WOLT PRIVACY STATEMENT
Wolt Enterprises Oy and Wolt Enterprises Deutschland GmbH (“Wolt”, “we”) process personal data of you within and in connection with the Wolt Services.
In this Privacy Statement, “Wolt Services” refers jointly to the website wolt.com (“Website”) and the Wolt App (“Wolt App”) through which you can purchase products and delivery services from Wolt Enterprises Deutschland GmbH. In this Privacy Statement, the word “User” or “you” refers to users of the Wolt Services.
Our Privacy Statement explains, for example, the types of personal data we process, how we process the personal data and how you may exercise your rights as a data subject (e.g. right to object, right of access).
This Privacy Statement may be updated from time to time in order to reflect the changes in data processing practices or otherwise. You can find the current version of this Privacy Statement on the Website. We will not make substantial changes to this Privacy Statement or reduce the rights of the Users under this Privacy Statement without providing a notice thereof.
1. DATA CONTROLLER(S)
This Privacy Statement applies to processing of personal data carried out by Wolt.
In relation to the processing of personal data of Users, Wolt Enterprises Oy and Wolt Enterprises Deutschland GmbH are acting as joint controllers.
This means that Wolt Enterprises Oy and Wolt Enterprises Deutschland GmbH together determine the purposes for and means by which personal data is processed. Wolt Enterprises Oy as the parent company of Wolt Enterprises Deutschland GmbH implements the decisions regarding the purposes and means of processing personal data. Wolt Enterprises Oy has further been appointed responsible by its subsidiary companies for handling all data subject requests and questions relating to the processing of your personal data. Wolt Enterprises Oy and Wolt Enterprises Deutschland GmbH have entered into a joint controllership agreement in accordance with article 26 of the EU General Data Protection Regulation (“GDPR”) essentials of which can be acquired by contacting Wolt using the details shown below.
2. WOLT’S CONTACT DETAILS
Name: Wolt Enterprises Oy
Business ID: 2646674-9
Correspondence address: Arkadiankatu 6, 00100 Helsinki, Finland
E-mail address: firstname.lastname@example.org
Name: Wolt Enterprises Deutschland GmbH
Business ID: HRB 217122 B
Correspondence address: Stralauer Allee 6, 10245 Berlin, Germany
E-mail address: email@example.com
3. PERSONAL DATA PROCESSED AND SOURCES OF DATA
The personal data collected and processed by us can be divided into two general data categories: User Data and Analytics Data.
User Data is personal data collected directly from you. We may collect User Data from our Users as soon as Users register to the Wolt Services or subscribe to a newsletter. Further, please note that we also collect data with regard to purchase agreements and payments you conclude or carry out through the Wolt Services.
User Data that is necessary in order to use the Wolt Services
The following personal data collected and processed by us is necessary for a proper performance of the contract concluded between you and us and for the compliance with our legal obligations.
When you register to the Wolt Services and create a user account, you need to provide us with the following information:
· full name
· telephone number
· email address
· information relating to your payment instrument(s) such as the number of your payment instrument(s) and the expiration date of your payment instrument(s) (required for the purposes of ordering food products via the Wolt Services, however not stored by Wolt, since Wolt uses a third party payment service provider for processing of payments)
User Data you give us voluntarily
Your user or customer experience may be enhanced by providing us with the following information:
- Additional Account Information:
- a picture
- delivery address
- location data (if you consent to the processing of your location data)
- other information you provide either when creating a user account or later when modifying your account profile
- Other Information. We may also process other information provided by you voluntarily such as:
- information you provide when rating our services
- marketing opt-ins and opt-outs
- information you provide by phone or in email or chat correspondence with us, including call recordings of your calls with our customer service
In addition to User Data collected from you, we process certain personal data third party service providers provide about you.
If you connect or login to your user account with Facebook, Facebook shares with us personal information about you such as your profile picture, a sample of your Facebook friends and your Facebook ID.
Although we do not normally use Analytics Data to identify you as an individual, you can sometimes be recognized from it, either alone or when combined or linked with User Data. In such situations, Analytics Data can also be considered personal data under applicable laws and we will treat such data as personal data.
We may automatically collect the following Analytics Data when you visit or interact with the Wolt Services:
- Device Information. We collect the following information relating to the technical device you use when using the Wolt Services:
- device and device identification number, device IMEI
- IP address
- browser type and version
- operating system
- Internet service providers
- advertising identifier of your device
- visitor identifier
- Usage Information. We collect information on your use of the Wolt Services, such as:
- time spent on the Wolt Services
- interaction with the Wolt Services
- information on your orders made through the Wolt Services
- the URL of the website you visited before and after visiting the Wolt Services
- the time and date of your visits to the Wolt Services
- the sections of the Wolt Services you visited
- the products you searched for while using the Wolt Services
We use various technologies to collect and store Analytics Data and other information when the Users visit the Wolt Services, including cookies and web beacons.
A web beacon is a technology that allows identifying readers of websites and emails e.g. for identifying whether an email has been read.
Web analytics services
The Wolt Services use Google Analytics and other web analytics services to compile Analytics Data and reports on visitor usage and to help us improve the Wolt Services. For an overview of Google Analytics, please visit Google Analytics. It is also possible to opt-out of Google Analytics with the following browser add-on tool: Google Analytics opt-out add-on.
Advertising and visitor identifiers
The Wolt Services use pseudonymized identifiers to track and predict your app and service usage and preferences.
You can opt-out of the use of these identifiers by changing your operating system settings as follows:
Advertising identifiers can be disabled on iOS mobile devices by turning on the Limit Ad Tracking tab (Settings -> Privacy -> Advertising -> Limit Ad Tracking). For an overview and more information on the advertising identifier, please see Apple Advertising and Privacy site. For Android mobile devices, you can disable by going to Google settings, tapping “ads” under Services and turn on Opt out of Ads Personalization. For an overview and more information on the advertising identifier, please see Google Support site.
Wolt visitor identifiers can be disabled on iOS and Android mobile devices by changing your settings (for iOS: Settings -> Wolt -> Wolt settings -> Limit Tracking, and for Android: Wolt application -> Profile tab -> Settings icon in the top-right corner).
4. PURPOSES AND LEGITIMATE GROUNDS FOR THE PROCESSING OF YOUR PERSONAL DATA
There are several purposes of the processing of your personal data by Wolt. One or more of the following purposes may apply simultaneously:
To provide the Wolt Services and carry out our contractual obligations (legal ground: performance of a contract and legitimate interest under law in accordance with Art. 6(1)(b) and Art. 6(1)(f) of the GDPR)
Wolt processes your personal data to be able to offer the Wolt Services to you under the contract between you and Wolt or as otherwise may be necessary to perform the contract between you and Wolt. Wolt may also process personal data when it is necessary for an interest which is lawful and important for Wolt.
We use the data for example to process your requests, to communicate with you, to handle your payments or any refunds (where applicable) and to provide our partners (the restaurants and our courier partners) with the information necessary for the preparation or delivery of your order. If you contact our customer service, we will use the information provided by you to answer your questions or solve your complaint.
We may collect, use and share data on either your exact or approximate location, including real-time geographic location of your computer or mobile phone in order for us to show you the destination of an order and accurate information on the status of your order, as well as to display restaurants close to you. Information on your location that enables to identify you personally is not collected or used without your consent. The permission to use your location is requested in the Wolt Services. The tracking feature can be disabled through the Wolt App (Profile -> Settings -> Additional Settings -> Location and push-settings -> Location) and on your computer through the privacy and security settings in your browser.
For our legal obligations (legal ground: compliance with a legal obligation under Art. 6(1)(c) of the GDPR)
Wolt processes data to enable us to administer and fulfil our obligations under law. This includes data processed for complying with our bookkeeping obligations and providing information to relevant authorities such as tax authorities.
For claims handling and legal processes (legal ground: legitimate interest under Art. 6(1)(f) of the GDPR)
Wolt may process personal data in relation to claims handling, debt collection and legal processes. We may also process data for the prevention of fraud, misuse of our services and for data, system and network security.
For customer communication and marketing (legal ground: legitimate interest under Art. 6(1)(f) of the GDPR)
Wolt processes your personal data to contact you regarding the Wolt Services and to inform you of changes relating to them. Your personal data are also used for the purposes of marketing the Wolt Services to you. Legitimate interest is the basis for processing e.g. when we personalize our offerings and provide you with services which are more relevant to you and when we analyze information on your interests and feedback to develop our services.
When you obtain Wolt credits or tokens in accordance with the Wolt User Terms of Service and Purchase, Wolt processes your personal data to match your referral code with your user profile in order to assign the credits or tokens to the correct User account. Wolt will not process the personal data of a new User until the new User registers to the Wolt Service. Such processing is described in Section 3 above.
For quality improvement and trend analysis (legal ground: legitimate interest under Art. 6(1)(f) of the GDPR)
We may also process information about your use of the Wolt Services to improve the quality of the Wolt Services e.g. by analyzing any trends in the use of the Wolt Services. In order to ensure that our services are in line with your needs, personal data can be used for things like customer satisfaction surveys. When possible, we will do this using only aggregated, non-personally identifiable data.
Legal grounds for processing
Wolt processes your personal data to perform our contractual obligations towards you and to comply with legal obligations. Furthermore, we process your personal data to pursue our legitimate interest to run, maintain and develop our business and to create and maintain customer relationships. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy and e.g. provide you with easy to use opt-out from our marketing communications and use pseudonymized or non-personally identifiable data when possible.
In some parts of the Wolt Services, you may be requested to grant your consent for the processing of personal data. In this event, your personal data is not processed before you give consent and you may withdraw your consent at any time.
5. TRANSFER TO COUNTRIES OUTSIDE EUROPE
Wolt stores your personal data primarily within the European Economic Area. However, we have service providers and operations in several geographical locations. As such, we and our service providers may transfer your personal data to, or access it in, jurisdictions outside the European Economic Area or the User’s domicile.
We will take steps to ensure that the Users’ personal data receives an adequate level of protection in the jurisdictions in which they are processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with our service providers based on the Standard Contractual Clauses or through other appropriate safeguards.
More information regarding the transfers of personal data may be obtained by contacting us on any of the addresses indicated above.
We only share your personal data within the organization of Wolt if and as far as reasonably necessary for the purposes of this Privacy Statement.
We do not share your personal data with third parties outside of Wolt’s organization unless one of the following circumstances applies:
For the purposes set out in this Privacy Statement and to authorized service providers
To the extent that third parties (such as the restaurants which prepare your order, our courier partners who deliver your order or other third parties) need access to personal data in order for us and such third parties to perform the Wolt Services, we provide such third parties with your data. Furthermore, we may provide your personal data to our affiliates or to authorized service providers and partners who perform services for us or in collaboration with us (including data storage, accounting, sales and marketing) to process the data and to payment service providers to process your payments to us.
When data is processed by third parties on behalf of Wolt, Wolt has taken the appropriate contractual and organizational measures to ensure that your data are processed exclusively for the purposes specified in this Privacy Statement and in accordance with all applicable laws and regulations and subject to our instructions and appropriate obligations of confidentiality and security measures.
Please bear in mind that if you provide personal data directly to a third party, such as through a link in the Wolt Services, the processing is typically based on their policies and standards.
For legal reasons and legal processes
We may share your personal data with third parties outside Wolt if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, crime, security or technical issues; and/or (iii) protect the interests, properties or safety of Wolt, the Users or the public as far as in accordance with the law. When possible, we will inform you about such processing.
For other legitimate reasons
If Wolt is involved in a merger, acquisition or asset sale, we may transfer your personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all the Users concerned when the personal data are transferred or become subject to a different privacy statement.
With your explicit consent
We may share your personal data with third parties outside Wolt when we have your explicit consent to do so. You have the right to withdraw this consent at all times free of charge by contacting us.
7. STORAGE PERIOD
Wolt does not store your personal data longer than is legally permitted and necessary for the purposes of providing the Wolt Services or the relevant parts thereof. The storage period depends on the nature of the information and on the purposes of processing. The maximum period may therefore vary per use. Wolt takes reasonable steps to keep the personal data accurate and to delete incorrect or unnecessary personal data.
Most personal data relating to a User’s user account with the Wolt Services will be deleted after a period of 90 days have lapsed after the User has deleted its user account with the Wolt Services. Thereafter, a part of the personal data relating to a User’s user account with the Wolt Services may be stored only as long as such processing is required by law or is reasonably necessary for our legal obligations or legitimate interests such as claims handling, bookkeeping, internal reporting and reconciliation purposes. All personal data relating to a User’s user account with the Wolt Services will be deleted within a period of 10 years after the User has deleted its user account with the Wolt Services, with the exception of personal data required in certain rare situations such as legal proceedings.
We will store Analytics Data of Users that do not have an account with the Wolt Services for a period of 90 days.
8. YOUR RIGHTS
Right of access
You have the right to access and be informed about your personal data processed by us. We give you the possibility to view certain data through your user account with the Wolt Services or request a copy of your personal data using the contact details above.
Right to withdraw consent
In case the processing is based on a consent granted by the User, the User may withdraw the consent at any time free of charge. Withdrawing a consent may lead to fewer possibilities to use the Wolt Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to rectify
You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us. You can correct or update some of your personal data through your user account in the Wolt Services.
Right to erasure
You may also ask us to delete your personal data from our systems for example when the data is no longer necessary for the purposes for which it was collected. We will comply with such request unless we have a legitimate ground to not delete the data. Please note that if you want to delete such information, we may not be able to provide you the Wolt Services or certain features thereof.
Right to object
You have the right to object to the use of your personal data for direct marketing purposes. You may further have the right to object, on grounds relating to your particular situation, to processing of personal data which is based on our legitimate interest (article 6 (1) (f) GDPR). If you object to the further processing of your personal data, this may lead to fewer possibilities to use the Wolt Services.
Right to restriction of processing
You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. When the processing has been restricted, your data will only be stored and not processed further. For example, if you contest the accuracy of your data, such data will be restricted from processing until it is ensured that the data is accurate. This may however lead to fewer possibilities to use the Wolt Services.
Right to data portability
When processing is carried out by automated means and based on a contract or consent, you have the right to receive the personal data you have provided to us yourself in a structured and commonly used format and to independently transmit those data to a third party.
How to use your rights
The abovementioned rights may be used by sending a letter or an e-mail to us on the addresses set out above, including the following information: the full name, address, e-mail address and a phone number. We may request the provision of additional information necessary to confirm the identity of the User. We may reject or charge requests that are unreasonably repetitive, excessive or manifestly unfounded.
9. DIRECT MARKETING
We may send you information, news and offers about the Wolt Services if you have given your consent to receive such communication upon registering to the Wolt Services and creating a user account.
You can withdraw your consent anytime and prohibit us from using the User’s personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the functionalities of the Wolt Services (Profile -> Settings -> More Settings -> Push marketing opt-out) or the unsubscribe possibility offered in connection with any direct marketing messages.
10. LODGING A COMPLAINT
In case the User considers our processing of personal data to be inconsistent with the applicable data protection laws, the User may lodge a complaint with the local supervisory authority for data protection in Finland, the Data Protection Ombudsman (tietosuoja.fi). Alternatively, the User may lodge a complaint with any other supervisory authority for data protection within the EU.
11. INFORMATION SECURITY
We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, pseudonymization, firewalls, secure facilities and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability to restore the data. We regularly test the Wolt Services, systems, and other assets for security vulnerabilities.
Should despite of the security measures, a security breach occur that is likely to have negative effects to the privacy of the Users, we will inform the relevant Users and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.