Privacy Notice for Manna App & Delivery Service
Last updated: June, 2026
This Privacy Notice (“Notice”) describes how Manna Drone Delivery (“Manna”, “we”, “us” or “our”) collects, uses and stores personal data about you when you use our Manna App and drone delivery service to order goods from our partner restaurants and merchants. It also explains the privacy rights available to you under applicable data protection and privacy laws, including additional rights that may apply depending on where you reside.
For the purposes of this Privacy Notice, the controller of your personal data is Manna Drone Delivery. The contact details of our Data Protection Officer (“DPO”) are: dpo@manna.aero.
1. What Personal Data Do We Collect About You? Why and How Do We Process Your Personal Data?
This section explains the categories of personal data we may collect about you, why we process your personal data, and how we process it.
1.1. Drone Flight & Delivery
Why: All our drones have onboard cameras that are needed for safety management of flight and delivery. The flight/delivery is monitored by the drone pilot only, but not recorded. The drone flies at approximately 60m, at which height individual identification is not possible.
Data We Process: Eircode/zip code, streaming of images during flight/landing procedure.
How (Legal Basis): It is necessary for the safe operation of drone delivery; otherwise, we would not be able to provide the service to you in accordance with our contract with you. The legal basis for this processing is Subject to Contract.
1.2. App User registration & Security verification
Why: We collect this personal data to authenticate, verify, and grant you access to the Manna App. The information is used to communicate with you about your account and link your booking information to your user profile, allowing us to offer a personalized experience across devices. We may also use your device, location, user profile, usage, and other data to prevent, detect, and combat fraud.
Data We Collect: Account data including user name, phone number, Address/Eircode, device location, device identifiers and login details associated with Google/Facebook accounts (if you choose to use them).
How (Legal Basis): It is necessary to process this personal data to provide the Manna App and delivery service to you. If you do not provide certain personal data, we may be unable to provide the service to you in accordance with the contract. The legal basis for this processing is Subject to Contract.
1.3. Communication about offers and discounts (Marketing)
Why: We may notify you about our partner restaurants and merchants offers, discounts as well as provide you with company news through in-App notifications when you use our App and order from us and do not opt-out of notifications.
Data We Process: Basic account details including User ID, User Name, and phone number.
How (Legal Basis): Where we process your data for the purpose of promoting our company, our delivery services or partner merchants to you, we rely on your consent to do so.
Important: You may withdraw your consent to our processing of such data at any time – this can be done within the Manna App (see “your App, Your Choice). For information about your rights, please see below for more details.
1.3.1. Email Communication (Marketing)
Why: We may contact you by email to provide you with updates on our service, including offers and customer surveys.
Data We Process: Email Address
How (Legal Basis): Where you are a customer, and we process your data for the purpose of email marketing, we rely on our legitimate interest to do so. When you sign up for our mailing lists to receive marketing, we use consent as our legal basis.
Important: You may withdraw your consent to our processing of such data at any time – this can be done within the Manna App (see “your App, Your Choice). For information about your rights, please see below for more details.
1.4. Location Data for future expansion of our service
Why: We ask for your location when you register to provide you with personalised updates on services available in your area.
Data We Collect: We collect such data from users’ mobile devices if you enable us to do so (See “Your App, Your Choice” below for information on how you can enable/disable location data collection), or we may ask you to provide your Eircode/zip code.
How (Legal Basis): When we ask for your location unrelated to delivering orders, we rely on your consent.
Important: You may withdraw your consent to our processing of such data at any time – this can be done within the Manna App (see “your App, Your Choice). For information about your rights, please see below for more details.
1.5. Order, Payment and Delivery
Why: When you register with our App and place an order, we collect all the information required to deliver to you. We will also use this information to instruct our drone operators to deliver the order to your location.
Data We Collect: We will process your account information and may collect your location from your mobile devices if you enable us to do so, or we request your address/Eircode/zipcode directly from you. We will also process the restaurant, the goods ordered and the payment option you select.
How (Legal Basis): It is necessary to process this information to successfully deliver your order to you. If you do not provide this information, we will not be able to deliver your order in accordance with your contract with us. The legal basis for this processing is Subject to Contract.
1.6. Customer Service & Support
Why: If you contact us through our App or by email to request any customer support such as technical support, general account queries or an order, Manna will process relevant information to provide customer support services to you.
Data We Collect: We collect personal data about you, such as your account and contact details, as well as any other information you provide to us in your enquiry. When you contact our customer support, any phone conversations or email correspondence with our representatives may be monitored and reviewed for training purposes.
How (Legal Basis): It is necessary to process this personal data to provide you with customer service. The legal basis for this processing is Subject to Contract.
1.7. Customer Surveys
Why: We may communicate with you to improve our service. From time to time, we may ask you to provide customer feedback on our delivery service or to participate in customer satisfaction surveys.
Data We Process: We will use the information we have from when you registered with us in our Manna App. If you agree to provide feedback, we will collect your feedback about our service.
How (Legal Basis): It is our legitimate interest to contact you to ask for your feedback to improve our service to you. When you agree to participate in our surveys, we rely on your Consent.
Important: You may withdraw your consent to our processing of such data at any time. For information about your rights, please see below for more details.
1.8. Service Improvement
Why: To operate, provide and improve our services, we will collect and analyse specific usage and technical data. We collect information for troubleshooting, diagnostics, debugging, and aggregating metrics, including analytics, to monitor service performance, reliability, and efficiency, and to optimise service quality. To test new features and assess their performance, conduct experiments to evaluate their impact and track adoption metrics. We collect and aggregate activity and system events to understand breakdowns of how and how often the service is being used.
Data We Process: We collect data from your device including Usage Information, Log and Troubleshooting Information, Analytical Data, Device and Connection Information and General Location Information.
Who we share personal information with:
Third parties who undertake various activities to support our services. This includes website and application support and hosting providers, customer support applications, SMS and email communication platforms such as Twilio and Microsoft, payment and ordering platforms and analytics solutions. These service providers will only have access to the personal data necessary to perform these limited functions on our behalf and are required to protect and secure your personal data.
5. International Transfer of Personal Data
Personal data collected by Manna is stored and processed in the European Union. In very limited circumstances and only where permitted, Manna may transfer your personal data to a limited number of recipients who are outside the European Economic Area (“EEA”).
Where such transfers occur, it is our policy that:
• They do not occur without our prior written authority.
• An appropriate transfer agreement is put in place to protect your personal data (i.e., Module 2 of the Standard Contractual Clauses, as published by the European Commission);
• your data protection rights remain fully effective; and
• that your personal data are kept secure by way of technical, organizational and contractual measures (in the form of access controls, encryption (in transit and at rest), pseudonymization, staff training and data processing agreements) to ensure that these recipients cannot identify you or process your personal data for any purposes other than those which are necessary to provide their services to us.
If you would like to find out more about any such transfers, please contact us by emailing dpo@manna.aero.
6. Your Rights in Relation to Your Personal Data
You have a number of rights regarding your personal data – these rights are set out below. In particular, these rights include the right to withdraw your consent to our processing of your personal data (where we rely on your consent). Note that in certain circumstances, these rights might not be absolute. You can exercise these rights by contacting us at dpo@manna.aero. Manna will respond to your request within the timeframe set out in the applicable data protection legislation.
6.1. Right to Withdraw Consent
Where you have provided your consent to allow us to process your personal data, you have the right to withdraw your consent to the processing of your personal data at any time. For example, you can withdraw your consent by updating your settings (e.g., opting out). In certain cases, we may continue to process your personal data after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities. Where you withdraw your consent, it does not affect the lawfulness of any processing we carried out in relation to your personal data before your withdrawal.
6.2. Right of Access
You have the right to access and receive a copy of your personal data held by us. You can access much of your personal data by logging into your account.
6.3. Right to Erasure
You may request that your account or any personal data we hold about you be deleted. Once deleted, your personal data, including your account data and related activities, cannot be retrieved.
6.4. Right to Rectification
You have the right to ask us to update or correct any inaccurate personal data we hold about you. You can also update your personal data by logging in to your account.
6.5. Right to Restriction
You have the right to ask us to restrict our processing of your personal data in certain situations, including if you believe that the personal data we hold about you is inaccurate, or our processing of your personal data is unlawful. If you validly exercise this right, we will store your personal data and will not carry out any other processing until the issue is resolved. You can also restrict your personal data by logging into your account.
6.6. Right to Data Portability
You can request us to provide you with your personal data which you have provided to us in a structured, commonly used and machine-readable format, and you may request us to transmit your personal data directly to another controller where this is technically feasible.
6.7. Rights in Respect of Automated Decision Making (including Profiling)
You have the right not to be subject to solely automated decision-making, including profiling, which has legal effects or other similarly significant effects on you. To exercise this right, you can: (a) request that a person review any such decision; (b) express your point of view; and/or (c) contest the decision.
6.8. Right to Lodge a Complaint with the Data Protection Authority
If you wish to raise a concern about our processing of your personal data (and without prejudice to any other rights you may have), you have the right to do so by lodging a complaint with either the Data Protection Commission in Ireland (please see www.dataprotection.ie for further information) or your local data protection authority or regulator.
6.9 Additional Rights for Texas Residents
If you are a resident of Texas, you may have additional rights under the Texas Data Privacy and Security Act (TDPSA), subject to applicable exemptions.
Depending on the circumstances, you may have the right to:
• confirm whether we process your personal data;
• access your personal data;
• correct inaccuracies;
• delete personal data provided by or obtained about you;
• obtain a portable copy of your personal data where applicable;
• opt out of:
o the sale of personal data;
o targeted advertising; and
o profiling in furtherance of decisions that produce legal or similarly significant effects.
To exercise these rights, please contact us at dpo@manna.aero.
If we refuse your request, Texas residents may appeal our decision by contacting us at dpo@manna.aero. If we deny your appeal, we will provide information on how to submit a complaint to the Texas Attorney General.
7. Collection of Personal Data from Children
Manna does not provide services to children, nor do we market to children. If you are under the age of 16, please do not submit any personal information through our website. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce this Privacy Notice by instructing their children never to provide personal information via our website without their guardian’s consent.
8. Changes to the Notice
This Notice is subject to change from time to time. We encourage you to review this Notice occasionally, and we will notify you of any material changes. If you object to any of the changes to this Notice, you should stop using the Manna App and delete your account immediately.
9. How to Contact Us
If you have any technical or support questions, please contact us via email at info@manna.aero or use our contact forms in the App.
If you have any privacy concerns, complaints or inquiries for the DPO of Manna, please contact us via email at dpo@manna.aero.
10. Community Engagement
Why: From time to time, we may invite you to participate in community-building activities such as sharing your stories, providing testimonials, engaging in in-app community spaces, attending events, or contributing content for marketing or community initiatives. These contributions help foster an engaged user community and may be featured in our communications.
Data We Process: Name, city/country, story content, shared messages or quotes, images or videos you provide, and any associated social media handle if relevant.
How (Legal Basis): We rely on your consent under Article 6(1)(a) of the GDPR. With your consent, your contributions may be used in public or promotional materials, including our app, website, newsletters, and social media.
Important: You may withdraw your consent at any time by contacting us or by adjusting your app settings. For more information, see “Your App, Your Choice”.
