Captain D’s (International), LLC
Privacy Policy
Introduction
This Privacy Policy describes how Captain D’s (International), LLC collects, uses, protects, and shares the personal information of our customers in the United Kingdom. Customers include those who visit our restaurants, use our websites and mobile apps, and otherwise interact with us. The data controller of your personal information is Captain D’s (International), LLC (“we” or “us”).
Information We collect
We may collect personal information about you when you visit our restaurants, use our websites or mobile apps (“online services”), and otherwise interact with us (collectively, “services”). The information we collect falls into three categories: (a) information you provide to us; (b) information we collect through automated methods when you use our services; and (c) information we collect from other sources (see below).
Generally, you are under no obligation to provide your personal information. However, in certain cases, we may be unable to provide you with our services unless you provide your personal information.
We may combine the information you provide to us with information that is collected through automated methods and with information we receive from other sources.
You may provide the following information to us, depending on how you interact with us:
- personal details, such as your name, postal and email addresses, phone number, birthday information, and other contact information, when you register with our online services, log-in to Wi-Fi, enter one of our competitions, or contact us by phone or through our online services.
- demographic information such as age or gender.
- transaction information, including information about the products you buy, prices, method of payment, and payment details.
- account information, such as your username or password (or anything else that identifies you) used to access our online services or to buy or use our products and services.
- profile information, including products and services you like, or times you prefer to visit us; and
- other personal information you choose to provide us when you interact with us (including through social media).
We may use automated technology to collect information from your computer system or mobile device when you visit our restaurants, use our online services, or in-restaurant technology. Automated technology may include cookies, local shared objects, and web beacons.
We may collect information about your:
- internet protocol (IP) address;
- computer or mobile-device operating system and browser type;
- type of mobile device and its settings;
- device identifier for vendors (IDFV);
- unique device identifier (UDID) or mobile equipment identifier (MEID) of your mobile device;
- device and component serial numbers;
- advertising identifiers (for example, an Identifier for Advertising (IDFA) on Apple devices) or similar identifiers;
- referring webpage (a page that has led you to ours) or application;
- online activity on other websites, applications, or social media;
- visits to our restaurants, where recorded using digital technology (e.g. video recordings); and
- activity related to how you use our online services or in-restaurant technology, such as the pages you visit on our websites or in our mobile apps.
Our online services and in-restaurant technology may collect information about the exact location of your mobile device or computer using geolocation and technology such as GPS, Wi-Fi, Bluetooth, or cell tower proximity. For most mobile devices and computer systems, you can disable the collection of this information by using the device or web-browser settings. If you have any questions about how to prevent us from collecting exact information about your location, we recommend you contact your mobile-device service provider, the device manufacturer, or your web-browser provider. Some online services and in-restaurant technology may not work properly without information about your location.
We may collect information about you from our business partners and vendors (e.g., food delivery platforms, data providers, or payment processors) or from public sources (e.g., your public social media posts).
How We Share the Information We Collect
We do not sell your personal information and only share your information as described in this Privacy Policy or as otherwise communicated to you at the time we collect your information.
We may share your personal information with
- Our franchisees and subfranchisees;
- vendors who help us operate our business (including information technology service providers and marketing agencies that we use as well as those who use the information to detect or prevent fraud for us, and who may use the information to provide fraud detection and prevention services to others);
- public authorities and courts;
- buyers or other parties involved in a corporate transaction if we decide to sell or transfer all or part of our business;
- our professional advisers such as our legal representatives, auditors and insurance brokers; and
- business partners if they are involved in your customer experience, including product or service delivery (e.g., food delivery platforms).
How We Use the Information We Collect
a) To carry out online advertising
We may share your personal information with third party advertising technology companies (“Advertising Partners”) so that we can advertise to our customers and other people on websites apps and digital properties that are operated by the Advertising Partners or third parties that also work with our Advertising Partners (“Third Party Sites”). Our Advertising Partners include Meta, Twitter, Tik Tok, and Google.
We carry out the following online advertising activities:
We may share your email address or other identifiers (e.g. your device ID) with our Advertising Partners, so that our Advertising Partners can try to “match” your data with their data or the registration data of Third Party Sites.
Where there is a match, our advertising will be displayed to you when you use the relevant Third Party Site (e.g. on your Facebook newsfeed). This is known as “custom audience” advertising, because we “customise” the audience that we want to reach on other online services.
We may also share your personal information with Advertising Partners in order to exclude you from seeing our advertising (because we are trying to reach people that are not yet our customers).
We will only do this activity where we have appropriate permission (for example, where you have given us permission to track you through your app settings).
Where your data is collected through the use of non-essential cookies, we rely on consent to collect your personal data and for the onward processing purpose. Please see the “Cookies” section for more information about the cookies and other similar technologies that we use. In certain circumstances, we may rely on another lawful basis when we use your personal data collected via the use of cookies as detailed in the relevant section.
Where we share your personal information with Advertising Partners as described in this section, we may also ask the Advertising Partner to find other people that share similar interests and behaviours to you, and to show our advertising to those people when they use Third Party Sites. We will only share this personal information where we have appropriate permission (for example, where you have given us permission to track you through your app settings).
This is based on personal information that you have provided through your use of Third Party Sites (which may include Third Party Sites of the Advertising Partner). This personal information might include demographic data (such as your age or gender) and interest-based data (things that you like). This personal information is not shared with us.
To the extent we are a controller of this personal information, we consider it is in our legitimate interest to use this personal data in this way to increase the effectiveness of our advertising by displaying our ads on individuals who share similar interests and characteristics to our customer base.
Advertising Partners may provide tools that we can use to deliver our advertisements to people who we think are more likely to be interested in our products and services.
For example, an Advertising Partner may have determined that you are a ‘seafood-lover’ using data that they have collected about you through your use of Third Party Sites (which may include Third Party Sites of the Advertising Partner). If we want to display a Captain D’s advertisement to seafood lovers, the Advertising Partners that we work with may allow us to show our advertisement to you using selection tools that they make available. The personal information that is used for this is not shared with us.
To the extent we are a controller of this personal information, we consider it is in our legitimate interest to use this personal data in this way to ensure our advertising is relevant to those receiving it.
We and the Advertising Partners that we work with may use your personal information, cookies, and other similar technologies to measure the effectiveness of our advertising. Where we use personal data collected through the use of cookies to measure the effectiveness of our advertising, it is in our legitimate interest to use your personal data in such a way to inform our advertising strategy.
Please see the “Cookies” section for more information about the cookies and other similar technologies that we use.
In addition, when you see our advertisements on Third Party Sites, the Third Party Sites and Advertising Partners that we work with may separately collect personal information about your interaction with our advertisements, which is used to provide us with aggregated statistics and reports (which do not contain your personal information) to help to measure the effectiveness of our advertising.
b) Our Facebook Page
When you visit our Facebook page, Facebook does not share your personal information with us for this purpose, but they may provide us with aggregated statistics about your use of our Facebook Page.
c) CCTV
CCTV is used in Captain D’s restaurants for the following purposes:
- To prevent and detect crime, disorder, and misconduct, and to protect Captain D’ssystems, facilities, and property against damage, disruption, vandalism, fraudulent activity, and other crime (including detecting fraudulent use or misuse of customer-facing services);
- To assist law enforcement in the prevention, investigation, detection, and prosecution of crime;
- To provide evidence in the event of legal proceedings issued by or bought against Captain D’s; and
- To assist in day-to-day management of restaurants and offices, including for health and safety purposes.
d) Customer Services
We may monitor, record, store, and use any telephone, email, or other communication with you to check any instructions given to us, for training purposes, and to improve the quality of our customer service. It is in our legitimate interests to use your personal information for this purpose.
e) Bringing and defending legal claims – sharing with our insurer
We may share your personal information with our insurance brokers where necessary to bring or defend legal claims and/or to protect the rights, interests, safety, and security of our organisation, our employees, franchisees, or members of the public.
It is in our legitimate interest to bring and defend legal claims and to use your personal information for this purpose.
f) Fraud Detection and Prevention
e may share your personal information with suppliers who help to protect you and Captain D’s from fraud.
It is in our legitimate interest to ensure that we and you are not subject to fraud and for us to use your information for this purpose.
g) Personalising your Captain D’s experience
We want to ensure that you have the best possible experience. To do this, we may use your personal information to tailor our products and services to you, including as follows:
- Personalised marketing: If you receive marketing from us (for example where you have subscribed to receive our email marketing) we may use your personal information to tailor the communications that we send to you. This means that the marketing communications are more likely to be relevant and of interest to you.
- Personalised advertising: If we deliver online advertising to you on Third Party Sites, we and Advertising Partners that we work with may use your personal information to tailor the advertising that you see. This means that the advertising is more likely to be relevant and of interest to you. Please note, if we do not have your consent for this, you may still see our advertisements on Third Party Sites but they may be about products and services that do not interest you.
Children’s Privacy Notice
Our policy is to not collect personal information from any child unless data is needed for a specific activity or as a result of exceptional circumstances, in which event we will ensure the details are written specifically in this policy and that the child’s parent or guardian has first provided us with written consent to that specific activity or that we have another lawful basis for collecting the personal information.
Marketing Communications
If you are subscribed to our marketing communications, you can later opt out by following the opt-out instructions in the marketing communications we send you. You can also generally find your communication preferences with instructions on how to opt out in the profile section of the online services that you use. You may also have the ability to change your communication preferences using your device settings. You can also opt out by contacting us at webmaster@captainds.com.
If you do opt out of receiving marketing communications from us, we may still send communications to you about your transactions, any accounts you have with us, and any contests, competitions, prize draws or sweepstakes you have entered. Opting out of one form of communication does not mean you have opted out of other forms as well. For example, if you opt out of receiving marketing emails, you may still receive marketing text messages if you have opted in to receiving them.
We do not share personal information with third parties for their own direct marketing purposes, unless you give us permission to do so. When we give you notice, and you consent, we will share your personal information as you direct us to.
Our Advertising Partners’ Platforms
In this section, we provide further information about the Advertising Partners’ Platforms that we work with, and how these Advertising Partners use your data.
a) Facebook
For further information about how we and Facebook use your personal information in connection with these activities, including the legal basis Facebook relies on and the ways to exercise your data subject rights against Facebook, please see Facebook’s Data Policy at https://www.facebook.com/about/privacy.
b) Google
Google has published information about how it uses your personal information in connection with its services here. In addition, Google provides further information about how it uses personal information in connection with online advertising in its Privacy Policy and here. You can also use Google’s Ad Settings to manage your online advertising preferences.
c) Twitter
Twitter has published information about how it uses your personal information in connection with its advertising services, including how you can opt-out of Twitter’s interest-based advertising, here.
Your Personal Information Rights
You have certain rights in relation to the personal data we hold about you. In connection with these rights, you may:
- Withdraw this consent at any time, where we rely on your consent as a basis for processing your personal information. The withdrawal of the consent shall not affect the lawfulness of the processing that took place based on your consent before its withdrawal;
- Request access to your personal information and obtain a copy of it;
- Obtain your personal information in a structured, commonly used and machine-readable format and request us to transmit it directly to another company in case your personal information is processed based on your prior consent, or required for the performance of a contract;
- Have your personal information corrected when it is inaccurate or incomplete;
- Object on grounds relating to your particular situation to our processing of your personal information based on our legitimate business interest, including profiling, and to the sending of marketing communications;
- Have your personal information erased, including any links to, copy or replication of such information, in certain circumstances, such as where we no longer need it or if you withdraw your consent (where applicable); and
- Obtain the restriction of the processing while we are processing your request or challenge the accuracy of your personal information or the lawfulness of the processing of your personal information and our legitimate interests to process this information, or if you need the personal information for litigation purposes.
You also have the right to lodge a complaint about our processing of your personal information with the Information Commissioner’s Office, which is the Supervisory Authority in the UK. Contact details are as follows: https://ico.org.uk/concerns/ or casework@ico.org.uk.
Cookies and Other Technologies
a) What are cookies and other similar technologies?
Cookies are very small text files or pieces of code, which often include a unique identifier. When you visit a website, the website sends information to your computer or mobile device and creates a text file that is then stored on your computer or mobile device. This information may then be accessed by that website or other websites you visit in the future. Information gathered through cookies may include the date and time of visits and show how people use the particular website or mobile application, usually so the website operator can make improvements. Amongst other things, cookies are also used to help you access a website and its content as efficiently as possible (by remembering you from your last visit) and to make sure you are presented with advertising that is relevant to you.
Similar to cookies are technologies known as “web beacons,” “pixels,” or “tags.” These technologies do a similar job to cookies, allowing website operators to count page views and understand how visitors interact with and respond to certain content.
For the purposes of the policy, we refer to cookies and the other technologies described above as “cookies.”
We use “first party cookies” and “third party cookies.” First party cookies are cookies placed by us. Third party cookies are either placed by us on behalf of a third party or by the third party with our approval. Information collected by third party cookies will be shared with the relevant third party. Please refer to the relevant third party’s privacy notice for more details about the information they collect and how they use it.
Please note that our Site, App, or emails may link to third party websites or digital properties which are not operated by us. Where you follow links from our Site, App, or emails to the website or digital property of a third party, that website or digital property may place different cookies on your device. You should check the relevant privacy notice and/or cookie notice for more information about how that third party uses cookies.
You should be aware that applications you use to access our Site, such as your web browser, may also place cookies on your device when visiting our Site, or other websites. An example of this would be where you sign in to Google Chrome using a Google Account (see What about Google Chrome cookies?). We have no control over these third party cookies, so you will need to manage these cookies in the settings of the relevant applications.
b) How long do cookies last?
The lifespan of a cookie depends on its purpose and how you interact with it:
Session Cookies – these are temporary cookies that are placed on your device during your browsing session and then automatically erased when you close your browser.
Persistent Cookies – these are designed to last for a pre-defined period of time, which varies depending on the nature of the cookie. Persistent cookies stay in your browser until they reach their individual expiry date or you manually delete them.
c) Which cookies are used on our Site and App?
We use the following types of cookies:
Essential Cookies/Strictly Necessary Cookies – These cookies are necessary for the website or service to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work.
Functional Cookies – These cookies enable the website or service to provide enhanced functionality and personalisation. If you do not allow these cookies then some or all of these services may not function properly. These cookies may also allow you to sign in to our services using your social media account.
Analytics Cookies – These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site and digital services. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is used on an aggregate and/or anonymous basis (i.e. to understand more about our users generally and not any one individual). If you do not allow these cookies, we will not be able to monitor the performance of the site or service.
Advertising Cookies – These cookies (also known as targeting cookies or social media cookies) may be set through our site or digital service by us or our third-party advertising partners (including social media platforms). They may be used by us and those third-parties to build a profile of your interests and show you relevant adverts on other sites and services. They do this by uniquely identifying your browser and device. If you do not allow these cookies, you will experience less targeted advertising.
d) Is consent needed to use cookies?
Essential/Strictly Necessary Cookies – We do not need your consent to store and access essential cookies on your device, although you can still block or delete them.
Other (“non-essential”) Cookies – We may only store and access non-essential cookies on your device with your permission. You are not obliged to give consent to our use of non-essential cookies. If you do give your consent and then change your mind, you can still delete any cookies that have already been placed.
e) How do I refuse, block or delete cookies?
There are various ways that you can manage your cookie preferences but please be aware that to use some parts of our Site and App you will need to allow certain essential or functional cookies. If you block or subsequently delete those cookies, some aspects of our Site and App may not work properly and you may not be able to access all or part of our Site or App.
Your options for managing your cookie preferences are set out below:
Through the Cookie Settings on our Site
When you access our Site, we will ask you to provide consent for our use of non-essential cookies. We may repeat this request on subsequent visits to our Site, for example if you delete cookies from your browser or we need to request new consents from you.
When we seek your consent, you will either be able to provide consent for all cookies that we would like to use, or you can tailor your cookie preferences (provide consent for some but not all non-essential cookies) using our Cookie Settings.
You can also change your preferences and/or withdraw your consent at any time by visiting our Cookie Settings. However, please be aware that withdrawing your consent does not remove the cookie from your device and, in the case of Advertising cookies, the cookie may still be used by third parties to show you personalised content and/or advertisements. To delete the cookie from your device and prevent the data from the cookie being used in this way, please see Using your browser settings or other tools.
Where cookies are essential to the operation of our Site, we can use these without your consent and they cannot be managed using our Cookie Settings.
Using your browser settings or other tools
You can block the use of cookies generally (not just in respect of our Site) by activating the relevant settings in your browser.
Some cookies are dropped by third parties who operate the browser or application through which you access the Site (such as Google Chrome – see What about Google Chrome cookies?). We do not have control of this and you will need to manage those cookie settings through the relevant third party application.
If you do not want to be tracked by Google Analytics, you can install the Google Analytics opt-out browser add-on (but this will only work on certain browsers). For further information on Google Analytics and its use of cookies, please consult the Google Analytics cookie policy.
f) What about Google Chrome cookies?
Separately to our use of Google Analytics cookies, when you access the Site via Google applications such as Google Chrome, Google may collect user information for the purpose of Google serving personalised advertising across your devices. Google can place these advertising cookies on the devices used by visitors to the Site because we use Google services to run the Site. However, these cookies are dropped for Google’s own purposes and as such we do not have any control over how or when they are dropped. You will need to opt out of receiving these cookies via your Google settings. For further information about these cookies please see: https://policies.google.com/technologies/types?hl=en-US. Please note that other browsers may use similar tools.
g) What technologies do we use in emails?
Emails you receive from us may contain cookies or similar technologies. Cookies in our emails do a similar job to cookies on our Site and App. These technologies tell us if you open an email and help us understand how you interact with its content. Once you click on an email that contains a cookie, your contact information may subsequently be cross-referenced to the source email and/or the relevant cookie. If you have enabled images, cookies may be set on your computer or mobile device. Cookies will also be set if you click on any link within the email. If you open one of our emails, triggering a cookie, you can prevent further use of cookies in that email by closing it without downloading any of the content or clicking on any of the links.
Information Security
We are committed to taking appropriate measures designed to keep your personal information secure. Our technical, organizational and physical measures are designed to protect personal information from accidental, unlawful or unauthorized loss, access, disclosure, use, alteration, or destruction. While we make efforts to protect our information systems, no website, mobile application, computer system, or transmission of information over the internet or any other public network can be guaranteed to be 100% secure.
Retention
We keep your information for the length of time needed to carry out the purposes outlined in this Privacy Policy and to adhere to our policies on keeping records (unless a longer period is needed by law). Our records policies reflect applicable laws. We will retain and use your information to the extent necessary to manage your relationship with us, personalize and improve your overall customer experience, and to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this policy.
Changes To Our Privacy Policy
This Privacy Policy is in effect as of the date noted at the top of this policy. We may change this Privacy Policy from time to time. If we do, we will post the revised version here and change the “last updated date” below and/or contact you directly where we deem appropriate to do so under applicable law. You should check here regularly for the most up-to-date version of this policy.
How To Contact Us
We welcome any feedback or questions you may have concerning the collection and processing of your personal data. If you have data protection questions, you can reach us at webmaster@captainds.co.m.