Privacy Policy

Effective Date: November 5, 2025
Last Updated: November 5, 2025
Version: 1.0


Introduction

JEGantic Hospitality (“JEGantic,” “we,” “us,” or “our”) is committed to protecting your privacy and ensuring you have a positive experience on our mobile application, website, and related services (collectively, the “Service”).

This Privacy Policy explains:

  • What personal information we collect
  • How we use and protect your information
  • Your rights regarding your data
  • How we share information with third parties
  • How to contact us about privacy concerns

This Privacy Policy is separate from our Terms and Conditions. Please read both documents to understand your rights and our obligations.

Important: If there is a conflict between this Privacy Policy and our Terms and Conditions, this Privacy Policy governs data handling and privacy practices.


1. Data We Collect

1.1 Information You Provide Directly

We collect personally identifiable information that you voluntarily provide, including:

  • Account Information: First name, last name, email address, phone number, date of birth
  • Profile Information: Membership ID, tier status, loyalty points balance, preferences
  • Payment Information: Credit card details, billing address (processed securely by payment processors; we don’t store full card numbers)
  • Communication Information: Messages you send to customer support, feedback submissions, survey responses
  • Reservation Information: Reservation details, guest preferences, special requests
  • Event Information: Event bookings, ticket purchases, attendance history

1.2 Information Collected Automatically

When you use the Service, we automatically collect certain information about your device and usage:

Device Information:

  • Device type, model, and operating system
  • Device identifiers (unique device ID, advertising ID)
  • Mobile network information
  • App version and build number
  • Browser type and version
  • IP address

Usage Information:

  • Pages or features you access
  • Actions you take in the App (viewing rewards, making reservations, redeeming points)
  • Date and time of your activities
  • Time spent on pages or features
  • Clicks, taps, and navigation patterns
  • Search queries
  • Error messages and crash logs

Location Information:

  • Precise GPS location (with your permission)
  • Approximate location based on IP address
  • Location history of your reservations and venue visits

1.3 Information from Third Parties

We may receive information about you from:

Third-Party Services:

  • SevenRooms: Reservation history, spending data, venue preferences
  • Payment Processors: Payment confirmation and transaction details
  • TIXR: Event ticket purchases and attendance information
  • Facebook: Profile information (if you authorize via Facebook login)

Venue Partners:

  • Reservation confirmations
  • Spending records for points calculation
  • Special requests or accommodations notes

Other Sources:

  • Business partners and affiliates
  • Publicly available sources
  • Data brokers (for fraud prevention)

1.4 Information We Do NOT Collect

  • Biometric Data: We do not collect fingerprints, facial recognition, or other biometric identifiers
  • Precise Location Without Permission: We do not collect precise GPS location without your explicit consent
  • Call/Text Records: We do not access your call history or text messages (except general phone number you provide)
  • Medical Information: We do not collect health or medical information
  • Financial Information: We do not store your full credit card number; payment processors handle sensitive financial data

2. How We Use Your Information

2.1 Service Delivery & Account Management

We use your information to:

  • Create and maintain your account
  • Process reservations and transactions
  • Send booking confirmations and reminders
  • Calculate and track loyalty points
  • Process reward redemptions
  • Manage tier status and upgrades
  • Provide customer support
  • Verify your identity and prevent fraud

2.2 Loyalty Program Operation

We use your information to:

  • Track spending for points calculation
  • Apply tier multipliers to earned points
  • Determine reward eligibility
  • Process points-to-cash conversions
  • Send tier upgrade notifications
  • Provide personalized rewards based on your preferences and history

2.3 Communications

We use your information to send:

  • Transactional Messages: Reservation confirmations, point balance updates, reward redemption codes
  • Promotional Messages: Special offers, new rewards, tier-specific benefits (only if you opt in)
  • Service Updates: App updates, feature announcements, policy changes
  • Support Communications: Responses to your inquiries, troubleshooting assistance
  • Notification Preferences: You control which types of messages you receive through in-app settings

2.4 Analytics & Service Improvement

We use aggregated, anonymized information to:

  • Understand how the Service is used
  • Identify usage patterns and trends
  • Improve App functionality, performance, and user experience
  • Test new features
  • Troubleshoot technical issues
  • Optimize rewards and loyalty program mechanics
  • Conduct research and data analysis

Important: Analytics use anonymized data that cannot identify you personally.

2.5 Fraud Prevention & Security

We use your information to:

  • Detect fraudulent or suspicious activity
  • Prevent unauthorized access to accounts
  • Identify and investigate points or rewards fraud
  • Protect against corporate reservation misclassification
  • Monitor for policy violations
  • Comply with legal and regulatory requirements

2.6 SevenRooms Profile Synchronization

We use your information to:

  • Sync your profile with SevenRooms (reservation management platform)
  • Track spending and points across venues
  • Link reservations to your loyalty account
  • Provide integrated reservation and loyalty services
  • Enable seamless venue integration

Scope: Your name, email, phone number, loyalty tier, and points balance are shared with SevenRooms to enable the integrated service experience.

2.7 Marketing & Personalization

We use your information to:

  • Send targeted offers based on your tier and preferences
  • Customize the App experience to your preferences
  • Create marketing campaigns (with your opt-in consent)
  • Conduct surveys and gather feedback
  • Deliver personalized content and recommendations

Your Choice: You can opt out of marketing communications at any time through your notification preferences or by emailing support@jegantic.com.

2.8 Legal Compliance

We use your information to:

  • Comply with applicable laws, regulations, and legal requests
  • Enforce our Terms and Conditions
  • Protect our legal rights and interests
  • Respond to government or regulatory inquiries
  • Maintain records for audit and compliance purposes

3. Legal Basis for Processing (GDPR/PIPEDA Compliance)

We process your personal information based on the following legal bases:

  • Contractual Necessity: Processing necessary to provide the Service and fulfill our obligations under the Terms and Conditions
  • Legitimate Interests: Processing to protect our interests and prevent fraud
  • Your Consent: Processing for marketing and optional features (you can withdraw consent anytime)
  • Legal Obligation: Processing required by law (tax records, fraud prevention, etc.)
  • Public Interest: Processing necessary for public benefit (fraud prevention, security)

4. Cookies & Tracking Technologies

4.1 Cookies

Cookies are small files stored on your device that help us recognize you and deliver a better experience. We use:

  • Essential Cookies: Required for App login, account security, and basic functionality
  • Analytics Cookies: Help us understand how you use the Service
  • Preference Cookies: Remember your notification settings and preferences
  • Marketing Cookies: Track your engagement for personalized offers (with your consent)

4.2 Web Beacons & Device Identifiers

We use:

  • Web Beacons: Tiny tracking pixels to measure engagement and effectiveness
  • Device IDs: Unique identifiers to track App usage and personalize content
  • Advertising IDs: To measure ad effectiveness and prevent duplicate tracking

4.3 Opting Out of Tracking

You can:

  • Disable cookies in your browser settings
  • Use “Do Not Track” browser features (we honor these signals)
  • Opt out of personalized advertising through device settings
  • Disable location tracking in App settings
  • Request that we stop tracking by contacting support@jegantic.com

5. Location Data Collection & Use

5.1 Precise Location Tracking

With your permission, we collect precise GPS location data to:

  • Show nearby venues on a map
  • Provide location-based recommendations
  • Track check-ins for points accuracy
  • Enable location-based notifications

Obtaining Consent: When you first use location-dependent features, the App will request permission. You can revoke location permission at any time through device settings.

5.2 Anonymous Location Data

We collect and analyze aggregated, anonymized location data (that cannot identify you personally) to:

  • Understand which venues are popular
  • Identify traffic patterns and peak times
  • Improve venue recommendations
  • Optimize service delivery

5.3 Location Data Sharing

  • With Venues: Your precise location may be shared with venues to confirm check-in and validate points
  • With Analytics Partners: Aggregated location patterns are shared to help us understand Service usage
  • With Marketing Partners: Anonymous location data may be used for targeted offers (never revealing your identity)

6. Access, Correction & Deletion of Your Data

6.1 Access Your Personal Data

You have the right to view your personal data:

  1. Log into your account in the App
  2. Navigate to Profile or Settings
  3. View your stored information:
    • Personal details (name, email, phone)
    • Membership ID
    • Loyalty points and tier status
    • Reservation history
    • Redemption history

6.2 Correct Inaccurate Data

You can update your personal information:

  1. Log into your account
  2. Navigate to Profile Settings
  3. Edit any inaccurate information
  4. Save changes

If you need help correcting data, contact support@jegantic.com with details of the correction needed.

6.3 Delete Your Personal Data

You have the right to request deletion of your personal data:

Automatic Deletion:

  • Account deletion will remove your profile, contact information, and notification preferences
  • Some data may be retained in anonymized form for analytics (cannot identify you)

Manual Deletion Request:

  1. Email support@jegantic.com with subject “Data Deletion Request”
  2. Include your Membership ID and email address
  3. Specify what data you want deleted (all data or specific categories)
  4. We will process your request within 30 days

Limitations on Deletion:

  • We may retain data if required by law (tax records, fraud investigation, etc.)
  • Aggregate analytics data cannot be deleted (it’s already anonymized)
  • We may retain transaction history for accounting and audit purposes
  • Loyalty points earned through the Program cannot be “deleted” (they represent past transactions)

6.4 Data Retention Policy

Data Type Retention Period Reason
Account Information Duration of account + 2 years Legal/tax compliance
Transaction History 7 years Accounting, fraud investigation
Loyalty Points & Redemptions Duration of account (permanent record) Program integrity, dispute resolution
Marketing Preferences Until changed or account deleted Respecting user choices
Device/IP Logs 90 days Security, troubleshooting
Precise Location Data 30 days (anonymized thereafter) Service improvement
Support Communications 3 years Service quality, dispute resolution
Cookies & Tracking Data Duration of browser session or until cleared Website functionality

7. Data Sharing & Third Parties

7.1 Service Providers & Vendors

We share your personal information with vendors and service providers who assist us in delivering the Service. These include:

Essential Partners:

  • SevenRooms: Reservation management and venue integration
  • TIXR: Event ticketing platform
  • Payment Processors: Credit card processing and transaction management (Stripe, Square, etc.)
  • Cloud Hosting Providers: AWS, Google Cloud (for data storage and security)
  • Customer Support Tools: Zendesk, Intercom (for support interactions)

Analytics & Data Partners:

  • Firebase Analytics: App usage and crash reporting
  • Sentry: Error tracking and debugging
  • MixPanel, Amplitude: User behavior analytics

Advertising Partners:

  • Facebook Pixel: Conversion tracking for ads
  • Google Analytics: Website traffic analysis
  • Ad Networks: For targeted advertising (with your consent)

Security Partners:

  • Fraud Detection Services: Third-party tools to detect suspicious activity
  • Identity Verification Services: Background check and age verification providers

All vendors are contractually required to:

  • Keep your information confidential
  • Use data only for specified purposes
  • Implement reasonable security measures
  • Comply with applicable privacy laws

7.2 Data Sharing Limitations

What We Do NOT Share:

  • We do NOT sell your personal information to data brokers or marketing companies
  • We do NOT share full credit card numbers or sensitive financial data
  • We do NOT share your location data with venues for marketing purposes
  • We do NOT allow vendors to use your data for their own marketing

Mobile & Text Messaging Data:

  • No Mobile Marketing Sharing: Mobile information is NOT shared with third parties for marketing or promotional purposes
  • No Text Message Sharing: Text messaging opt-in data and consent are NOT shared with any third parties
  • Call Records: We do not share your phone call or message history

7.3 Business Transfers

If JEGantic is involved in a merger, acquisition, bankruptcy, dissolution, or sale of assets, your personal information may be transferred as part of that transaction. We will notify you via email and the App of any such change and any choices you may have regarding your personal information.

7.4 Legal Compelled Disclosure

We may disclose your information when required by law or in response to:

  • Court orders, subpoenas, or government requests
  • Legal investigations or law enforcement
  • Regulatory compliance (tax authorities, privacy regulators, etc.)
  • To protect the safety, rights, or property of JEGantic, users, or the public

We will attempt to notify you of legal requests unless prohibited by law.

7.5 Aggregated & Anonymized Data

We freely share aggregated, anonymized data (that cannot identify you) with:

  • Research organizations
  • Business partners
  • Marketing partners
  • Industry analysts

Examples of aggregated data:

  • “20% of Gold tier members redeem rewards monthly”
  • “Average spending per reservation is $150”
  • “Peak reservation times are Friday-Saturday evenings”

8. Ad Tracking & Personalized Advertising

8.1 How Ad Companies Use Your Data

Ad companies and ad networks may:

  • Collect anonymous data about your interests
  • Track your interactions with ads and the Service
  • Link interest data to your device (but NOT to your identity)
  • Use this data to customize advertising on the Service and other websites/apps

8.2 Your Advertising Choices

You can:

  1. Opt Out of Personalized Ads:
    • iOS: Settings → Privacy → Apple Advertising → Limit Ad Tracking
    • Android: Settings → Google → Manage Your Google Account → Data & Privacy → Ad Personalization → Turn Off
  2. Opt Out of Specific Ad Networks: Visit www.networkadvertising.org or www.youradchoices.com
  3. Block All Third-Party Cookies: Adjust browser or device settings
  4. Opt Out in the App: Navigate to Settings → Advertising and disable personalized advertising

Important: Even if you opt out of personalized ads, you will still see advertising—it just won’t be tailored to your interests.

8.3 Data Not Linked to Your Identity

Interest and location data used for advertising is NOT linked to your personal identity. Advertisers cannot see your name, email, or account information—only aggregated interest categories and anonymous device IDs.


9. Data Security

9.1 Security Measures We Implement

JEGantic takes data security seriously and implements:

  • Encryption: Data transmitted to/from our servers uses SSL/TLS encryption (HTTPS)
  • Secure Servers: All data stored on secure, access-controlled servers with firewalls
  • Password Protection: Your account is protected by a strong password you create
  • Access Controls: Only authorized employees have access to personal data
  • Multi-Factor Authentication: Available for additional account security
  • Regular Security Audits: Third-party security assessments and penetration testing
  • Incident Response: Immediate response to suspected data breaches
  • Vendor Security Requirements: All vendors must maintain security standards

9.2 Limitations & Disclaimers

We Cannot Guarantee 100% Security:

  • No system is completely immune to cyberattacks
  • Data breaches, while rare, can occur despite security measures
  • User password compromise is your responsibility

Your Responsibility:

  • Keep your password private and secure
  • Do not share your account credentials
  • Log out after using shared devices
  • Report suspected unauthorized access immediately

No Liability for User-Compromised Data:

  • If your account is compromised due to password negligence, JEGantic is not liable
  • We will assist in account recovery and will investigate potential security issues

10. International Data Transfers

10.1 Data Storage & Processing Locations

Your personal information may be stored and processed in:

  • Canada (primary location)
  • United States (AWS, Google Cloud, cloud storage)
  • Other Countries (via third-party vendors)

10.2 Privacy Protections for International Transfers

For international transfers, we implement:

  • Standard Contractual Clauses (SCCs) with vendors
  • Binding Data Processing Agreements
  • Vendor privacy certifications (EU-US Privacy Shield, etc.)

10.3 Your Consent

By using the Service, you consent to:

  • Collection and processing of your personal information in Canada and abroad
  • Transfer of your data to countries with potentially different privacy laws
  • Storage on cloud servers located in multiple jurisdictions

11. Children’s Privacy

11.1 Age Requirement

The Service is intended for users 18 years of age or older. We do not knowingly collect personal information from children under 13.

11.2 Parental Consent

If we discover we have collected information from a child under 13:

  1. We will delete the information immediately
  2. We will notify the parent/guardian
  3. We will not use the information for any purpose

If you believe we have collected information from a child under 13, please contact us immediately: privacy@jegantic.com

11.3 Teens (13-17 Years Old)

Users aged 13-17 may create accounts with parental consent. However:

  • Certain features (alcohol-related venues, late-night events) may be restricted
  • Parental notification may be required for account activity
  • Additional safeguards protect teen privacy

12. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

12.1 Right to Know

You have the right to request what personal information we collect, use, and share about you.

12.2 Right to Delete

You have the right to request deletion of personal information we have collected about you (with limited exceptions).

12.3 Right to Opt-Out

You have the right to opt-out of:

  • Sale or sharing of your personal information
  • Targeted advertising based on your data

12.4 Right to Non-Discrimination

We will not discriminate against you for exercising your privacy rights.

12.5 How to Submit a Request

Email: privacy@jegantic.com
Include: Your name, email, and specific request

Response Time: We will respond within 45 days (extendable by 45 days if necessary).


13. EU/GDPR Rights

If you are located in the European Union, you have rights under the General Data Protection Regulation (GDPR):

13.1 Right to Access

You have the right to access your personal data.

13.2 Right to Rectification

You have the right to correct inaccurate personal data.

13.3 Right to Erasure (“Right to Be Forgotten”)

You have the right to request deletion of your personal data.

13.4 Right to Restrict Processing

You have the right to restrict how your data is processed.

13.5 Right to Data Portability

You have the right to receive your data in a portable format.

13.6 Right to Object

You have the right to object to certain processing activities.

13.7 Right to Lodge a Complaint

You have the right to lodge a complaint with your local data protection authority.

13.8 How to Submit a Request

Email: privacy@jegantic.com
Include: Your name, email, and specific request

Response Time: We will respond within 30 days.


14. Canadian Privacy Rights (PIPEDA)

If you are a Canadian resident, you have rights under the Personal Information Protection and Electronic Documents Act (PIPEDA):

14.1 Right to Access

You have the right to access your personal information held by JEGantic.

14.2 Right to Correction

You have the right to request correction of inaccurate information.

14.3 Right to Opt-Out

You have the right to opt-out of marketing communications.

14.4 How to Submit a Request

Email: privacy@jegantic.com
Include: Your name, email, and specific request

Response Time: We will respond within 30 days.


15. Updates to This Privacy Policy

15.1 Right to Change

JEGantic reserves the right to update this Privacy Policy at any time.

15.2 Notification of Changes

Material changes will be communicated via:

  • In-app notification
  • Email to your registered address
  • Update to this page with a new “Last Updated” date

15.3 Your Acceptance

Your continued use of the Service after changes constitutes acceptance of the updated Privacy Policy.

15.4 Significant Changes

If changes are significant and require new consent, we will:

  • Notify you prominently in the App
  • Request your explicit consent
  • Allow you to review the full updated policy

16. Contact Us

16.1 Privacy Questions & Concerns

If you have questions about this Privacy Policy or want to exercise your privacy rights, please contact:

Email: privacy@jegantic.com
Support Email: support@jegantic.com
Mailing Address (if needed):
JEGantic Hospitality
Toronto, Ontario
Canada

16.2 Response Time

We will respond to privacy inquiries within 5-10 business days.

16.3 Data Protection Officer

For GDPR/PIPEDA inquiries, contact our Privacy Officer at: privacy@jegantic.com

16.4 Complaints

If you are not satisfied with our response, you may:

  • Canada: Contact the Office of the Privacy Commissioner of Canada (OPC)
  • EU: File a complaint with your national data protection authority
  • California: File a complaint with the California Attorney General
  • Other US States: Contact your state’s Attorney General

17. Specific Data Practices by Feature

17.1 Loyalty Points Tracking

Data Collected:

  • Every transaction amount and venue
  • Tier status at time of transaction
  • Multiplier applied
  • Points earned

Data Used For:

  • Calculating points balance
  • Determining tier status
  • Auditing for fraud
  • Analytics on earning patterns

Data Retention: Permanent (to maintain accurate tier status and points history)

17.2 Reservation History

Data Collected:

  • Reservation date, time, party size
  • Venue name and location
  • Guest preferences and special requests
  • Cancellation/modification history

Data Used For:

  • Providing reservation management
  • Sending reminders
  • Calculating spending for points
  • Improving venue recommendations
  • Customer support

Data Retention: Permanent (for points calculation and history)

17.3 Reward Redemption Tracking

Data Collected:

  • Reward redeemed
  • Redemption date
  • Redemption code/QR code
  • Fulfillment status
  • Venue where redeemed

Data Used For:

  • Enforcing redemption limits
  • Preventing fraud
  • Customer support
  • Analytics on popular rewards

Data Retention: Permanent (to prevent duplicate redemptions)

17.4 Push Notifications

Data Collected:

  • Device token (unique device ID)
  • Device type and OS
  • Notification preferences
  • Notification open/click history

Data Used For:

  • Sending notifications
  • Measuring engagement
  • Personalizing notification content
  • Removing inactive devices

Data Retention: Until notification preference disabled or device unregistered

17.5 Shake Gesture Feedback

Data Collected:

  • Feedback text you submit
  • Timestamp of submission
  • Current screen/feature being used
  • Device info and app version

Data Used For:

  • Improving App functionality
  • Identifying bugs or issues
  • Understanding user satisfaction
  • Contacting you for clarification (if you provided contact info)

Data Retention: 1 year (then deleted)


18. Third-Party Links & Services

Our Service may contain links to third-party websites and services:

  • SevenRooms
  • TIXR
  • Facebook
  • Google
  • Payment processors

We are not responsible for the privacy practices of these third parties. Please review their privacy policies directly.


19. Entire Agreement

This Privacy Policy, together with our Terms and Conditions, constitutes the entire agreement regarding your privacy and data handling. If there is a conflict, this Privacy Policy takes precedence for data-related matters.


20. Effective Date & Version

Effective Date: November 5, 2025
Last Updated: November 5, 2025
Version: 1.0

For the most current version, visit: www.jegantic.com/privacy-policy or review the policy in the App.


Thank you for trusting JEGantic with your personal information. We are committed to protecting your privacy and providing a secure, enjoyable experience.

If you have any questions, please don’t hesitate to contact us at privacy@jegantic.com.


END OF PRIVACY POLICY