Purpose and who we are
The purpose of this Privacy Policy is to
describe how Gastronomist Limited (“Gastronomist”, "CORD,"
"us," "we," or "our") collects, uses and shares
information about you through our online interfaces (e.g., websites and mobile
applications) owned and controlled by us, including www.cordrestaurant.co.uk (collectively referred to
herein as the "Site"). Please read this notice carefully to
understand what we do.
Launched
in June 2022, CORD is the first dining concept to open in the City of London by
Le Cordon Bleu. A unique offering under one roof: a fine dining destination
restaurant, an all-day café and an outpost to the London Le Cordon Bleu
culinary institute. Central to this mission is our commitment to be transparent
about the data we collect about you, how it is used and with whom it is shared.
This Privacy Policy applies when you use our
Services. We offer our users choices about the data we collect, use and share
as described in this Privacy Policy. CORD is the data controller of all
Personally Identifiable Information (as defined below) collected via the Site
and of certain Personally Identifiable Information collected from third
parties, as set out in this Privacy Policy.
What Information this Privacy
Policy Covers
This Privacy Policy covers information we
collect from you through our Site. Some of our Site’s functionality can be used
without revealing any Personally Identifiable Information, though some features
or services will require Personally Identifiable Information. In order to
access certain features and benefits on our Site (obtain information about CORD
or to register on a mailing list, or wish to be redirected to an on-line
application for courses run by Le Cordon Bleu), you may need to submit, or we
may collect, "Personally Identifiable Information" (i.e., information
that can be used to identify you). Personally Identifiable Information can
include information such as your name and email address, among other things.
You are responsible for ensuring the accuracy of the Personally Identifiable
Information you submit to CORD. Inaccurate information may affect your ability
to use the Site, the information you receive when using the Site, and our
ability to contact you. For example, your email address should be kept current
because that is one of the primary manners in which we communicate with you.
What You Agree to by Using Our
Site
Please understand that by submitting any
Personally Identifiable Information to us, you consent and agree that we may
collect, use and disclose such Personally Identifiable Information in
accordance with this Privacy Policy and our Terms of Use, and as
permitted or required by law. If you do not agree with these terms, please do
not provide any Personally Identifiable Information to us. If you refuse or
withdraw your consent, or if you choose not to provide us with any required
Personally Identifiable Information, we may not be able to provide you with the
services that can be offered on our Site. Consent can be withdrawn at any time,
but please note that we may also rely on legitimate interests or fulfilment of
a contract to continue processing your data.
What Information We Collect
Information relating to your use of
our Site.
Cookies are created when you use your browser to visit a website
that uses cookies to keep track of your movements and preferences within the
site. We use cookies on CORD website to offer the best user experience to our
visitors.
To learn more about how our website uses cookies, please refer
to our Cookie Policy.
CORD
collects IP addresses for the purposes of its system administration and to
analyse the use of its Site. We do not link IP addresses to any information
that is personally identifiable, which means that your session will be logged,
but you remain anonymous to us. We may use your IP address in cooperation with
your Internet service provider to identify you if we feel it is necessary to
enforce compliance with our Terms of Use or to protect our services, customers
or as required by law.
Personally Identifiable Information
provided directly by you or via third parties. We collect
Personally Identifiable Information that you provide to us when you register
for an account, update or change information for your account, purchase
products or services, complete a survey, sign-up for email updates or send us
email messages. We may use the Personally Identifiable Information that you
provide to respond to your questions, send you updates about CORD events, and
send you email messages about Site maintenance or updates.
Type of data
we Collect. Personal data such as first name, last name, email and
phone number are required to be able to follow up with the interest that you
have shown in CORD.
Banking data will
be required only when the users will need to proceed to an online payment.
Account Registration. If you
register for an account on our Site, you may be required to provide us with
Personally Identifiable Information such as your name and email address.
Updates. CORD may
offer you the ability to receive updates via email. In order to subscribe to
these services, you may be required to provide us with Personally Identifiable
Information such as your name and email address.
Please also reference our Terms of Use for
our Rules for Online Conduct and additional information about proper use of our
systems.
Posting and Uploading. We collect personal data from you
when you provide, post or upload it to our Services, such as when you fill out
a form, respond to a survey, or submit a resume. You don’t have to post or
upload personal data; though if you don’t, it may render some of our services
and products unavailable.
Service Use: We log your visits and use of our Services.
We log usage data when you visit or otherwise use our Services, including our
sites, app and platform technology, such as when you view or click on content
(e.g., learning video),perform a search, or apply for jobs. We use log-ins,
cookies, and internet protocol (“IP”) addresses to identify you and log your
use.
Participation in our courses. If you
desire to participate in a course, you will be asked to provide us with certain
information necessary to conduct such a course. This information may include,
among other things, your name and email address.
Communications with CORD. We may
receive Personally Identifiable Information when you send us an email message
or otherwise contact us.
Third Party Sites. We may
receive Personally Identifiable Information when you access or log-in to a
third party site. This data includes information such as the amount of time
spent on the partner site and pages viewed.
Data Integrity and Purpose
Limitation. We will process Personal Information in a manner that is
compatible with and relevant to the purpose for which it was collected or
authorized by you. To the extent necessary for those purposes, we will take
reasonable steps to ensure that Personal Information is accurate, complete,
current and reliable for its intended use.
The basis for processing your
personal data (other than with your consent)
Performance of a contract with you: We process
your personal data because it is necessary for the performance of a contract to
which you are a party or in order to take steps at your request prior to
entering into a contract. In this respect, we use your personal data for the
following:
•
To deal with any complaints or feedback you may have;
•
For any other purpose for which you provide us with your personal data.
In
this respect, we may share your personal data with or transfer it to the
following:
•
Your agents, intermediaries;
•
Third parties whom we engage to assist in delivering the services to you
•
Our professional advisers where it is necessary for us to obtain their advice
or assistance
Legitimate interests: We also
process your personal data because it is necessary for our legitimate
interests, or sometimes where it is necessary for the legitimate interests of
another person. In this respect, we use your personal data for the following:
• For marketing to you. In this respect, see
the separate section on Marketing below;
• For the administration and management of our courses,
services, sales, and events
• To ensure a safe environment for our staff
Legal obligations: We also
process your personal data for our compliance with a legal obligation which we
are under. In this respect, we will use your personal data for the following:
•
As required by tax authorities or any competent court or legal authority.
In
this respect, we will share your personal data with the following:
•
With third parties who assist us in conducting background checks;
• With relevant regulators or law enforcement
agencies where we are required to do so.
Marketing
•
We
will send you marketing about similar services we provide, as well as other
information in the form of newsletters and invitations to events or functions
which we believe might be of interest to you.
•
We
will communicate this to you in a number of ways including by post, telephone,
email, SMS or other digital channels.
•
When emailing, recipients always have the right to unsubscribe and a
link is included on all email communications to do so.
•
The
data subject can unsubscribe at any
How We Use the Information
Information relating to your use of
our Site. We use information relating to your use of the Site to build
higher quality, more useful services by performing statistical analyses of the
collective characteristics and behaviour of our users, and by measuring
demographics and interests regarding specific areas of our Site. We may also
use this information to ensure the security of our services and the Site.
Personally Identifiable Information
provided directly by you or via third parties. Except as set forth in this
Privacy Policy or as specifically agreed to by you, CORD will not disclose any
of your Personally Identifiable Information. In addition to the other uses set
forth in this Privacy Policy, we may disclose and otherwise use Personally
Identifiable Information as described below.
Providing the Site and our services. We use
Personally Identifiable Information which you provide to us in order to allow
you to access and use the Site and in order to provide any information,
products or services that you request from us.
Updates. We use
Personally Identifiable Information collected when you sign-up for our various
email or update services to send you the messages in connection with the Site
or Events. We may also archive this information and/or use it for future
communications with you, where we are legally entitled to do so.
Security and Investigations: We may use data for
security, fraud prevention and investigations. We may use your data (including
your communications) if we think it’s necessary for security purposes or to
investigate possible fraud or other violations of our Terms and Conditions, or
this Privacy Policy and/or attempts to harm our Staff or Visitors.
Identity Verification. For
services that require identity verification, we use the Personally Identifiable
Information that we collect for verifying your identity, and for authenticating
that submissions made on the Site were made by you. We take data privacy
protection very seriously and, to validate that any request relating to the
retrieval of your personal data is in fact initiated by the data subject, we
may ask additional information necessary to confirm identity when the request
is made.
Aggregate Insights: We use data to generate aggregate
insights. We use your data to produce and share aggregated insights that do not
identify you.
Communications with CORD. When you
send us an email message or otherwise contact us, we may use the information
provided by you to respond to your communication and/or as described in this
Privacy Policy. We may also archive this information and/or use it for future
communications with you where we are legally entitled to do so.
Depending on the services you are interested
in, or enrolled in, we may contact you through email, mobile phone, notices
posted on our websites or apps, and other ways through our Services, including
text messages and push notifications. We will send you messages about the
availability of our Services, courses, events, security, or other
service-related issues.
We
promote our Services to you and others: We use data and content about Members
for invitations and communications promoting membership and network growth,
engagement and our Services.
Disclosure to CORD Operations and
Maintenance Contractors. We use various service providers, vendors and
contractors (collectively, "Contractors") to assist us in providing
our products and services to you. Our Contractors may have limited access to
your Personally Identifiable Information in the course of providing their products
or services to us, so that we in turn can provide our products and services to
you. These Contractors may include vendors and suppliers that provide us with
technology or services. Access to your Personally Identifiable Information by
these contractors is limited to the information reasonably necessary for the
contractor to perform its limited function for us.
Where we process personal data on behalf of our
business partners, we will work with them to ensure you are offered appropriate
choices (and means to exercise those choices) for limiting use or disclosure of
your personal data (where appropriate).
Notwithstanding the foregoing, you agree that
we may disclose Personal Information under the following circumstances without
offering you an opportunity to opt out of such disclosure: (i) to our partner
institutions and other service providers that we have retained to perform
requested services on our behalf; (ii) if we are required to do so by law or
legal process; (iii) pursuant to valid requests by law enforcement or other
government authorities (which we are legally required to respond to); and (iv)
when we believe disclosure is necessary to prevent physical harm or financial
loss or in connection with an investigation of suspected or actual illegal activity.
In addition, we reserve the right to transfer Personal Information in the event
we sell or transfer all or a portion of our business or assets (including in
the event of a reorganization, dissolution or liquidation). Should such a sale
or transfer occur, we will use reasonable efforts to direct the transferee to
use the Personal Information in a manner consistent with this Privacy Policy.
We will only transfer Personal Information to
third parties where the third party: (i) has provided satisfactory assurances
to us that it will protect the Personal Information; (ii) is located in the EU
or a country considered "adequate" for privacy by the EU Commission,
and therefore is required to comply with the EU data protection laws or
substantially equivalent privacy laws
Government Authorities, Legal
Rights and Actions. CORD may share your Personally Identifiable Information with
various government authorities in response to subpoenas, court orders, or other
legal process; to establish or exercise our legal rights or to protect our
property; to defend against legal claims; or as otherwise required by law. In
such cases we reserve the right to raise or waive any legal objection or right
available to us. We also may share your Personally Identifiable Information
when we believe it is appropriate to investigate, prevent, or take action
regarding illegal or suspected illegal activities; to protect and defend the
rights, property, or safety of CORD, the Site, our users, customers, or others;
and in connection with our Terms of Use and other agreements.
External Links: For your convenience we may provide links to sites operated by
organizations other than CORD ("Third Party Sites") that we believe
may be of interest to you. We do not disclose your Personally Identifiable
Information to these Third Party Sites without obtaining your consent. We do
not endorse and are not responsible for the privacy practices of these Third
Party Sites. If you choose to click on a link to one of these Third Party
Sites, you should review the privacy policy posted on the other site to
understand how that Third Party Site collects and uses your Personally
Identifiable Information.
Confidentiality & Security of
Personally Identifiable Information
We consider the confidentiality and security of
your information to be of the utmost importance. We will use industry standard
physical, technical and administrative security measures to keep your
Personally Identifiable Information confidential and secure and will not share
it with third parties, except as otherwise provided in this Privacy Policy, or
unless such disclosure is necessary in special cases, such as a physical threat
to you or others, as permitted by applicable law. Because the Internet is not a
100% secure environment we cannot guarantee the security of Personally
Identifiable Information, and there is some risk that an unauthorized third
party may find a way to circumvent our security systems or that transmission of
your information over the Internet will be intercepted. It is your
responsibility to protect the security of your login information. Please note
that e-mails communications are typically not encrypted and should not be
considered secure.
Retention of Personally
Identifiable Information: If you reside or are located in the EEA, we
keep your Personally Identifiable Information for no longer than necessary for
the purposes for which the Personally Identifiable Information is processed.
The length of time we retain Personally Identifiable Information for depends on
the purposes for which we collect and use it and/or as required to comply with
applicable laws and to establish, exercise or defend our legal rights.
Access. Upon
request, we will provide you with reasonable access to the Personal Information
about you that we hold. We will also take reasonable steps to correct, update,
amend or delete any information that is demonstrated to be inaccurate, except
where the burden or expense of doing so would be disproportionate to the risks
to your privacy in the case in question or where the rights of third parties
would be violated. Where we process personal data on behalf of our business
partners, we will work with them in complying with such requests in accordance
with applicable law.
Updating or Deleting Your
Personally Identifiable Information
You have certain rights in relation to your
Personally Identifiable Information. You can access your Personally
Identifiable Information and confirm that it remains correct and up-to-date or
choose whether or not you wish to receive material from us or some of our
partners by logging into the Site and visiting your user account page. you can also
withdraw your consent to receive electronic messages at any time by clicking
the “unsubscribe” link at the bottom of an email.
If you reside or are located in the EEA and
would like further information in relation to your rights or would like to
exercise any of them, you may also contact us via pdprivacy@cordrestaurant.co.uk.
If you reside in the EEA, you have the right to
request that we:
· provide
access to Personally Identifiable Information we hold about you The right to
access personal information may be limited in some circumstances by local law
requirements. To exercise this right, please email pdprivacy@cordrestaurant.co.uk..
- prevent
the processing of your Personally Identifiable Information for
direct-marketing purposes. Update your direct marketing preferences.
- update
any Personally Identifiable Information which is out of date or incorrect;
- delete
any Personally Identifiable Information which we are holding about you. Contact
us outlining
what information you would like deleted;
- restrict
the way that we process your Personally Identifiable Information. Contact
us outlining
what processing of information you would like to object to;
- provide
your Personally Identifiable Information to a third party provider of
services; or
- provide
you with a copy of Personally Identifiable Information which we hold about
you. To
exercise this right, please Contact us;
Please
note that the above rights are not absolute, and we may be entitled to refuse
requests where legal exceptions apply.
We
try to answer every email promptly where possible, and provide our response
within the time period stated by applicable law. Keep in mind, however, that
there will be residual information that will remain within our databases,
access logs and other records, which may or may not contain your Personally
Identifiable Information. Please also note that certain Personally Identifiable
Information may be exempt from such requests in certain circumstances, which may
include if we need to keep processing your Personally Identifiable Information
to comply with a legal obligation.
We take data privacy protection very seriously
and, to validate that any request relating to your personal data is in fact
initiated by the data subject, we may ask information necessary to confirm
identity when the request is made.
Questions, Suggestions and
Complaints
If you reside or are located in the EEA and would like
further information in relation to your rights or would like to exercise any of
them, you may also contact us via pdprivacy@cordrestaurant.co.uk.
Changing Our Privacy Policy
Please note that we review our privacy
practices from time to time, and that these practices are subject to change.
Any change, update, or modification will be effective immediately upon posting
on our Site. We will notify you of any material change to this Privacy Policy
by posting a notice on our Site’s homepage for a reasonable period of time
following such update, and by changing the effective date (located at the
bottom of this page). Be sure to return to this page periodically to ensure
familiarity with the most current version of this Privacy Policy.