Privacy policy

Azumi Limited Group Privacy Policy

Last update 24th May 2018

Welcome to Azumi Limited Group’s Privacy Policy.


1. What does this Privacy Policy Cover?

Azumi respects your privacy and is committed to protecting your Personal Data.We want to be transparent with you about how we collect and use your Personal Data in your dealings with us and your use of our websites (“ Sites”) and tell you about your privacy rights and how the law protects you.

With that in mind, this Privacy Policy is designed to describe:

This Privacy Policy aims to give you information on how Azumi collects and processes your Personal Data through your use of our Sites, including any data you may provide through our Sites, and other dealings with us.

The Privacy Policy is intended to meet our duties of Transparency under the “General Data Protection Regulation” or “ GDPR”.

We will post any modifications or changes to this Privacy Policy on this page.

2. Who we are and how to contact us?

Azumi Limited and its affiliates and associated companies is made up of different legal entities, details of which can be found in Appendix 1 (“Azumi Limited Group”).

This Privacy Policy is issued on behalf of the entire Azumi Limited Group so when we mention “Azumi”, “ we”, “ us” or “ our” in this Privacy Policy, we are referring to the relevant company(ies) in the Azumi Limited Group responsible for processing your Personal Data.

We will let you know which entity(ies) are the Controller(s) (for the purposes of the GDPR) of your Personal Data if you ask us to give you this information by contacting us at the details below.

You can contact us by emailing: [email protected].


3. Your rights relating to your Personal Data

Under certain circumstances, by law you have the right to:

How to exercise your rights:

If you want to exercise any of the rights described above, please contact us using the contact details shown here “Who We Are and How to Contact Us”.

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


4. Complaints

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at: [email protected]

We will reply to your complaint as soon as we can.

If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.


5. Marketing communications preferences

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or and/or by contacting us at any time using the contact details shown here “Who We Are and How to Contact Us”.

Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of restaurant reservations and other purchases where we require your Personal Data to complete your order.


6. What Personal Data we collect

All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.

Before you read that table, it might be useful to explain what “Personal Data” is. The GDPR definition of Personal Data can be found here. Essentially, it boils down to: information about an individual, from which that individual is either directly identified or can be identified.

It does  not include ‘anonymous data’ (i.e., information where the identity of individual has been permanently removed).

However, it  does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).

Category of Personal Data collected What this means
Identity Data First name, surname, marital status, title, date of birth and gender.
Contact Data Your home address, work address, billing address, email address and telephone numbers.
Financial Data Your payment card details. Note that we pass any Financial Data we receive from you immediately to our third party payment processors. We do not store any of your Financial Data.
Transaction Data Details about payments to and from you in respect of meals and gift cards you have purchased from us.
Marketing and Communications Data Your preferences in receiving marketing from us and your communication preferences.
Behavioural Data Inferred or assumed information relating to your behaviour and interests based on your online activity on our Sites.
Technical Data Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or use our services.
Allergy Data Information about food allergies, intolerances and/or preferences you have.

We also collect, use and share “Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute considered Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Behavioural Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

The GDPR defines “Special Categories of Personal Data” to include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. As noted above, we may (with your explicit consent) collect and use Allergy Data that you provide to us, which may constitute health data, in order to provide our services to you. We do not otherwise collect any Special Categories of Personal Data unless you provide your explicit consent to us to do so. We do not collect any information about criminal convictions or offences.


7. How we use your Personal Data and why

We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.


8. What is our “legal basis” for processing your Personal Data? 

In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:

Generally we do not rely on your Consent as a legal basis for using your Personal Data other than in the context of direct marketing communications.

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.

Purpose Category(ies) of Personal Data involved Why do we do this Our legal basis for this use of data
Reservations/ Bookings · Identity Data

· Contact Data

· Transaction Data

To secure and manage customer reservations. Contractual Necessity.
Marketing · Identity Data

· Contact Data

· Marketing and Communications Data

To send you newsletters and offers which we think may be of interest to you. Consent.

We obtain opt-in consent to send marketing communications to you.

To process payments for gift cards · Identity Data

· Contact Data

· Financial Data

· Transaction Data

To process and deliver your order. Contractual Necessity.
To process advance payments for bookings · Identity Data

· Contact Data

· Financial Data

· Transaction Data

To process your order to secure a reservation or to pay, or part pay, for a reservation in advance and allocate such payments correctly. Contractual Necessity.
To improve our Sites · Behavioural Data

· Technical Data

To monitor use of our Sites, to improve our Sites and to help operate our Sites more efficiently, and to improve your experience on our Sites. Legitimate Interests.

We have a legitimate commercial interest in ensuring that our Sites operate as efficiently as possible and that we improve our Sites based on information we learn from our users’ use of our Sites.

To provide your order to you, taking your food allergies, intolerances and preferences into account · Allergy Data To ensure that we take into account information about your food allergies, intolerances and/or preferences when preparing and delivering your order to you. Explicit Consent.

We obtain your explicit consent to use data relating to your food allergies and intolerances.

Legitimate interests.

We have a legitimate interest in taking your food preferences into account when preparing and delivering your order to you, to ensure that you are satisfied with the services you receive from us.


9. What happens when you do not provide necessary Personal Data?

Where we  need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Sites).

In this case, we may have to stop you using our Sites but we will notify you if this is the case at the time.


10. Personal Data from Third Party Sources

In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.

Third party data source Publicly available? Category(ies) or other types of personal data received.
Online booking platforms No · Identity Data

· Contact Data

· Transaction Data

Gift card purchase platform No · Identity Data

· Contact Data

· Transaction Data

Analytics providers No · Behavioural Data

· Technical Data


11. How we use cookies & other tracking or profiling technologies

What are cookies?

We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Sites.

We use two broad categories of cookies:

Cookies we use: 

Our Sites use the following types of cookies for the purposes set out below:

Type of cookie Purpose
Essential Cookies These cookies are essential to provide you with services available through our Sites and to enable you to use some of its features.
Functionality Cookies These cookies allow our Sites to remember choices you make when you use our Sites, such as remembering your language preferences. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Sites.
Analytics and Performance Cookies These cookies are used to collect information about traffic to our Sites and how users use our Sites. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Sites. The information collected is aggregated and anonymous. It includes the number of visitors to our Sites, the websites that referred them to our Sites, the pages they visited on our Sites, what time of day they visited our Sites, whether they have visited our Sites before, and other similar information. We use this information to help operate our Sites more efficiently, to gather broad demographic information and to monitor the level of activity on our Sites.

We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Sites work. You can find out more information about Google Analytics cookies here:

You can find out more about how Google protects your data here:

Social Media Cookies These cookies are used when you share information using a social media sharing button or “like” button on our Sites or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.

Disabling cookies:

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our Sites. For example, our Sites not remembering your language setting.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit and

You can also prevent the use of Google Analytics relating to your use of our Sites by downloading and installing the browser plugin available via this link:


12. Who we share your Personal Data with

The table below describes who we share your Personal Data with, what we share and why we share it.

Recipients Category(ies) of Personal Data we share. Why we share it Location(s)
Payment systems · Financial data To process payments via 3rd party platforms in a PCI compliant manner. · Within Europe
Reservations Platforms · Identity Data

· Contact Data

Our service providers provide us with IT systems that help manage our bookings and reservations process. · Within Europe
Marketing Digital Platforms · Identity Data

· Contact Data

Our service providers administer our marketing communications with customers who have opted-in to receive such communications from us. · Within Europe
Azumi Group Restaurants outside Europe & the Reservations Platforms they use · Identity Data

· Contact Data

We only share data with our restaurants outside Europe where a customer has requested that we do so to, for example, to make a reservation. · Global


13. Data transfers

As you can see from the above, we share your Personal Data with our affiliated companies within the Azumi Group and certain external third parties who are based outside the European Economic Area (“ Europe”). Any processing of your Personal Data by these parties will involve an export of your Personal Data outside of Europe.

We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:


14. How we keep your Personal Data secure

We have put in place appropriate technical and organisational security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We store all the personal information you provide on secure password and firewall protected servers.

We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.


15. How long we store your Personal Data

We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above “How we use your Personal Data and why.”, unless a longer retention period is required by law (for example for regulatory purposes).

The table below shows our standard retention practices:

Category of Personal Data Retention period
Identity Data Where you have not opted in to receive marketing communications from us or for your data to be held on our customer database, your Identity Data will be deleted after two (2) years from the date of your last visit.
Contact Data Where you have not opted in to receive marketing communications from us or for your data to be held on our customer database, your Contact Data will be deleted after two (2) years from the date of your last visit.
Financial Data We pass any Financial Data we receive from you immediately to our third party payment processors. We do not store any of your Financial Data.
Transactions Data We store Transactions Data for a period of two (2) years from the date of your last visit.
Marketing and Communications Data We store Marketing and Communications Data until you unsubscribe from our marketing communications.
Behavioural Data We anonymise Behavioural Data almost immediately following collection. We then retain Behavioural Data in anonymised form for thirty-eight (38) months.
Technical Data We anonymise Technical Data almost immediately following collection. We then retain Technical Data in anonymised form for thirty-eight (38) months.
Allergy Data We store Allergy Data for a period of two (2) years from the date of your last visit.


16. Our policy on children

Our Sites are not intended for children below 16 and we do not knowingly collect data relating to children via our Sites.

However, you may provide us with Identity Data relating to children where, for example, you make a booking for a child’s birthday party, and we may store this information on your account. In providing us with this Identity Data, you are agreeing that you hold parental responsibility for that child or that you have been properly authorised by the holder of parental responsibility for the child to give us this Identity Data to use for these purposes.


17. Third party links

Our Sites 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 your Personal Data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every site you visit.


Azumi Limited, 2018 - Appendix

Appendix 1 - Company Name

Azumi Limited

Wildfire Entertainment Limited

Robata Restaurants Limited

Roka Mayfair Limited

Roka Aldwych Limited

Inko Nito Broadwick Street Limited

Zuma (Rome) s.r.l


Zuma Las Vegas LLC

Zuma Japanese Restaurant Miami LLC

Inko Nito Garey St LLC

Beach-Chu Hallandale LLC

Zuma Restaurant Ltd

Zuma Club LLC

Time Result Investments Limited

Zuma Bangkok Limited

Beach-Chu Las Olas LLC

ROKA Restaurant LLC

Azumi LLC


Zuma Japanese Restaurants Inc

Zuma Turizm Ve Gida Pazarlama

Taddeo Trading Limited

Beach-Chu Inc

Inko Nito Inc

Inko Nito UK Limited

ROKA Limited

ROKA Chelsea Limited

Taraneete International Limited

Zuma Holdings USA LLC

Wildfire Holdings USA LLC

Robata Holdings USA LLC