CHOICE QR s.r.o.
PERSONAL DATA PROCESSING INFORMATION
Identification of the controller: Choice QR s.r.o., Company ID: 095 17 600, with its registered office at Na příkopě 857/18, Nové Město, 110 00 Prague 1, registered in the Commercial Register maintained by the Municipal Court in Prague under file no. C 337491 (“we”).
Contact details of the controller: [email protected], Na příkopě 857/18, Nové Město, 110 00 Prague 1
By this document, we inform you about how we process personal data as controllers of personal data. At the same time, we also act as a processor of personal data in connection with the processing of personal data for partners within the provided products and services. In other words, individual restaurants are in the position of a personal data controller in relation to you, and the Personal Data Processing Terms for processors are available in the terms of use of the Choice application for partners.
The processing of personal data is carried out in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”) and in accordance with other personal data protection regulations.
All information about us and our services and products can be found on the website https://choiceqr.com/cs/ („website”). As controllers, we also operate two applications, namely the Choice application, which is intended for customers of restaurants and other establishments (“Choice”), and Choice Business, which serves for restaurant management by partners (“Choice Business”). Both applications are also available on the App Store and Google Play.
A. SCOPE OF PERSONAL DATA
We have divided the individual categories of personal data into several separate sections, depending on the nature of our mutual relationship.
You are our partner (restaurant)
- Identification data, such as your name and surname (or company name or your role).
- Contact details, which include your email address and phone number.
- Information related to the contractual relationship, which consists of supplementary information about you as a natural person that we record in connection with the contractual relationship (specific requirements, information related to the restaurant).
- Information from mutual communication, which consists of information that you as a user share within joint communication, when using customer support.
- Information contained in reviews, which consists of information that you provide to us in a review.
- Choice Business technical data, which consists of information related to the use of the Choice Business application, such as device ID, user data, application access code, and other related information.
You create a user account in Choice or make a purchase at a restaurant
Specifically, we may also process the following personal data as controllers of personal data, provided that you create a user account within the Choice application or make a purchase at a restaurant. In such a case, we are the controllers of personal data for the user account, and we process the following categories of personal data:
- Contact details, which include your email address.
- User data, which is your identification within the user account.
- Information related to orders, which includes order history, information related to ordering services from individual partners, and related order information.
- Choice technical data, which consists of information related to the use of the Choice application, such as device ID or other technical information about the device.
Common categories
Whether you visit the website, use Choice or Choice Business, we may process the following categories of personal data:
- Contact details, which include your email address and phone number.
- Communication data, i.e., information about communication with you, such as email contents, chats, etc.
- Cookie data, i.e., data obtained from cookies and similar technologies that we use. For more information about their use, please read the purposes described below.
B. PURPOSES OF PERSONAL DATA PROCESSING
Your personal data is processed for the processing purposes described below. For each processing purpose, you will also find the scope of processed personal data and the retention period of personal data.
Processing purposes depending on whether you are our partner, a Choice user, or the processing common to all processing activities applies to you (for example, you visit the website).
You are our partner (restaurant)
B.1 Fulfilment of the mutual contractual relationship and partnership management (onboarding, account setup and management, provision of features and services)
We process personal data in order to enter into and perform a cooperation agreement with you, set up and manage your partner account, enable access to the administration interface, process and display order information, and provide related functionalities (e.g., menu management, operation settings, data export, access and role management), according to the scope of products and services you order. This purpose may also include sending product and operational information related to the contractual relationship (functional changes, security notices, service information).
For this purpose, we process in particular your Identification data, Contact details, Information related to the contractual relationship, Choice Business technical data, and to the necessary extent also Communication data.
The legal basis is the performance of a contract and the necessity to take steps at your request prior to entering into a contract. To the extent that we communicate with a contact person of the partner (B2B), the legal basis may also be our legitimate interest in ensuring cooperation.
We process data for the duration of the contractual relationship (active partner account) and for a reasonable period after its termination, typically up to 1 year, during which your account is retained in case of return. However, personal data may be processed for a longer period in connection with other purposes stated in this document.
B.2 Conclusion and management of contractual documentation (including electronic signing)
We process personal data for the purpose of concluding and managing contractual documentation, including electronic signing, signature records, and management of contractual documents.
For this purpose, we process in particular Identification data (first name, surname) and Contact details, as well as data required for the signing process and the audit trail of the signature.
The legal basis is the performance of a contract and/or the necessity to take steps prior to its conclusion.
We process data for the duration of the contractual relationship and further for the duration of limitation periods (typically up to 10 years), if necessary for the protection of our legal claims.
B.3 Customer support, incident resolution, and access of our managers to the partner interface
We process personal data for the purpose of providing customer support, resolving technical problems and incidents, and also for system administration and management purposes. In justified cases, our authorized employees/managers may access the partner interface (e.g., when resolving a request or incident), always to the necessary extent.
For this purpose, we process in particular Communication data, Choice Business technical data, and to the necessary extent also Identification and Contact details and operational and security logs.
The legal basis is our legitimate interest in ensuring support, security, and proper operation of the service, or the performance of a contract (if it concerns the handling of a contractual request).
We process data for the period necessary to handle the request and subsequently for a reasonable period, typically a maximum of 1 year, unless it is necessary to retain them longer (e.g., for the protection of legal claims).
B.4 Commercial communications
We may send you offers of our services and other commercial communications. If you are not our customer, we will send commercial communications only to the extent and under the conditions required by legal regulations (in particular, based on consent). In every e‑mail, you can opt out of receiving these.
For this purpose, we process Contact details and, where applicable, Identification data.
The legal basis is our legitimate interest in direct marketing to existing partners, or your consent (if‑required).
B.5 Reviews
We may also use your personal data to publish review information related to your restaurant/partnership.
For this purpose, we process Identification data and Information contained in reviews.
The legal basis is our legitimate interest in our support and promotion. However, we will always agree together on the scope and manner of publishing the review.
Personal data is published for the duration of the mutual cooperation and for a maximum of 10 years after the end of cooperation.
You are a Choice user (end customer)
Below is the processing purposes related to when you create an account in Choice.
B.6 Creation and management of a user account in Choice and provision of application features
If you create a user account in the Choice application, we process personal data for the purpose of registration, account management, login, ensuring application functionality, and providing related features (e.g., order overview, account settings management).
For this purpose, we process in particular Contact details (e‑mail), User data, Information related to orders (order history within the platform), and Choice technical data.
The legal basis is the performance of a contract (provision of the application service) and the necessity to take steps at your request prior to entering into a contract.
We process data for the duration of the account and for a reasonable period after its cancellation, typically up to 3 years, unless we need them longer for legal claims.
B.7 Orders at individual restaurants and our role as a processor
When ordering from a specific restaurant through our solutions (e.g., restaurant web interface), order data may be processed (e.g., what you ordered, delivery contact details, address, number of orders, and feedback). In such cases, the respective restaurant is generally the controller, and we act as a processor providing the technical solution. Information about processing by the restaurant will be provided to you by the respective restaurant in its policies.
B.8 Customer support and handling of user requests
We process personal data for the purpose of handling your inquiries and requests, resolving technical problems, and communicating with customers.
For this purpose, we process Contact details, Communication data, and where applicable, Account data and Choice technical data.
The legal basis is our legitimate interest in ensuring support and/or the performance of a contract.
We process data for the period necessary to handle the request and subsequently typically for a maximum of 1 year, unless it is necessary to retain them longer.
B.9 Analytics and improvement of our services
We may process data to understand how the website and applications are used and to improve features and user experience (e.g., measuring traffic, performance, and feature usage).
For this purpose, we process Technical data and Cookie data, if analytics are carried out through cookies or similar identifiers.
The legal basis is our legitimate interest in the development and optimization of the service, or your consent (if required for cookies).
We process data for the period necessary to fulfil the purpose, typically no more than 12 months, or until the withdrawal of consent.
Common purposes for all processing
B.10 Communication through the website (contact forms, demo, inquiries)
If you contact us through the website or other channels, we process personal data for the purpose of handling your inquiry and conducting communication.
For this purpose, we process Identification data (if you provide them), Contact details, and Communication data.
The legal basis is our legitimate interest in ensuring communication. If a contract is subsequently concluded, the legal basis may also be the performance of a contract.
We process data for the period necessary to handle the inquiry and subsequently for a reasonable period, typically up to 12 months from the closure of communication.
B.11 Internal records, reporting, and protection of our rights
We may process personal data for the purpose of maintaining internal records, account management, statistics and reporting, and for the protection of our rights and legal claims (including defense against potential claims).
For this purpose, we process personal data listed in Section A, always to the extent necessary for the given purpose.
The legal basis is our legitimate interest in maintaining records and protecting legal claims.
We process data for the duration of limitation periods, typically up to 10 years from the occurrence of the event from which the limitation period is calculated.
B.12 Fulfilment of legal obligations
We may process personal data in order to fulfil our legal obligations, in particular in the area of accounting, taxes, and related obligations, and to provide cooperation to public authorities if required by law.
For this purpose, we process in particular Identification data, Contact details, and billing/accounting data (if relevant).
The legal basis is the fulfilment of a legal obligation.
We process data for the period stipulated by legal regulations (typically up to 10 years in the area of accounting and taxes).
Processing related to cookies
B.13 Website/platform operation and security (necessity)
We use necessary cookies and similar technologies to ensure the basic functions of the website and security. These cookies cannot be disabled in the cookie bar.
For this purpose, we process Cookie data to the extent of necessary cookies.
The legal basis is our legitimate interest in the proper functioning and secure operation of the website.
Data is generally processed for the duration of your website visit, or for the lifetime of the specific necessary cookie, but no longer than 1 year.
B.14 Analytical cookies
We use analytical cookies to measure traffic and evaluate the use of the website and our campaigns. We store these cookies only after you grant your consent in the cookie bar.
For this purpose, we process Cookie data and related technical data (e.g., IP address truncated/encoded according to the tool settings).
The legal basis is your consent.
We process data for the period according to the settings of specific cookies/tools, but no longer than until the withdrawal of consent. Details are provided in the cookie bar/cookie table.
B.15 Marketing cookies
We use marketing cookies to measure advertising effectiveness and display personalized advertising. We store these cookies only after you grant your consent in the cookie bar.
For this purpose, we process Cookie data and related technical data.
The legal basis is your consent.
We process data for the period according to the settings of specific cookies/tools, but no longer than until the withdrawal of consent; details are provided in the cookie bar/cookie table.
C. SHARING OF PERSONAL DATA
Your personal data may be shared with the following recipients:
- CRM providers (e.g., Pipedrive) for partner and communication records;
- providers of electronic signing and document management tools (e.g., DocuSign);
- providers of communication tools;
- providers of analytical and marketing tools (e.g., Google Analytics, Google Ads) – generally only based on your consent granted in the cookie bar;
- storage provider (MongoDB, Inc., the transfer is based on standard contractual clauses);
- providers of e‑mail services and communication platforms used for operational and marketing communication;
- providers of accounting and tax services, external accountants;
- public authorities and other entities, if this obligation is imposed on us by a legal regulation;
- in the case of mobile applications, also operators of distribution platforms (Apple App Store / Google Play), who act as independent controllers.
If we share your personal data with controllers and processors in third countries (outside the EEA), we do so only where these persons provide adequate safeguards as set out under Article 44 et seq. of the GDPR.
D. YOUR RIGHTS IN PROCESSING AND THE POSSIBILITY OF EXERCISING THEM
You have the right to (i) request access to your personal data; (ii) withdraw your consent; (iii) request rectification of your personal data; (iv) request erasure of your personal data; (v) request restriction of processing of your personal data; (vi) request portability of your personal data; (vii) object to the processing of your personal data; or (viii) lodge a complaint with the relevant supervisory authority.
In all matters related to the processing of your personal data, whether it is a question, exercise of rights, sending a complaint to us, etc., you can contact us via the email address stated at the beginning of this document.
D.1 Right of access
You have the right to obtain from us confirmation as to whether or not we process your personal data.
If we process your personal data, you also have the right to request access to information about the purpose and scope of processing, data recipients, processing period, the right to rectification, erasure, restriction of processing and to object to processing, the right to lodge a complaint with the supervisory authority, and about the sources of personal data (this information is already provided in this document).
You may also request a copy of the processed personal data from us. We provide the first copy free of charge; additional copies may be subject to a fee. The scope of data provided may be limited so as not to infringe on the rights and freedoms of other persons.
D.2 Right to withdraw consent
You have the right to withdraw your consent to the processing of personal data at any time. However, the withdrawal of consent does not affect the lawfulness of processing prior to such withdrawal, nor will it lead to the termination of processing of personal data that have already been anonymized.
D.3 Right to rectification
You have the right to request from us the rectification of inaccurate personal data concerning you. Depending on the purpose of processing, you may also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
D.4 Right to erasure (right to be forgotten)
You have the right to request the erasure of your personal data in cases where:
- your personal data are no longer necessary for the purposes for which they were collected or processed;
- you withdraw the consent on the basis of which the personal data were processed, and there is no other reason for their processing;
- you object to the processing and there are no further overriding grounds for the processing, or you object to the processing for the purpose of direct marketing;
- the personal data are processed in violation of legal regulations.
However, you cannot exercise this right where processing is necessary for the fulfilment of our legal obligations or tasks entrusted to us in the public interest, or for the establishment, exercise, or defense of legal claims.
D.5 Right to restriction of processing
You have the right to request the restriction of processing of your personal data in cases where:
- you contest the accuracy of your personal data; in such a case, you may request the restriction of processing for the period necessary to verify the accuracy of the personal data;
- the processing is in violation of legal regulations and instead of erasure, you request the restriction of processing of personal data;
- we no longer need your personal data for the purposes for which they were collected or processed, but you require them for the establishment, exercise, or defense of legal claims;
- you have objected to the processing of personal data; in such a case, you may request the restriction of processing for the period necessary to verify whether our legitimate interests prevail.
D.6 Right to portability
You have the right to obtain a copy of your personal data that we process automatically on the basis of your consent or for the performance of a contract. We will transfer these data in a commonly used and machine-readable format to you or to a controller designated by you, where technically feasible. The scope of data provided may be limited so as not to infringe on the rights and freedoms of other persons.
D.7 Right to object
You have the right to object to the processing of your personal data that we process on the basis of our legitimate interest. We will cease processing your data unless there are further overriding grounds for processing or unless processing is necessary for the establishment, exercise, or defense of legal claims, or if you object to processing for the purpose of direct marketing.
E. RIGHT TO LODGE A COMPLAINT
In addition to the possibility of exercising your rights with our company, you may also lodge a complaint with the relevant supervisory authority, which is the Office for Personal Data Protection, located at Pplk. Sochora 27, 170 00 Prague 7.
F. CHANGES TO THIS PROCESSING INFORMATION
We are entitled to change this processing information from time to time, so please check it regularly. We will publish any changes to this document on our website.