Privacy Policy
Who We Are
ABCS SOLUTIONS LIMITED, incorporated in Scotland (Company Number SC697188) whose registered office is at Flour Mill Dundee, 34, Commercial Street, Dundee, Angus, Scotland, DD1 3EJ (“ABCS”, “We”, “Us”, “Our”).
Data Protection Team: [email protected]
We take privacy of customers and end users seriously. This document sets out how we collect and use personal data.
Customers are required to read and accept the terms of this privacy notice as a condition of using Our services.
1. Definitions and Interpretation
In this Notice, the following terms shall have the following meanings:
- “Customer Account” means an account required to access and/or use Services.
- “Data Protection Legislation” means the Privacy and Electronic Communications Regulation (PECR), the UK GDPR (General Data Protection Regulations), Data Protection Act 2018 and Data (Use and Access) Act 2025 and all other legislation applicable to the United Kingdom relating to the protection of personal data and information.
- “Services” means the BookGusto platform and other services made available by Us from time to time.
The terms “Personal Data”; “Data Subject”; “Data Controller”; “Data Processor”, and “Processing” have the meaning given in the Data Protection Legislation.
2. What Data Do We Collect?
We may collect the following type of Personal Data:
- name;
- business name;
- title;
- contact information such as email addresses and telephone numbers;
- postal address;
- billing and shipping addresses;
- login credentials such as usernames and passwords;
- IP address;
- device identifiers such as device ID, browser type, and operating system;
- order history and transaction records;
- dietary preferences or allergy information; and
- customer support communications such as emails, chat logs, and call recordings.
3. What do We Use Your Personal Data For?
All Personal Data is held and Processed securely in accordance with our data retention periods set out in this Notice.
Details of how we Process your Personal Data and the lawful basis we have for doing so are set out in the table below:
| Activity | Lawful Basis |
|---|---|
| Providing you with the Services and a Customer Account | Contract performance |
| Personalising and tailoring Our Services for you | Contract performance |
| Communicating with you by email | Contract performance (services) Consent (marketing) |
| Analysing performance of Services and identifying improvements | Contract performance |
| Direct marketing via email and/or text message | Consent (if applicable) |
| Direct marketing via telephone and post | Legitimate Interests |
| Retention post-termination of Services to enable reactivation of Services if required (for up to 6 months) | Legitimate Interests |
4. How Long Do We Use Your Personal Data For?
We do not keep Personal Data for any longer than is necessary in light of the reason(s) for which it was first collected.
We retain Personal Data associated with Customer Accounts for so long as a contract to access the Services is in place and for an ongoing period of up to 6 months.
5. How Do We Store Your Data?
We store your Personal Data in the United Kingdom in data centres operated by our host provider (https://www.fasthosts.co.uk/).
We may transfer some of your Personal Data outside of the EEA (European Economic Area). We will only do that if we have an appropriate safeguards in place to ensure that your Personal Data is treated as safely and securely as it would be within the EEA and under the Data Protection Legislation.
6. Do We Share Your Personal Data?
We may sometimes contract with third parties to supply some of the Services to you on Our behalf, for example support and maintenance for the Services. In some cases, the third parties may require access to some or all of your Personal Data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your Personal Data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
We may aggregate data to prepare statistics regarding the use of the Services including user activities, user activities, analytics, system performance, usage patterns and other matters. Where we do this we shall remove all personally identifiable information so that any such data is anonymised. We may share this data with others including potential suppliers, commercial partners, investors and advisers.
We work with the following sub processors:
- Fasthosts – provider of hosting services at its UK data centres.
- Yodeck – Cloud-based digital signage platform used to manage and schedule TV displays in venues, including menus, promotions and announcements.
- Freshpay – Payroll management service used to process staff wages, manage employee records, and handle tax and compliance reporting.
- 2GoToCreative – Commercial printing company used to produce physical materials such as menus, signage, promotional posters, and branded stationery.
- Sentry – Application monitoring and error tracking service used to identify, diagnose, and fix software issues in real time.
- Cookiebot by Usercentrics – Cookie management platform for helping our services stay GDPR compliant.
We may share your Personal Data where legally compelled to do so: e.g. where subject to applicable regulatory requirements or a court order.
If we sell Our business or part of it, any of your Personal Data which is relevant to the sold business will be transferred and may be used by the new operator of the business in the ways described in this Notice. We will let you know if this happens.
7. Your Rights
As set out in the Data Protection Legislation, you have a number of rights you can exercise over Personal Data. You have the rights:
- to ask Us not to use your Personal Data for direct marketing;
- to ask Us not to process your Personal Data where it is processed based on legitimate interests if there are no compelling reasons for that processing;
- to access Personal Data held about you;
- to ask that We correct any Personal Data we hold about if it is inaccurate or incomplete;
- to ask that We stop any consent-based processing of your Personal Data if you withdraw that consent;
- to ask, in certain circumstances, that We delete your Personal Data and/or restrict processing of Personal Data; and
- to ask, in certain circumstances, for portability of Personal Data.
If you have any cause for complaint about Our use of personal data, please contact Us using the contact details set out above. If we do not resolve your complaint, you also have a right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office details of which can be found here: https://ico.org.uk/
8. Our Use of Cookies
We use a cookie management platform (Cookiebot by Usercentrics) for you to express preferences as to the use of cookies. The Services may not function correctly if you change certain preferences, such as disabling all cookies.
9. Updates to Our Privacy Notice
This Privacy Notice is subject to change from time to time to reflect ongoing legal, operational and business changes. If We update this Notice, we will publish the updated Notice prior to it coming into effect. You will be deemed to have accepted the updated Privacy Notice if you continue to use the Services after it takes effect. You should check the terms of this Notice on a regular basis.