Processing Personal Data on Behalf of Businesses (Mosey as Processor): When Mosey acts as a Data Processor, we process Personal Data strictly on the documented instructions of the respective Business (Data Controller). We do not use this data for our own independent purposes (such as our own marketing or service improvement) unless explicitly agreed with the Business in the Data Processing Addendum or required by law.

Create and Sell Anonymised Market Intelligence Reports

Purpose: To generate revenue that keeps the Platform free for users, and to provide valuable market insights to businesses planning food service investments.

Legal Basis: Legitimate Interests - Our legitimate interest in generating revenue to maintain a free Platform, and third parties' legitimate interest in understanding market trends for business planning. Data is fully anonymised with no individual identification possible.

Information Used: Anonymised and aggregated search data, location data, cuisine preferences, and usage patterns.

Your Rights: You can object to this processing, though data anonymisation means your individual data cannot be identified in reports. You can opt-out of future anonymous data collection via Settings > Privacy > Analytics Preferences.

6.2. Contractual Necessity

If you have the legal capacity to enter into an enforceable contract, we use Information You Provide, Automatically Collected Information, and Information From Other Sources where it is necessary to perform the contract you enter into (our Terms) when you register for, access, or use the Platform. This means we use your information to:

• Provide you with the Platform. We use your information to allow you to access and use the Platform, including allowing you to create and consume content, interact with Businesses, create bookings, find businesses and provide you with services you purchase. We also personalise certain features and content on the Platform, such as showing you your next plans, or suggestions that we think you would be interested in.

• Product orders. We use your information to process things like bookings, vouchers, events  and communicate with you about those bookings. This includes sharing Purchase Information with Merchants, Payment and Transaction Fulfilment Providers, and Other Service Providers.

• Enforce our Terms, Guidelines, or policies. We use your information to enforce our Terms, Guidelines, and policies (including through automated means and human moderation). This may include removing content or suspending or banning your account if we determine that you are violating our Terms or Guidelines.

• Administer the Platform. We also use the information we have to administer the Platform, such as to communicate with you on service related matters, provide you with updates and support regarding any purchase you make on or through the Platform, and respond to and process your queries, claims or disputes (including when you tell us about a problem, or ask for a copy of your information).

Your Rights: Whenever we use your information on the basis that it is necessary for the contract we have with you, you have the right to port information you have provided to us.

6.3. Legitimate Interests

We use your information where this is necessary to achieve legitimate interests - whether belonging to us, you, or a third party - provided these interests are not outweighed by your interests or fundamental rights and freedoms. We use the information we collect to:
 

• Enable users to create content with interactive features:

  • Legitimate Interest relied upon: To provide users with tools to inspire creativity, collaboration, and enjoyment, and to create opportunities for users to reach new audiences.

  • Information used: Information You Provide and Automatically Collected Information.

 

• Suggest your account to other users. We may suggest your account to other users, including when a user chooses to sync their contacts with the Platform.

  • Legitimate Interest relied upon: To enable users to quickly and efficiently find and connect with other users.

  • Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

 

• Provide all users with non-personalised advertising. We show all users non-personalised advertising, including those who have chosen not to receive personalised ads.

  • Legitimate Interest relied upon: We show non-personalised ads such as sponsored posts to keep the Platform free of charge. We process limited categories of your information to make sure our advertising service is useful to our hosted Businesses.

  • Information used: Information You Provide and Automatically Collected Information.

 

• Provide measurement and analytics services. We help advertisers measure the effectiveness and distribution of ads and other content viewed on the Platform.

  • Legitimate Interest relied upon: To enable creators and advertisers to view and understand how their ads or content performed and the audience that viewed or interacted with their ads or content. This is so that they can make informed decisions (such as what kinds of ad campaigns they may want to run, the type of audience they want to reach and the types of content that users enjoy the most). This helps keep the advertising and other content we show users relevant and entertaining, and keeps the Platform free for all users.

  • Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

 

• Ensure the safety and well-being of our community. We use your information to ensure the safety and well-being of our community, including by reviewing User Content (and if permitted under applicable law, Direct Messages and associated metadata) for breaches of our Terms, Guidelines, and other policies. We also infer your age range, and under certain circumstances, may ask you to provide additional information to confirm your age.

  • Legitimate Interest relied upon: To keep our community safe, review compliance with our Guidelines, and identify misuse of the Platform.

  • Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

 

• Ensure the security and stability of the Platform. We use your information to ensure the stability and security of the Platform, including by identifying and combating technical or security issues (such as technical bugs, spam accounts, and detecting abuse, fraud, and illegal activity).

  • Legitimate Interest relied upon: To ensure the ongoing stability and security of the Platform and to ensure it is continuously available and functioning.

  • Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

 

• Review, improve, promote, and develop the Platform. We use the information we have to understand how people are using the Platform and to develop, test, and make improvements to the Platform, including to develop and improve our technology, such as our machine learning models and algorithms. We also use this information to better understand and promote the Platform, popular topics, and emerging trends.

  • Legitimate Interest relied upon: To improve, promote, and develop the Platform in an informed way.

  • Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

 

• Facilitate independent research. We share your information with independent researchers to facilitate research that meets certain criteria, including where such researchers have demonstrable experience and expertise in their area.

  • Legitimate Interest relied upon: To facilitate independent research that aims to develop society’s collective knowledge, including in the areas of misinformation and disinformation, violence, cybercrime, and social trends.

  • Information used: Information You Provide, Automatically Collected Information.

 

• Share your information with third parties. We share your information with third parties whose platforms or services are integrated with the Platform.

  • Legitimate Interest relied upon: To provide you with a seamless experience, allow your content to be shared on other platforms, enable third parties to authenticate users, and optimise user experience.

  • Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

 

• Marketing communications. We may send you direct marketing messages about features of the Platform and third-party services that we think will interest you. We may also send you promotions, contests, or marketing campaigns or event information. We will obtain your consent to send you messages where required by law.

  • Legitimate Interest relied upon: To promote the Platform or third party products and services.

  • Information used: Information You Provide, Automatically Collected Information, and Information From Other Sources.

Your Rights: Whenever we use your information on the basis that it is necessary for legitimate interests, you can object to, and request restriction of, such usage.

6.4. Your Consent

We ask for your consent to access or use your information for specific purposes. If we do, you’ll always be able to revoke your consent through your device permissions, in-app settings or by contacting us at gdpr@moseyfoodfinder.com.

Your rights: Whenever we use your information based on your consent, you can withdraw your consent at any time. However, your withdrawal of consent will not affect the lawfulness of processing your information based on your consent prior to your withdrawal of consent. You also have the right to port information you have provided to us that we use based on your consent.

6.5 Age Requirements

Minimum Age Requirements

The Platform is restricted to users who are 18 years of age or older in all jurisdictions where we operate.

Legal Basis: Compliance with our Terms of Service and to ensure appropriate use of our adult-oriented food and beverage marketplace.

Age Verification: We may request age verification information during account creation or at any time to confirm eligibility to use the Platform.

7. Enhanced Consent Mechanisms

7.1 How We Obtain Your Consent

When we require your consent, we will:

Marketing Communications before a purchase:

• Present a clear, separate opt-in checkbox for marketing communications

• Use plain language: "I agree to receive marketing emails about Mosey features and promotions"

• Never use pre-ticked boxes or inactivity as consent

• Provide immediate access to unsubscribe options
   

Marketing Communications after a purchase:

• Use a soft opt-in option to send you marketing communications about similar purchases that may be of interest to you

• Give clear opt-out options and immediate access to unsubscribe from these communications

• Allow you to opt-out of this consent in settings on Mosey

Location Services:

• Request device-level permissions through your operating system

• Explain in-app what location data will be used for

• Allow you to change permissions at any time in device settings

7.2 Withdrawing Consent

You can withdraw your consent at any time by:
 

• Marketing: Clicking unsubscribe in any email or updating preferences in your account settings

• Advertising: Visiting Settings > Privacy > Advertising Preferences in the app

• Location: Disabling location permissions in your Settings. Also in device settings

• General: Emailing gdpr@moseyfoodfinder.com
   

Important: Withdrawing consent will not affect the lawfulness of processing based on consent before its withdrawal.

7.3. Compliance with a Legal Obligation

We may use your information including your Profile Information or User Content where it is necessary to comply with a legal obligation. This includes situations where we have obligations to take measures to ensure the safety of our users, or comply with a valid legal request such as an order or disclosure request from regulators, law enforcement agencies or courts. We generally use Information You Provide and Automatically Collected Information, although it depends on the specific situation.

7.4. To Perform a Task in the Public Interest

We may use your information where it is necessary to perform a task in the public interest, including undertaking research, preventing and detecting crime, safeguarding children and promoting public safety, security, and integrity as laid down by applicable law. We generally use Information You Provide and Automatically Collected Information, although it depends on the specific situation.
Your rights: When we use your information on the basis that it is necessary for a task carried out in the public interest, you have the right to object to, and seek restriction of, our usage.

7.5. To Protect Someone's Vital Interests

We may use your information where it is necessary to protect your or someone else's life, physical integrity, or safety. This could include providing law enforcement agencies or emergency services with information in urgent situations to protect health or life. We generally provide Information You Provide and Automatically Collected Information, although it depends on the specific situation.

7.6 Jurisdiction Specific Rights

United States (California) - CCPA Rights

California residents have additional rights under the California Consumer Privacy Act (CCPA):

Right to Know: You can request information about the personal information we collect, use, disclose, and sell about you.

Right to Delete: You can request deletion of personal information we have collected about you.

Right to Opt-Out: You can opt-out of the sale of your personal information. Note: Our anonymised market reports do not constitute "sale" under CCPA as data cannot identify individuals.

Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

Authorised Agent: You may designate an authorised agent to make requests on your behalf.

Exercise Rights: Email us at gdpr@moseyfoodfinder.com or use our online form.

Australia - Privacy Act Rights

Australian users have rights under the Privacy Act 1988:

Access and Correction: You can request access to your personal information and request corrections to inaccurate information.

Complaints: You can lodge complaints with the Office of the Australian Information Commissioner (OAIC).

Notifiable Data Breaches: We will notify you and the OAIC of eligible data breaches as required by law.

Direct Marketing: You can opt-out of direct marketing communications at any time.

United Kingdom - UK GDPR Rights

UK residents have the same rights as outlined in Section 8, enforced under UK GDPR:

Supervisory Authority: You can lodge complaints with the Information Commissioner's Office (ICO).

• Website: ico.org.uk

• Phone: 0303 123 1113

• Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

 
8. YOUR DATA PROTECTION RIGHTS AND CHOICES

You have rights and choices when it comes to your information. Some of these rights apply generally, while others will only apply in certain circumstances. Depending on the scenario, these rights may be subject to some limitations. Mosey will be responsible for responding to your request within the relevant periods provided by law.

• Access your information. You can ask us, free of charge, to confirm what information we process about you, to provide certain information about the processing, and for a copy of your information.

• Delete your information. You can delete or ask us to delete some or all of your information. In-app controls enable you to:

  • delete the content posted on your profile, such as your User Content and your Profile Information.

  • delete your full account.

• Rectify your information. You can change or ask us to change or correct your information where that information is not accurate. You can change or correct much of your information through the in-app controls and settings (such as your Profile Information).

• Port your information. You have the right to data portability in circumstances where we rely on contractual necessity or consent as our legal basis. This means that you have the right to receive your information in a structured, commonly used, and machine-readable format and to share it with a third party.

• Object to the processing of your information. You also have the right to object to the processing of your information in certain circumstances where you have a legal basis to do so. In submitting an objection request, please provide all relevant information, including the processing activity you are objecting to, why you want to object and how the processing activity affects you, and any additional information that you think will help us review your request. We will stop the particular processing if we don't have compelling legitimate grounds to continue that processing or don’t need it for legal claims.

• Restrict the processing of your information. You have the right to request the restriction of the processing of your information where (a) you are challenging the accuracy of the information, (b) the information has been unlawfully processed, but you are opposing the deletion of that information, (c) where you need the information to be retained for the pursuit or defence of a legal claim, or (d) you have objected to processing and you are awaiting the outcome of that objection request.
   

Market Research Opt-Out

While our market intelligence reports contain no identifying information about you, you can opt-out of having your anonymised usage patterns included in commercial reports by:

• Visiting Settings > Privacy > Analytics Preferences in the app

• Emailing gdpr@moseyfoodfinder.com

• Using our online opt-out form
   

Important: This opt-out applies to future data collection for reports. Previously collected anonymised data cannot be removed from existing reports as it cannot be identified as relating to you.

To exercise any of these rights, please contact us at gdpr@moseyfoodfinder.com. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details or provide additional information so that we can understand your request.

In certain circumstances, and in accordance with applicable law, we may charge a reasonable fee or refuse to act on a request if it is manifestly unfounded or excessive.

We encourage you to “Contact us” if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the Irish Data Protection Commission (Mosey’s lead supervisory authority).

In addition to these rights, you can control privacy settings for your account.

9. Enhanced Rights Exercise Process

9.1 How to Exercise Your Rights

Online Portal (preferred method):

1. Log into your Mosey account

2. Visit Settings > Contact Us > GDPR

3. Tell us the right you wish to exercise

4. Submit your request
    

Email Requests:

• Send requests to: gdpr@moseyfoodfinder.com

• Include: Full name, account email, specific right being exercised, and verification information

• We will respond within 30 days (may extend to 60 days for complex requests)

Postal Requests: Mosey Limited - Data Protection Officer, 77 Camden Street Lower, Dublin 2, D02 XE80, Ireland

9.2 Identity Verification Process

To protect your privacy, we may request:

• Account password verification

• Government-issued ID (for deletion requests)

• Answers to account security questions

• Recent account activity confirmation

9.3 Response Timeframes
 

• Standard Requests: 30 days from receipt

• Complex Requests: Up to 60 days (we will notify you of any extension)

• Urgent Safety Requests: Within 72 hours where possible

9.4 Free Exercise of Rights

• No Fees: Exercising your data protection rights is free of charge

• Manifestly Unfounded Requests: We may charge a reasonable fee for clearly excessive or repetitive requests

• Fee Explanation: We will always explain any fees before processing paid requests

9.5. Data Processed by Businesses

When Businesses process your data through our Platform (such as for delivery, notifications, or CRM), you have rights in relation to that data:

1. Direct Contact: For data processed by Businesses (delivery information, marketing preferences, reservation details), contact the Business directly to exercise your rights.

2. Business Responsibility: The Business, not Mosey, is responsible for responding to your data rights requests for data they control.

3. Mosey Assistance: If you cannot reach a Business or they fail to respond within reasonable timeframes, contact us at gdpr@moseyfoodfinder.com and we will attempt to facilitate resolution.

4. Technical Deletion: If you delete your Mosey account, we will notify relevant Businesses, but they may retain data according to their own retention policies and legal obligations.

10. Automated Decision-Making and Profiling

10.1 Automated Decisions We Make

We use automated systems for:

Content Moderation:

• Automated detection of prohibited content (spam, harassment, inappropriate material) that violates its Content Guidelines and may be violent, graphic, political, nude, discriminatory, or hateful (for a full list of prohibited content, please view our content guidelines). The automated system will remove the post or content from the public view to be assessed by our Content Moderators. For a full explanation of our content moderation systems, please visit our content guidelines.

• Account restrictions or content removal based on algorithm assessment

• Human Review Available: You can request human review of any automated content decision

Personalised Content:

• Algorithm-based recommendations for restaurants and content

• Customized "Discover" feed based on your activity and preferences

• Opt-Out Available: You can disable personalized recommendations in Settings > Content Preferences

Fraud Detection:

• Automated assessment of payment and booking transactions for fraud risk

• Account security monitoring for suspicious activity

• Human Review: All fraud blocks are reviewed by human analysts within 24 hours

10.2 Your Rights Regarding Automated Decisions

You have the right to:

• Not be subject to decisions based solely on automated processing that significantly affect you, such as post removal, account suspension or account termination

• Request human intervention in any automated decision

• Express your point of view regarding automated decisions

• Contest automated decisions that affect you

Exercise These Rights: Contact gdpr@moseyfoodfinder.com or use the automated decision review form in your account settings.
 
 
11. DATA SECURITY AND RETENTION

Security of your information is important to us. We maintain appropriate technical, administrative, and physical security measures that are designed to protect your information from unauthorised access, theft, disclosure, modification, or loss. We regularly review our security measures to consider available new technology and methods but no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to protect your Personal Data, we cannot guarantee its absolute security.

We retain information for as long as necessary to provide the Platform and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Platform, and enhancing its safety, security and stability), and for the exercise or defence of legal claims.

The retention periods will be different depending on the type of information and the purposes for which we use the information. For example, when we process your information to provide you with the Platform, we keep this information for as long as you have an account. This information includes your Profile Information, User Content, and Direct Messages. If you violate our Guidelines or Terms, we may remove your Profile Information and/or User Content from public view immediately but keep your information as is necessary to process the violation.

11.1 Retention Schedule