Privacy Notice for Manna App & Delivery Service
Last updated: March, 2024
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 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 not be able to provide the service to you in accordance with the contract with you. 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, 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 to 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.
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 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 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 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 Subject to Contract.
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.
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, diagnostic, debugging and aggregate metrics including analytics to monitor service performance, reliability and efficiency so we can optimise service quality. To test out new features to see if they work, undertake experimentation to evaluate the impact of new features and track adoption metrics. We collect and aggregate activity and system events to understand breakdowns 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.
How (Legal Basis): It is necessary to process this personal data to provide customer service to you. The legal basis for this processing is Subject to Contract. The legal basis for processing Location Information is Consent Article 6(1)(a)
1.9. Research
Why: You may decide to enrol in one of our Research Programs. Specific information on the program will be provided on the enrolment screen.
Data We Process: We collect data from users’ mobile devices including location data if you enable us to do so (See “Your App, Your Choice” below for information on how you can enable/disable location data collection)
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.
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.
the length of time we have an ongoing relationship and/or provide our services,
whether there is a legal requirement to which we are subject; and
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.
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.
We do not sell your personal data.
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 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.
