Privacy Policy
UAE DATA PROTECTION NOTICE
Nusret Restaurant LLC and D Et ve Et Ürünleri Gıda Pazarlama Tic. A.Ş. (hereinafter also “Nusr-et”, “we”, “us”) wish to inform you below of how your personal data are Processed within the context of our website. We jointly determine themethod and criteria for Processing (as defined below) your Personal Data, for the purposes of certain activities that we undertake in the course of our business, which we have described below. This makes us “Controllers” under the UAE Federal Decree Law No. (45) of 2021 concerning the protection of personal data (the “DP Law”). We are, therefore, required to comply with the DP Law in how we perform this role. Since we perform this role together, we are joint Controllers. Reference in this notice to “Data Controller” refers to us as joint Controllers.
Any personal data (such as your name, voice, image, electronic identifier, identification number, location data, or one or more factors specific to your physical, physiological, economic, cultural or social identity and includes Sensitive Personal Data and Biometric data as those terms are defined in the DP Law) (“ Personal Data ”) Processed (as defined below) in connection with the activities described below in this Data Protection Notice must be Processed in accordance with the DP Law.
Where the DP Law is silent or a matter is deferred to the Executive Regulations of the DP Law (which are yet to be published), the UAE Federal Law No. (31) of 2021 Promulgating the Penal Code, and the UAE Federal Telecommunications Regulatory Authority’s Regulatory Policy on the Internet of Things issued on 22 March 2018, apply.
We are committed to protecting the privacy and security of your Personal Data as a Data Controller. Therefore, we are committed to ensuring that your Personal Data is handled lawfully, fairly and in a transparent manner in accordance with the principles set out in the UAE DP Laws. This Data Protection Notice explains how we will collect, use, disclose, retain and protect your Personal Data.
2. WHEN DOES THIS DATA PROTECTION NOTICE APPLY?
This Data Protection Notice applies to your Personal Data that we collect, use and Process in connection with the transaction you take when you visit our website www.nusr-et.com.tr as a website visitor, job applicant, customer or potential customer.
“Process” in the context of this Data Protection Notice means any operation or set of operations performed on Personal Data using any electronic means, including processing and other means. This processing includes collecting, storing, recording, organizing, adapting, modifying, circulating, altering, retrieving, exchanging, sharing, using, characterizing, disclosing Personal Data by broadcasting, transmitting, distributing, making available, coordinating, merging, restricting, blocking, erasing or destroying it or creating forms thereof.
3. HOW DO WE COLLECT PERSONAL DATA?
We may obtain your Personal Data from the following sources:
- a) from you directly: for example, at the time of subscribing to, or registering for any services offered on our website, including but not limited to email mailing lists, using interactive services, downloading content, or requesting further goods or services);
- b) from your device or browser: data that is automatically collected (which will vary depending on your browser settings) by your browser or device, for example, the IP address of your internet service provider, the operating system you use, the name and version of your internet browser. The information provided by your browser does not identify you personally.
- c) from correspondence with us (for example, by e-mail or any other digital or electronic form, including social media).
4. CATEGORIES OF PERSONAL DATA AND PURPOSES AND LAWFUL BASIS FOR PROCESSING
We may Process your Personal Data in different ways. In all cases we are committed to protecting your Personal Data. In each of the subheadings listed below, we describe how we obtain your Personal Data and how we treat it.
4.1. JOB APPLICANTS
We may collect Personal Data related to job applicants for positions advertised on our website.
4.1.1. Personal Data that we collect and Process
| Category of Personal Data | Personal Data |
|---|---|
| Identity Details: | Name, surname, date of birth, place of birth, ID number/tax number, nationality, driving license, marital status. |
| Contact Details: | Telephone number, e-mail address, address information. |
| Personnel information: | CV, work/performance details, payroll details, certificate of employment records, professional/personal skills, registration number. |
| Professional Experience: | Taken course details, vocational education details, certificates, profession details. |
| Visual and Audio Records: | Photograph, voice records, visual records (such as video records, etc.). |
4.1.2. Why do we collect your Personal Data and what are our lawful bases for it?
| Purpose of Data Processing | Lawful Basis |
|---|---|
| Creating an Employee Candidate CV archive | Your prior consent. |
| Execution the Employee Candidate online application process | Your prior consent. |
| Performing Reference Check | Your prior consent. |
| Verification of training certificate records | Your prior consent. |
4.1.3. How long do we keep your Personal Data?
We will keep and Process your Personal Data only for as long as is necessary for the purposes for which it was collected. If you are successful and we hire you, we will keep your CV as part of your employee record for the duration of your employment with us. We will keep CVs and documents submitted by unsuccessful candidates only if they consent to us doing so and only for a specified period of no longer than 6 months, unless we obtained their consent to keep it for longer.
4.2. CUSTOMER
We may collect Personal Data related to our existing customers.
4.2.1. Personal Data that we collect and Process
| Category of Personal Data | Personal Data |
|---|---|
| Identity Details: | Name, surname, date of birth, ID number/ tax number, driving license, signature. |
| Contact Details: | Telephone number, e-mail address. |
| Personnel information: | Registration number, Education information, certificate of employment records, professional/personal skills. |
| Your Professional Experience: | Vocational education details, certificates, profession details. |
| Visual and Audio Records: | Photograph. |
| Vehicle Details: | License plate information. |
| Your Special Categories of Personal Data: | Personal health details, disability details. |
4.2.2. Why do we collect your Personal Data and what are our lawful bases for it?
| Purpose of Data Processing | Lawful Basis |
|---|---|
| Opentable reservation process | Your prior consent. |
| Supplier, subcontractor, visitor OHS Basic Requirements Control | Mandatory requirements under Emirate decrees or laws and/ or Municipality regulations mandating the use of surveillance cameras in restaurants in the relevant Emirate. |
Some of the information we collect (such as health information) under the heading of Special Categories of Personal Data may be deemed to fall within the definition of Sensitive Personal Data under the DP Law. These are Personal Data which are afforded additional legal protection due to the sensitive nature of such data. We shall not be prohibited from Processing such data for the specific purpose we have explained to you provided you explicitly consent to the same and we Process such data for a legitimate purpose and in a lawful manner.
4.2.3. How long do we keep your Personal Data?
We will Process your Personal Data only for as long as is necessary for the purposes for which it was collected in connection with the provision of service to you, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defence of legal claims.
4.3. POTENTIAL CUSTOMER
We may collect Personal Data related to potential customers.
4.3.1. Personal Data that we collect and Process
| Category of Personal Data | Personal Data |
|---|---|
| Identity Details: | Name, surname. |
| Contact Details: | Telephone number, e-mail address. |
| Your Special Categories of Personal Data: | Personal health details. |
4.3.2. Why do we collect your Personal Data and what are our lawful bases for it?
| Purpose of Data Processing | Lawful Basis |
|---|---|
| Opentable Reservation Process | Your prior consent. |
Some of the information we collect (such as health information) under the heading of Special Categories of Personal Data may be deemed to fall within the definition of Sensitive Personal Data under the DP Law. These are Personal Data which are afforded additional legal protection due to the sensitive nature of such data. We shall not be prohibited from Processing such data for the specific purpose we have explained to you provided you explicitly consent to the same and we Process such data for a legitimate purpose and in a lawful manner.
4.3.3. How long do we keep your Personal Data?
We will Process your Personal Data only for as long as is necessary for the purposes for which it was collected in connection with the provision of service to you, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defence of legal claims.
5. WHO DO WE SHARE YOUR PERSONAL DATA WITH?
In Sections 5 and 6 of this Website Data Protection Notice, the following words shall have the following meanings:-
“Affiliate” means in relation to Nusret Restaurant LLC or D Et ve Et Ürünleri Gıda Pazarlama Tic. A.Ş, any other Person directly or indirectly controlling or controlled by or under direct or indirect common control with Nusret Restaurant LLC or D Et ve Et Ürünleri Gıda Pazarlama Tic. A.Ş. For the purposes of this definition, “control” when used with respect to either Nusret Restaurant LLC or D Et ve Et Ürünleri Gıda Pazarlama Tic. A.Ş means the power to direct the management and policies of such Person, directly or indirectly, whether through the ownership of voting securities, by contract or otherwise; and the terms “controlling” and “controlled” have meanings correlative to the foregoing.
“UAE MainlandAffiliate” means an Affiliate registered in the UAE mainland;
"Non-UAE Mainland Affiliate” means an Affiliate registered outside the UAE mainland; and
“Person” means any natural person, corporation, limited liability company, trust, joint venture, association, company, partnership, governmental authority or other entity.
We do not sell your Personal Data to third parties.
We may share your Personal Data with Nusr-et’s UAE Mainland Affiliates and Non-UAE Mainland Affiliates because we share the same guest management and IT systems. Such transfers are governed by jurisdiction-compliant agreements between the Affiliates for the integrity and confidentiality of Personal Data.
Service Providers
We may disclose information about you to organisations that provide a service to us, ensuring that they are contractually obligated to keep your Personal Data confidential and will comply with the DP Law, GDPR, and any other relevant data protection laws.
We may share your information with the following types of service providers:
- a) technical support providers who assist with our website and IT infrastructure,
- b) third party software providers, where the provider hosts the relevant Personal Data on our behalf;
- c) professional advisers such as solicitors, accountants, tax advisors, auditors and insurance brokers;
- d) providers that help us generate and collate reviews in relation to our goods and services;
- e) our advertising and promotional agencies and consultants and those organisations or online platforms selected by us to carry out marketing campaigns on our behalf (for example, Facebook, Google, Instagram);
- f) service providers that assist us in providing our services; and/or
- g) our business associates in the UAE mainland and outside the UAE mainland.
Law Enforcement or Government Bodies
We may disclose your Personal Data to the required authorities, as permitted by law, in order to investigate, prevent or take action regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of our Terms and Conditions or other agreements, or as required by law.
6. TRANSFERS OF PERSONAL DATA OUTSIDE THE UAE MAINLAND
We share Personal Data with external vendors or service providers or suppliers that we engage to perform services or functions on our behalf and under our instructions. Where these vendors are located within the UAE mainland (i.e. not within a free trade zone such as DIFC or ADGM), we ensure that they are contractually obligated to comply with the DP Law. Where they are located outside the UAE, we shall ensure that your Personal Data shall only be transferred to a jurisdiction outside the UAE mainland if that jurisdiction has proper levels of protection for that type of Personal Data, meaning it has personal data protection legislation which includes the most significant provisions, measures, controls, stipulations and rules relating to the protection of the privacy and confidentiality of a data subject’s Personal Data, and his/her ability to exercise their legal rights. We also ensure in our contracts with these organisations that they only Process your Personal Data fairly, lawfully and transparently, in accordance with our instructions, and in order to provide the agreed services and protect the integrity and confidentiality of your Personal Data entrusted to them.
7. LINKS TO OTHER WEBSITES
Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Data Protection Notice. Nusr-et has a presence on social media (Facebook, Twitter, YouTube etc.) and you can interact with us through your existing social media accounts in accordance with their relevant privacy policies.
8. YOUR DATA PROTECTION RIGHTS
You have the following rights in relation to your Personal Data:-
- Ø Right to receive information: Individuals have the right to request the information that an organisation holds on them, which includes what Personal Data of theirs is being collected, how it is being used, decisions made based on automated processing, the targeted sectors or establishments inside and outside the UAE with whom their Personal Data will be shared with, the controls and standards for the period of storage and preservation of their Personal Data, protection measures for cross-border Processing, actions to be taken in the event of a breach or misuse of their Personal Data, and how to submit complaints to the UAE Data Office (once it is established).
- Ø Right to correction or erasure: Individuals have the right to correct data that is inaccurate or incomplete. In certain circumstances, individuals can ask organisations to erase any Personal Data that is stored with them
- Ø Right to request transfer: Individuals have the right to receive their data provided to us in an orderly and machine-readable manner, whenever the Processing is based on their consent or necessary for the implementation of a contractual obligation and it is carried out by automated means. Individuals can also request that organisation transfer any data that it holds on them to another company, provided such transfer does not infringe the rights of any other individuals.
- Ø Right to restrict Processing: Individuals can request that an organisation limits the use of and stops the Processing of their Personal Data.
- Ø Right to stop Processing: Individuals have the right to object to certain types of Processing, such as direct marketing.
- Ø Rights Processing and automated Processing including profiling: Individuals have the right to object to any decision based solely on automated Processing, including profiling, which produces legal consequences concerning him or other seriously impactful consequences and to require such decision to be reviewed manually.
- Ø Right to withdraw consent: Individuals may withdraw consent to the Processing of their Personal Data at any time by notifying us.
9. HOW CAN YOU WITHDRAW YOUR CONSENT?
If you consent to us Processing your Personal Data, please note that you may withdraw this consent at any time. In order to withdraw the consent, please contact privacy@nusr-et.com.tr Please note that your consent can only be withdrawn for future Processing activities and such a withdrawal does not have any influence on the lawfulness of past Processing activities. In some cases, we may be entitled in spite of your withdrawal to continue to Process your Personal Data on a different legal basis.
10. UPDATING THIS DATA PROTECTION NOTICE
We reserve the right to update this Data Protection Notice at any time. We will let you know about the changes by publishing the updated version of the Data Protection Notice. We are committed to protecting and respecting your privacy and will continue to do so in any future changes we make to this Data Protection Notice.
11. HOW TO GET IN TOUCH WITH US AND HOW CAN YOU EXERCISE YOUR LEGAL RIGHTS?
If you have any questions about our Data Protection Notice , or if you would like to make a complaint about a possible breach of Personal Data or to exercise one of your data protection rights, please contact us as described below.
Contact us;
Company E-mail address: privacy@nusr-et.com.tr
If you have any concerns about how we Process your Personal Data, please feel free to contact our data protection officer, who will investigate the matter and come back to you, by sending an email to privacy@nusr-et.com.tr
If you are still not satisfied after our response or believe we are not using your personal information in line with the law, you also have the right to complain to the data-protection regulator in the country where you live or work.