1. WHO WE ARE AND WHAT WE DO

1.1   We are Garsonna Menu and our address is 273 Madina Monawara Street, Amman, The Hashemite Kingdom of Jordan. Garsonna Menu is the business name of First Source Engineering LLC. Garsonna Menu provides the following products and services (“Products”):

• Garsonna Menu RMS – a cloud-based restaurant management solution (RMS) including the provision of websites and KIOSKs
• Garsonna Menu Pay – a licensed payment aggregator

1.2   In providing the Products Garsonna Menu will process personal data. This document sets out how Garsonna Menu processes personal data for both Garsonna Menu RMS and Garsonna Menu Pay. This includes personal data collected when you use our website (“Website”) and Products (together, “Services”). 

2. WHAT DOES THIS POLICY COVER?

2.1  Garsonna Menu takes your data seriously and processes it by applicable laws and regulations. Garsonna Menu acts as the ‘controller’ (i.e. person responsible for deciding how your data is processed) and has adopted this privacy policy (“Policy”) to establish and maintain the privacy and security of your personal data. This Policy:

(a) sets out the types of personal data we collect about you;
(b) explains how and why we collect and use your data;
(c) explains how long we keep your data;
(d) explains how we will share your data – when, why, and who with;
(e) explains the different rights and choices you have when it comes to your data;
(f) explains the security measures we apply to protect your data; and
(g) explains how we may contact you and how you can contact us.

2.2   Please understand that by accepting this Policy and submitting any personal data to us, you agree that we may collect, use, disclose, and retain such data by this Privacy Policy, and as permitted or required by law. If you do not agree with these terms, then please do not accept them or provide any personal data to us.

2.3   Please also note that we will not be able to respond to you, provide the relevant Services to you, or deal with your inquiries unless you provide us with the required personal data as set out or referred to in this Privacy Policy unless we indicate the supply of the personal data is optional.

3. WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU AND HOW DO WE COLLECT IT?

3.1   We collect the content, communications, and other information you provide when you use our Services, including when you sign up for an account (if relevant) or communicate with us including by email. This includes your name, email address, phone number, name of your business (where relevant), and location/country and payment information (where relevant),

3.2   We also collect additional, specific personal data depending on the Products you are using:

• For Garsonna Menu Pay we need to carry out customer due diligence and KYC which includes the collection and processing of the following information:

o ID Validation: ID number, place of issue, expiry date, date of issue.
o CR Validation: CR number, UNN, entity name, issue date, expiry date, business type, place of issue, owner name, manager name.
o Other information: outlet name, address, contact person, contact details, and other information you may supply us with during the onboarding process.

• For Garsonna Menu RMS the information we collect includes:

o CR information (CR number, UNN, entity name, issue date, expiry date, business type, place of issue, owner name, manager name, as relevant)
o ID information (ID number, place of issue, expiry date, date of issue, as relevant)
o VAT registration information
o Recordings of sessions/meetings
o Any other information you provide us with

3.3   In addition we also collect the following personal data:

(a)   Usage: we collect information about how you use our Services, such as the time, frequency, and duration of your browsing activities, and how you use the features provided by the Services.

(b)   Device information: we collect information on the devices you use, such as the model and kind of the device you are using to access our Services, the operating system, hardware and software version together with other technical information (e.g. your IP address).

(c)   Your opinions about our products and services: information you share rating your experiences and satisfaction with the provision or receipt of our products or services or otherwise dealing with us.

4. COOKIES

4.1   Where you use our Website we also use cookies to collect personal data from your device to help us enhance the Services provided, and to ease your access to our services, for example, they allow you to repeatedly use our services on the same device without having to log in or adjust the preference settings each time. We collect web statistics automatically about your visit to our Website based on your IP address. This information is used to help us in improving your experience on our Website.

5. WHERE DO WE COLLECT PERSONAL DATA ABOUT YOU FROM?

5.1   We collect your data directly from you i.e. this is the personal data you provide to us when using our Services or communicating with us, We also collect your data by deploying cookies as described above. We may also collect personal data from you when you visit our offices (e.g. through the use of CCTV). We may also collect personal data from your organization, any relevant third-party partners, and (in the case of Garsonna Menu Pay) from government entities as follows:

• ID information collected from ELM (a government entity) through an API integration
• CR information collected from WATHIQ (a government entity) through an API integration

6. HOW AND WHY DO WE USE YOUR DATA?

6.1   We use your data for the following purposes:

(a)   send you information in connection with our products and services
(b)   respond to your communications and requests;
(c) to manage our relationship with you or your organization;
(d) to manage our relationship with third-party partners and referrers;
(e) billings and payment;
(f) deal with any disputes;
(g) provide our Services to you;
(h) to validate you under KYC, AML, sanctions screening, and carry out due diligence;
(i) marketing – including contacting you by email, postal mail, or phone (including via SMS messages) regarding Garsonna Menu and third-party products, services, surveys, research studies, promotions, special events, and other subjects that we think may be of interest to you or your organization based on your consent as shown by your acceptance of this Privacy Policy and under applicable law. We will provide you with the ability to opt out of promotional and marketing communications;
(j) customize the content and services we provide through our Services and more generally;
(k) help us better understand your interests and needs and those of your organization, and improve our Services;
(l) engage in analysis, research, and reports regarding the use of our Services;
(m) training;
(n) archiving;
(o) secure our Services and our systems;
(p) comply with any procedures, laws, and regulations which apply to us;
(q) establish, exercise, or defend our legal rights;
(r) prevent and detect crime and fraud;
(s) protect health and safety and to ensure security;
(t) comply with contractual requirements; and
(u) carry out our internal business purposes, such as corporate transactions, audits, and data analysis

7. HOW LONG DO WE KEEP YOUR DATA FOR?

7.1   The length of time for which we retain personal data typically depends on the purposes for which we collect and use it and/or as required to comply with applicable laws. Once we no longer need to keep your data we will take reasonable steps to erase it from our systems and ensure it is erased from those systems where it is processed on our behalf.

8. WHO DO WE SHARE YOUR DATA WITH?

We may share your data with the following:

(a) Businesses within our group: we may share your information within our group to process your information as described in this Privacy Policy.
(b) New owner: if the ownership or control of Garsonna Menu, or all or part of the Services changes, we may transfer your information to the new owner.
(c) Third-party service providers and partners: we may work with third-party partners (including IT providers and developers) to:
• improve and provide our Services,
• to develop, offer, and provide products and services that we consider will be of interest to you,
• to make payments.

Where we share your information with these persons we will do so to the extent required for the above purposes. We will impose restrictions on how these persons can use and disclose the data we provide by applicable laws and regulations.

(d) Government authorities: Garsonna Menu may share your data with various government authorities in response to inquiries you may make and assist us in carrying out our operations and responding to inquiries. Also, we may share your data with various government entities in response to legal proceedings; to establish and/or enforce our rights (including under our terms and conditions) or to protect our property; to defend against legal claims; or as otherwise required by law; we retain the right to raise or waive any legal objection or right available to us. We may also share your data when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities.
(e) Our employees, agents, consultants, and contractors: we may share your information with these persons and entities to process your information as described in this Privacy Policy. Any sharing will be on terms protective of your information.
(f) Banks, payment providers, and payment technology providers: where you use Garsonna Menu Pay we will share your information as follows:
• Bank: basic information such as merchant name, address, city, UNN number/CR number, and terminal number information is shared to set up the merchant in the banking system
• POS hardware vendor: basic information such as merchant name, address, city, contact number, and terminal information is shared with the POS hardware vendor to install the payment hardware at the merchant location
• AMEX: if a merchant requests to enable the AMEX service, similar information to that above is also shared with AMEX to enable the service

By accepting this Privacy Policy you consent to the above sharing and disclosure of your data to the extent your consent is a requirement for the disclosure to lawfully take place under applicable laws and regulations.
9. THIRD PARTY LINKS AND FEATURES

9.1   Our Website may contain links to third-party websites such as social media sites, and also may contain third-party integrations and functionalities. If you choose to use these sites or features, you may disclose your personal data not just to those third parties, but also to their users and the public more generally depending on how their services function. Foodics is not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your data will be subject to the privacy policies of the third-party websites or services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third parties.

10. STORAGE AND INTERNATIONAL TRANSFERS

10.1   By accepting this Privacy Policy, you consent to the storage of your information inside Jordan. Garsonna Menu may subcontract the processing of your data to, or otherwise share your data with, service providers located inside Jordan. Such third parties may be engaged in, among other things, the provision of goods and services to you, the processing of transactions, payments, and/or the provision of support services. By accepting this Privacy Policy, you agree to any such transfer storage or use.

We will always fulfill any requirements about the international transfers of personal data under applicable laws. For more information about these transfer mechanisms, please contact us using the contact details given below.

11. SECURITY OF YOUR DATA

11.1   We consider the confidentiality and security of your data to be of the utmost importance. Garsonna Menu takes a variety of technical, administrative, and physical measures to protect your information from disclosure to or access by third parties. Please note that we do not guarantee the security of personal data, as no method of internet transmission or storage is completely secure.

12. CHANGES TO THIS POLICY

12.1   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 Website or where we update you by email. You must read and accept the Policy every time it is updated. Otherwise, your use of the Services is not permitted.

13. YOUR RIGHTS

13.1   You have certain rights under and by applicable laws and regulations including:

(a) The right to be informed – to inform you of the valid legal or practical justification for collecting your data, and the purpose of such collection, and that your data should not be processed later in a manner inconsistent with the purpose for which it is collected, Garsonna Menu complies with this requirement by providing this Privacy Policy to you. If you require further information about your rights under applicable laws and regulations please inform us.
(b) The right to have access to your data – the right for you to have access to it and obtain a copy of it
(c) The right to request correction, completion, or updating of your data that Garsonna Menu controls.
(d) The right to request the destruction or deletion of your data which Garsonna Menu no longer needs to process for the purposes for which it was collected.
(e) The right to withdraw your consent at any time, where we relied on your consent to use and disclose your personal information. If you do this we may not be able to provide the Services to you.

By accepting this Privacy Policy you consent to the above sharing and disclosure of your data to the extent your consent is a requirement for the disclosure to lawfully take place under applicable laws and regulations.

14. HOW CAN YOU CONTACT US?

14.1   If you are unhappy with how we’ve handled your data, or have further questions on the processing of your data, contact us here

14.2

By email:  privacy@garsonna.com

By written notice to:

The Data Protection Office

,  is a business name of First Source Engineering LLC. Garsonna Menu provides the following products and services (“Products”):

• Garsonna Menu RMS – a cloud-based restaurant management solution (RMS) including the provision of websites and KIOSKs
• Garsonna Menu Pay – a licensed payment aggregator

1.2   In providing the Products Garsonna Menu will process personal data. This document sets out how Garsonna Menu processes personal data for both Garsonna Menu RMS and Garsonna Menu Pay. This includes personal data collected when you use our website (“Website”) and Products (together, “Services”). 

2. WHAT DOES THIS POLICY COVER?

2.1  Garsonna Menu takes your personal data seriously and processes it in accordance with applicable laws and regulations. Foodics acts as the ‘controller’ (i.e. person responsible for deciding how your data is processed) and has adopted this privacy policy (“Policy”) to establish and maintain the privacy and security of your data. This Policy:

(a) sets out the types of personal data we collect about you;
(b) explains how and why we collect and use your data;
(c) explains how long we keep your data;
(d) explains how we will share your data – when why, and who with;
(e) explains the different rights and choices you have when it comes to your data;
(f) explains the security measures we apply to protect your data; and
(g) explains how we may contact you and how you can contact us.

2.2   Please understand that by accepting this Policy and submitting any personal data to us, you agree that we may collect, use, disclose and retain such data in accordance with this Privacy Policy, and as permitted or required by law. If you do not agree with these terms, then please do not accept them or provide any personal data to us.

2.3   Please also note that we will not be able to respond to you, provide the relevant Services to you, or deal with your inquiries unless you provide us with the required personal data as set out or referred to in this Privacy Policy, unless we indicate the supply of the personal data is optional.

3. WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU AND HOW DO WE COLLECT IT?

3.1   We collect the content, communications, and other information you provide when you use our Services, including when you sign up for an account (if relevant) or communicate with us including by email. This includes your name, email address, phone number, name of your business (where relevant), and location/country and payment information (where relevant),

3.2   We also collect additional, specific personal data depending on the Products you are using:

• For Garsonna Menu Pay we need to carry out customer due diligence and KYC which includes the collection and processing of the following information:

o ID Validation: ID number, place of issue, expiry date, date of issue.
o CR Validation: CR number, UNN, entity name, issue date, expiry date, business type, place of issue, owner name, manager name.
o Other information: outlet name, address, contact person, contact details, and other information you may supply us with during the onboarding process.

• For Garsonna Menu RMS the information we collect includes:

o CR information (CR number, UNN, entity name, issue date, expiry date, business type, place of issue , owner name, manager name, as relevant)
o ID information (ID number, place of issue, expiry date, date of issue, as relevant)
o VAT registration information
o Recordings of sessions/meetings
o Any other information you provide us with

3.3   In addition we also collect the following personal data:

(a)   Usage: we collect information about how you use our Services, such as the time, frequency, and duration of your browsing activities, and how you use the features provided by the Services.

(b)   Device information: we collect information on the devices you use, such as the model and kind of the device you are using to access our Services, the operating system, hardware and software version together with other technical information (e.g. your IP address).

(c)   Your opinions about our products and services: information you share rating your experiences and satisfaction with the provision or receipt of our products or services or otherwise dealing with us.

4. COOKIES

4.1   Where you use our Website we also use cookies to collect personal data from your device to help us enhance the Services provided, and to ease your access to our services, for example, they allow you to repeatedly use our services on the same device without having to log in or adjust the preference settings each time. We collect web statistics automatically about your visit to our Website based on your IP address. This information is used to help us in improving your experience on our Website.

5. WHERE DO WE COLLECT PERSONAL DATA ABOUT YOU FROM?

5.1   We collect your data directly from you i.e. this is the personal data you provide to us when using our Services or communicating with us, We also collect your data by deploying cookies as described above. We may also collect personal data from you when you visit our offices (e.g. through the use of CCTV). We may also collect personal data from your organization, any relevant third-party partners, and (in the case of Garsonna Menu Pay) from government entities as follows:

• ID information collected from ELM (a government entity) through an API integration
• CR information collected from WATHIQ (a government entity) through an API integration

6. HOW AND WHY DO WE USE YOUR DATA?

6.1   We use your data for the following purposes:

(a)   send you information in connection with our products and services
(b)   respond to your communications and requests;
(c) to manage our relationship with you or your organization;
(d) to manage our relationship with third-party partners and referrers;
(e) billings and payment;
(f) deal with any disputes;
(g) provide our Services to you;
(h) to validate you under KYC, AML, sanctions screening, and carry out due diligence;
(i) marketing – including contacting you by email, postal mail, or phone (including via SMS messages) regarding Foodics and third-party products, services, surveys, research studies, promotions, special events, and other subjects that we think may be of interest to you or your organization based on your consent as shown by your acceptance of this Privacy Policy and under applicable law. We will provide you with the ability to opt out of promotional and marketing communications;
(j) customize the content and services we provide through our Services and more generally;
(k) help us better understand your interests and needs and those of your organization, and improve our Services;
(l) engage in analysis, research, and reports regarding the use of our Services;
(m) training;
(n) archiving;
(o) secure our Services and our systems;
(p) comply with any procedures, laws, and regulations which apply to us;
(q) establish, exercise, or defend our legal rights;
(r) prevent and detect crime and fraud;
(s) protect health and safety and to ensure security;
(t) comply with contractual requirements; and
(u) carry out our internal business purposes, such as corporate transactions, audits, and data analysis

7. HOW LONG DO WE KEEP YOUR DATA FOR?

7.1   The length of time for which we retain personal data typically depends on the purposes for which we collect and use it and/or as required to comply with applicable laws. Once we no longer need to keep your data we will take reasonable steps to erase it from our systems and ensure it is erased from those systems where it is processed on our behalf.

8. WHO DO WE SHARE YOUR DATA WITH?

We may share your data with the following:

(a) Businesses within our group: we may share your information within our group to process your information as described in this Privacy Policy.
(b) New owner: if the ownership or control of Garsonna Menu, or all or part of the Services changes, we may transfer your information to the new owner.
(c) Third-party service providers and partners: we may work with third-party partners (including IT providers and developers) to:
• improve and provide our Services,
• to develop, offer, and provide products and services that we consider will be of interest to you,
• to make payments.

Where we share your information with these persons we will do so to the extent required for the above purposes. We will impose restrictions on how these persons can use and disclose the data we provide by applicable laws and regulations.

(d) Government authorities: Garsonna Menu may share your data with various government authorities in response to inquiries you may make and to assist us in carrying out our operations and responding to inquiries. Also, we may share your data with various government entities in response to legal proceedings; to establish and/or enforce our rights (including under our terms and conditions) or to protect our property; to defend against legal claims; or as otherwise required by law; we retain the right to raise or waive any legal objection or right available to us. We may also share your data when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities.
(e) Our employees, agents, consultants, and contractors: we may share your information with these persons and entities to process your information as described in this Privacy Policy. Any sharing will be on terms protective of your information.
(f) Banks, payment providers, and payment technology providers: where you use Garsonna Menu Pay we will share your information as follows:
• Bank: basic information such as merchant name, address, city, UNN number/CR number, and terminal number information is shared to set up the merchant in the banking system
• POS hardware vendor: basic information such as merchant name, address, city, contact number, and terminal information is shared with the POS hardware vendor to install the payment hardware at a merchant location
• AMEX: if a merchant requests to enable the AMEX service, similar information to that above is also shared with AMEX to enable the service

By accepting this Privacy Policy you consent to the above sharing and disclosure of your data to the extent your consent is a requirement for the disclosure to lawfully take place under applicable laws and regulations.
9. THIRD PARTY LINKS AND FEATURES

9.1   Our Website may contain links to third-party websites such as social media sites, and also may contain third-party integrations and functionalities. If you choose to use these sites or features, you may disclose your personal data not just to those third parties, but also to their users and the public more generally depending on how their services function. Garsonna Menu is not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your personal data will be subject to the privacy policies of the third-party websites or services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third parties.

10. STORAGE AND INTERNATIONAL TRANSFERS

10.1   By accepting this Privacy Policy, you consent to the storage of your information inside Jordan. Garsonna Menus may subcontract the processing of your data to, or otherwise share your data with, service providers located inside Jordan. Such third parties may be engaged in, among other things, the provision of goods and services to you, the processing of transactions, payments, and/or the provision of support services. By accepting this Privacy Policy, you agree to any such transfer storage or use.

We will always fulfill any requirements about the international transfers of personal data under applicable laws. For more information about these transfer mechanisms, please contact us using the contact details given below.

11. SECURITY OF YOUR DATA

11.1   We consider the confidentiality and security of your data to be of the utmost importance. Foodics takes a variety of technical, administrative, and physical measures to protect your information from disclosure to or access by third parties. Please note that we do not guarantee the security of personal data, as no method of internet transmission or storage is completely secure.

12. CHANGES TO THIS POLICY

12.1   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 Website or where we update you by email. You must read and accept the Policy every time it is updated. Otherwise, your use of the Services is not permitted.

13. YOUR RIGHTS

13.1   You have certain rights under and per applicable laws and regulations including:

(a) The right to be informed – to inform you of the valid legal or practical justification for collecting your data, and the purpose of such collection, and that your data should not be processed later in a manner inconsistent with the purpose for which it is collected, Garsonna Menu complies with this requirement by providing this Privacy Policy to you. If you require further information about your rights under applicable laws and regulations please inform us.
(b) The right to have access to your data – the right for you to have access to it and obtain a copy of it
(c) The right to request correction, completion, or updating of your data that Foodics controls.
(d) The right to request the destruction or deletion of your data which Garsonna Menu no longer needs to process for the purposes for which it was collected.
(e) The right to withdraw your consent at any time, where we relied on your consent to use and disclose your personal information. If you do this we may not be able to provide the Services to you.

By accepting this Privacy Policy you consent to the above sharing and disclosure of your data to the extent your consent is a requirement for the disclosure to lawfully take place under applicable laws and regulations.

14. HOW CAN YOU CONTACT US?

14.1   If you are unhappy with how we’ve handled your data, or have further questions on the processing of your data, contact us here

14.2

By email:  privacy@garsonna.com

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