Privacy policy

Data Management/Protection and Cookie Policy

This privacy policy describes how the site, and by extension the owner company HATLO Trading Ltd ("Route66 Cafe", "website", "we", "company") collect, use, communicate and store personal data. This Policy applies to website, pages, applications, services, and content (collectively called "Services").

This policy is in-line with the provisions of the Regulation (EU) 2016/679 of the European Parliament on the protection of individuals with regards to the processing of personal data and on the applicable national legislation.  

1. Categories and purposes of processing your personal data

Description of data processing  Personal Data Purpose of processing Legal base for the processing of data
Website contact form Full name, Email and other information that may be included in your messages. Processing, handling, and serving your request. We process the data in the context of serving our legitimate interests, in this case to serve your requests, to maintain and improve the communication of the website with its users. 
As you browse the website, information about your connection and activity is automatically collected IP address and other connection information, data collected through cookies (for more information see the Cookies Policy later in this document) Website use optimization and security We process the data in the context of serving our legitimate interests, in this case to ensure the smooth operation, security of the website and its optimal operation.
Operating needs of the customer support / chat service (ZenDesk Chat) which monitors the user throughout the connection. Details that the customer can provide during communication. Optimal and prompt customer service. We process the data in the context of serving our legitimate interests, in this case to ensure the smooth operation of our service and optimal customer service.
Order placement When placing an order various contact details are requested. Please, see also the relevant Terms of Use for the ordering service. Customer service and purpose of service. We process the data in the context of serving our legitimate interests, in this case, to serve orders that customers have voluntarily submitted.

The personal data provided by the visitors to our site are used solely for the purpose for which they were submitted as stated in the respective collection point (further processing for archiving purposes in the public interest or for scientific or historical research or statistical purposes shall not be considered incompatible with the original purposes).

We keep only strictly necessary data to serve the purpose for which you disclose it to us.

We keep your data in a format that allows you to be identified only for the time required for the processing of your data.

Any provision of statistics to third parties is done in such a way that they will not be able to identify the data subject.

2. Registering users in areas of the site

The registration of users on our website, in particular for the preparation and submission of orders, as well as their subsequent monitoring and re-registration, is subject to your express consent and acceptance of the terms of our data protection/privacy policy and the use of cookies.

3. To whom do we disclose your personal data?

The Website undertakes not to disclose personal data to third parties. 

As an exception, we may disclose your personal data in the following cases:

(a) to various companies or service providers who work with us to help us respond to your requests and the service which we provide in the first hand.

(b) to competent public services, either for our compliance with legal obligations or for the exercise and defence of our rights, and 

(c) to third parties who provide services to us, such as IT service providers, service providers with whom we work, and only to the extent necessary to provide their services to us and/or directly to you. 

When these service providers provide services to us, they act as the executors of the processing and therefore process personal data solely on our behalf and on the basis of our recorded instructions and have no right to re-use the data for their own benefit.

(d) where necessary to comply with applicable law and judicial decisions.    

We will under no circumstances and for any reason announce or disclose the personal data of users of the website, unless we have clearly expressed and free consent of them to do so.

4. Security of your personal data

The security of your personal data is our primary goal. We take and enforce the highest technical and organizational measures to ensure the integrity, confidentiality and availability of personal data and to protect them from the risk of unauthorized access, abuse, disclosure, illegal destruction or loss.

5. Cookies

Our website uses cookies. The cookies are small data files created and stored by the Internet browser on your computer's hard drive. Accessing a website may result in a cookie being stored on your computer. This cookie contains a specific set of characters that allows the browser to be clearly identified each time you access the website.

We use cookies to make our website more user-friendly.

The processing of personal data based on the use of cookies is legal under the article 6(1) GDPR. The purpose of these technical cookies is to simplify the use of the website.

The cookies are stored on the user's computer and transferred to us. This is why you, as a user, have complete control over the cookies’ application. You can disable or restrict cookies by changing your browser settings. The cookies already stored on your hard disk can be deleted at any time. This can also be done automatically. However, disabling cookies for our site may result in some features not working properly.

Find out more by reading our dedicated Cookies Policy later in this document.

6. What are your rights?

We have taken the appropriate steps to provide you with any information about your rights and the way to exercise those rights. According to Chapter III of the GDPR you have the following rights:

I. Transparent information, communication and details about exercising your rights

You have the right to receive the data we have available about you freely and in an understandable manner. Upon your request, we will provide you with information without undue delay and in any event within one month of receipt of the request. This period may be extended, where applicable, by a further two months, taking into account the complexity and the number of applications. In this case, we will inform you of the reasons for the delay.

II. Information to be provided when collecting personal data from the data subject

You have the right to know the contact details of the person who collects your data, the purposes of the processing for which the personal data is intended, the legal basis for processing, the recipients or the categories of recipients of personal data.

III. Right of access

You have the right to request and receive a copy of your personal data being processed. However, for any further requests you make, we reserve the right to charge you a reasonable fee based on the administrative expenses.

IV. Right of correction

You have the right to request within a reasonable time to correct inaccurate personal data concerning you.

V. Right of cancellation ("right to be forgotten")

You have the right to request the deletion of your personal data when the personal data are no longer necessary for the purposes for which they were collected.

However, in cases where the website retains and processes personal data in accordance with Article 6 (1) (c) of the GDPR, we reserve the right to object to such a request and to retain the relevant personal data required since we must comply with our legal obligations or the legal obligations of a processor of the data who works with us in accordance with the terms of a Data Processing Agreement.

If you decide to opt out of a service or communication, we will try to delete your data as soon as possible, although we may need some time and / or information before we can process your request.

VI. Right to limit processing

We offer a specific procedure by which the users may request restriction of the processing of their personal data. However, for the personal data necessary to comply with a legal obligation, we reserve the right to oppose the restriction.

VII. Right to data portability

You have the right to receive your personal data previously provided to us in a structured and mechanically readable form and you have the right to transfer this data to another controller without hindrance from the controller to whom the personal data has been provided.

VIII. Right to refuse processing

You have the right to object to the processing of your personal data. However, as we process such data legally in accordance with Article 6 (1) (c), we will still have the right to process such data.

IX. Automated individual decision making, including formatting

You have the right not to make any decision solely on automated processing, including formatting, which has legal effects on you or has a significant effect.

Cookie policy 

This part of the policy sets out the terms of use of cookies by the website, explains the purposes for which cookies are used, and describes the rights of users of the website to modify and select and adjust cookies according to their needs.

Cookies are necessary for the provision and improvement of the service provided by the website, as well as to ensure that information provided by users remains confidential in an appropriate manner. We take appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of data provided by users in the form of cookies.

How the website uses the cookies   

When you browse and access the website, we can place a number of cookie files on your computer through your web browser. We use cookies for the following purposes: to enable certain features of the website, to obtain detailed performance information for the website, to store your preferences for ease of access and navigation to the website, to enable ad serving (where applicable). We use session cookies and persistent cookies at the same time on the website and use different types of cookies to provide the services included on the website. We can use key cookies to authenticate users and prevent fraudulent user accounts.

How to control cookies 

You can control and/or delete cookies at your convenience - for details, visit You can delete all cookies that already exist on your computer, and you can set most browsers to prevent them from being placed. If you do, you may have to manually set some preferences each time you visit our website or use our other services, and some of the services and features we offer may not work.

The cookies we use:  

Absolutely Necessary Cookies: These are absolutely essential cookies for the proper functioning of the website.  

Performance and analytics cookies: They allow us to identify and analyze the number of visitors to our sites and the way they browse through it. We use this information to improve the way our website operates in order to make it easier for users to access the content.  

Functionality related Cookies: These cookies are used for third parties to be able to offer special required functionality through the website such as alerts, notifications in social networks and more content relevant to your interests. 

Audience Targeting and Advertising Cookies: These cookies track your visits to our website and the links you followed. We use the information to show you ads that are most relevant to your interests. We may share this information with third parties for this purpose. 

Where to find more information about cookies 

You can learn more about cookies through the following third-party sites:

• AllAboutCookies: