Privacy Policy
Privacy Policy for 7thHole Business Mobile App
Last modified: September 20th, 2023
Thank you for your interest in the 7thHole application for your mobile device (the "App”, “7thHole app” or “7thHole application”) provided to you by Appadia Inc. ("Appadia", “7thHole”, "us" or "we"), and our web site at 7thhole.com (the "Site"), as well as all related web sites, networks, and downloadable software provided by us and on which a link to this Privacy Policy is displayed (collectively, together with the App and Site, our "Platform"). Please read the following privacy policy that explains how we use and protect your information. We are the "controller" of the information we process unless otherwise stated.
7thHole is committed to protecting the privacy of individuals who are representatives of a company that has a corporate relationship with 7thHole App or is a prospective business partner of 7thHole, including restaurant partners, 7thHole for Business clients, 7thHole suppliers, and restaurant suppliers.
This includes 7thHole Partner Representatives who use a technology provided by or on behalf of 7thHole, including Restaurant Order Manager (“ROM”), Restaurant Home, and the food brokerage application (the “Business App”) and related services and websites.
Please read the following privacy policy which explains how and why we collect, use, and protect your information under the following headings:
Contact details
Information that we collect about you
Use of your information and why
Direct marketing
Sharing your information
Retention of your information
Your rights
Changes to our privacy policy
Complaints
7thHole Group Company Details
1. Contact details
If you have any queries or requests concerning this privacy policy or how we handle your data more generally, please get in touch with us by contacting our Data Protection Officer:
2. Information that we collect about you
We collect your information in a variety of ways, such as when we onboard a restaurant as a new partner and you use the Business App. More details about how your information is collected are listed below.
Lead generation
In some instances, when looking for opportunities with new 7thHole Partners, we may have obtained your contact details from a third-party source, such as LinkedIn, Google, a publicly available source or business data provider, or another business contact may have provided us with your details.
Negotiation of a contract and onboarding a new 7thHole Partner
When a contract is being negotiated with a 7thHole Partner and we are onboarding a new 7thHole Partner, we ask you as a 7thHole Partner Representative to provide information about yourself including your name, contact details, and business address.
During the onboarding process, we create a business profile for the 7thHole Partner and we will ask you to provide information to create and maintain this partner profile, which will include business payment data.
Management
Once we recruit a new partner to 7thHole we process your personal data as a 7thHole Partner Representative, to manage the 7thHole Partner’s relationship with 7thHole.
Where a 7thHole Partner chooses to register via a Business App, we will collect your personal data as a 7thHole Partner Representative, to register on the Business App and to enable the 7thHole Partner to participate in the Business Apps. This includes where you interact with the 7thHole for Business portal.
We collect technical information from your mobile device or computer, such as its operating system, the device and connection type, and the IP address from which you are accessing the Business Apps.
We also collect technical information about your use of our services through technology, for instance where you use a ROM as a 7thHole Partner Representative.
Payment
When we make payments to or receive payments from 7thHole Partners we produce payment files (which are transferred to third-party providers for processing payments), which include 7thHole Partner payment data, and as a 7thHole Partner Representative, this will include your name.
Your location
When you have provided permission at a device level, we may process location data obtained from your use of the Business Apps and via our security providers. This is collected for the reasons explained in section 3 below.
Support
When a 7thHole Partner requires support from us (“Business Support”) we collect certain information, such as information about your query, including notes regarding the issue, your use of the ROM device (if relevant) and your contact details, as a 7thHole Partner Representative.
When you interact with our Business Support team via email, phone, post, chat, or on the Business Apps, including when you report any incident, our team may collect and use information about you. Your communications with us will be stored. If you contact the support team by phone, your calls may be recorded for internal support training and improvement purposes.
Cookies
We use cookies or other similar technologies to enable auto-login for you into the Business App and to obtain technical information about your device that may affect the technical functionality of the Business App, for example, certain characteristics of and performance data about your device, Business App and operating system, including your device type, network connection type, app version, phone language, screen size, and platform.
You have the right to use your device settings to reject or remove these functional technologies, however, please be aware that if you do this, the Business App will not function correctly and you lose the ability to carry out certain functions on the Business App.
Information about the services
If a 7thHole Partner takes advantage of the perks offered by service providers on our perks page, we will share with the service provider the information provided to us about the 7thHole Partner’s interest in those perks, which may include your details as a 7thHole Partner Representative.
We may collect information about you from the feedback you send us or provide it to us through focus groups or surveys.
When you use websites or applications of third parties in connection with the services being provided by 7thHole, including during the onboarding process, those sites or applications may collect and process your information independently of 7thHole. We recommend that you check their privacy policies to understand how they process your personal data.
3. Use of your information and why
We will only process the data we collect about you if there is a reason for doing so, and if that reason is permitted under data protection law. We will have a lawful basis for processing your information if: we need to process your information for the performance of a contract with you, or at your request before we enter into a contract; we have your consent; we have a justifiable reason for processing your data; it is in the public interest for us to process your data; or we are under a legal obligation to do so.
We process your data where we have a justifiable reason for doing so. We have listed these reasons below:
To facilitate the contract between 7thHole and the 7thHole Partner:
To provide and manage the 7thHole Partner application, account, and onboarding process, including executing the agreement between the 7thHole Partner and the relevant 7thHole entity (the “Agreement”)
To provide you with access to and use of the Business App as a means of 7thHole providing the business with services, including enabling the business to make orders
To communicate with you about operational information relating to any services being provided to you by 7thHole, such as any important changes or developments to a Business App and about your upcoming booked orders
To enable Business Support to communicate with you to support the provision of services to the 7thHole Partner
To enable us to process payments to the 7thHole Partner
To communicate with you:
To help you complete the 7thHole Partner application
To contact you for your feedback on your experience
To provide you with news and information in connection with 7thHole and to help you understand more about 7thHole, by email or phone
To inform you of 7thHole product updates
To provide support to you for live operations
For onboarding and managing our relationship with 7thHole Partners:
To create and maintain 7thHole Partner account information
To enable our Business Support, tech, and engagement teams to help you with any issues, inquiries, or complaints efficiently and effectively, including fixing any bugs or other technical issues in a Business App using technical information relating to your device
To use location data to confirm the position of your restaurant (if relevant) to avoid riders arriving at the incorrect location
To arrange to take pictures of restaurant premises for the 7thHole app or website
To maintain a list of restaurants that 7thHole has on board
To develop our business, systems, and services:
To understand from your data what attributes to a positive or negative customer, restaurant, or rider experience with 7thHole and what might cause inefficient deliveries or damage to 7thHole, and use this data to responsibly design, develop, test, and implement new tools, processes, and relationships to improve our business, systems, and services
To analyze data to make certain assumptions about your position within the 7thHole Partner entity so that we send you the types of promotional offers that may be particularly relevant to your area of business
To use basic location data on an aggregate basis to develop and improve our business
To interact with you (such as via communications or Business App functionality) to encourage 7thHole network efficiency based on our analysis of your services
To analyze your activity on the Business App so that we can administer, support, improve, and develop our business for statistical and analytical purposes and to help us prevent fraud
To protect 7thHole:
For the exercise or defense of legal claims and to exercise and protect the rights of 7thHole, restaurant partners, customers, or others, including determining our liability
To enforce the terms of the Agreement and keep records of such enforcement, including using your data to analyze whether you have breached the Agreement (such as by misusing the Business App or acting fraudulently), which may result in us disabling or terminating the Agreement if we have the right to do so
To investigate any complaints or incident reports relating to 7thHole's relationship with 7thHole Partners and to prevent fraud or other misuse of our systems and services
We also process your personal data where we are under a legal obligation to do so we may use your information:
To keep a record of payments made to or from the 7thHole Partner, to the extent they include your personal data
To comply with any other legal obligation or regulatory requirement to which we are subject
Where we rely on our justifiable reasons for processing as a basis for processing your personal information, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our justifiable reasons for processing. You can find out more information about these balancing tests by contacting us using the details above
4. Direct Marketing
Where we have a justifiable reason for doing so (and are permitted to do so by law) we will use your information to let you know by email about 7thHole's products and services and/or any promotions from third parties relevant to your business (such as broadband and telecommunications services, payment processing, and customer review platforms), except where local law requires us to obtain your consent, in which case we will obtain your consent before sending the relevant communication. You always have the option to unsubscribe from these emails.
5. Sharing your information
The information we collect about you will be transferred to and stored on our servers located within the EU. We are very careful and transparent about who else your information is shared with globally.
Sharing your information internally: We share your information with other 7thHole group companies only where necessary for the purposes set out in section 3.
Sharing your information with third parties: We share your information with third-party service providers who will store your information on their servers. The types of third-party service providers with whom we share your information include:
IT service providers: including cloud, software, analytics, communications, and data storage providers and SDKs.
Operational service providers: including feedback and survey providers, onboarding providers, our support service providers, payment providers, user research partners, professional advisors, financial services providers and other suppliers, business partners, contractors, and subcontractors.
Suppliers: Where a 7thHole Partner is registered on the Business App, we will share your contact details with the supplier to facilitate transactions on the Business App.
In applicable circumstances, we may also share your information:
If our business enters into a joint venture with, purchases, or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners, or their advisors
If we are under a duty to disclose or share your information to comply with (and/or where we believe we are under a duty to comply with) any legal obligation or regulatory requirement. This includes where we’re under a legal obligation to respond to police data requests or to exchange information with other companies and organizations for fraud protection and prevention
To enforce our contractual terms with the 7thHole Partner
In the event of a dispute relating to the 7thHole Partner’s services to 7thHole or the services provided to the 7thHole Partner, or to protect the rights of 7thHole, restaurant partners, customers, or others, including to prevent fraud
With such third parties as we reasonably consider necessary to detect or prevent crime, e.g. the police
International data transfers: In some cases, the personal data we collect from you might be processed outside of the country in which you reside, such as in the United States, the Philippines, Madagascar, and the other countries in which 7thHole operates. These countries may not have the same protections for your personal data as in your country. However, we are obliged to ensure that the personal data that is processed by us and our suppliers outside of your country is protected in the same way as it would be if it was processed within your country. There are therefore certain safeguards in place when your data is processed internationally.
Where your data is being transferred from within the European Economic Area to outside of it, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Your personal data is transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission
We use the EU-approved Standard Contractual Clauses
Where your personal data is transferred to third-party providers based in the US, data may be transferred to them if they have self-certified under the Privacy Shield framework about the type of data being transferred, which requires them to provide similar protection to personal data shared between the EU and the US.
Please contact us using the contact details above if you want further information on the countries to which personal data may be transferred and (if applicable to your country) the specific mechanism used by us when transferring your personal data out of your country.
6. Retention of your information
We will not retain your information for any longer than we think is necessary for our purposes.
Information that we collect will be retained for as long as needed to fulfill the purposes outlined in the ‘Use of my information’ section above, in line with our justifiable reasons for processing or for a period specifically required by applicable regulations or laws, such as retaining the information for regulatory reporting purposes.
When determining the relevant retention periods, we will take into account factors including:
Our contractual obligations and rights concerning the information involved
Legal obligation(s) under applicable law to retain data for a certain time
Statute of limitations under applicable law(s)
Our justifiable reasons for processing where we have carried out balancing tests (see the section on ‘Use of your information and why’ above)
(Potential) disputes
Guidelines issued by relevant data protection authorities
Otherwise, we securely erase your information where we no longer require your information for the purposes collected.
7. Your rights
Under your local data protection law, you may have several rights concerning the data we hold about you. For additional information on your rights in your local country, please contact your data protection authority. If you wish to exercise any of these rights, please contact us using the contact details set out below. If you are in the EU, you have the following rights under EU data protection law:
The right to be informed. You have the right to access/ be provided with clear, transparent, and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this policy.
The right of access. You have the right to obtain access to your information (if we’re processing it). This will enable you, for example, to check that we’re using your information following data protection law. If you wish to access the information we hold about you in this way, please get in touch (see Contact Details).
The right to rectification. You are entitled to correct any information that you submit if it is inaccurate or incomplete. You can request that we rectify any errors in the information that we hold by contacting us (see Contact Details).
The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of the information that we hold about you by contacting us (see Contact Details). The right is not absolute and only applies in certain circumstances.
The right to restrict processing. You have the right to ‘block’ or ‘suppress’ further use of your information. When processing is restricted, we can still store your information, but will not use it further.
The right to data portability. You have the right to obtain your personal information in an accessible and transferrable format so that you can re-use it for your purposes across different service providers. This is not a general right however and there are exceptions. To learn more please get in touch (see Contact Details).
The right to complain. You have the right to complain about the way we handle or process your information with a competent data protection authority (see Complaints).
The right to withdraw consent. If you have given your consent to anything we do with your information (i.e. if we rely on consent as a legal basis for processing certain information), you have the right to withdraw that consent at any time. You can do this by contacting us (see Contact Details). Withdrawing consent will not however make unlawful our use of your information while consent has been apparent.
The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing and profiling. You can object by contacting us on the details above (Contact Details).
8. Changes to our privacy policy
Any changes to our Privacy Policy will be posted on the 7thHole website and to the Business App and, as appropriate, through notification in the Business App or by email.
This privacy policy was last updated: September 20th, 2023
9. Complaints
If you’re not satisfied with our response to any complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the data protection regulator in your local jurisdiction or by contacting 7thHole using the contact details in the Contact Us section:
Website: https://www.7thhole.com/
100 Mill Pond Plantation Way, Warner Robins GA 31088
10. 7thHole Group Company Details
7thHole is operated by Appadia Inc., a company incorporated and registered at 100 Mill Pond Plantation Way, Warner Robins GA 31088. You may contact us at support@7thhole.com