-Privacy Policy

OffYourPlate is a trading brand of A.W.O.L TRAVEL Ltd ("AWOL"). This Privacy Policy explains how we collect, use, process and protect personal data when providing our services and operating our websites.

Legal Entity: A.W.O.L TRAVEL Ltd
Registered Address: Ioanni Kapodistria 10, Limassol 3032, Cyprus
Registration Number: HE456930
Tax Number: 60057321V
VAT Number: CY 60057321V

1. Scope of This Policy

This Privacy Policy applies to:

(a) visitors to OffYourPlate websites;

(b) businesses and individuals who purchase or enquire about our services; and

(c) data processed when we build, host, maintain, or optimise client websites.

This Policy does not cover third-party websites or platforms that may be linked to or integrated with our services.

2. Roles Under Data Protection Law

Under the General Data Protection Regulation (EU) 2016/679 (“GDPR”):

(a) AWOL acts as a Data Controller for personal data collected via OffYourPlate’s own websites and sales channels.

(b) When building, hosting or maintaining a client website, the Client is the Data Controller for personal data collected via that website, and AWOL acts as a Data Processor processing data on the Client’s documented instructions.

Clients remain fully responsible for their own GDPR compliance obligations.

3. Information We Collect

We may collect and process the following categories of personal data:

(a) Business and contact information – name, business name, email address, telephone number, billing details, and correspondence.

(b) Technical data – IP address, browser type, device information, access logs, and security logs.

(c) Website content data – business descriptions, menus, images, opening hours, social media content, and other information made publicly available by the Client.

(d) Usage and analytics data – aggregated data about how websites perform and are accessed.

(e) Communications – emails, messages, questionnaire responses, and support tickets.

We do not intentionally collect special category data (such as health or religious information).

4. Use of Publicly Available Online Presence

In order to deliver our services efficiently, AWOL may use information that the Client has made publicly available online, including but not limited to:

(a) business profile information from search engines and map services;

(b) publicly available website content;

(c) publicly accessible social media posts and images.

This information is used solely to generate, populate, optimise, and maintain the Client’s website and related digital assets. We do not represent that such information is exhaustive or error-free, and the Client is responsible for verifying accuracy.

5. How We Use Personal Data

We process personal data for the following purposes:

(a) to provide, manage, and support our services;

(b) to generate website content, layouts, and optimisation using automated and manual processes;

(c) to communicate with clients regarding their accounts and services;

(d) to process payments and manage subscriptions;

(e) to monitor security, prevent fraud, and improve our systems;

(f) to comply with legal and regulatory obligations.

We do not sell personal data.

6. Automated Processing and AI

We use automated systems and artificial intelligence tools to assist with content generation, layout creation, SEO optimisation, and image selection.

All outputs generated through such systems are provided on an “as-is” basis. The Client is responsible for reviewing, approving, and ensuring compliance of all content before use.

7. Ownership of Generated Content

All content, designs, layouts, text, images, code, data compilations, and other materials generated or assembled by AWOL in the course of providing the services remain the property of AWOL.

This applies even if:

(a) the content is derived from publicly available sources; or

(b) the Client terminates or cancels the service.

Clients are granted a limited licence to use the website only while their subscription remains active, subject to the Terms & Conditions.

8. Legal Bases for Processing

Where AWOL acts as Data Controller, we process personal data on the following legal bases:

(a) performance of a contract;

(b) compliance with legal obligations;

(c) legitimate interests, including operating, securing, and improving our services;

(d) consent, where required by law.

Where AWOL acts as Data Processor, we process data on the Client’s documented instructions.

9. Data Sharing and Third Parties

We may share personal data with trusted third parties who assist us in delivering our services, including:

(a) hosting and infrastructure providers;

(b) domain registrars;

(c) email and communications providers;

(d) analytics providers;

(e) payment processors;

(f) professional advisers where required.

All such third parties are required to implement appropriate data protection measures.

10. International Transfers

Where personal data is transferred outside the European Economic Area, AWOL ensures appropriate safeguards are in place, such as standard contractual clauses or equivalent lawful mechanisms.

11. Data Retention

We retain personal data only for as long as necessary for the purposes described in this Policy or as required by law.

Data may be anonymised or deleted when no longer required.

12. Security Measures

We implement appropriate technical and organisational security measures to protect personal data against unauthorised access, loss, alteration, or disclosure.

However, no internet-based system can be guaranteed to be completely secure.

13. Data Subject Rights

Where AWOL is Data Controller, individuals may have the right to:

(a) access their personal data;

(b) request correction or deletion;

(c) restrict or object to processing;

(d) request data portability;

(e) withdraw consent where applicable.

Where AWOL acts as Data Processor, such requests should generally be directed to the Client as Data Controller.

14. Complaints and Supervisory Authority

Individuals have the right to lodge a complaint with the Cyprus Commissioner for Personal Data Protection or another competent supervisory authority.

15. Changes to This Policy

We may update this Privacy Policy from time to time. The latest version will always be published on our website.