Wolt Privacy Statement
Wolt Enterprises Oy and certain Wolt group companies (“Wolt”, “we”) process personal data of their users of Wolt’s food ordering services (“Wolt App”) 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. In this Privacy Statement, the word “User” or “you” refers jointly to our and our group companies’ customers, representatives and other authorized users of our customer organizations, potential customers and the users of the Wolt Services. You become a customer of Wolt when you register to the Wolt Services and create a user account.
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 on the Website. We will not make 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 is the controller of User’s personal data, which means that it determines the purposes for and means by which personal data is processed.
Wolt Enterprises Oy is further responsible for handling all data subject requests and questions relating to the personal data processing of the Wolt group.
2. WOLT’S CONTACT DETAILS
Name: Wolt Enterprises Oy Business ID: 2646674-9 Correspondence address: Arkadiankatu 6, 00100 Helsinki, Finland E-mail address: email@example.com wolt.com/hu Wolt has appointed a data protection officer who you can reach through the above contact details.
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 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 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:
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:
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 and the Customer Organization, we process certain personal data third party service providers provide about you.
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.
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
browser type and version
Internet service providers
advertising identifier of your device
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 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.
Wolt uses session-only 3rd-party tracking technologies to verify and report transactions initiated by our advertising partners. We use third parties such as TradeDoubler and Interspace for such tracking and collect the information from our website, including following:
● Time of arrival at the Wolt page
● IP address of User who reached the page
● Unique identifier of the User who arrived at the Wolt page
● Device information of User who arrived at the Wolt page
● Event ID meaning the event ID for the lead/sale taking place
● Unique tracking ID set in a cookie and session variable by redirect page
● User’s hashed email address
You can manage your cookie preferences through the cookie banner on our websites and opt out from the collecting and manage your preferences through e.g. the following websites: http://www.aboutads.info/choices and http://www.youronlinechoices.eu/.
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.
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)
Wolt processes your personal data to be able to offer the Wolt Services to you under the contract between you and Wolt or between Customer Organization 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)
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)
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)
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.
For quality improvement and trend analysis (legal ground: legitimate interest)
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 or the Customer Organization 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.
If you place an order with a Partner who is selling you medicine or other products and services relating to your health, Wolt may process a limited amount of personal data concerning your health in connection to such order. Wolt processes the personal data to the extent necessary to perform the contract between you and Wolt for purposes of managing and delivering your Order. Wolt adheres to any additional safeguards that 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 contacting Wolt support services at firstname.lastname@example.org.
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, such as the Privacy Shield Framework.
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, the Customer Organization which may pay 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.
Furthermore, we may provide your personal data to the Courier which are necessary for the delivery of the Order, in case delivery applies. Since the Courier performs the delivery service directly to you as User, the Courier is a data controller of your personal data which are necessary for the delivery of the Order. Wolt shall only provide personal data to Courier to the extent it is necessary for the delivery of the Order. Courier shall use the personal data to a limited extent which is necessary for the delivery of the Order and is in direct connection therewith (such as compliance with legal obligations, such as taxation rules), and Courier is required to comply with data privacy laws and cannot use personal data for other purposes. With respect to data processed by the Courier as data controller, the Courier is liable for compliance with data privacy (and other applicable) laws and is likewise liable for infringement thereof.
In case of delivery services, Wolt is also a data controller for personal data which is necessary for the issuance of the invoice on the delivery fee in Courier’s name.
With Partners for performance of Wolt Services
To the extent that third parties, such as the Partners which prepare 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 including your name 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 prepare 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 programme on the Wolt Service for purposes of linking any orders placed at the Partner to the relevant loyalty programme, 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 with the partner preparing your order if it's necessary e.g. for asking you whether you accept a replacement product in the order or inform you that an item is missing from your order or for any special request clarifications.
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 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. For example, you can request that we stop processing your personal data for direct marketing or profiling purposes based on legitimate interest. 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 based on the customer relationship between you and Wolt. In other cases, we do not send you direct marketing without your explicit consent. 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 anytime by contacting us on the addresses indicated above or by using the functionalities of the Wolt Services (Profile 🡪 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 the local supervisory authority for data protection of the User’s country of domicile.
The Hungarian data protection supervisory authority is the National Authority for Data Protection and Freedom of Information, with the below contact details:
Address: 1055 Budapest, Falk Miksa utca 9-11.
Postal address: 1363 Budapest, Pf.: 9.
Telephone no.: +36 (1) 391 1400.
You may file a lawsuit against the data controller on infringement grounds as a data subject. The Hungarian court shall deal with the case as a matter of urgency, and a lawsuit taken in relation to the protection of personal data is exempt from stamp duty.
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.
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.