Privacy Policy
Kulcha Express Global Ltd
Effective Date: 1st March 2025
Last Updated: 1st March 2025
Introduction
At Kulcha Express, we are committed to protecting your privacy and ensuring the security of your personal information in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our restaurants, use our website, or engage with our services.
Data Controller: Kulcha Express Global Ltd. is the data controller for the personal information we collect and process.
Lawful Basis for Processing
We process your personal data under the following lawful bases:
• Contract: To fulfill our contractual obligations when you order food or use our services
• Legitimate Interests:
To improve our services, conduct marketing, and operate our business
• Consent:
For marketing communications and non-essential cookies (where required)
• Legal Obligation:
To comply with legal and regulatory requirements
• Vital Interests:
To protect health and safety in emergency situations
Information We Collect
Personal Information You Provide Directly
• Contact Information: Name, email address, phone number, delivery address
• Order Information:
Food preferences, dietary requirements, delivery instructions
• Communication:
Messages, feedback, survey responses, customer service interactions
• Marketing Preferences:
Newsletter subscription, communication preferences
• Accessibility Requirements:
Special dietary needs, allergies
Information Collected Automatically
• Website Usage: IP address, browser type, device information, pages visited, session duration
• Cookies and Similar Technologies:
Essential cookies, analytics cookies, marketing cookies (with consent)
• CCTV:
Images captured in our restaurants for security purposes
Information from Third Parties
• Delivery Partners: Order information from UberEats, Deliveroo, and JustEat when you order through their platforms
• Social Media:
Information when you interact with our social media pages
• Analytics Providers:
Aggregated website usage statistics
Note: We do not collect or store payment card information directly. All payments are processed securely by our delivery partners or third-party payment processors.
How We Use Your Information
Contract Fulfillment
Processing and fulfilling food orders
Coordinating delivery through our partner platforms
Providing customer service and order support
Managing restaurant operations and table bookings
Legitimate Interests
• Service Improvement: Analyzing customer preferences and feedback to enhance our menu and services
• Business Operations:
Managing inventory, staff scheduling, and restaurant efficiency
• Marketing:
Sending promotional materials about our services (with appropriate opt-out options)
• Security:
Protecting our premises, customers, and staff through CCTV monitoring
Consent-Based Processing
• Email Marketing: Sending newsletters and promotional offers (you can unsubscribe at any time)
• Non-Essential Cookies:
Analytics and marketing cookies (you can manage preferences through our cookie banner)
Legal Compliance
• Food Safety: Maintaining records for food hygiene and safety regulations
• Tax and Accounting:
Keeping financial records as required by HMRC
• Health and Safety:
Incident reporting and compliance with workplace regulations
Information Sharing and Disclosure
Third-Party Service Providers
• Delivery Partners: UberEats, Deliveroo, and JustEat receive necessary order and contact information
• Technology Providers:
Website hosting, email services, and analytics platforms
• Professional Services:
Accountants, lawyers, and business advisors (under strict confidentiality)
Legal Requirements
• Regulatory Authorities: Food Standards Agency, local councils, HMRC, ICO
• Law Enforcement:
When required by law, court order, or to protect public safety
• Emergency Services:
In case of health and safety emergencies
Business Transfers
In the event of a merger, acquisition, or sale of assets, your personal information may be transferred as part of the business assets, subject to the same privacy protections.
We do not sell your personal data to third parties.
Your Rights Under UK GDPR
Access and Portability
• Right of Access: Request a copy of the personal data we hold about you
• Data Portability:
Receive your data in a structured, commonly used format
Correction and Deletion
• Rectification: Correct inaccurate or incomplete personal data
• Erasure:
Request deletion of your personal data (subject to legal obligations)
Processing Controls
• Restriction: Limit how we process your personal data in certain circumstances
• Objection: Object to processing based on legitimate interests or for marketing purposes
Withdraw Consent: Withdraw consent for consent-based processing at any time
Automated Decision-Making
We do not use automated decision-making or profiling that significantly affects you.
To exercise your rights, contact our Data Protection Officer using the details below.
Data Security
Technical Measures
• Encryption: Data encrypted in transit using SSL/TLS protocols
• Access Controls:
Role-based access to personal information
• Regular Updates:
Security patches and system updates
• Backup Systems:
Secure data backup and recovery procedures
Organizational Measures
• Staff Training: Regular data protection training for all employees
• Policies and Procedures:
Comprehensive data protection policies
• Third-Party Agreements:
Data processing agreements with all service providers
• Incident Response:
Procedures for detecting and responding to data breaches
Data Breach Notification
In the event of a data breach that poses a risk to your rights and freedoms, we will:
Notify the ICO within 72 hours of becoming aware of the breach
Notify affected individuals without undue delay where required
Take immediate steps to contain and remediate the breach
International Data Transfers
Some of our service providers may be located outside the UK. When we transfer personal data internationally, we ensure appropriate safeguards are in place:
• Adequacy Decisions: Transfers to countries with adequate data protection laws
• Standard Contractual Clauses:
EU/UK Standard Contractual Clauses for other transfers
• Binding Corporate Rules:
Where applicable for multinational service providers
Data Retention
We retain personal data only for as long as necessary for the purposes outlined in this policy:
• Order Information: 6 years for accounting and tax purposes
• Customer Communications:
3 years from last contact
• Marketing Data: Until you unsubscribe or 3 years of inactivity
• CCTV Footage:
30 days unless required for ongoing investigations
• Website Analytics:
26 months in anonymized form
Cookies and Similar Technologies
Essential Cookies
Required for website functionality, including:
Session management
Security features
Basic website operations
Analytics Cookies
With your consent, we use cookies to:
Understand website usage patterns
Improve user experience
Measure marketing effectiveness
Marketing Cookies
With your consent, we may use cookies for:
• Personalized advertising
• Social media integration
• Remarketing campaigns
You can manage your cookie preferences through our cookie banner or browser settings.
Children's Privacy
We do not knowingly collect personal information from children under 16 years of age without parental consent. If we discover that we have collected information from a child under 16 without verification of parental consent, we will delete such information immediately.
Changes to This Privacy Policy
We may update this Privacy Policy to reflect changes in our practices or legal requirements. When we make significant changes, we will:
• Post the updated policy on our website with a new effective date
• Provide additional notice as required by law
Your continued use of our services after changes take effect constitutes acceptance of the updated policy.
Contact Information and Complaints
Data Protection Officer & General Data Protection Enquiries
Post: Data Protection Officer
Kulcha Express Global Ltd
398 Farnham Road
Slough, SL2 1JD
United Kingdom
Specific Information for Different Data Subjects
Restaurant Customers
When you visit our restaurants, we may collect information through CCTV for security purposes and your order information if you provide contact details for bookings or feedback.
Website Visitors
We collect limited information through cookies and website analytics to improve your browsing experience and understand how our website is used.
Delivery Customers
When you order through UberEats, Deliveroo, or JustEat, these platforms share necessary order and contact information with us to fulfill your order.
Newsletter Subscribers
If you subscribe to our newsletter, we will only use your email address to send you updates about our services and special offers. You can unsubscribe at any time.
This Privacy Policy is designed to be transparent about our data practices. If you have any questions or need clarification, please contact our Data Protection Officer.