User Privacy Policy

Your privacy is of the utmost importance to us. This User Privacy Policy ("Privacy Policy") sets out how The Digital Fox (Cyprus) Ltd. (referred to as "we," "us," or "The Digital Fox") handles your personal data when you access or use our Services, which comprise the following:

• our website https://thedigitalfox.com/
• the Digital Fox Web application (the "Digital Fox Web App"), which you can access by scanning the QR code at your table to view and settle your bill;
• The Digital Fox Insights, a back-office dashboard available to restaurant managers and owners, enabling them to review restaurant information;

collectively referred to as the "Services", and/or when you engage with us or otherwise interact with The Digital Fox.

We will update this Privacy Policy periodically to reflect any changes or proposed changes to our use of your personal data or to comply with changes in applicable law or regulatory requirements. We encourage you to review this Privacy Policy periodically to stay up to date on how we use your personal data. If we update this Privacy Policy, the effective date at the top of the page will reflect these changes.

Section 1 – Purpose of this Privacy Policy

This Privacy Policy explains our approach to any personal data that we collect, use, and disclose about you, whether we collect it from you or obtain it from a third party, and the purposes for which we process your personal data. It also outlines your rights concerning our processing of your personal data. It does not apply to personal data collected by third parties during your interactions with them or your use of their products or services (e.g., when you follow links to third-party websites or services).

When we talk about "personal data," we mean any information that relates to an identified or identifiable individual. This can include a name, identification number, location data, online identifiers (such as an IP address), or other specific factors.

This Privacy Policy is intended to help you make informed decisions when using our Services. Please take a moment to read and understand it. It should be read in conjunction with our User Terms of Service and our Cookie Policy.

Section 2 – About Us, Our Role, and How to Reach Us

The Digital Fox is a technology company specializing in seamless, pay-at-the-table solutions for the restaurant industry. Our platform enhances the dining experience by enabling fast, secure, and hassle-free checkout while providing valuable insights for restaurants. We prioritize user convenience, data security, and compliance.

When you use the Digital Fox Web App as a guest, The Digital Fox (Cyprus) Ltd. is the data controller of the personal data we collect through the Services, such as your device information, your electronic receipt details, your reviews and feedback, and your marketing preferences. This means we determine the purposes and means of processing this data, and we are your point of contact for exercising your rights.

In limited cases, we process personal data on behalf of, and under the documented instructions of, an Establishment (a "Merchant"), for example where a Merchant provides us with data for processing in connection with the services we provide to that Merchant. In those cases, the Merchant is the data controller and The Digital Fox acts as a data processor. That processing is governed by a Data Processing Agreement (DPA) between The Digital Fox and the Merchant. For questions about how a Merchant processes your personal data as a controller, please contact the Merchant or review its privacy policy.

The Digital Fox is not a payment service provider and does not process or store your full payment details. Payment services are provided by licensed third-party payment service providers, which act as independent controllers of the payment data they process under their own privacy policies.

If you have any questions about this Privacy Policy or want to exercise your rights as a data subject, you can contact us at:

Email: dataprivacy@thedigitalfox.com

Section 3 – What Personal Data We Receive

We collect only the minimum personal data necessary for the purposes of providing our Services through the Digital Fox Web App. This includes:

• Device Information: Data about the device used to interact with the Digital Fox Web App, such as the phone's IP address, browser type, operating system, and device identifiers.
• Approximate Location Data: Where geolocation is enabled on your device and required for a feature, we may process approximate location data to provide that feature.
• Payment Confirmation Information: When you complete a payment using the Digital Fox Web App, we receive limited transaction confirmation details from the payment service provider, such as the date, time, card type, and the last four digits of your card number, used for transaction identification. We do not receive or store your full card details. To the extent such information may directly or indirectly identify an individual, it constitutes personal data.
• Email Address: If you choose to receive a receipt or subscribe to marketing communications, we will collect your email address.
• Reviews and Feedback: The content of any reviews, ratings, comments, or feedback you submit through the Services.
• Settings and Preferences: Information about your browser and device settings, including privacy preferences, to enhance your experience using the Digital Fox Web App.
• Communications with The Digital Fox: Information such as messages and email content when you contact us for support, feedback, or inquiries.
• Order Details: Where you place an order through the Services, the contents of your order, which are shared with the relevant Establishment for fulfillment.

We do not collect names, phone numbers, or other personally identifiable information unless you voluntarily provide this information for specific purposes (e.g., requesting a receipt via email or subscribing to marketing communications).

Section 4 – How We Collect and Receive Personal Data

We collect personal data in various ways:

• Personal Data You Provide: You may give us personal data directly when using the Digital Fox Web App or Insights, filling out forms, providing feedback or reviews, or subscribing to marketing communications.
• Personal Data Collected via Cookies: We collect personal data when you use our website or the Digital Fox Web App through cookies and similar technologies. Please refer to our Cookie Policy for more details.
• Personal Data Received from Third Parties: We may receive personal data from third parties such as payment service providers (transaction confirmation details), analytics providers, or technical services that enable us to provide the Services.

Section 5 – How We Use Your Personal Data

We process your personal data for the following purposes (as applicable):

We may also aggregate or anonymize personal data so that it no longer identifies you, and we may use such aggregated data for any purpose.

Section 6 – How We Process Personal Data on Behalf of Merchants

Where a Merchant provides us with personal data for processing in connection with the services we provide to that Merchant, we process such data at the documented direction of the Merchant, and the Merchant's privacy policy governs that processing. In such cases, The Digital Fox acts as a data processor and the Merchant acts as the data controller. This processing is governed by a Data Processing Agreement (DPA) between The Digital Fox and the Merchant.

For clarity, this does not apply to the personal data we collect from you directly through the Digital Fox Web App in connection with our own digital services, for which The Digital Fox is the data controller as described in Section 2.

Section 7 – If You Fail to Provide Personal Data

If you choose not to provide your email address when requested, we may be unable to send you an electronic receipt for your transactions or include you in marketing communications. However, you can still use other services within the Digital Fox Web App without providing an email address.

Section 8 – How We Obtain Your Consent

Where consent is required for processing your personal data, e.g. for marketing communications or the sharing of your email address with an Establishment for its own marketing, you may provide such consent when we collect your data (e.g., by opting in through a checkbox that is not pre-ticked) or by contacting us as outlined in this Privacy Policy. You may withdraw your consent at any time.

Section 9 – Third-Party Links

Our website https://thedigitalfox.com/ may contain links to third-party websites and services. This Privacy Policy does not apply to interactions with those third parties, and we encourage you to review their privacy practices.

Section 10 – Sharing Personal Data

We may share your personal data with (as applicable):

• The Establishment where you paid: After you complete a payment, we share limited transaction confirmation details with the relevant Establishment: the date and time of payment, the card type, and the last four digits of your card. This enables the Establishment to fulfill your order and/or reconcile your payment against your bill. The lawful basis is contractual necessity and our legitimate interest in enabling the Establishment to match payments to bills.
• The Establishment where you paid, for its own marketing (with your consent): Where you have given your consent, we may share your email address with the relevant Establishment so that it may send you marketing communications on its own behalf. In that case, the Establishment acts as an independent data controller and processes your data under its own privacy policy. You may withdraw your consent to this sharing at any time by contacting dataprivacy@thedigitalfox.com.
• Third-Party Service Providers: To provide technical or support services. Our service providers are bound by the necessary legal acts, including Data Processing Agreements (DPAs), to ensure they comply with applicable data protection legislation.
• Payment Service Providers: To process payments securely. Payments are processed by licensed third-party providers who comply with PCI-DSS (Payment Card Industry Data Security Standard) requirements and act as independent controllers of the payment data they process.
• The Digital Fox Group Companies: We may share data within our group of companies (if applicable) for administrative purposes.
• Transfers Outside the EEA: If we transfer personal data outside the European Economic Area (EEA), we will ensure that adequate protection measures are in place, such as using Standard Contractual Clauses (SCCs) approved by the European Commission or transferring to countries with an adequacy decision. You can request more information about the safeguards we have implemented by contacting us.

We do not sell or rent your personal data to third parties for their marketing purposes. The consent-based sharing of your email address with an Establishment described above takes place only with your prior opt-in consent and is not a sale or rental of your data.

Section 11 – How Long We Keep Your Personal Data

We retain personal data only as long as necessary to fulfill the purposes for which it was collected and/or in accordance with the requirements of applicable data protection legislation or any other applicable law. Retention periods vary depending on the nature of the data:

• Transaction Confirmation Data: Retained for up to 7 years to comply with financial and tax regulations.
• Communications Data: Retained for up to 12 months following the resolution of your inquiry.
• Marketing Data: Retained until you withdraw your consent / opt out of receiving marketing communications.

After the retention period and/or after fulfilment of the purpose for which they were collected, personal data will be securely deleted or anonymized.

Section 12 – Confidentiality and Security of Your Personal Data

We are committed to protecting your personal data with technical and organizational security measures. All employees and data processors are bound by confidentiality obligations.

Security measures include:

• Encryption: We use industry-standard encryption protocols to protect data in transit and at rest.
• Access Controls: Personal data is accessible only to authorized personnel who require access to perform their job duties.
• Regular Audits: We conduct regular security audits and assessments to identify and address potential vulnerabilities.
• Firewalls and Monitoring: Implementation of firewalls and intrusion detection systems to protect against unauthorized access.
• Payment Security: We do not store or process payment information directly. All payments are securely processed through third-party providers who comply with PCI-DSS requirements and with whom we have the requisite agreements in place for compliance with the applicable data protection legislative framework to the extent legally required. We only have access to the last four digits of your card when used for payments.

Section 13 – Personal Data of Minors

Our Services are intended for individuals aged 18 or over, and we do not knowingly collect personal data from anyone under 18 years of age. If you believe we have received data from a person under 18, please contact us at dataprivacy@thedigitalfox.com, and we will promptly delete it.

Section 14 – Your Rights as a Data Subject

Under the General Data Protection Regulation (GDPR), you have the following rights regarding your personal data:

• Access: Request a copy of your personal data.
• Correction: Correct inaccurate personal data.
• Deletion: Request deletion of your data.
• Transfer: Request a copy of your data in a machine-readable format.
• Restriction: Restrict the processing of your data.
• Objection: Object to processing based on legitimate interests.
• Withdraw Consent: Withdraw consent for processing where applicable.

You may exercise these rights by contacting us at dataprivacy@thedigitalfox.com or by writing to us at our physical address provided in Section 2. We will respond to your request within one month in accordance with the applicable legislative framework. In some cases, we may require proof of identity before processing your request. If your request is excessive or manifestly unfounded, we may charge a reasonable fee.

Section 15 – Marketing Communications

Opt-In for Marketing Communications

With your explicit consent, we may use your email address to send you marketing communications, including newsletters, promotions, updates about our services, and offers from Establishments where you have paid. You will have the opportunity to opt in to receive these communications when you provide your email address.

How to Provide Consent

When you provide your email address for receiving an electronic receipt or other services, you will see an option to subscribe to marketing communications. This option will be presented as an unchecked checkbox with a clear statement such as:

"Yes, I would like to receive news, offers, and updates from The Digital Fox via email."

Where we intend to share your email address with an Establishment for its own marketing, we will ask for your separate consent to that sharing. Your consent is not a condition for using our services, and you can choose whether or not to receive marketing communications.

Right to Withdraw Consent

You have the right to withdraw your consent to receive marketing communications at any time. If you no longer wish to receive these communications, you can:

• Click the "unsubscribe" link located at the bottom of any marketing email you receive from us.
• Contact us directly at dataprivacy@thedigitalfox.com with your request.

We will process your request promptly, and your data will no longer be used for marketing purposes.

Section 16 – Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. If we make material changes, we will notify you by posting the updated policy on our website and updating the "Last updated" date at the top of this policy.

Section 17 – Data Protection Officer

While we are not required to appoint a Data Protection Officer under the GDPR, we have designated a privacy contact to address any concerns or questions regarding your personal data.

Privacy Contact: Email: dataprivacy@thedigitalfox.com

Section 18 – Complaints

If you have concerns about our handling of your personal data, you have the right to lodge a complaint with the supervisory authority in Cyprus:

Office of the Commissioner for Personal Data Protection
Website: http://www.dataprotection.gov.cy

Section 19 – Employee Training

All our employees receive training on data protection, are aware of their responsibilities to protect your personal data, and are bound by confidentiality obligations.

Section 20 – Glossary

• "GDPR" means the General Data Protection Regulation (EU) 2016/679.
• "EEA" means the European Economic Area.
• "Personal Data" means any information relating to an identified or identifiable natural person.

Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at:

Email: dataprivacy@thedigitalfox.com

Cookie Policy — For information about how we use cookies and similar technologies.

User Terms of Service — Please also review our User Terms of Service, which govern your use of the Digital Fox Web App.