Host Privacy Policy

1. Introduction

Welcome to Express Foodie Restaurant Partner Platform.

This Privacy Policy explains how EXPRESS FOODIE LLP ("Express Foodie", "we", "our" or "us") collects, uses, stores, shares and protects the personal and business information of restaurant partners ("Restaurant", "Restaurant Partner", "Host", "you" or "your") when you use the Express Foodie Restaurant Partner Mobile Application, Restaurant Partner Portal, Website and related services.

This Privacy Policy applies to information collected during restaurant onboarding, verification, account management, food ordering operations, table booking management (where applicable), settlement processing, customer support and other services provided through the Express Foodie Restaurant Partner Platform.

By registering as a Restaurant Partner or using any Express Foodie Restaurant Partner service, you acknowledge that you have read, understood and agreed to this Privacy Policy.

2. Company Information

Company Name:

EXPRESS FOODIE LLP

LLPIN:

ACY-6617

PAN:

AANFE0610P

Registered Office:

Govindgarh (Jaipur),
Rajasthan – 303712,
India

Support Email:

support@expressfoodie.in

Privacy Email:

privacy@expressfoodie.in

3. Scope of this Privacy Policy

This Privacy Policy applies to:

• Express Foodie Restaurant Partner Mobile Application
• Express Foodie Restaurant Partner Web Portal
• Restaurant onboarding and verification process
• Restaurant profile management
• Menu management services
• Food ordering services
• Table booking management (where available)
• Settlement and payment related services
• Restaurant support services
• Other services provided by EXPRESS FOODIE LLP to Restaurant Partners

This Privacy Policy applies only to Restaurant Partners using official Express Foodie services.

This Privacy Policy does not apply to third-party websites, applications or services that may be linked from the Express Foodie platform and are governed by their own privacy policies.

4. Our Commitment to Privacy

At EXPRESS FOODIE LLP, protecting the privacy, security and confidentiality of Restaurant Partner information is one of our highest priorities.

We are committed to:

• Collecting only the information reasonably required to provide our services.
• Using Restaurant Partner information lawfully, fairly and responsibly.
• Protecting personal and business information using reasonable administrative, technical and organizational security measures.
• Limiting access to authorized personnel only where operationally necessary.
• Maintaining transparency regarding how information is collected, used, shared and protected.
• Respecting the privacy rights of Restaurant Partners under applicable laws.

5. Services Covered Under This Policy

This Privacy Policy covers Restaurant Partner use of:

• Restaurant Registration and Onboarding
• Mobile Number OTP Login
• Restaurant Profile Management
• Business Information Management
• Restaurant Verification
• Menu Management
• Restaurant Images Management
• Order Management
• Table Booking Management (where available)
• Earnings and Settlement Information
• Reports and Statements
• Customer Support
• Notifications
• Restaurant Account Management

6. Effective Date

Effective Date:

DD/MM/YYYY

Last Updated:

DD/MM/YYYY

EXPRESS FOODIE LLP may update or modify this Privacy Policy from time to time to reflect changes in applicable laws, operational requirements, platform features, security practices or business processes.

The latest version of this Privacy Policy will always be made available through the Express Foodie Restaurant Partner Platform or other official communication channels.

Where required, significant changes may be communicated through the Restaurant Partner application, website, email or other official communication methods.

Continued use of the Express Foodie Restaurant Partner Platform after such updates constitutes acceptance of the revised Privacy Policy.

7. Acceptance of this Policy

By registering, completing onboarding, submitting business information, logging into the Restaurant Partner Platform, accessing the Restaurant Partner application or using any services provided by EXPRESS FOODIE LLP, you acknowledge that you have read, understood and agreed to this Privacy Policy.

If you do not agree with this Privacy Policy, you should not register as a Restaurant Partner or use the Express Foodie Restaurant Partner Platform or related services.

1. Information You Provide To Us

When you apply to become a Restaurant Partner or use the Express Foodie Restaurant Partner Platform, EXPRESS FOODIE LLP may collect certain personal, business and operational information directly from you.

The information collected depends on the services you use, the onboarding process and applicable legal or business requirements.

2. Information Generated Through Platform Usage

While using the Restaurant Partner Platform, certain operational information may be generated, including:

• Restaurant Profile Information
• Order Information
• Table Booking Information (where applicable)
• Earnings Information
• Settlement Information
• Reports Generated through the Platform
• Customer Ratings and Reviews
• Support Requests
• Account Activity

This information is used to operate, improve and support the Restaurant Partner Platform and related services.

3. Information Available Through the Restaurant Partner Platform

Depending on the services enabled for your Restaurant Partner account, the Express Foodie Restaurant Partner Platform may display operational information to assist you in managing your restaurant.

The information available through the platform may include:

• Order Details
• Table Booking Details (where applicable)
• Customer Name
• Order ID
• Order Items
• Delivery Address for active orders, where operationally required
• Customer Contact Number where reasonably necessary for order-related communication
• Settlement Reports
• Earnings Information
• Customer Ratings and Reviews
• Operational Reports generated through the platform

Where available, certain reports and settlement information may be exported in supported formats such as:

• CSV
• Microsoft Excel
• PDF

The availability of dashboard features, reports and export formats may change from time to time as the Express Foodie Restaurant Partner Platform evolves.

Restaurant Partners are responsible for maintaining the confidentiality of information accessible through their accounts and must use such information only for legitimate business purposes related to services provided through the Express Foodie Platform.

4. Information Collected Automatically

When you use the Restaurant Partner Platform, certain technical information may be collected automatically, including:

• Device Model
• Operating System Version
• Application Version
• Device Language
• Device Identifier
• IP Address (where applicable)
• Crash Logs
• Error Reports
• Session Information

This information helps us:

• Improve platform performance
• Detect technical issues
• Maintain platform security
• Improve service reliability
• Provide technical support

5. Information We Do Not Collect

Unless specifically required for a feature or permitted by applicable law, EXPRESS FOODIE LLP does not intentionally collect or access:

• Contact List
• SMS Messages
• Call History
• Personal Photos or Videos unrelated to restaurant onboarding or profile management
• Device Files unrelated to services provided through the platform
• Debit Card PIN
• Credit Card PIN
• CVV
• UPI PIN
• Internet Banking Password
• Biometric Information

6. Accuracy of Information

Restaurant Partners are responsible for ensuring that all information and documents submitted to EXPRESS FOODIE LLP are accurate, complete and up to date.

Providing false, inaccurate, misleading or unauthorized information may affect onboarding, verification, access to services or continued use of the Express Foodie Restaurant Partner Platform in accordance with applicable policies and agreements.

7. Future Services

If EXPRESS FOODIE LLP introduces new services, features or regulatory requirements that require additional information or documentation, Restaurant Partners will be informed appropriately and this Privacy Policy may be updated accordingly.

1. Overview

EXPRESS FOODIE LLP requests only those device permissions that are reasonably necessary to provide Restaurant Partner services through the Express Foodie Restaurant Partner Platform.

These permissions help Restaurant Partners manage restaurant operations, maintain restaurant information, receive important notifications and perform other platform-related activities.

Restaurant Partners may allow, deny or revoke permissions at any time through their device settings. However, disabling certain permissions may affect the availability or proper functioning of specific features within the Restaurant Partner Platform.

2. Location Permission

The Express Foodie Restaurant Partner application may request access to your device location while the application is in use.

Why We Use Location

Location information may be used to:

• Verify the restaurant's operating location.
• Support restaurant onboarding and verification.
• Improve location accuracy for restaurant listings.
• Assist in providing location-based operational services where applicable.

Location information is collected only for purposes related to the services provided through the Restaurant Partner Platform.

Express Foodie does not collect background location data through the Restaurant Partner application.

Restaurant Partners may manage location permission at any time through their device settings.

3. Camera Permission

The Express Foodie Restaurant Partner application may request access to your device camera.

Why We Use Camera

Camera access may be used for:

• Capturing and uploading restaurant documents during onboarding.
• Uploading restaurant logo, cover image and gallery images.
• Uploading menu images.
• Updating restaurant profile information where applicable.

The camera is accessed only when the Restaurant Partner voluntarily chooses to use a camera-related feature.

Express Foodie does not access the device camera without user interaction or permission.

4. Notification Permission

The Express Foodie Restaurant Partner application may send notifications to keep Restaurant Partners informed about important platform activities.

Notifications may include:

• Restaurant account updates
• Order notifications
• Table booking notifications (where applicable)
• Settlement-related notifications
• Platform announcements
• Support-related updates
• Service updates and new features

Restaurant Partners may disable notifications through their device settings. However, doing so may result in missing important operational or account-related updates.

5. Phone Permission

The Express Foodie Restaurant Partner application may request phone-related permission for communication features.

Why We Use Phone Permission

Phone-related functionality may be used to:

• Contact Express Foodie Customer Support.
• Contact authorized Express Foodie operational representatives when assistance is required.
• Facilitate communication related to restaurant operations where applicable.

Express Foodie does not use this permission to:

• Access call history
• Read phone logs
• Record phone calls

Phone-related functionality is used only when initiated by the Restaurant Partner.

6. Permissions We Do Not Currently Use

At present, the Express Foodie Restaurant Partner application does not request or access:

• Contacts
• SMS Messages
• Call History
• Background Location
• Microphone
• Device Storage

If any additional permission becomes necessary due to new platform features or legal requirements, Restaurant Partners will be informed appropriately and this Privacy Policy may be updated accordingly.

7. User Control Over Permissions

Restaurant Partners have control over the permissions granted to the Express Foodie Restaurant Partner application.

Restaurant Partners may:

• Allow permissions
• Deny permissions
• Revoke permissions at any time

through their device settings.

Please note that denying or revoking certain permissions may limit the availability or proper functioning of specific features of the Restaurant Partner Platform.

1. Overview

EXPRESS FOODIE LLP uses Restaurant Partner information only for legitimate business, operational, security and legal purposes related to the Express Foodie Restaurant Partner Platform.

Information is processed only to the extent reasonably necessary for providing platform services, maintaining business relationships, supporting restaurant operations and complying with applicable laws.

2. Restaurant Verification

Restaurant Partner information may be used to:

• Verify the identity of the Restaurant Partner.
• Review business information and submitted documents.
• Complete restaurant onboarding and verification.
• Maintain the integrity of the Express Foodie Restaurant Partner Platform.

3. Restaurant Listing

Restaurant information may be used to:

• Create and manage restaurant listings.
• Display restaurant profile information on the Express Foodie Platform.
• Enable customers to discover restaurants.
• Display restaurant business information, operating hours, menu and other information voluntarily provided by the Restaurant Partner.

4. Menu Management

Restaurant information may be used to:

• Display menu items and related information.
• Maintain restaurant menu records.
• Process menu updates and approved changes.
• Improve menu management services available through the Restaurant Partner Platform.

5. Order Management

Restaurant Partner information may be used to:

• Facilitate food ordering services.
• Enable communication related to customer orders.
• Support order fulfilment and operational activities.
• Generate order records and operational reports.

6. Table Booking Management

Where table booking services are available, Restaurant Partner information may be used to:

• Process table booking requests.
• Display table booking availability.
• Support booking management.
• Maintain booking records.

7. Payment Settlement

Financial information may be used to:

• Process payment settlements.
• Verify financial information.
• Maintain settlement records.
• Perform financial reconciliation.
• Support accounting and audit requirements.

8. Commission, Charges and Taxes

Restaurant Partner information may be used for purposes related to:

• Applying applicable platform commissions.
• Processing payment gateway charges where applicable.
• Supporting taxation, accounting and financial reporting requirements.
• Complying with applicable legal and regulatory obligations.

Details relating to commissions, business charges and settlement calculations are governed by the applicable Restaurant Partner Agreement, Settlement Policy or other applicable business policies and do not form part of this Privacy Policy.

9. Fraud Prevention and Platform Security

Restaurant Partner information may be used to:

• Detect and prevent fraudulent activities.
• Verify account authenticity.
• Protect the security and integrity of the Express Foodie Platform.
• Investigate suspected misuse or unauthorized activities.
• Maintain a safe platform for Restaurant Partners, customers and delivery partners.

10. Customer Support

Restaurant Partner information may be used to:

• Respond to support requests.
• Resolve technical issues.
• Provide operational assistance.
• Investigate complaints or service-related concerns.
• Improve customer and Restaurant Partner support services.

11. Legal and Regulatory Compliance

Restaurant Partner information may be processed where reasonably necessary to:

• Comply with applicable laws and regulations.
• Respond to lawful requests from competent authorities.
• Meet accounting, taxation and audit obligations.
• Protect the legal rights, safety and security of EXPRESS FOODIE LLP and its stakeholders.
• Enforce applicable agreements, policies and legal obligations.

12. Future Services

If EXPRESS FOODIE LLP introduces new services or platform features that require Restaurant Partner information to provide those services, such information will be processed in accordance with this Privacy Policy and applicable laws. Where appropriate, this Privacy Policy may be updated to reflect such changes.

1. Sharing Information with Customers

To enable customers to identify and place orders from your restaurant, certain restaurant information may be displayed or shared through the Express Foodie Platform.

This may include:

• Restaurant Name
• Restaurant Logo
• Restaurant Cover Image
• Restaurant Gallery Images
• Menu Information
• Cuisine Categories
• Business Hours
• Restaurant Address (where applicable)
• Customer Ratings and Reviews
• Table Booking Availability (where applicable)

This information is shared solely for providing restaurant discovery, ordering, table booking and other services available through the Express Foodie Platform.

2. Sharing Information with Delivery Partners

To facilitate order collection and delivery, certain restaurant information may be shared with authorized Delivery Partners.

This may include:

• Restaurant Name
• Pickup Address
• Restaurant Contact Information (where necessary)
• Order Information necessary for pickup
• Operational instructions related to order collection (where applicable)

This information is shared only to facilitate the pickup and delivery of customer orders.

3. Sharing Information with Payment Service Providers

Where payment settlement services are provided through authorized payment service providers or banking partners, certain financial information may be shared to process settlements and related financial transactions.

This may include:

• Account Holder Name
• Bank Account Details
• IFSC Code
• UPI ID (where applicable)
• Settlement-related information

Payment service providers process such information in accordance with their own privacy and security practices.

EXPRESS FOODIE LLP does not store sensitive payment credentials such as debit card PIN, credit card PIN, CVV or UPI PIN.

4. Sharing Information with Government Authorities

EXPRESS FOODIE LLP may disclose Restaurant Partner information where required:

• To comply with applicable laws or regulations.
• In response to valid legal processes, court orders or lawful requests from competent authorities.
• For fraud prevention or investigation.
• To protect the rights, property, safety or security of EXPRESS FOODIE LLP, Restaurant Partners, customers, delivery partners or the public.
• To comply with regulatory, taxation or statutory obligations.

Any such disclosure will be limited to the extent reasonably required under applicable law.

5. Sharing Information with Authorized Personnel

Restaurant Partner information may be accessed by authorized Express Foodie personnel only where such access is necessary for legitimate business or operational purposes.

This may include activities related to:

• Restaurant onboarding
• Account verification
• Customer support
• Technical support
• Settlement assistance
• Compliance
• Fraud prevention
• Platform operations

Access to Restaurant Partner information is restricted to authorized personnel based on operational responsibilities and business requirements.

6. We Do Not Sell Personal Information

EXPRESS FOODIE LLP does not sell or rent Restaurant Partner personal information to third parties for their independent marketing purposes.

Any sharing of information is carried out only for providing Express Foodie services, complying with legal obligations, supporting business operations or with the Restaurant Partner's authorization, where applicable.

1. Our Commitment to Security

EXPRESS FOODIE LLP is committed to protecting the personal, business and financial information of Restaurant Partners.

We implement reasonable administrative, technical and organizational measures to safeguard Restaurant Partner information against unauthorized access, misuse, alteration, disclosure, accidental loss or destruction.

Our security practices are designed to help maintain the confidentiality, integrity and availability of information processed through the Express Foodie Restaurant Partner Platform.

2. Security Measures

To help protect Restaurant Partner information, EXPRESS FOODIE LLP implements reasonable security measures, which may include:

• Secure HTTPS communication for data transmission.
• Authentication and access control mechanisms.
• Protected databases and cloud infrastructure.
• Role-based access controls for authorized personnel.
• Security monitoring and routine system maintenance.
• Security logging and audit records where applicable.
• Periodic review and improvement of security practices.

Security measures may be updated from time to time to improve the protection of Restaurant Partner information and platform services.

3. Limited Access to Information

Restaurant Partner information is accessible only to authorized Express Foodie personnel who require access to perform legitimate business, operational, technical, financial or compliance-related responsibilities.

Where operationally necessary, limited information may also be made available to authorized customers, delivery partners, payment service providers or other authorized service providers solely for providing services through the Express Foodie Platform.

Access to Restaurant Partner information is restricted based on operational responsibilities and business requirements.

4. Secure Data Transmission

Information exchanged between Restaurant Partners and the Express Foodie Restaurant Partner Platform is transmitted using secure communication methods designed to reduce the risk of unauthorized access, interception or misuse during transmission.

5. System Infrastructure

Restaurant Partner information may be stored and processed using protected cloud infrastructure and technology systems used for operating the Express Foodie Platform.

EXPRESS FOODIE LLP takes reasonable steps to maintain the security, reliability and availability of its systems in accordance with operational requirements and applicable laws.

6. Security Monitoring and Audit Records

To support platform security, operational integrity and service reliability, EXPRESS FOODIE LLP may maintain system logs, security records and audit information where reasonably necessary.

Such information may be used for:

• Security monitoring
• Fraud prevention
• System maintenance
• Troubleshooting
• Performance improvement
• Compliance with applicable legal obligations

Access to security logs and audit records is limited to authorized personnel where required for legitimate business, operational or legal purposes.

7. No Absolute Security Guarantee

While EXPRESS FOODIE LLP takes reasonable steps to protect Restaurant Partner information, no method of electronic storage, cloud infrastructure or internet transmission can be guaranteed to be completely secure.

Accordingly, although we strive to implement appropriate security measures, we cannot guarantee absolute security of information transmitted, processed or stored through electronic systems.

8. Continuous Security Improvements

EXPRESS FOODIE LLP continuously reviews and improves its security practices, technical safeguards and operational procedures to strengthen the protection of Restaurant Partner information and maintain a secure Restaurant Partner Platform.

1. Overview

EXPRESS FOODIE LLP collects and processes certain financial information necessary for payment settlement and other business-related financial operations associated with the Restaurant Partner Platform.

Financial information is collected only for legitimate business purposes and is handled using reasonable administrative, technical and organizational security measures.

2. Financial Information We Collect

For payment settlement and financial verification, we may collect information including:

• Account Holder Name
• Bank Name
• Bank Account Number
• IFSC Code
• UPI ID (where applicable)
• Passbook Photograph or Bank Account Proof
• Cancelled Cheque (where applicable)

Restaurant Partners are responsible for ensuring that the financial information provided is accurate and up to date.

3. Payment Settlement

Financial information provided by Restaurant Partners may be used for:

• Processing settlement payments
• Payment verification
• Financial reconciliation
• Accounting and audit purposes
• Compliance with applicable legal and regulatory requirements

Settlement of payments is subject to the applicable Express Foodie Restaurant Partner agreements, operational policies and settlement policies.

4. Commission and Other Business Charges

Express Foodie may apply platform commissions, payment gateway charges, taxes or other applicable business charges in accordance with the Restaurant Partner Agreement, Settlement Policy, applicable operational policies or as otherwise agreed with the Restaurant Partner.

Details relating to such charges are governed by the applicable business agreements and policies and do not form part of this Privacy Policy.

5. Payment Security

EXPRESS FOODIE LLP takes reasonable measures to protect financial information processed through the Restaurant Partner Platform.

Financial information is protected through appropriate security practices, including:

• Secure HTTPS communication
• Encrypted data transmission
• Access controls for authorized personnel
• Protected systems and infrastructure
• Reasonable security and monitoring practices

6. Information We Do Not Store

EXPRESS FOODIE LLP does not store sensitive payment credentials such as:

• Debit Card PIN
• Credit Card PIN
• CVV
• UPI PIN
• Internet Banking Password

Where payment services are provided through authorized payment service providers, sensitive payment credentials are processed in accordance with the privacy and security practices of the respective service provider.

7. Tax and Regulatory Compliance

Restaurant Partners remain responsible for complying with their own applicable taxation, licensing and regulatory obligations.

Where required under applicable laws, Express Foodie may process or retain financial information for accounting, taxation, audit, fraud prevention, dispute resolution or other legal and regulatory purposes.

8. Payment Related Support

Restaurant Partners may contact EXPRESS FOODIE LLP through officially provided support channels for payment settlement, financial account or payment-related assistance.

1. Overview

EXPRESS FOODIE LLP respects the privacy and rights of its Restaurant Partners.

Restaurant Partners are provided with certain rights regarding their account information, business information and use of the Express Foodie Restaurant Partner Platform.

These rights are intended to promote transparency, accuracy and responsible use of the platform and may be updated from time to time in accordance with applicable laws, operational requirements and platform improvements.

2. Right to Access Account Information

Restaurant Partners may access and review eligible information associated with their Restaurant Partner account through the Express Foodie Restaurant Partner Platform.

This may include:

• Restaurant Profile Information
• Business Information
• Contact Information
• Restaurant Images
• Menu Information
• Business Verification Status
• Earnings Information
• Settlement Information
• Order History
• Table Booking History (where applicable)

Availability of certain information may depend on the services enabled for the Restaurant Partner account.

3. Right to Request Updates to Restaurant Information

Restaurant Partners may update or request updates to eligible business information through the Restaurant Partner Platform or other officially provided methods.

Certain information, including regulatory or business verification information, may require review or verification before changes become effective.

4. Right to Request Updates to Financial Information

Restaurant Partners may request updates to eligible financial or settlement-related information, including bank account details or UPI information, through officially provided procedures.

For security, verification or regulatory purposes, Express Foodie may require additional verification before such changes are approved or applied.

5. Right to Access Reports

Where available, Restaurant Partners may access operational reports and settlement-related information generated through the Restaurant Partner Platform.

Available reports may include earnings, settlements or other operational information and may be provided in supported formats such as CSV, Microsoft Excel or PDF.

The availability of reports and export formats may change as the platform evolves.

6. Right to Request Account Deactivation

Restaurant Partners may request deactivation of their Restaurant Partner account through officially provided communication channels.

Account deactivation does not automatically result in permanent deletion of information.

Certain information may continue to be retained where reasonably necessary for:

• Compliance with applicable laws
• Financial and accounting records
• Audit requirements
• Fraud prevention
• Dispute resolution
• Security purposes
• Enforcement of applicable agreements and policies

7. Right to Contact Support

Restaurant Partners may contact EXPRESS FOODIE LLP for assistance regarding:

• Restaurant account related queries
• Onboarding and verification
• Technical support
• Settlement related queries
• Privacy related concerns
• Platform related issues
• Other Restaurant Partner services

Restaurant Partners may contact Express Foodie through officially provided support channels, including in-app support, official email or other authorized communication methods.

8. Policy Updates

Restaurant Partner rights described in this Privacy Policy may be updated from time to time to reflect:

• New platform features
• Service improvements
• Operational requirements
• Security enhancements
• Applicable legal or regulatory requirements

Where appropriate, material updates will be communicated through the Restaurant Partner Platform, website or other official communication channels.

1. Data Retention

EXPRESS FOODIE LLP retains Restaurant Partner information only for as long as reasonably necessary to:

• Provide Restaurant Partner services.
• Maintain Restaurant Partner accounts.
• Process settlements and financial records.
• Support restaurant operations.
• Comply with applicable laws and regulatory requirements.
• Prevent fraud and misuse of the platform.
• Resolve disputes and complaints.
• Maintain accounting, taxation and audit records.
• Protect the legal rights of EXPRESS FOODIE LLP and its stakeholders.
• Enforce applicable agreements and policies.

Information is retained only for the period reasonably required for the purposes described above or as otherwise required under applicable law.

2. Account Deactivation

When a Restaurant Partner account is deactivated, access to the Restaurant Partner Platform may be discontinued.

However, certain information may continue to be retained where reasonably necessary for:

• Legal and regulatory compliance
• Financial and accounting purposes
• Taxation and audit requirements
• Fraud prevention
• Dispute resolution
• Security purposes
• Enforcement of applicable agreements and policies

Account deactivation does not automatically result in permanent deletion of Restaurant Partner information.

3. Data Deletion Requests

Restaurant Partners who wish to request deletion of eligible personal information may contact EXPRESS FOODIE LLP through officially provided support channels.

Deletion requests will be reviewed in accordance with applicable laws, regulatory obligations and Express Foodie's legitimate operational requirements.

Certain information may continue to be retained where legally required or reasonably necessary for accounting, taxation, audit, fraud prevention, dispute resolution, security or compliance purposes.

4. Secure Disposal

Where Restaurant Partner information is no longer required and no legal, regulatory or operational obligation exists to retain it, EXPRESS FOODIE LLP will take reasonable steps to securely delete, anonymize or otherwise dispose of such information using appropriate administrative, technical and organizational measures.