCIAL NETWORKING SERVICES
The Services may include links to third-party websites, plug-ins and applications.
Clicking on those links or enabling those connections may allow third parties to collect or share data about you.
We do not control these third-party websites and are not responsible for their privacy policies.
When you leave our Services, we encourage you to read the privacy policy of every website you visit.The Services may integrate with social networking services.
We do not control such services and are not liable for the way they operate or process data.
While we may provide you with the ability to use such services in connection with our Services, we are relying upon those third-party services to operate in line with their terms and conditions and privacy policies. You should be aware that information which you voluntarily include and transmit online in a publicly- accessible forum (e.g., blog, social network) may be viewed and used by others.
We are unable to control such uses of your information, and by using such services you acknowledge that the information provided by you may be viewed and used by third parties.

DATA SECURITY
We will keep your information confidential and limit access to your information to those who specifically need it to conduct their business activities, except as otherwise permitted by applicable law.
We refer to industry standards and use reasonable administrative, technical and physical security measures to protect your information from unauthorized access, destruction, use, modification or disclosure.
We require industry standard data security measures from those third parties who are authorized by us to process your information on our behalf.

DATA RETENTION
We will only retain your information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.
We review our retention periods on a regular basis.
We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as it is set out in any relevant contract you hold with us.In some circumstances we may anonymize information about you (so that it can no longer be associated with you) for research or statistical purposes in which case we may use and retain this information indefinitely without further notice to you.
If your account is closed, we may take steps to delete certain information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws.
We will continue to use and disclose information in accordance with this privacy policy.

CUSTOMER CHOICES

Opting out of email messages from us
To opt out of any future promotional email messages from us, you should unsubscribe in the body of the promotional message that was sent to you (found at the bottom of the email) or send an unsubscribe request to us at privacy@dorsia.com. We will process your request within the timeframes required by applicable law.

Opting out of sharing with third parties for marketing purposes
If you do not want your personal information/personal data shared with any third party who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to privacy@dorsia.com. Please note that if you decide to opt out in this manner, certain aspects of the Services may no longer be available to you. We will process your request within a reasonable time after receipt.

Opting out of interest-based advertising
The online advertising industry provides a service through which you may opt out of receiving targeted ads from certain data partners and other advertising partners that participate in self-regulatory programs. We comply with the U.S. Self-Regulatory Principles for Online Behavioral Advertising set forth by the Digital Advertising Alliance (DAA) and the European Interactive Digital Advertising Alliance (EDAA). You can opt out of targeted advertising from certain providers at www.aboutads.info/consumers. Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities. Please note that cookie-based opt-outs must be performed on each device and browser that you wish to have opted out. For example, if you have opted out on your device browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device. EU residents who have provided their consent to our use of cookies and similar technologies can use the EDAA’s opt-out tool which can be found via the Dorsia Services.

Opting out of cookies
If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Services or some of its functionality may be affected. Cookies and similar items are not used by us to automatically retrieve personal information/personal data from your device without your knowledge. For more information about cookies, please visit our Cookie Policy.

Opting out of location tracking
You may also adjust the settings on your mobile device to allow or restrict the sharing of location information. For example, the "location" permissions on your mobile device may allow you to elect whether to never share location information with us, to share location information only while you are using the app, or always share location information even if you are not using the app. If you elect to not share your location information, you may be unable to access some features of our Services that are designed for mobile devices. Also, if you prevent the sharing of location information, we may still estimate your general location based on the IP address you use to access our Services.

DATA RELATING TO MINORS
Our Services are designed for those 18 years of age and older. We do not knowingly collect information from anyone under the age of 18 (or such other age as may be restricted under local law). If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.

CROSS BORDER TRANSFERS
Our Services are provided from the United States. By using the Services, please note that information about you may be transferred to the United States and other countries around the world. You understand that the data is stored in the United States and it may be subject to lawful requests by the courts or law enforcement authorities in the United States. If you are situated in the EU, whenever we transfer your personal data outside of the EU, we ensure appropriate and suitable safeguards are used in such transfer. We may use specific contracts approved by the European Commission which give personal data the same protection it has in the EU.

ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS
Certain residents of California ("CA") may receive additional protections under the California Consumer Privacy Act of 2018 ("CCPA") for "personal information."
Personal information includes information which identifies or could reasonably identify an individual.
It does not include information that is publicly available or that has been de-identified or aggregated.
This section describes the categories of personal information that Dorsia collects, the purposes for which that information is collected, and any rights you may have.Categories of personal information that we collect
Depending on the nature of your relationship with us (e.g., Dorsia user, Restaurant or Dorsia employee), we may collect the following categories of personal information about you, including:
- Identifiers such as name, postal address, email address, account name, social security number, driver’s license or state identification card number, or telephone number;
- Information that identifies, relates to or is capable of being associated with, an individual, such as financial information;
- Credit card information;
- Commercial information such as dining history;
- Internet or other electronic network activity information such as browsing history;
- Geolocation data, available through your device, if enabled;
- Professional or employment-related information;
- Other personal information, as described to you in this privacy policy, or otherwise at the point of collection; and
- Inferences drawn from any of the information identified above, including about your preferences.Depending on your relationship with us, we may have collected each of the above categories of personal information about you from the time you began using the Dorsia Services.
In addition, we may have shared each of these categories of personal information with third parties for the business purposes described below and in the rest of this privacy policy.
For each of these categories of personal information, please refer to the "INFORMATION USE AND SHARING" section above for more detailed information regarding why we collect personal information, and the categories of third parties with whom we may share personal information.Why we collect personal information
Depending on your relationship with us (e.g., Dorsia user, restaurant partner, or Dorsia employee), we may use information about you for our business purposes, including:
- To perform a contract with you;
- To perform specific services that you have requested, such as processing a Reservation request;
- To respond to your direct inquiries;
- To process payments via Dorsia;
- For joint marketing with other financial companies;
- For our affiliates’ everyday business purposes;
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests;
- To send you Dorsia marketing materials;
- To send you marketing materials for our affiliates’ products and services;
- To manage your employment relationship with us, if applicable;
- Where we need to comply with a legal or regulatory obligation; and
- In other ways as required or permitted by law or with your consent
- All above exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Your CA privacy rights
Beginning January 1, 2023, CA residents who have a business or employment relationship with us may have certain rights under the CCPA, such as the right to access, deletion, and nondiscrimination in the event you exercise these rights.
The CCPA requires that we verify the requests we receive from you or your authorized representative when you exercise certain of the rights listed above.
Once those rights become available, we will update our privacy policy to reflect any changes, including descriptions of how we verify your identity and how to exercise your rights.We do not offer an opt out of sale link on our homepage for the purposes of the CCPA.
We may share personal information with our service providers, with third parties with whom we jointly offer products or services, with third parties from whom you request a product or service through us, in the context of a merger, acquisition, bankruptcy, or other corporate transaction, or as otherwise permitted by the CCPA.
Dorsia will update its disclosure for California residents as state regulation evolves.

ADDITIONAL DISCLOSURES FOR THE EU AND THE UK
Personal Data
Some of the data that we collect from individuals in the European Union (EU) and the United Kingdom (UK) may identify or be identifiable to an individual. This information is considered “personal data” in the EU and the UK, and subject to additional protections.
Legal basis for our processing of your personal dataBelow are the types of lawful bases that we will rely on to process your personal data:Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.With your consent.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without consent, in compliance with the above rules, where this is required or permitted by law.Withdrawing your consentIf we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time by contacting us at privacy@dorsia.com.
Use of your personal data for marketing purposes
We provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
Promotional offers from us: We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our services and have not opted out of receiving that marketing. For the EU and the UK, you must opt in to receive marketing communications.
Third-party marketing: We will get your consent before we share your personal data with any company outside our company for marketing purposes.
To see how you can opt out of marketing communications, please see the "CUSTOMER CHOICES" section.
Rights of data subjectsUnder certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). 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 data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. 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 at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, 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 will respond to requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated. If you are situated in the EU or the UK and have any complaints regarding our privacy practices as a data controller or want to exercise your rights, please contact our Data Protection Officer at privacy@dorsia.com. You may also contact the local Supervisory Authority or seek legal remedies.
Additionally, if you would like a Restaurant to delete information it has collected about you, we encourage you to contact the Restaurant directly. If you are unsuccessful in reaching the appropriate contact at the Restaurant, please contact us at privacy@dorsia.com and we will do our best to connect you with the right person who can help you.

UPDATES TO THIS PRIVACY POLICY
We reserve the right, at our discretion, to change, modify, add, or remove portions from this privacy policy at any time. However, if at any time in the future we plan to use your information in a way that materially differs from this privacy policy, we will post such changes here and email you. We encourage you to periodically review the privacy policy for the latest information on our privacy practices. You are bound by any changes to the privacy policy when you use the Services after such changes have been first posted.

CONTACT US
ELOMI CORPORATION
3921 Alton Road
Suite 413
Miami Beach, FL 33140

Last Updated: December 2021

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