Wolt Privacy Statement - Albania

At Wolt we take data protection seriously. Privacy and information security are at the heart of Wolt. This Privacy Policy Statement describes the key principles and practices we abide by in order to ensure your privacy is respected while using our services.

Wolt Enterprises Oy, local country-specific Wolt companies and DoorDash Inc. belonging to the same group of companies (“Wolt”, “we”) process personal data of users of Wolt’s food and retail ordering services ordered through Wolt application (“Wolt App”) and users of other Wolt delivery products and services and the visitors of the website wolt.com (“Website”).

In this Privacy Statement, the word “Wolt Services” refers jointly to the Website and the Wolt App and other services provided by Wolt to users. In this Privacy Statement, the word “User” or “you” refers jointly to our and our group companies’ customers, users of Wolt delivery services, representatives and other authorized users of our customer organizations, potential customers and the 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 (for example, right to object, right of access).

Some of our services might be subject to a separate privacy policy. If a separate privacy policy applies to a particular service, we will post it in connection with the service in question.

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 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 CONTROLLERS

This Privacy Statement applies to processing of personal data carried out by Wolt. Wolt is part of DoorDash, Inc., a technology company with an official address at 303 2nd St, Suite 800, San Francisco, CA 94107, USA. We form one team and sometimes we can decide together on processing of personal data.

In relation to the processing of personal data of Users, Wolt Enterprises Oy and Wolt Albania SHPK are acting as joint data controllers. This means that Wolt Enterprises Oy and Wolt Albania SHPK together determine the purposes for, and means by which, personal data is processed.

Wolt Enterprises Oy has been appointed responsible for handling all data subject requests and questions relating to the personal data processing of the Wolt group on behalf of the local joint controllers. This does not exempt the local controller i.e. Wolt Albania SHPK from the obligation to comply with the processing responsibilities under the applicable law.

Wolt also provides delivery as a service to other companies (for example, Wolt Drive API and eCommerce integrations). In such a case Wolt is the data processor for the parts of the processing activities related to receiving, managing and completing the delivery as well as communicating and confirming the delivery to the company in question.

2. WOLT’S CONTACT DETAILS

Wolt Enterprises Oy

Business ID: 2646674-9

Correspondence address: Pohjoinen Rautatiekatu 21, 00100 Helsinki, Finland

E-mail address: support@wolt.com

Alternatively, the data subject may contact Wolt Albania SHPK in the following contact details:

Wolt Albania SHPK

Business ID: M32418016P

Correspondence address: Rr. Ibrahim Rugova, Sky Tower, Kati 5, Ap. 2, Tirana, Albania

E-mail address: support@wolt.com

Data Protection Officer: Wolt has appointed a data protection officer who you can reach through the above contact details or by sending e-mail to privacy@wolt.com.

3. PERSONAL DATA PROCESSED AND SOURCES OF DATA

We process personal data only to the extent necessary and appropriate for the specific processing purpose. The personal data collected and processed by us can be divided into two general data categories: User Data and Usage Data.

User Data

User Data is personal data collected directly from you or from our customer organization on behalf of which you are using the Wolt Services (“Customer Organization”), as the case may be. We may collect User Data from our Users and Customer Organizations in a variety of ways, including, after conclusion of a service agreement with the Customer Organization or when Users register to the Wolt Services, subscribe to a newsletter or fill out a form. Further, please note that we also collect details of any transactions and payments you 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 in order for a proper performance of the contract between you and us as well as for our legitimate interest whilst fulfilling our contractual obligations towards our Customer Organizations and for the compliance with our legal obligations.

After the conclusion of the service agreement between us and the Customer Organization, the Customer Organization provides us with your full name and email address.

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 and other 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 and while using Wolt Services

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),

• partner-specific bonus card or participation in other loyalty programme if applicable in your country,

• when ordering age-restricted goods: age, and

• 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 related to your orders from Wolt or through Wolt Services (for example, items purchased, special instructions, date and time of order, total amount of order and other order history),

• information you provide when submitting ratings, comments or responding to surveys,

• favorite restaurants or merchants and other preferences,

• marketing opt-ins and opt-outs, and

• 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 and the Customer Organization, we process certain personal data third party service providers provide about you. For example, for corporate customers, we may process company contact person information to enable communication and marketing with the company as well as managing the customer relationship. Such data is primarily obtained from public sources such as local trade registers, companies providing this type of information services, or the companies themselves.

If your order contains products or services which may imply a health condition or other sensitive (special category) personal data, Wolt needs to process this data in order to provide the Wolt Services to you. In addition to the contents of the order, this may also include, for example, medical prescription data in the case of prescription medicine. Wolt adheres to any additional safeguards that may apply to processing such personal data under applicable laws and regulations. If required under applicable laws, Wolt will ask for separate consent for processing such personal data and you may withdraw such consent anytime through your profile settings or by contacting Wolt support at support@wolt.com.

If you connect or login to your 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. While Wolt maintains its page on Facebook both Wolt and Facebook are joint controllers for your personal data. More information on processing of personal data on Facebook is available at Meta Privacy Policy.

Usage Data

Usage Data arises from User interactions with the Wolt Services. Although we do not normally use Usage Data to identify you as an individual, you can in certain circumstances be identified from it, either alone or when combined or linked with User Data. In such situations, Usage 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 Usage Data when you visit or interact with the Wolt Services:

• Information that describes your device or browser and Wolt’s application, their versions, features, capabilities, and settings

• Information about your operator, Internet service provider and network connection type, including your IP address

• Identifiers provided by your device or third parties for application vendors or advertisers, or identifiers we create ourselves

• Country, locale, time zone and geo-IP level location information

• Where you followed a link to Wolt Services, and links you followed from Wolt Services

• Details of your interactions with, and usage of, Wolt Services. This includes, for example, usage patterns, which features you use, advertisement, participating into a specific campaign and offer impressions and interactions, and information on orders

• Data for tracking and reporting transactions initiated by our advertising partners, including timestamps, and identifiers mentioned above

For details on how to control advertising and analytics identifiers on your device, see below under the section “Cookies and other technologies”.

Cookies and other technologies

We use various technologies to collect and store Usage Data and other information when the Users visit the Wolt Services, including cookies, storing website data, and using web and application telemetry.

Cookies and other website data saved on your device allow us to identify visitors of the Wolt Services and facilitate the use of the Wolt Services and to create aggregate information of our visitors. This helps us to improve the Wolt Services and better serve our Users. The cookies and other website data will not harm your device or files. We use cookies and other website data to tailor the Wolt Services and the information we provide in accordance with the individual interests of our Users. Please note that the retention time of different cookies is limited and varies from less than a minute till indefinitely and when a specific cookie is deleted.

You can manage the cookie preferences you have submitted earlier by clicking here.

The Users may choose to set their web browser to refuse cookies. For example, the following links provide information on how to adjust the cookie and other web data settings on some popular browsers:

• Apple Safari

• Google Chrome

• Microsoft Edge

• Mozilla Firefox

Please note that some parts of the Wolt Services may not function properly if use of cookies is refused.

The Wolt Services use pseudonymized identifiers to track and predict your app and service usage and preferences. Wolt also uses session-only 3rd-party tracking technologies to verify and report transactions initiated by our advertising partners.

You can manage your cookie preferences through the cookie banner on our websites.

You can also manage your communication and other privacy settings via Wolt App.

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).

Generally, 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.

Wolt uses different third party analytics and telemetry providers, marketing or affiliate partners, and other services integrated into our client software listed below:

Please note that not all of the above vendors are necessarily being used at any given time, or on all market areas.

4. THE PURPOSES AND GROUNDS FOR THE PROCESSING

We process personal data only to the extent necessary and appropriate for the specific processing purposes. Please note that one or more of the following purposes and legal grounds may apply simultaneously.

Firstly, Wolt processes your personal data to perform our contractual obligations towards you or the Customer Organization, for example, to the extent necessary to:

• offer the Wolt Services to you under the contract between you and Wolt or between Customer Organization and Wolt or between Wolt Drive customer and Wolt;

• perform the contract between you and Wolt and for purposes of managing and delivering your Order as well as communicating with you about changes to terms and conditions, privacy policies, or other important changes related to the contract;

• handle your payments or any refunds (where applicable) and to provide our partners (the restaurants, retailers and our courier partners hereinafter collectively also as “Partner”)) with the information necessary for the preparation or delivery of your order; and

• to answer your questions or solve your support cases if you contact us.

Secondly, we may process your personal data if there is an appropriate and justifiable interest (that is, a legitimate interest) to run, maintain and develop our business or 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, for example, provide you with easy to use opt-out from our marketing communications and use pseudonymized or non-personally identifiable data when possible. You have the right to object processing of your data on the basis of legitimate interest. However, Wolt can refuse such an objection in accordance with applicable legislation, for example, if the processing is necessary for preparing, exercising or defending legal claims.

We process your personal data to the extent necessary and based on legitimate interest, for example, to:

• claims handling, debt collection and legal processes. We may also process data for the prevention of fraud, misuse of our services and for information, system and network security and safety.

• contact you regarding the Wolt Services and to inform you of changes relating to them or asking your review or feedback on Wolt Services.

• market the Wolt Services to you or show you targeted or personalized advertisements through Wolt Services or send you otherwise targeted marketing of services or products that may be of your interest. In order to form such a target group we may process information listed above in the section on Usage Data. Please note that if required by applicable law processing of personal data for marketing purposes will be based on your consent (see also section “Direct Marketing” below).

• improve the quality of the Wolt Services and develop our business, for example, by analyzing any trends in the use of the Wolt Services by processing data related to your use of Wolt Services.

• 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.

• process your data within the Wolt group of companies in accordance with this Privacy Statement.

While processing your personal data for the purposes of providing Wolt Services to you as well as other purposes stated above we may use automated means in processing that may also include automated decision-making.

Further, we may process your personal data to administer and fulfill our legal obligations. This includes data processed for complying with our bookkeeping obligations and providing information to relevant authorities such as tax authorities or law enforcement authorities in accordance with mandatory legal provisions.

In some parts of the Wolt Services, you may be requested to grant your consent for the processing of personal data. For example, within Wolt App you may manage your marketing and other permissions. If processing of your personal data is based on your consent, you may withdraw it at any time by contacting us or amending the respective consent setting for example within the Wolt App.

5. TRANSFER TO COUNTRIES OUTSIDE EUROPE

Wolt stores your personal data primarily within the European Economic Area. However, we have service providers, operations and group companies in several geographical locations. As such, we and our service providers may transfer your personal data to, or process it in, jurisdictions outside the European Economic Area or the User’s domicile. Please note that if required by applicable law, transferring your personal data outside the European Economic Area will be based on your consent.

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 appropriate and 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.

6. DATA RECIPIENTS

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, merchants or retailers which provide your order, our courier partners who deliver your order and Customer Organization which may pay your order) need access to personal data in order for us to perform the Wolt Services or for other legitimate reasons, we provide such third parties with your data. As an example, we may share your phone number with the Partner you ordered from if it's necessary, for example, for asking you whether you accept a replacement product in the order or to inform you that an item is missing from your order or for any special request clarifications.

Furthermore, we may provide your personal data to our group companies or to authorized service providers who perform services for us (including data storage, accounting, analytics, sales and marketing and payment fraud prevention) to process it for us 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.

With Partners for the performance of Wolt Services

To the extent that third parties, such as the Partners which prepare, sell and/or deliver your order, our courier partners who deliver your order and Customer Organization which may pay your order, need access to personal data in order for us to perform the Wolt Services, we provide such third parties with your data.

We provide the Partner and where applicable, its parent company or franchisor, with personal data necessary to fulfill your order. Depending on the Partner’s role this may include your name, delivery address and data relating to your purchase, including venue details, order number, time of order and delivery, delivery method, ordered products, comments and feedback that you've given about the order. Such data is shared for enabling the Partner to provide the order including, where applicable, picking up the products in the store, ensuring the quality of the Partner's service and product selection available at Wolt as well as complying with Partner's legal obligations. Where Partner processes such details for purposes of fulfilling its own rights and obligations, such as its legal obligations towards you, Partner is independent controller of the Personal Data and responsible for the lawfulness of its processing operations.

You may be able to add the details of your Partner-specific bonus card or loyalty program on the Wolt Service for purposes of linking any orders placed at the Partner to the relevant loyalty program, in accordance with the terms defined by Partner. Wolt will share such details to the Partner and Partner is independent controller of such details and thereby responsible for ensuring lawfulness of the processing.

We may also share your phone number and name with the Partner you ordered from if it's necessary, for example, for asking you whether you accept a replacement product in the order or to inform you that an item is missing from your order or for any special request clarifications or other necessary purposes related to completing the order. For deliveries that are performed by our merchant partners themselves we may also share your delivery address and phone number with those Partners.

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, for example, 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.

After a User has deleted their user account personal data 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.

We assess regularly the storage period for personal data to ensure the data is stored only for the necessary time period.

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 by contacting us.

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. We will comply with such a request unless we have a legitimate ground to not delete the data.

Right to object

You may have the right to object to certain use of your personal data if such data are processed for other purposes than necessary for the performance of the Wolt Services or for compliance with a legal obligation. 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. This may however lead to fewer possibilities to use the Wolt Services.

Right to data portability

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 contacting Wolt support or 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. If you have Wolt account we recommend you contacting us through Wolt support as that allows us to identify you more easily. 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

The User has the right to 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 or the unsubscribe possibility offered in connection with any direct marketing messages. In any case, Wolt can process the personal data of the User for marketing purposes based on their opt-in (consent) in accordance with the applicable law.

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 the other local and competent supervisory authority for data protection.

In Albania, the local supervisory authority is the Commissioner for the Right of Information and Protection of Personal Data, Abdi Toptani Str., Building no.5, 1001, Tirana, +35542237200, info@idp.al (https://www.idp.al/).

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. Furthermore, access to personal data by employees of Wolt is restricted and access is subject to what is necessary for purposes of the employee’s work assignments.