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MinglEat FZ-LLC

Privacy Policy

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE REGISTERING FOR, ACCESSING, OR USING THE MINGLEAT PLATFORM. BY REGISTERING FOR, ACCESSING, OR USING THE PLATFORM, YOU ACCEPT AND AGREE TO BE LEGALLY BOUND BY THIS PRIVACY POLICY, THE TERMS, AND OUR GUIDELINES. IF YOU DO NOT AGREE, YOU MUST NOT USE THE PLATFORM.

  1. ABOUT MINGLEAT AND THE PLATFORM

This Privacy Policy (the "Policy") governs your access to and use of the MinglEat mobile application, website, and all associated booking systems, dashboards, content, features and functionality together, operated by MinglEat FZ-LLC "MinglEat," a company incorporated in the United Arab Emirates with its registered address at DMC-BLD05-VD-G00-594, Ground Floor, DMC5, Dubai Media City, Dubai, United Arab Emirates.

MinglEat is a social dining platform. It connects people who use the app with restaurants, cafés, bars and other food and beverage venues, for organised group meals built around shared interests, professions, industries, hobbies or other common topics. These gatherings may be arranged by a user who chooses to host one, with MinglEat coordinating the booking and logistics with the relevant venue.

We operate as a technology and marketplace intermediary. Except where we expressly say otherwise, we do not organise, host, or operate the venues where these gatherings take place, and we are not responsible for the conduct of any user, or for the quality, availability or provision of services by any venue. Our role is limited to enabling introductions, bookings and coordination between users and venues through the Platform.

Because delivering that role involves handling personal information – when you access the Platform, create an account, sign up for a gathering, communicate with us, or otherwise interact with MinglEat – this Policy explains what personal data we collect, how and why we use it, who we share it with, and the rights you have over it.

DEFINITIONS AND INTERPRETATION

Throughout this Policy:

  • “Account” means your individual MinglEat profile and login, created on successful registration.

  • “Booking” means a confirmed reservation for a Dining Experience made through the Platform.

  • “Applicable Law” means all applicable laws, regulations, orders, and directives relating to privacy, data protection, cybersecurity, electronic communications, and the processing of Personal Data, including Federal Decree-Law No. (45) of 2021 Concerning the Protection of Personal Data, and their implementing regulations and any related guidance, together with any other data protection or data security laws applicable (including, where applicable, the data protection regimes of the DIFC or ADGM);

  • “Dining Experience” means an in-person gathering arranged through the Platform at a Restaurant, where Members meet to dine and engage in discussions centred around a specified topic, shared interest, profession, industry, hobby or other common purpose;

  • “Host” means a Member who creates and hosts a Dining Experience at a Restaurant on the Platform;

  • “Member” or “you” means a registered user who books and participates in Dining Experiences through the Platform;

  • “Personal Data” means any information relating to an identified or identifiable natural person, whether collected directly or indirectly, and whether alone or in combination with other information, including any data that can identify a person by reference to an identifier such as a name, contact details, identification number, location data, or other physical, physiological, health, economic, cultural, social, or online identifiers; and

  • “Restaurants” means any restaurant, café, bar, hotel, private dining venue, food and beverage establishment, or other hospitality venue that is listed on, or otherwise made available through, the Platform for the purpose of hosting Dining Experiences.

“Terms” means MinglEat’s Terms of Use, available at our website (mingleat.com) which are incorporated herein by reference. “Guidelines” means MinglEat’s Community Guidelines, available at our website (mingleat.com) which are incorporated herein by reference.

SCOPE AND CONSENT

This Policy applies to the Personal Data processed by MinglEat in connection with the Platform and the Bookings, including Personal Data of website and app users, Members (including Hosts and Members), prospective Members, Hosts, service providers, and relevant business contacts. It covers Personal Data collected directly from individuals, generated through use of the Platform, or received from third parties in connection with Dining Experience sign-ups, payments, service delivery, support, compliance, and related operations.

By registering for or using the Platform, you consent to this Policy. If you do not accept the terms of this Policy, your sole remedy is to discontinue use of the Platform or contact us if you have any specific concerns in relation to this Policy.

This Policy does not apply to Personal Data processed by Restaurants or other third parties acting as independent controllers for their own purposes, including restaurant access control, CCTV, security, venue operations, or regulatory compliance. Such processing is subject to the relevant third party's own privacy policy and legal obligations.

MINGLEAT AS DATA CONTROLLER

For the purposes of Applicable Law, MinglEat acts as the controller of the Personal Data collected through the Platform and in connection with the Dining Experiences. In other words, MinglEat determines the purposes for which, and the manner in which, Personal Data is collected, used, stored, disclosed, and otherwise processed.

Where MinglEat engages third-party service providers, including Restaurants, payment service providers, cloud hosting providers, analytics providers, customer support providers, and other service providers to process Personal Data on its behalf, such parties shall process Personal Data only for the purposes authorised by MinglEat and in accordance with Applicable Law, contractual obligations, and MinglEat's instructions, where applicable.

Certain third parties, including Restaurants, payment service providers, regulatory authorities, and other entities that independently determine the purposes and means of processing Personal Data, may act as separate or independent controllers of Personal Data. In such circumstances, the processing of Personal Data by such parties shall be governed by their respective privacy policies and legal obligations.

If you have any questions regarding MinglEat's processing of your Personal Data or wish to exercise your rights under Applicable Law, you may contact MinglEat using the contact details set out in this Policy.

HOW DO WE COLLECT PERSONAL DATA?

We collect Personal Data from and about you through the following methods:

  1. Direct interaction: You provide us with your Personal Data when you interact with us. This includes Personal Data you provide when you:

  1. create an Account or profile with us;

  2. use our Platform, or host or join a Dining Experience;

  3. enter a promotion, user poll, or online survey;

  4. request marketing communications to be sent to you; or

  5. report a problem with the Platform, provide feedback, or contact us.

  1. Automated technologies or interactions: Each time you visit the Platform, we will automatically collect data about your Dining Experience views, browsing actions, and patterns. We collect this Personal Data by using cookies, web beacons, pixel tags, server logs, and other similar technologies. We may also receive data about you if you visit other websites or apps that employ our cookies.

  2. Third parties or publicly available sources: We receive Personal Data about you from various third parties:

  1. Technical data from analytics providers such as Facebook and Google Analytics and advertising networks;

  2. Identity and profile-related data and contact data from publicly available sources; and

  3. Personal Data about you from the Restaurants or from other Members with whom you interact through a Dining Experience.

LAWFUL BASIS FOR PROCESSING

MinglEat processes Personal Data only where there is a lawful basis for doing so under Applicable Law. Depending on the nature of the processing activity, MinglEat may process Personal Data on one or more of the following legal bases:

  1. where processing is necessary to perform a contract with you or to take steps at your request prior to entering into a contract;

  2. where processing is necessary to comply with a legal or regulatory obligation applicable to MinglEat;

  3. where you have provided your consent to such processing, including the receipt of marketing communications;

  4. where processing is necessary to protect your vital interests or those of another individual; and

  5. where processing is necessary for MinglEat's legitimate interests, provided such interests are not overridden by your rights and freedoms under Applicable Law.

MinglEat relies on the foregoing legal bases for activities including Account creation, managing Bookings, customer support, fraud prevention, payment processing, platform security, service improvement, marketing activities, and compliance with legal obligations.

USE OF PERSONAL DATA

We will use your Personal Data where we need to facilitate your Bookings, enable you to use the Platform, or where we need to comply with a legal obligation. We use your Personal Data for the following purposes:

  1. to verify your identity to register you as a user, and create your user Account with us on the Platform;

  2. to facilitate a transaction between you and a Host to enable you to join their Dining Experience as a Member;

  3. to track your activity on the Platform;

  4. to improve the functionality of our Platform based on the information and feedback we receive from you;

  5. to improve customer service to effectively respond to your Dining Experience sign-up requests and support needs;

  6. to send periodic notifications to manage our relationship with you, including to notify you of changes to the Platform, send you information and updates pertaining to the Dining Experiences you have signed up to, and to receive occasional company news and updates related to us or the Platform;

  7. to assist with the facilitation of the services offered to you, including to send you information and updates about the Dining Experiences you have signed up for;

  8. to market and advertise the Platform to you;

  9. to comply with legal obligations;

  10. to administer and protect our business and the Platform, including for troubleshooting, data analysis, system testing, and performing internal operations;

  11. to improve our business and delivery models;

  12. to perform our obligations that arise out of the arrangement we are about to enter or have entered with you;

  13. verifying financial transactions in relation to any payments you make through the Platform;

  14. to personalise and enhance user experience;

  15. to enforce our Terms and Guidelines; and

  16. to respond to court orders, establish or exercise our legal rights, or defend ourselves against legal claims.

Personal Data shall be processed only with your consent and acknowledgement that, by using our Platform and creating an Account with us, you authorise us, our Restaurants, the Hosts, associate partners, and affiliates to contact you via email, phone, or otherwise. This is to provide the Platform to you, ensure that you are aware of all the features of the Platform, and for related purposes.

COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and similar tracking technologies on the Platform to enable core functionality, improve user experience, understand usage patterns and ensure security. Cookies are small text files stored on your device by our website. They allow us to remember your actions and preferences over time, and to recognise you when you return. Similar technologies include web beacons, pixels, local storage objects and device identifiers.

We and our third-party service providers use cookies to:

  • operate and maintain the core functionality of the Platform;

  • authenticate users and protect against fraud or unauthorised access;

  • remember user preferences and improve user experience;

  • analyse usage patterns and improve performance and features; and

  • (where applicable) deliver and measure marketing and advertising.

Some cookies are placed by third-party service providers that we use for analytics, communications, infrastructure, or marketing purposes. These third parties may collect and process information in accordance with their own privacy policies. We encourage you to review those policies before consenting to such cookies.

We will ask for your permission to place cookies or similar technologies on your device, except where they are essential for us to provide you with a requested service, such as your IP address, operating system, browser, domain, or other user information (e.g., your username).

You can withdraw any consent to the use of cookies or manage any other cookie preferences by turning them off in your browser and/or deleting them from your hard drive. You do not need to have cookies turned on to view Dining Experiences, but you will need them to sign up to a Dining Experience and to access personalised or secure content on the Platform.

DATA SHARING AND DISCLOSURE

We may share or disclose your Personal Data where necessary for the operation of the Platform, our legitimate business operations, or compliance with Applicable Law. We do not sell, rent, or trade your Personal Data to third parties for their own independent marketing purposes.

In particular, we may share your Personal Data with:

  1. Restaurants – we may share Personal Data with participating Restaurants that facilitate your Dining Experience sign-up, table reservation, and the delivery of the Dining Experiences. Such Personal Data may include your name, Dining Experience sign-up reference number, Dining Experience date, time and location, and such other information as may be reasonably necessary for reservation, seating, operational, security, safety, or incident-management purposes.

  2. Other Members – Personal Data may be shared with other Members of the Platform in the following circumstances:

    1. where you host or join a Dining Experience, we may share limited Personal Data (including your name, profile photo, social media profile and shared interest or theme information) with other Members or the Host participating in the same Dining Experience, limited to the duration of the Dining Experience, and where you have explicitly consented to facilitate introductions and enable the dining experience; and

    2. we may also share Personal Data with the Hosts where you separately request or direct us to do so, or where you have explicitly consented to such disclosure.

  3. Service providers and processors – we may share Personal Data with trusted third-party service providers that process Personal Data on our behalf and under our instructions. These may include providers of cloud hosting and infrastructure, analytics and monitoring tools, customer support platforms, communications services, payment processing, transaction support, and other services necessary to operate, secure, maintain, and improve the Platform.

Where such third parties act as our processors, we require them to process Personal Data only on our documented instructions, maintain appropriate technical and organisational security measures, preserve confidentiality, and process Personal Data only for the specified purposes for which it was disclosed.

  1. Payment service providers – payment transactions conducted through the Platform may be processed by authorised third-party payment service providers. These providers may collect and process payment information directly from you in accordance with their own privacy notices and regulatory obligations. MinglEat does not collect or store complete payment card details, but may receive limited transaction-related information, such as transaction identifiers, payment status, and limited card-reference information, for reconciliation, record-keeping, fraud prevention, and customer support purposes.

  2. Regulators, authorities, and legal disclosures – we may disclose Personal Data to regulators, courts, law enforcement agencies, governmental authorities, or other competent bodies where required by Applicable Law, regulation, court order, legal process, or official request, or where necessary to establish, exercise, or defend legal claims, protect rights or safety, investigate misconduct, or prevent fraud or unlawful activity.

  3. Corporate transactions – we may disclose or transfer Personal Data in connection with an actual or proposed merger, acquisition, restructuring, financing, sale of assets, or other corporate transaction involving all or part of our business, provided that appropriate confidentiality obligations and data protection safeguards are maintained.

We require recipients that process Personal Data on our behalf to respect the security of your Personal Data and to process it in accordance with Applicable Law. Where a recipient acts as an independent controller rather than our processor, its processing of your Personal Data will be subject to its own privacy notice and legal obligations.

By using the Platform, signing up to a Dining Experience, or participating in the Dining Experiences, you acknowledge that your Personal Data may be shared in accordance with this Section where necessary for Dining Experience administration, Dining Experience participation, Platform delivery, safety, operational coordination, payment processing, and compliance with Applicable Law.

Once Members meet through a Dining Experience, they may choose to exchange contact details or connect with one another independently of the Platform, including through phone numbers, personal social media accounts, or other means. Any such exchange, and any subsequent interaction or data sharing between Members outside the Platform, is undertaken at the Members' own discretion and is not processed, controlled, or facilitated by MinglEat. MinglEat is not responsible for how Members handle each other's Personal Data once shared outside the Platform.

YOUR RIGHTS

Subject to Applicable Law, you have the following rights regarding your Personal Data. These rights help ensure fair, transparent, and accountable processing by MinglEat as a data controller.

  • Right to access: Request a copy of the Personal Data we hold about you

  • Right to rectification: Request correction of inaccurate or incomplete data

  • Right to erasure: Request deletion of your data, subject to legal retention obligations

  • Right to restriction: Request that we limit how we process your data in certain circumstances

  • Right to data portability: Receive your data in a structured, machine-readable format

  • Right to withdraw consent: Withdraw marketing consent at any time without affecting prior processing

  • Right to object: Object to processing based on legitimate interests

  • Rights relating to automated decision-making and profiling: The right to object to such processing

To exercise your rights, submit requests to: info@mingleat.com. Include your name, contact details and a clear description of your request. We may verify your identity for security.

We aim to respond within 30 days. Complex requests may take longer (up to 60 days total), and we will explain any extension. Requests are free unless manifestly unfounded, repetitive or excessive.

DATA RETENTION

We retain Personal Data only for as long as necessary for the purposes described in this Policy or as required by Applicable Law. After the applicable retention period expires, Personal Data is deleted, anonymised or aggregated, unless we are required or permitted to retain it longer (for example, to comply with legal obligations, resolve disputes or enforce our agreements).

DATA SECURITY

MinglEat implements appropriate technical and organisational measures to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access, in accordance with Applicable Law. These measures are designed based on the nature, scope, context, purposes and risks of our processing activities.

In the event of a Personal Data breach, we follow a structured response: immediate containment and forensic investigation; notification to appropriate authorities as soon as possible; individual notification without undue delay where a high risk to rights exists, explaining the breach, its impacts, and mitigation measures; and full remediation with root cause analysis.

AUTOMATED PROCESSING AND RECOMMENDATIONS

MinglEat may use automated tools, analytics, and algorithmic models to improve the Platform, including recommending Dining Experiences, Hosts, or Members with shared interests, personalising content, identifying user preferences, improving Dining Experience sign-up experiences, and generating dining-related insights. Such automated processing is intended to enhance user experience and operational efficiency and is not intended to produce legal effects or similarly significant impacts on users without appropriate human oversight. Where required by Applicable Law, MinglEat will provide additional information regarding such processing upon request.

DATA PROTECTION AND INTERNATIONAL DATA TRANSFERS

MinglEat is committed to protecting Personal Data in accordance with Applicable Laws. Your Personal Data is processed and stored within the United Arab Emirates. However, some of our service providers and technical infrastructure may process your Personal Data outside the UAE. This can occur when using cloud hosting, analytics tools, content delivery networks, or other processors that operate data centres or have operations in jurisdictions such as the United States, the European Union, or other regions.

In accordance with Applicable Law, we ensure that Personal Data transferred outside the UAE receives an adequate level of protection through one or more of the following mechanisms:

  1. Adequacy: Where the destination jurisdiction is recognised as providing an adequate level of data protection (pending UAE Data Office designations).

  2. Permitted grounds (where adequacy is unavailable):

  1. Your explicit consent to the specific transfer;

  2. Necessary for the execution of a contract between MinglEat and you, or to perform a contract in your interest;

  3. Necessary to establish, exercise or defend legal claims;

  4. Necessary for international judicial cooperation; or

  5. Necessary to protect the public interest.

These safeguards may include, where appropriate, contractual commitments with our service providers, access controls, data minimisation measures, encryption, secure hosting arrangements, and restrictions on onward transfers.

By using the Platform, you acknowledge that your Personal Data may be transferred to and processed in jurisdictions outside the UAE in accordance with this Policy.

SERVICE COMMUNICATIONS AND MARKETING

MinglEat may send you communications that are necessary for the operation of the Platform, including Dining Experience sign-up confirmations, Dining Experience reminders, Account notifications, payment confirmations, service updates, security alerts, and customer support communications. Such communications are considered service-related communications and may be sent regardless of your marketing preferences.

Where permitted by Applicable Law and subject to your preferences, MinglEat may send promotional messages, newsletters, offers, surveys, and information relating to new services and features.

You may withdraw your consent to receive marketing communications at any time by following the unsubscribe instructions included in such communications or by contacting MinglEat using the contact details provided below.

CHANGES TO THIS POLICY

We may update this Policy from time to time to reflect changes to the Platform, our data processing practices, Applicable Laws or regulatory requirements, or for other operational, legal, or business reasons.

Where we make material changes to this Policy, we will take reasonable steps to bring those changes to your attention, which may include updating the “Last Updated” date above and, where appropriate, providing notice by email, through your account, or by posting a prominent notice on the Platform.

Your continued access to or use of the Platform after the updated Policy becomes effective will constitute your acknowledgement of the updated Policy to the extent permitted by Applicable Law.

CHILDREN’S DATA

The Platform is not intended for use by children, and we do not knowingly collect or solicit Personal Data from individuals under the age of 18.

If we become aware that we have collected Personal Data from a person under the age of 18 without a lawful basis or appropriate authorisation, we may delete that Personal Data and take reasonable steps to disable or restrict the relevant submission, Account, or interaction, subject to any applicable legal or record-keeping obligations.

If you believe that a child or minor has provided us with Personal Data, please get in touch with us so that we can review and take appropriate action.

CONTACT US

If you have any questions about this Policy, our processing of your information, or if you wish to exercise any of your rights, you may contact us at: info@mingleat.com

If you believe that your rights under Applicable Law have been infringed, you may also have the right to raise a complaint with the relevant competent authority in the United Arab Emirates, including the UAE Data Office, where applicable.