PRIVACY POLICY

‍Data CONTROLLER

‍UAB DennyPay, legal entity code 304887823, registered office address Ulonų str. 5, LT-08240 Vilnius, e-mail address info@dennytips.com
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‍1. TERMS USED
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‍1.1. 'Personal data'means any information relating to a natural person, a data subject whose identity is known or can be directly or indirectly established by means of data such as an identification number, one or more physical, physiological, psychological, economic, cultural or social characteristics specific to a person, data on the location of a person and an online identifier.

1.2. Company - UAB DennyPay, legal entity code 304887823, registered office address Ulonų str. 5, LT-08240 Vilnius.

1.3. Data subject – a natural person or a representative of a legal entity who uses the services of collecting and distributing the Company's tips , or performs the payment of tips or a person who browses the Website.

1.4. AN IP address is a unique number that identifies a computer, phone, tablet, or other device that connects to the Internet. The IP address can be used to identify the country where the computer is connected to the Internet.

1.5. Client – a natural or legal person registered on the Website who, in accordance with the Rules of Use of the Website, intends and / or uses the services of tip collection and distribution provided on the Website. The customer is considered to be both a catering establishment that has registered and has an account on the Website, as well as its employee, catering establishments included in its account and having concluded a commercial representation agreement with the Companye and having approved the rules for using the Dennytips.com.

1.6. Privacy Policy – this document, which contains the main rules for the collection, accumulation, processing and storage of Personal Data applicable when visiting the Website, as well as the rights of data subjects and the procedure for their implementation applicable in the Company.

1.7. Cookies Cookies) are small files uploaded to a computer, phone, tablet or other device used when any person visits the dennypay.com platform, with the help of which the Website recognizes the device.

1.8. Website – the website managed by the Company www.dennytips.com, including the internal system of the Company, where the catering establishment and its employees are registered.

1.9. Direct marketing is an activity designed to offer goods or services to individuals by post, telephone or other direct means and/or to inquire about their opinion on the goods or services offered.
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‍Regulation - Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
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‍2. GENERAL PROVISIONS
‍2.1. In this Privacy Policy, we provide you with information on how the Company processes personal data of Data Subjects . Additional information may be provided to Dennytips.com terms of use, which you will confirm before using the Company's services.

2.2. You can register on the Website only after you have familiarized yourself with this Privacy Policy and confirm it. We recommend that you carefully read this Privacy Policy before registering on the Website. You can re-access the Privacy Policy at any time on the Website.

2.3. The processing of personal data in the Company is regulated by the Regulation, the Law on Legal Protection of Personal Data of the Republic of Lithuania and other legal acts and local acts of the Company.
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‍3. Principles of personal data processing
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‍3.1. The scope of the personal data processed depends on the data provided by the Data Subject, which is indicated in the registration form provided by the Data Controller.

3.2. The data is processed only in accordance with the criterion of lawful processing – in order to ensure the provision of the services publicized by the Company;s vetainė s e e; with the consent of the person; when the Company is obliged to process personal data by the relevant legal acts; when personal data must be processed for the legitimate interest of the Company or a third party.
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3.3. We strive to ensure that Personal Data is processed accurately, fairly and lawfully, so that it is processed only for the purposes for which it is collected, in accordance with the clear and transparent principles and requirements for the processing of personal data established by legal acts.

3.4. You are not obliged to provide any Personal Data, but it is possible that certain services will not be able to be provided if the Personal Data is not provided.

‍4. Scope, purposes, basis of personal data processing

‍4.1. The Company shall process personal data collected by customers when visiting the Company's Website in connection with the services provided on the Website for the purposes and on the grounds specified in this paragraph.

4.2. Personal dataprovided tothe Client, the processing of which is based on the services of tip collection and distribution, and the purpose is to verify the identity of the Data Subject and provide the Customer with the services provided by the Company:

4.2.1.1. The name of the data subject, who is a natural person – an employee of a catering establishment, and uses the services of collection and distribution of the Company's tips, surname, surname, personal identification numberas, birth data, telephone number, e-mail addressas, settlement bank account number, photo;

4.2.1.2. The name of the data subject, who is a natural person - a customer of a catering establishment, and carries out the payment of a tip in a catering establishment,

4.2.1.3. Name, surname, e-mail address of the data subject, who is the representative of the legal entity (catering establishment).

4.3. The above-mentioned Personal Data is processed while the services are provided; after that, the data is stored for 10 (ten) years in order to assert, execute or defend the legal claims of the Company and for the Company to fulfill the obligation provided for in legal acts regarding archiving of documents.

4.4. The website also collects the name, telephone number, e-mail address, when a potential customer of the Company applies to the Company, fills in the registration form on the website, the goals are to provide a preliminary consultation according to the submitted request, to offer the services provided by the Company. Personal data is processed while services are provided on the Website; after which the data are stored for 10 (ten) years in order to assert, execute or defend the legal claims of the Company and for the Company to fulfill the obligation provided for in legal acts regarding archiving documents.

4.5. The Website also collects the data of visitors to the Website: IP address, time of login to visitors' accounts, website browsing history and date. The data shall be collected for statistical purposes. Website visitor statistics are analyzed with the help of Google Analytics. The information collected by google analytics cookie apie your website browsing history will be transmitted and stored on Google.org servers. The information collected by cookies allows us to ensure more convenient navigation on the Website, to provide suggestions and learn more about the behavior of our Website visitors, to analyze trends and to improve both the Website and the services provided. If you do not agree to the storage of cookies on your computer or other terminal device, you can change the settings of your web browser and disable all cookies or enable / disable them one by one. However, please note that in some cases this may slow down the speed of browsing the Internet, limit the operation of certain functions of the Website or block access to the Website. More detailed information can be found at AllAboutCookies.org or www.google.com/privacy_ads.html .

4.6. On the website we provide information about cookies (personal data intended to be collected with the help of cookies and the purposes of processing the collected personal data, the term of storage of cookies, information about the fact that the user can withdraw his consent to the storage of cookies at any time when cookies are stored on the basis of the consent of the data subject). The Company allows you to agree to the storage of cookies on the website visitor's terminal device when storing functional, tracking, advertising cookies and (or) third-party cookies. Necessary cookies are used on the basis of a legitimate interest. Cookies are used for the purposes of improving the Website, actualizing marketing campaigns, statistics and monitoring website traffic, collecting the following information about the visitors of the Website: the browser and its version, the choice of language, location, the time that the visitor visited the Website. Information on the use of cookies must be provided to you and your consent must be obtained before using the cookie for the first time, i.e. there must be prior consent to the use of the cookie. In the event that consent has been obtained, there is no need to obtain consent again in the future by reusing the same cookie for the same purpose. This also applies to cookies used by third parties.

4.7. For direct marketing purposes, we process Personal Data on the basis of your consent. For direct marketing purposes, the Company processes the following Personal Data: name, surname, address, e-mail address, telephone number. Data is processed from the receipt of the data subject's consent for 5 (five) years or until you withdraw the given consent to the processing of Personal Data. If you withdraw your consent to the processing of data for the purpose(s) discussed in this paragraph, only the fact of giving your consent for 10 (ten) years from the end of the consent period or the withdrawal of consent in order to assert, execute or defend our legal claims shall be stored. You have the right to refuse advertising messages sent by the Company at any time and have the right, without giving reasons for disagreement, to object to the processing of Personal Data for the purpose of direct marketing. You can withdraw the already given consent regarding the processing of Personal Data for the purpose of direct marketing by clearly and unambiguously expressing your will in writing to an employee of the Company. You can exercise the right to object to the processing of personal data for the purpose of direct marketing by contacting the Company by e-mail indicated on the Website.

‍4.8. The company has created and operates an account on the social media outlet Facebook. All information that you provide via social media on Facebook (including messages, the use of the "Like" and "Follow" fields, and other communication) or that is obtained when you visit the Company's Facebook account (including information received through cookies used by the social media) or when you read the Company's posts on the social media network, is controlled by the social network operator Facebook. Therefore, we recommend that you read the privacy statements of the social network operator Facebook and contact him directly regarding the use of your personal data. To learn more about the privacy policy of the operator of the social network Facebook, click here https://www.facebook.com/policy.php . To learn more about the cookies used on Facebook, click here https://www.facebook.com/policies/cookies/ .

4.9. Other goals. The Company may also process personal data for other purposes in accordance with the requirements and procedure of the Regulation, the Law on Legal Protection of Personal Data of the Republic of Lithuania.

4.10. Time limits for data processing. We process personal data for no longer than required by the purposes of data processing, data subjects and / or legal acts. Usually (unless otherwise specified) personal data are processed in the Company for 10 (ten) years from the receipt of personal data. If the data subject expresses a request to restrict the processing of his data and the Company satisfies such a request, the collected personal data is no longer processed in the Company, except for the storage of the collected data within the time limits set out in the Rules. This Privacy Policy may specify specific time limits for the processing of Personal Data, including storage.

‍5. Provision of processed data to other entities. data controllers and processors

‍5.1. The Company does not provide the processed Personal Data to third parties without the prior consent of the person (data subject), except in accordance with the procedure established by legal acts.

5.2. Data recipients and groups of recipients: state tax inspectorate under the Ministry of Finance of the Republic of Lithuania, other state institutions and institutions, law enforcement institutions; auditors, legal and financial consultants; third parties maintaining registers.

5.3. Your Personal Data may be processed by data processors providing the Company with accounting, website hosting, data center and/or server rental, IT maintenance, external audit and other services.

5.4. Data processors have the right to process Personal Data only in accordance with the instructions of the Company and only to the extent necessary for the proper performance of the obligations set out in the contract. With the help of data processors ,we strive to ensure that data processors have implemented appropriate organizational and technical security measures and maintain the secrecy of personal data.

5.5. Your personal data may be provided to third parties in the following ways: in writing, by electronic means of communication, by logging in to databases or information systems collecting individual data or in another way agreed with the controller of personal data.

5.6. The Company, as a data processor, processes the personal data of the employees of the catering establishment, which are provided on the Website by a person authorized by the catering establishment: name, surname, personal identification number, date of birth of the employee, number of the settlement bank account, e-mail address and phone number.

‍6. SECURITY OF PERSONAL DATA

‍6.1. With the help of its internal organizational and technical measures, the Company makes all reasonable efforts to ensure that personal data is protected from any unlawful actions. All Personal Data and other information provided by the Data Subject shall be considered confidential. Access to Personal Data is limited to those employees of the Company and data processors of the Company, for whom it is necessary for the performance of work functions or the provision of services.

6.2. If you want to register on the Site as a representative of a catering establishment, you must provide your name, surname, e-mail address, invented sheetand information about the catering establishment: its name, company name, company code, address. During registration, a p asceyra is created for the catering establishment. In the section, you enter the name, surname, personal identification number, telephone number, e-mail address and settlement bank account number of the catering staff, therefore you are responsible for the correctness and relevance of this Personal Data. You may at any time adjust or supplement personal data. You can apply to the Company by e-mail address info@dennytips.com for the cancellation of the section. You undertake to ensure that the system contains only the personal data of the existing employees of the catering establishment who have agreed to participate in the tipping collection system.

6.3. If you are an employee of a catering establishment and want to participate in the program for collecting and paying tips, your personal data is indicated in 6.2. you submit it to the catering establishment and are responsible for their correctness and updating when they change. We are not responsible for the incorrectness or relevance of the data provided to your catering establishment. To participate in the tip collection system, you must approve the contract for the provision of services and the rules for using the system, which you receive by e-mail. You may at any time adjust or supplement personal data by informing the catering establishment thereof. Also, at any time you can apply to the catering establishment for refusing to participate in the tip collection system and deleting your data from the system. Your data in the system is provided, adjusted or deleted by the actions and initiative of the representative of the catering establishment.

6.4. As a representative of the catering establishment, you must protect your login password and login name to the Website, as well as other data, and not to disclose your login details to any other third parties. We shall not be liable if your Personal Data is unlawfully altered, disclosed, destroyed, your identity is stolen or otherwise fraudulently used by you or the Personal Data controlled by you, due to your own fault or negligence, which arose as a consequence of non-compliance with this Privacy Policy, the Rules of Use of the Website, the Company's Terms of Service or legal acts. We are also not liable if you indicate incorrect, invalid data of the employees of the catering establishment, include in the system employees who have not expressed their consent to participate in the tip collection system, or do not delete the data from the system in a timely manner after the termination of the employment contract with the employees.

‍7. RIGHTS OF DATA SUBJECTS

‍7.1. Each data subject has the following rights:

7.1.1. to get acquainted with the Personal Data provided by you at any time by contacting the Company;

7.1.2. having submitted a request in writing for information on what sources and what personal data of his /her personal data were collected from, for what purpose they are processed, to whom they are provided;

7.1.3. after submitting a request in writing, to request by e-mail the correction of incorrect, incomplete, inaccurate personal data and / or to suspend the processing of such personal data.

7.1.4. to object to the processing of his/ her Personal Data, unless these personal data are processed for the legitimate interest pursued by the controller or the third party to whom the personal data are provided and if the interests of the data subject are not overriding;

7.1.5. to demand that the personal data provided be destroyed;7.1.6. to require the restriction of the processing of personal data;

7.1.7. to require that personal data provided by him or her, if they are processed on the basis of his or her consent or contract, and if they are processed by automated means, be transferred by the processor to another controller, if this is technically possible (data portability);

7.1.8. the right to object to the use of only automated data processing;

7.1.9. the right to object to the processing of personal data for direct marketing purposes;

7.1.10. the right to withdraw the consents given to the processing of data;

7.1.11. the right to submit a complaint regarding the processing of personal data to the State Data Protection Inspectorate.

7.2. The data subject has the right to apply for the implementation of the rights of the data subject orally or in writing, by submitting a request in person, by mail or by electronic means. If the implementation of the rights of the data subject is requested in writing by submitting a request by mail, then a copy of the identity document certified by a notary or other procedure established by legal acts must be submitted together with the request. If the data subject's personal data, such as name, surname, have changed, copies of the documents confirming the change in these data shall be provided together; if they are sent by post, then they must be certified by a notary or other procedure established by legal acts. When submitting an application by electronic means, the application must be signed with a qualified electronic signature or it must be formed by electronic means, which allows to ensure the integrity and irreplaceability of the text.

7.3. The request to implement the rights of the data subject must be legible, signed by the person, it must contain the name, address and (or) other contact details of the data subject for communication or by which it is desired to receive a response regarding the implementation of the rights of the data subject.

7.4. The data subject may exercise his or her rights himself or herself or through a representative. The person's representative must indicate in the request his name, surname, address and (or) other contact details for communication, by which the person's representative wishes to receive a response, as well as the name of the represented person and indicate other data that are necessary for the proper identification of the data subject and provide a document confirming the representation or a copy thereof. In case of doubts about the identity of the data subject, the Company requests additional information necessary to verify it.

7.5. Upon receipt of the Request, we will provide a response no later than within 30 calendar days from the date of receipt of the Request.

7.6. The Company, acting as a Data Processor, has the right to refuse to exercise your rights in a reasoned manner on the grounds set out in the Regulation.

7.7. Information about the processing of your data is provided to you, the lawfulness and integrity of the data processing is checked, the data processing actions are terminated, the data is destroyed free of charge.

7.8. Youcan request your submission by e-mail info@dennytips.com

‍8. FINAL PROVISIONS

‍8.1. The law of the Republic of Lithuania shall apply to the implementation and interpretation of the provisions of the Privacy Policy.

8.2. If any provision of the Privacy Policy becomes or is invalidated, the remaining provisions shall remain in force.

8.3. This Privacy Policy is valid from the date of its publication on the Website. This Privacy Policy is not considered to be an agreement between the Company and you regarding the processing of A person's data. We may change the Privacy Policy at any time. All changes to the Privacy Policy are published on the Website. Amendments and (or) additions to the Privacy Policy shall take effect after the moment of their publication on the Website. We recommend that you review our Privacy Policy regularly.

8.4. If you would like to check, find out how the Company processes your personal data, or if you intend to exercise your rights as a data subject, please contact the data protection officer appointed by the Company by e-mail: info@dennytips.com