WEBSITE PRIVACY POLICY

1. INTRODUCTION

Welcome to the KellyDeli’s privacy policy.

KellyDeli respects your privacy and is committed to
protecting your personal data. This privacy policy will inform you as to how we
look after your personal data when you visit our website kellydeli.com
(regardless of where you visit it from) and tell you about your privacy rights
and how the law protects you.

2. IMPORTANT INFORMATION AND WHO WE ARE

2.1 PURPOSE OF THIS PRIVACY POLICY

We take your privacy very seriously. Please read this
privacy policy carefully as it contains important information on who we are and
how and why we collect, store, use and share any information relating to you
(your personal data) in connection with your use of our website. It also
explains your rights in relation to your personal data and how to contact us or
a relevant regulator in the event you have a complaint.

We collect, use and are responsible for certain personal
data about you. When we do so we are subject to the UK General Data Protection
Regulation (UK GDPR). We are also subject to the EU General Data Protection
Regulation (EU GDPR) in relation to goods and services we offer to
individuals in the European Economic Area (EEA).

This website is not intended for children, and we do not
knowingly collect data relating to children.

It is important that you read this privacy policy together
with any other privacy policy or fair processing policy we may provide on
specific occasions when we are collecting or processing personal data about you
so that you are fully aware of how and why we are using your data. This privacy
policy supplements other notices and privacy policies and is not intended to
override them.

2.2. CONTROLLER

KellyDeli Group is made up of different legal entities. This
privacy policy is issued on behalf of the KellyDeli Group so when we mention
“KellyDeli”, “we”, “us” or “our” in this privacy policy, we are referring to
the relevant company in the KellyDeli Group responsible for processing your
data.

KellyDeli Company Limited – as identified below – is the
controller and responsible for this website.

2.3. HOW TO CONTACT US

If you have any questions about this privacy policy or our
privacy practices, please contact us in the following ways:

Full name of legal entity: KellyDeli Company Limited

Email address: privacy@kellydeli.com

Postal address: 91-93 Great Eastern Street London EC2A3HZ
London United Kingdom

2.4 CHANGES TO THE PRIVACY POLICY

We keep our privacy policy under regular review.

This version was last updated in September 2025.

2.5 THIRD-PARTY LINKS

This website may include links to third-party websites,
plug-ins and applications. Clicking on those links or enabling those
connections may allow third parties to collect or share data about you. We do
not control these third-party websites and are not responsible for their
privacy statements. When you leave our website, we encourage you to read the
privacy policy of every website you visit.


3. THE DATA WE COLLECT ABOUT YOU

3.1 Personal data, or personal information, means any
information about an individual from which that person can be identified. It
does not include data where the identity has been removed (anonymous data).

3.2 We collect personal information about you when you use
our website ("Website") or otherwise interact with us via other
channels such as social networks.

3.3. We collect information that you provide to us directly
when communicating with us, making enquiries, completing our partnership
application form or visiting/using our website. This includes your name,
username, password, address, date of birth, email address, telephone number,
your location, social media profile information (where you reach out via social
media such as Facebook or Instagram) and content of your communications. We
also

collect transaction information from when you make a
purchase including your payment credit card information and the products you
buy. This also includes profile information such as the products you like.

3.4 Other personal data can be collected indirectly and
automatically, for example, your browsing or shopping activity. We may also log
general information about your browser or device whenever you visit our
website. This information may include your computer’s Internet Protocol (IP)
address, your browser type and version, the pages you visit on our website, the
time and date of your visit, and the time spent on each page. Like most website
operators, we collect this data to better understand how our visitors use our
services, and how we may improve your experience of our website in future. Some
of this data may be obtained automatically through the use of cookies – please
refer to our Cookies Policy (https://sushidaily.com/gb-en/cookies-policy/)
for more information.

3.5 In specific instances, we may need to collect additional
data for the purposes explained to you at that time.

3.6 We work with third parties (including, for example
sub-contractors) who may collect personal information from you and pass it on
to us. Where this is the case, the relevant third party is responsible for
notifying the details of the same to you and for obtaining the relevant
consents from you (if necessary).

4. HOW IS YOUR INFORMATION USED AND WHAT IS THE LEGAL
BASIS FOR THIS USE?

4.1 We process your information for the following purposes:

4.1.1 To fulfil a contract. This includes:

- to process and fulfil any orders, subscriptions or other
purchase made;

- to provide customer service;

- to process your payments;

- to verify your identity;

- to process any entries that you make into competitions run
by us;

4.1.2 To conduct our business and pursue our legitimate
interests, in particular:

- to communicate with you about products, services and
offers that may be of interests to you;

- to provide products you have requested and for customer
services purposes to respond to any comments or complaints you send us;

- to continuously improve our products and services and
personalise your experience online;

- to notify you about changes to our website.

- to provide you access to our website and to improve your
user experience;

- to better understand our customers, how often they come to
and how long they spent in our website.

- for market research and customer services purposes.

4.1.3 Where you give us your consent:

- we send you marketing communications.

- we place cookies

- on other occasions where we ask you for consent, we will
use the data for the purpose which we explain at that time.

4.1.5 For purposes which are required by law:

- responding to court orders, subpoenas or other legal
processes with which we are required to comply

- for crime and fraud prevention, detection and related
purposes.

4.2 In certain circumstances, some of the above grounds for
processing will overlap and there will be several grounds which justify our use
of your personal information.

4.4 You aren't always required to give us your personal
data, but where we need to collect or process your personal data by law, or
under the terms of a contract we have with you, and you fail to provide that
data when requested (or fail to consent to the processing of that data, if
necessary), we may not be able to perform the agreement or arrangement we have
or are trying to enter into with you, or provide you with certain of our goods
and services.



5. WHO WE SHARE YOUR PERSONAL DATA WITH?

5.1 Third Party Service Providers working on our behalf

In order to make certain services available to you, we may
pass your information to our third-party service providers, suppliers.
subcontractors. These include IT, website hosting,

marketing service providers and payment processors (for
example, to process deliveries and send you your order confirmation). We only
allow those organisations to handle your personal data if we are satisfied they
take appropriate measures to protect your personal data

5.2 Third Parties with whom we transact

If any of our businesses enter into a joint venture with,
purchase or are sold to or merge with another business entity, your information
may be disclosed or transferred to the target company, our new business
partners, administrators, or owners or their advisors.

5.3 Sharing to comply with legal obligations

We may use the information that you provide to us if we are
under a duty to disclose or share your information in order to comply with any
legal obligation.

5.4. Data Transfers

In addition to the data sharing described in section 5.1,
5.2 and 5.3, the information that we collect from you may, where lawful, be
transferred to, and stored at, a destination outside the UK or the European
Economic Area ("EEA").

Where we do so, we will sure that transfers:

- are made to countries that have been deemed to provide an
adequate level of protection to personal data; or

- are carried out under standard contractual clauses
approved by the European Commission as providing appropriate safeguards, copies
of which are available to view on the Commission’s website (https://ec.europa.eu).

If you would like further information about data transferred
outside the UK/EEA, please contact our Data Protection Officer (see ‘HOW TO
CONTACT US
’ above).


6. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data
protection laws in relation to your personal data. You have the right to:

6.1 Request access to your personal data (commonly
known as a “data subject access request”). This enables you to receive a copy
of the personal data we hold about you and to check that we are lawfully
processing it.

6.2 Request correction of the personal data that we
hold about you. This enables you to

have any incomplete or inaccurate data we hold about you
corrected, though we may need to verify the accuracy of the new data you
provide to us.

6.3 Request erasure of your personal data. This enables
you to ask us to delete or remove personal data where there is no good reason
for us continuing to process it. You also have the right to ask us to delete or
remove your personal data where you have successfully exercised your right to
object to processing (see below), where we may have processed your information
unlawfully or where we are required to erase your personal data to comply with
local law. Note, however, that we may not always be able to comply with your
request of erasure for specific legal reasons which will be notified to you, if
applicable, at the time of your request.

6.4 Object to processing of your personal data where we
are relying on a legitimate interest (or those of a third party) and there is
something about your particular situation which makes you want to object to
processing on this ground as you feel it impacts on your fundamental rights and
freedoms. You also have the right to object where we are processing your
personal data for direct marketing purposes. In some cases, we may demonstrate
that we have compelling legitimate grounds to process your information which
override your rights and freedoms.

6.5 Request restriction of processing of your personal
data. This enables you to ask us to suspend the processing of your personal
data in the following scenarios:

6.5.1. If you want us to establish the data’s accuracy.

6.5.2. Where our use of the data is unlawful but you do
not want us to erase it.

6.5.3 Where you need us to hold the data even if we no
longer require it as you need it to establish, exercise or defend legal claims.

6.5.4. You have objected to our use of your data but we
need to verify whether we have overriding legitimate grounds to use it.

6.6 Request the transfer of your personal data to you
or to a third party. We will provide to you, or a third party you have chosen,
your personal data in a structured, commonly used, machine-readable format.
Note that this right only applies to automated information which you initially
provided consent for us to use or where we used the information to perform a
contract with you.

6.7 Withdraw consent at any time where we are relying
on consent to process your personal data. However, this will not affect the
lawfulness of any processing carried out before you

withdraw your consent. If you withdraw your consent, we may
not be able to provide certain products or services to you. We will advise you
if this is the case at the time you withdraw your consent.

6.8 If you wish to exercise any of the rights set out above,
when contacting us please: provide enough information to identify yourself (eg
your full name, address and customer or matter reference number)
and any
additional identity information we may reasonably request from you, and let us
know which right(s) you want to exercise and the information to which your
request relates.

You may also find it helpful to refer to the guidance from the
UK’s Information Commissioner
 (https://ico.org.uk/for-the-public/)
on your rights under the UK GDPR.

7. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

7.1 Where we process personal data for marketing purposes or
with your consent, we process the data until you ask us to stop and for a short
period after this (to allow us to implement your requests). We also keep a
record of the fact that you have asked us not to send you direct marketing or
to process your data indefinitely so that we can respect your request in
future.

7.2 Where we process personal data in connection with
performing a contract, subscription or for a competition, we keep the data for
2 years from your last interaction with us.


8 COOKIES

A cookie is a small text file which is placed onto your
device when you use our website.

You can set your browser to refuse all or some browser
cookies, or to alert you when websites set or access cookies. If you disable or
refuse cookies, please note that some parts of this website may become
inaccessible or not function properly.


9 KEEPING YOUR PERSONAL DATA SECURE

We have appropriate security measures to prevent personal
data from being accidentally lost, or used or accessed unlawfully. We limit
access to your personal data to those who have a genuine need to access
it. 

We also have procedures in place to deal with any suspected
data security breach. We will notify you and any applicable regulator of a
suspected data security breach where we are legally required to do so.

10 FRANCHISEES

Some of our kiosks and other businesses are run by
franchisees. A franchisee is a separate business that has a licence to sell
produce under one of our brands.

Each franchisee is responsible for compliance with privacy
laws, and we place strict burdens on franchisees to ensure that they do so.
Occasionally, there may be an exchange of personal data with a franchisee where
it is necessary: for example, if you have raised a query with us about a matter
that relates to a franchised kiosk, we would be required to discuss that issue
with the franchisee, which would involve the use of your personal data for this
purpose.