Updated 22.05.2023
At Sticks’n’Sushi, protecting and respecting your privacy is very important to us.
This privacy policy explains when, why, and how we collect, use, and share personal information about individuals who visit our restaurants, use our websites, apps, booking solutions, or communicate with us.
Our collection and use of personal data include information from and about our suppliers, customers, recipients of our newsletters, as well as visitors to our website and social media platforms. We collect data for a variety of purposes, depending on which of our services you use.
The purpose of this data protection policy is to provide you with easy-to-access information about how we collect and use your personal data.
1. General Privacy Policy
1.1. How we collect information, what information we collect, and why
Depending on how you interact with us, we may collect and process information about you as described below:
Customer Information
We collect the information that you provide to us when using our website and app to create a user account, as well as when you make reservations or place orders with us. This information includes name, contact details (email address, phone number, and address), account information (username and password), language and payment preferences, and transactions (orders, reservations, and purchases). We may also process sensitive information about dietary restrictions or allergies if you provide such information in your profile or when placing an order. If you contact us, we may also store our correspondence to respond to and follow up on your inquiries, complaints, etc.
We process this information for the purpose of: (i) handling reservations and delivering the products/services you order, cf. Article 6(1)(b) of the EU General Data Protection Regulation (“GDPR”), (ii) complying with applicable law (e.g. information on financial transactions in accordance with tax and accounting rules), cf. Article 6(1)(c) of GDPR, and (iii) pursuing our legitimate interest in communicating with you, conducting statistical analysis, and improving our products, services, and customer experiences, cf. Article 6(1)(f) of GDPR. Information about dietary restrictions and allergies is processed for your safety and based on your prior consent, cf. Article 6(1)(a) and 9(2)(a) of GDPR.
Newsletters
If you sign up to receive our news or other information from us, we will process information about your name, email address, and preferred information.
We process this information for the purpose of: (i) delivering information and news in accordance with your preferences, cf. Article 6(1)(b) of GDPR, and (ii) pursuing our legitimate interest in communicating with recipients and improving our services and offers, cf. Article 6(1)(f) of GDPR.
Websites
We collect information about visitors to our website through cookies and similar technologies for the purpose of: ensuring that our website functions (necessary cookies), enabling the site to function as desired (e.g., by storing language settings and login), and tracking website visitors for statistical and marketing purposes. Cookies for functionality, statistics, and marketing are optional and only used based on your consent, cf. Article 6(1)(a) of GDPR. Necessary cookies are used to pursue our legitimate interest in operating our websites and managing cookie settings, cf. Article 6(1)(f) of GDPR.
Read more about the use of cookies on our websites in our cookie policy below.
Surveillance Videos
We use surveillance cameras in our restaurants to record video footage. This is done to ensure the safety and security of our guests, our staff, and our property, as well as to prevent and document criminal offenses. Surveillance videos will only be shared with law enforcement upon specific request when this is required for crime investigations.
This processing is based on our legitimate interest in protecting our guests, staff, and property, as well as preserving and securing evidence, cf. Article 6(1)(f) of GDPR. If the video reveals criminal acts, processing may also be based on the establishment and exercise of legal claims, cf. Article 9(2)(f).
Whistleblower Scheme
We have established a whistleblower scheme to allow former and current employees, suppliers, partners, and other external parties to report concerns and reasonable suspicions about actual or potential violations. You can read more about the scheme and how to report here.
To manage the whistleblower scheme, we may process personal data about whistleblowers as well as individuals mentioned in the reports or whose information becomes relevant in connection with an investigation. The processing includes receiving and handling reports, conducting investigations, notifying relevant authorities, and taking appropriate action.
This processing is based on our obligation to comply with applicable law, our legitimate interest in receiving and investigating serious violations, and the management of legal claims, cf. Articles 6(1)(c), 6(1)(f), and 9(2)(f) of GDPR. Individuals whose information is processed under the whistleblower scheme will be notified in accordance with applicable law.
Sticks’n’Sushi Loyalty Program
When you sign up as a user of our SNS loyalty app and join our SNS loyalty program, Frequent Fisher, we collect and process the information you provide upon registration (name, address, email, and phone number), information about your membership (member ID and start date of membership), as well as information about your activities (points earned and redeemed, benefits, bonuses, purchases made, offers received, and communication with us). Information about your payment card is collected and used to process payments, but this information is only accessible to the third-party payment provider handling the payment process.
We process your information to manage and fulfill our obligations to you as an SNS loyalty customer – including providing you with access to membership benefits, sending you relevant offers, and communicating with you about your membership. The legal basis is Article 6(1)(b) and Article 6(1)(f) of GDPR in respect of our legitimate interest in communicating with loyalty customers and improving our services and offers. Our processing of your information to send you customized marketing materials and offers is based on your consent, cf. Article 6(1)(a) of GDPR.
a. Who Receives the Information?
Your personal data may be disclosed to Sticks’n’Sushi employees who need to process the data for the purposes described above. This information will be treated responsibly and securely.
Your personal data may also be disclosed to third-party processors, such as our payment, delivery, and hosting providers, but only to the extent necessary for us to operate our business and fulfill our obligations to you. Third-party processors will only process the information in accordance with our instructions and for our purposes. They will not disclose your data to others and will delete it once their tasks are completed. We do not sell your personal data to third parties.
If authorities request access to your data, we conduct a legal assessment of the request. If required by law, we will comply with the request. You will be notified in accordance with applicable law.
1.2. Where We Store Your Information
We may transfer your personal data outside the European Union and the European Economic Area. Regardless of where your data is transferred, we ensure that this is done under appropriate safeguards. We ensure an adequate level of protection in accordance with applicable data protection law. This is done, for example, through the use of standard contractual clauses on data protection adopted by the EU, cf. Article 46(2)(c) of GDPR, or binding corporate rules, cf. Article 46(2)(b) of GDPR. For further information, you can contact us at [email protected].
1.3. How We Secure Your Information
Your personal data is protected by both technical and organizational measures. Any transfer of personal data and tokens will always be encrypted. All personal data will be stored securely, and any access to the data is monitored and restricted to the necessary extent. Recipients of the data are bound by confidentiality or are subject to confidentiality obligations.
1.4. How Long We Store Your Information
We retain your personal data only as long as we deem necessary to perform our activities and deliver our services to you, considering our legal obligations (e.g., retention of data for tax authorities). The criteria for determining the retention period relate to factors such as an ongoing contractual relationship with you, active customer status, and the nature of your inquiries, including any disputes.
For example:
Data about transactions are retained in accordance with applicable local law, e.g., in relation to bookkeeping or tax.
Data related to subscriptions for receiving information and news will be retained until you unsubscribe from these services.
Surveillance videos will be retained for a maximum of 30 days as required by applicable law.
If you have created an account on our website or app, the account will be deleted 30 days after you request deletion. Information about allergies can be deleted earlier if you withdraw your consent.
Posts, comments, or likes made on our social media will be deleted if you choose to remove them from your profile.
1.5. Your Rights to Your Personal Data
You have the following rights regarding the information we process about you:
Right of Access: You have the right to request access to the data we process about you.
Right to Rectification: If the information we process about you is inaccurate, you have the right to have it corrected.
Right to Erasure: You have the right to request that we delete your data before the usual retention period.
Right to Restrict Processing: You have the right to request that we restrict the processing of your data. In such cases, we are only entitled – apart from storage – to process such data for handling legal claims, to protect the rights of another natural person, or for reasons of significant public interest.
Right to Withdraw Consent: Where our processing of your data is based on your consent, you are entitled to withdraw this consent at any time. Sticks’n’Sushi will then cease to use your personal data.
Right to Object: You are entitled to object to our processing of your data.
Right to Data Portability: You are entitled to request to receive your data in a structured and commonly used format.
If you wish to exercise any of these rights or have other questions about our use of your personal data, please contact [email protected].
If you are dissatisfied with our processing of your personal data, you may also file a complaint with the relevant supervisory authority. The relevant authority for Denmark is the Danish Data Protection Agency. You can read more on the Data Protection Agency's website, where you can also find further information about your rights. You can see a complete list of European supervisory authorities here.
1.6. Responsible Entities
The legal entity responsible for processing your personal data is the local company operating the location you interact with:
Denmark:
Sticks’n’Sushi A/S, Nansensgade 49, 1366 Copenhagen
Phone: +45 3311 7030
E-mail: [email protected]
United Kingdom:
Sticks’n’Sushi UK Ltd, 58 Wimbledon Hill Road, SW19 7PA, London
Phone: + 44 0203 141 8840
Germany:
Sticks’n’Sushi Restaurants Berlin GmbH
Potsdamer Straße 85
10785 Berlin
Sticks’n’Sushi Germany GmbH
Kantstraße 152
10623 Berlin
Sticks’n’Sushi Kantstraße 152 GmbH
Kantstraße 152
10623 Berlin
Phone: +49 (0) 30 261 036 56
E-mail: [email protected]
1.7. Updates and Legal Information
We reserve the right to make changes to our privacy policy. Any changes take effect immediately upon posting. The date of the current version of our data protection policy is at the top of this page.
Our privacy policy is subject to Danish law and the Danish courts.
2. Social Media Policy
Sticks’n’Sushi and the individual social media platforms are joint data controllers regarding the processing of your personal data on our social media sites. This policy is supplementary to the general privacy policies of each social media platform. Our social media partners include Facebook, Instagram, and LinkedIn.
2.1. How We Process Your Personal Data Through Social Media
We use your personal data, such as behavior (based on your likes, comments, visits, etc.) or other information on social media, to improve our services and perform research and statistical analysis. We process this data based on our legitimate interest in improving our services, cf. Article 6(1)(f) of GDPR. For further information about the data we collect via cookies on our social media, see our cookie policy below.
Our social media partners collect statistical data on visitor behavior for their purposes through cookies and pixels on your device when you visit our pages. For further information on how these platforms process personal data, please refer to their privacy policies (Facebook, Instagram, and LinkedIn) and cookie policies (Facebook, Instagram and LinkedIn).
2.2. How We Share Your Personal Data
We do not sell your personal data collected via social media to third parties.
Social media platforms may share your personal data internally with their subsidiaries and externally with partners for analysis and advertising, as well as other individuals, survey partners, researchers, and academics. For further details, refer to their terms and privacy policies.
2.3. How to Exercise Your Rights With Social Media
Most social media platforms require that you contact them directly to exercise your rights, as they can take the necessary steps. If you believe we can comply with your request, you are welcome to contact us as well.
If you are a Facebook user, you may exercise your rights by changing your privacy settings (link) or configuring your preferences (link). If you are a LinkedIn user, click here (link) to change your settings or here (link) to exercise your rights. If you are an Instagram user, click here (link) to change your settings or here (link) to exercise your rights.
3. Cookie Policy
Some of the information we process is collected through cookies on our websites and social media.
3.1. What is a Cookie?
Cookies are files sent by web servers to web browsers and stored by the web browser. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track web browsers.
There are two main types of cookies: session cookies and persistent cookies. Session cookies are deleted from your computer when you close your browser, while persistent cookies remain on your computer until deleted or until they expire.
3.2. The Purpose of Cookies on Our Websites
The information collected via cookies is used to operate our websites, analyze and optimize the user experience, and measure traffic. Additionally, they are used for tracking purposes, allowing us to document site visits and their origins.
Our websites also use advertising and targeting cookies to deliver relevant advertisements. They are also used to limit the frequency of ads and measure the effectiveness of ad campaigns. These cookies are often placed by advertising agencies with the operator's consent.
3.3. What Information Do We Collect?
We may collect technical data (such as device type, unique device ID, IP address, operating system, web browser, etc.), location information (if you allow location sharing on your device), and behavioral data (including traffic data, web logs, etc.).
You can find more details about specific cookies used on our websites via our cookie management platform.
3.4. How to Delete or Block Cookies
Most browsers allow you to reject cookies. For more information, follow this link (https://uk.pcmag.com/how-to/40872/how-to-control-and-delete-cookies-on-your-browser).
If you adjust your browser settings to reject cookies, this may affect the functionality of our website. It is therefore not recommended to reject cookies, as we cannot guarantee the desired functionality or performance.