Data Protection Policy for the VAPIANO PEOPLE Programme

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1 Data Protection Policy for the VAPIANO PEOPLE Programme Effective on: 9 May 2016 The protection of your data is important to us. Therefore, we would like to inform you comprehensively and clearly about the processing of your data in connection with the VAPIANO PEOPLE Programme. 1. Data Controller Personal data in connection with participants of the VAPIANO PEOPLE loyalty programme will be collected, processed and used by Kurt- Schumacher-Str. 22, Bonn, Germany (hereinafter: Vapiano or We ). 2. Purpose of the collection, processing and use of personal data Unless otherwise indicated, Vapiano collects, processes or uses your personal data which you have provided via the Vapiano website, via Vapiano App or in handwritten registration form for the following purposes: to process your registration for the VAPIANO PEOPLE Programme and to generate a respective customer account, to enable you to participate in the VAPIANO PEOPLE Programme in all participating restaurants worldwide, to give you access to your customer profile on the website and to the offers which you may find there, to send you an for your birthday with a birthday gift, for anonymised, internal, statistical market research purposes in order to help us improve our response to your individual needs, to contact you in the event of questions in connection with your VAPIANO PEOPLE customer account, to inform you via about changes to this Data Protection Policy, changes to the General Terms and Conditions, or organisational changes to your VAPIANO PEOPLE membership, to identify you at the checkout during visits to a restaurant, to provide you with further information, in the event that you have explicitly asked Vapiano for the respective information, for the Vapiano Finder in the Vapiano app, in order to find the closest Vapiano restaurant, for the provision of the payment function, as soon as this is available and which we are unable to offer in all participating countries, to send you our newsletter, where you have requested it,

2 to inform you about vouchers, forthcoming promotions or special offers from Vapiano, where you have separately agreed to this, to notify you of the organisation of competitions in connection with VAPIANO PEOPLE and prizes, to allow points to be recorded later in the restaurant for other legally permitted purposes 3. Category of data collected, processed and used by Vapiano 3.1 Provision of your customer account Vapiano may collect, process and use the following personal information in order to provide you with your customer account after your application: name, address, date of birth, address, your VAPIANO PEOPLE membership number, password. 3.2 Identification at the checkout When using the VAPIANO PEOPLE card or the Vapiano app during a restaurant visit, we may collect, process or use the following data for purposes of identification at the checkout, to ensure that you are the owner of the card or an authorised participant: First name, surname date of birth. 3.3 Collection of reward points and status points When you collect PEOPLE Points or status points, we collect, process and use the following data via the participating VAPIANO restaurants for internal, statistical purposes: date and time of your visit, location of the restaurant, total turnover (sold products and foods), total number of visits, reward points redeemed, birthday presents redeemed.

3 3.4 Worldwide use So that you can use the advantages of the VAPIANO PEOPLE Programme and the app in participating restaurants worldwide, Vapiano transmits the following information to participating restaurants and national companies - but only where necessary: First name, surname date of birth, score of points, PEOPLE status, address. 3.5 Vapiano newsletter In the event that you ordered the Vapiano newsletter, the following data will be collected, processed and used by us: name, where you have told us this during registration, address. 3.6 Vapiano Finder When using the Vapiano Finder of the Vapiano App to find the closest Vapiano restaurant, we collect, process and use: your GPS location data, where you have activated this function. 3.7 Mobile payment function When using the mobile payment function via the Vapiano app, as soon as this function is available in the Vapiano app, our payment service provider collects, processes and uses the following data for purposes of handling the payment: name, date of birth, bank details or credit card data. For detailed information please refer to the separate data security provisions, which will be provided during registration for the payment function. 4. VAPIANO PEOPLE Card An anonymised participant number will be stored in the QR code ( Quick Response ) on your VAPIANO PEOPLE Card. Reward Points or status points and personal data provided by you, will be stored in the system only. This way, in the event of loss of the VAPIANO PEOPLE Card, none of your personal data will be lost or be made available to third parties.

4 5. VAPIANO App Vapiano makes a mobile app available. The app allows you to order in the restaurant, learn about our products, use the mobile payment function, as soon as this is available, or identify yourself at the checkout of participating Vapiano restaurants as a VAPIANO PEOPLE member using the QR code in this app, and use all functions of the VAPIANO PEOPLE programme without needing to use a VAPIANO PEOPLE card. 5.1 Data processing during use of the app: Vapiano Finder This app allows you to find the closest Vapiano restaurant via the Vapiano Finder. For this purpose we either need your GPS location data, or you can insert your current location data into the app. If you have activated the location functions on your mobile, Vapiano will collect and use your GPS data exclusively for purposes of locating the closest Vapiano restaurants. No movement-tracking profile will be prepared from this data. Use in the restaurant So that you can benefit from the advantages of the VAPIANO PEOPLE programme even in the event of a technical problem or limited battery life, we save your first name and your VAPIANO PEOPLE number for the duration of your visit to a restaurant, and display it in the checkout system. In this manner, it remains possible to correlate the data with you and your VAPIANO PEOPLE account, even in unforeseen circumstances. If you have chosen to use the VAPIANO PEOPLE app, you will agree to the following declarations of consent: By registering for the VAPIANO PEOPLE app, you agree to the creation of a personal user profile by Vapiano. To this end, Vapiano correlates the registration data from the app or the VAPIANO PEOPLE website with the use and transaction data generated in the Vapiano restaurants. If you log into the Vapiano app in one of the participating Vapiano restaurants, Vapiano will collect usage data (e.g. meal and drink orders, saved favourites, duration of visit in the restaurant). This data collection allows reward and status points to be credited, and serves purposes of market research in order to further improve our products and services, and on the other hand where you have separately requested this to send you advertising customised to your personal interests (e.g. information about products or promotions in the Vapiano restaurants) via , SMS or Push message. You will thus receive information that is relevant to you based on your previous restaurant visits. Saving login data When using the VAPIANO PEOPLE app, you have the option of staying permanently logged in. To this end, Vapiano or its authorised service providers use cookies and other similar

5 technologies in order to offer you a faster and better user experience. For this purpose, your access data, consisting of the address and password, will be saved so that you do not need to enter them again every time you open the VAPIANO PEOPLE app. 5.3 Withdrawal of consent By using the VAPIANO PEOPLE app, you consent to the use of your data described under section 5 of this Data Protection Policy. You can withdraw this consent at any time with effect for the future resulting in a termination of your membership in the VAPIANO PEOPLE programme. For details please refer to section 9: Termination of participation in the VAPIANO PEOPLE programme. Withdrawal of consent should be sent to: Kurt-Schumacher-Str. 22, Bonn, Germany. people-support@vapiano.de Phone: +49 (0) Newsletter On our website, you have the option to sign up for our free newsletter. The newsletter informs you about current offers, exciting specials and news from the world of Vapiano. We require your address for this subscription. You can tell us your name, but this is not essential. If you tell us your name, we will use it to address you personally. After sending the registration form, you will receive a confirmation from us. The registration only becomes effective when you have clicked on the link in the confirmation . You can unsubscribe from the newsletter at any time. To do this, use the unsubscribe function on our website, or the unsubscribe link at the end of each . Your address will then immediately be deleted from the distribution system. If you have subscribed to the newsletter, you will agree to the following declaration of consent for this: I agree to receive advertising from Vapiano in the form of newsletters. By subscribing to the newsletter, I consent to you analysing and processing my usage data (e.g. clicking links) in order to continuously improve your service, and in order to create newsletters customised according to my interests.

6 You can withdraw your consent to the analysis of your usage data at any time. We treat your data as strictly confidential and do not disclose it to third parties. Withdrawal of consent should be sent to: Kurt-Schumacher-Str. 22, Bonn,Germany. Phone: +49 (0) Marketing When you have granted your consent to marketing, Vapiano can send you advertising via , when using the app or Vapiano Website and, - depending on the means of communication you have selected- in other services (e. G. SMS/MMS, Push or in-app messages),- which is based on your individual interests, and which Vapiano selects on the basis of the following data: Your basic data, any voluntary specifications, and the data generated during your use of the PEOPLE membership card or the PEOPLE app. We record which links in the newsletter are clicked, and which products you are interested in. This enables us to send you customised newsletters. You can withdraw your consent to the analysis of your usage data at any time. We treat your data as strictly confidential and do not disclose it to third parties. You can withdraw these consents at any time, independently on one another, and with effect for the future. Withdrawal of consent should be sent to: Kurt-Schumacher-Str. 22, Bonn, Germany. OR via people-support@vapiano.de Phone: +49 (0)

7 8. Scope of the data disclosure Vapiano does not use the data for commercial purposes. The disclosure of your personal data to third parties takes place only with your permission, and within the scope described in the following. 8.1 Use of service providers Vapiano uses service providers in Germany and in the EU in order to realise the VAPIANO PEOPLE programme. The service providers will process the data exclusively according to the instructions of Vapiano and have been placed under an obligation to comply with the applicable data protection provisions. Vapiano and its assigned service providers will take reasonable technical and organisational precautions to protect the data of the participants. 8.2 Disclosure to other third parties Vapiano will otherwise not disclose your personal data to any third parties, unless we are obliged to do so by legal regulations (e.g. disclosure to courts or law enforcement authorities), unless you have given us your explicit consent, or unless the disclosure is permitted by law. Vapiano will not disclose a participant's data to address brokers or to other companies for advertising purposes. 8.3 Disclosure to participating Vapiano restaurants and Vapiano companies in Germany and in other countries The VAPIANO PEOPLE programme is fundamentally designed to enable its participants to use the VAPIANO PEOPLE card and the benefits of the programme in all participating countries. If you have signed up for the VAPIANO PEOPLE programme, you will agree to the following declaration of consent for this: I agree to Vapiano using the personal data defined under section 3.4 for the purposes defined in section 2, and transferring these data to the restaurants and national companies worldwide, who are participating in the VAPIANO PEOPLE programme. You can withdraw this consent at any time with effect for the future. Withdrawal of consent should be sent to: Kurt-Schumacher-Str. 22, Bonn, Germany. people-support@vapiano.de Phone: +49 (0) As soon as you withdraw your consent to the data processing under section 8.3, your participation in the VAPIANO PEOPLE programme will also be terminated. Upon termination of your participation, your customer data will be completely anonymised, with the exception of the data subject to statutory archiving periods.

8 9. Termination of the participation in the VAPIANO PEOPLE programme You may terminate your membership with the VAPIANO PEOPLE programme at any time. Upon termination of your participation, your customer data will be completely anonymised, with the exception of the data subject to statutory archiving periods. 10. Your rights as a VAPIANO PEOPLE member As a VAPIANO PEOPLE member, you have the right to request information regarding what data about you have been saved with us, and for what purpose they have been saved. Furthermore, you can correct inaccurate data, or request the deletion of data which it is either inadmissible to save or no longer required. In order to assert your rights, please contact the address specified in section 12 in writing or via Modification of VAPIANO PEOPLE Data Protection Policy We retain the right to modify this Data Protection Policy at regular intervals according to the underlying data processing procedures. When we make changes to this VAPIANO PEOPLE data protection policy, we will inform you via our website, via app or via Questions, suggestions, comments We are happy to answer your questions and receive your suggestions and comments regarding this Data Protection Policy for the VAPIANO PEOPLE programme. You can contact Vapiano on our website under CONTACT US or via at peoplesupport@vapiano.de, via phone (+49 (0) ): Kurt-Schumacher-Str. 22, Bonn, Germany. * * *

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