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 of the following:

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

collectively referred to as the "Services".

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 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 payments while providing valuable insights for restaurants. We prioritize user convenience, data security, and compliance, ensuring a smooth and efficient payment process for both restaurants and their customers.

If you are a user of our Services, or if you are any other individual that The Digital Fox has a direct relationship with, The Digital Fox (Cyprus) Ltd. is responsible for your personal data and will act as the Data Controller of such data. 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

If you provide your personal data to a The Digital Fox Merchant, the relevant Merchant is the data controller, and The Digital Fox acts as a data processor on their behalf to the extent we receive such personal data for processing on behalf of the Merchant. For questions about how a Merchant processes your personal information, please contact the Merchant or visit their privacy policy.

Section 3 – What Personal Data We Receive

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

• Device Information: We collect 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.
• Payment Information: When you make a purchase using The Digital Fox Web App, we collect tokenized payment details, such as the last four digits of your card number, used for transaction identification. To the extent such payment information may directly or indirectly identify an individual, this will constitute Personal Data.
• Email Address: If you choose to receive a receipt or subscribe to our marketing communications, we will collect your email address.
• Settings and Preferences: We collect 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: We collect information such as messages and email content when you contact us for support, feedback, or inquiries.

We do not collect any 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 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 analytics providers or technical services that enable us to provide The Digital Fox Insights.

Section 5 – How We Use Your Personal Data

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

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

When you interact with Merchants using our Services, we process your personal data at the direction of the Merchant, and their privacy policy governs how they process your personal data. In such cases, The Digital Fox acts as a data processor, while the Merchant acts as the data controller. This processing is governed by a Data Processing Agreement (DPA) between The Digital Fox and the Merchant.

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 our 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, 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.

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):

• Third-Party Service Providers: To provide technical or payment services. All our service providers are bound by the necessary legal acts including Data Processing Agreements (DPAs) to ensure they comply with the applicable data protection legislation.
• Payment Service Providers: To process payments securely. Payments are processed through third-party providers who comply with PCI-DSS (Payment Card Industry Data Security Standard) requirements.
• 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.

We do not sell or rent your personal data to third parties for their marketing purposes.

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 the applicable data protection legislation or any other applicable law. Retention periods vary depending on the nature of the data:

• Payment 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.

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.

Section 13 – Personal Data of Minors

We do not knowingly collect personal data from users under 14 years of age. If you believe we have received data from a child under 14, 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.

Section 15 – Marketing Communications

With your explicit consent, we may use your email address to send you marketing communications, including newsletters, promotions, and updates about our services.

You have the right to withdraw your consent to receive marketing communications at any time by:

• Clicking the "unsubscribe" link in any marketing email
• Contacting us at dataprivacy@thedigitalfox.com

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.

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, please see our Cookie Policy.

User Terms of Service

Please also review our User Terms of Service which govern your use of The Digital Fox Web App and The Digital Fox Insights.