Privacy

Privacy Notice for Manna App & Delivery Service

Last updated: June, 2022

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.

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 that we may collect about you, why we process your personal data and how we process your personal data.

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 identification of individuals is not possible.  

Data We Process: Eircode, streaming of images during flight/landing procedure  

How (Legal Basis): It is necessary for the safe operation of the drone delivery, otherwise we would not be able to provide the service to you in accordance with the contract we have with you. The legal basis for this processing is Article 6(1)(b) of the General Data Protection Regulation ("GDPR")

1.2. App User registration & Security verification

Why: We collect this personal data to authenticate, secure and provide you with access to the Manna App. The information is used to communicate with you about your account. 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.  

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 not be able to provide the service to you in accordance with the contract with you. The legal basis for this processing is Article 6(1)(b) of the General Data Protection Regulation ("GDPR").

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, 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 in accordance with Article 6(1)(a) of the GDPR. 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.

How (Legal Basis): When we ask for your location unrelated to delivering orders, we rely on your consent in accordance with Article 6(1)(a) of the GDPR.

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 when you place an order, we collect all information required to make a delivery 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 directly from you. We will also process the restaurant, 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 delivery your order in accordance with your contract with us. The legal basis for this processing is Article 6(1)(b) of the General Data Protection Regulation ("GDPR").  

1.6. Customer Service & Support  

Why: If you contact us through our App 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 and any other information you provide to us in your enquiry. When you contact our customer support, any phone conversations, 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 customer service to you. The legal basis for this processing is Article 6(1)(b) of the General Data Protection Regulation ("GDPR").

1.7. Customer Surveys  

Why: We may communicate with you to improve our service. For this we may ask you from time to time to provide customer feedback about our delivery service or to invite you to participate in customer satisfaction surveys.  

Data We Process: We will be using the information we have when you registered with us in our Manna App . If you agree to providing 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 in accordance with Article 6(1)(a) of the GDPR. 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.  

2. Your App, Your Choice

Manna enables users to access and/or control data that it collects, including through in-App privacy settings, device permissions and marketing consent.

Notifications

The App Settings > Notification in the Manna App allows you to select which notification you wish to receive.

Location data collection

You can enable/disable Manna to collect location data from your mobile device through the device settings.  

Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data such as location data that Manna cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. Please check the available settings on your device or check with your provider.

3. Retention of your Personal Data  

We will store your personal data only for as long as necessary for the purpose(s) for which it was obtained. The criteria used to determine our retention periods include  

  1. the length of time we have an ongoing relationship and/or provide our services;  
  1. whether there is a legal requirement to which we are subject; and  
  1. whether the retention is advisable in light of our legal position (such as in regard to Manna appliable statutes of limitations, litigation or regulatory investigations).  

We retain your Personal Data as long as we are providing the Services to you or for a period during which we reasonably anticipate providing the Services. Even after we stop providing Services directly to you and even if you close your account, we may retain your Personal Data in order to comply with our legal and regulatory obligations. We may also retain it to allow for fraud monitoring, detection and prevention activities. We also keep Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods you used. In cases where we keep Personal Data, we do so in accordance with any limitation periods and records retention obligations that are imposed by Manna Applicable law.

In case of marketing communication, if you haven’t placed an order in 24 months, then we will automatically opt you out of receiving further marketing communication from us.  

Please contact us if you wish to obtain further information concerning our retention periods (see ‘Contact Us’ below).  

4. Sharing of Personal Data

We will share your personal data with Manna business and customer teams for the purposes described in above in this Notice.  

We may share your personal information with 3rd party recipients (see below). Whenever we do share your data, we will ensure that we have appropriate security and contractual safeguards in place to protect it.  

Only the necessary data will be shared with our restaurant partners for the purpose of executing your order or to respond to customer service enquiries.  We will never share your data with any 3rd party partner for marketing purposes.

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 .

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 on this website are 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:  

  1. they do not occur without our prior written authority.  
  1. 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);  
  1. your data protection rights remain fully effective; and  
  1. that your personal data are kept secure by way of technical, organizational and contractual measures (in 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 e-mailing dpo@manna.aero.

6. Your Rights in Relation to Your Personal Data

You have a number of rights in relation to 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 to do so). 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 thirty (30) days or less. In some instances, we may need to extend this response time by two further months. We will let you know if this need arises.  

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 be provided with 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 of your personal data held by us is 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 have any inaccurate personal data which we hold about you updated or corrected. You can also rectify your personal data by logging into your account.

6.5. Right to Restriction  

You have the right to ask us to restrict our processing 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 to not 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 reviews any such decision; (b) express your point of view; and/or (c) contest the decision.

6.8. Right to Lodge a Complaint with 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 in Germany.

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.