Privacy Policy
1. Introduction
Ubbli App(“we” or “us”) takes the privacy of your information very seriously. Our Privacy Policy is designed to tell you, the user of our services, about our practices regarding the collection, use and disclosure of personal information about you that may be provided via the Ubbli App Apps or otherwise.
It applies to Information collected by us, or provided by you on the Ubbli App apps, the Ubbli Website (at www.ubbli.com) or in any other way (such as over the telephone). It is also intended to assist you in making informed decisions when using our Website, Apps and our products and services. Please take a minute to read and understand the policy.
All your personal Information shall be held and used in accordance with the EU General Data Protection Regulation 2016/679 (“GDPR”) and national laws implementing GDPR and any legislation that replaces it in whole or in part and any other legislation relating to the protection of personal data.
2. What information do we collect
When you visit our Website you may provide us with personal information including but not limited to name, email address, mobile phone number, birthdate (“Information”). You may provide us with Information in a number of ways:
2.1 by supplying us with the Information as listed above, on an individual basis by registering as a registered user or subscribing to receive updates or offers from us. To become a registered user you must provide us with your email address, but you may also provide us with additional information if you choose to do so.
2.2 by corresponding with us by email, in which case we may retain the content of your email messages together with your email address and our responses;
2.3 by Information provided when you use the Ubbli Apps;
2.4 We may collect Information about your computer, including where available your IP address, operating system, browser type and the geographical location of your computer, for system administration purposes. We may also report aggregate information to our partner restaurants. This is statistical data about browsing actions and patterns and does not identify you as an individual.
2.5 We also collect responses from trusted Payment Service Providers when you make purchases on the Platform. Depending on payment method, this may include a subscription ID that is sent to the Payment Service Provider. To complete purchases via the Ubbli app we require you to provide certain financial information (e.g. your PayPal user name or credit card information) in order to facilitate the processing of payments.
2.6 The Payment Service Provider needs to collect payment information (credit card information), as it is necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations), without it, you will not be able to use the Ubbli platform. Ubbli will only keep a payment token to process your payment.
2.7 We collect Location Data in several ways:
from your wireless carrier,
directly from the device on which you use our Services.
The way in which we collect Location Data is different depending on whether you are accessing the Services through a website or a mobile application.
2.8 Other Information: We may collect Other Information about your use of our Services. This includes, for example, your device type, carrier provider, browser type, operating system, internet domain and host name, date and time of access as well as referring and onward URL, as well as transactional data about the activities you undertake and how you interact with the Services, such as what data is displayed, clicked on or shared, the click stream patterns, and the length of time spent on each site or page; and searches you may conduct on the Services.
2.9 When you connect with us through social media, we may collect account or profile information.
You may choose to enable, log into or sign on to the Services through Facebook or other networking services ("Social Networking Services"). When you connect using your Social Networking Services accounts, we may collect Personal Data that you have provided to that Social Networking Service. For example, when you log in with your Facebook credentials, with your consent we may collect Personal Data from your Facebook profile that is permitted under Facebook’s Terms of Use, such as your email address. If you do not want to provide us with this information, you will need to amend the privacy settings on your Social Networking Services account. For more information, please review the privacy disclosures and terms of your Social Networking Services account, which govern how that account information is collected and shared with us.
3. How do we use your Personal Data
We use the data we collect to operate our business, advertise and improve our existing Platform, develop new services and to improve and personalize your experiences interacting with us. We also use your Personal Data to communicate with you.
We will use your Personal Data for the following purposes:
1. Operate our business and run our Services.
We use your Personal Data to create and manage your personal account at Ubbli and to process your orders.
2. Personalize experiences on our Services, better understand our Customers and gain customer insights
We use your Personal Data to conduct analyses in order to provide you with relevant functionality. This includes showing you a map or list view of nearby stores and suggesting the most relevant stores for you.
We may conduct profiling based on your interactions with the Ubbli Platform, your purchase history, your profile information and preferences, and other content you submit to the Ubbli Platform.
We process this information given our legitimate interest in improving the Ubbli Platform and our Customers’ experience with it, and where it is necessary for the adequate performance of the contract between you and the Store.
3. Communicate with you and respond to your requests
When registering an account with us, you have a choice of receiving announcements about us and our products and Services via email and/or push notifications. If you consent to such messages, we may use your Personal Data and Other Information to communicate with you about the Ubbli products or Services you have purchased or used and to notify you of other products, promotions and Services we think may be of interest to you. You can manage your communication preferences at any time from the mobile applications.
We may use your Personal Data to respond to your requests for technical support, online services, product information or to any other communication you initiate. This includes accessing your account to address technical support requests.
Additionally, when you request it, we will use your Personal Data to enroll you in contests, programs, or offers. We also may use your Personal Data to notify you of promotions and other special offers.
Please note that irrespective of your email and push notifications settings, we may send you notifications pertaining to the performance of our Services, such as revision of our Terms or this Privacy Policy or other formal communications relating to products or Services you have purchased or use. This also includes emails, push notifications and text messages in the event one or more of your purchases are cancelled by a store. We do this to avoid a situation where you show up at a store to pick up food when the store has no surplus food left to sell.
4. Tailor our advertising and marketing
We use Personal Data and Other Information to assist us in our advertising and marketing campaigns, to provide you with information on the products and Services that we think are most relevant to you.
Given you have provided your consent, we may send you promotional messages, marketing, advertising and other information that may be of interest to you based on your preferences and social media advertising through social media platforms. This includes contests, sweepstakes and other promotional activities. You always have the possibility to demand Ubbli not to send you any promotional material or information.
We will process your personal information for the purposes described above given our legitimate interest in undertaking marketing activities to offer you products that may be of your interest.
5. Create and Maintain a Trusted and Safe Environment
We may use Personal Data to detect and prevent fraud, spam, abuse, security incidents, and other harmful activity. To conduct security investigations and risk assessments, and to verify or authenticate information or identifications provided by you.
4. Where is your Personal Data stored
Ubbli uses a variety of third party service providers to help us provide services related to the Ubbli Platform. Service providers may be located inside or outside of the European Economic Area (“EEA”). Any such transfer of your Personal Data will be carried out in compliance with applicable laws.
These providers have limited access to your information to perform these tasks on our behalf and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this Privacy Policy. We have - prior to sharing your information with third parties – established the necessary means to ensure an adequate level of data protection. This may be an agreement on the basis of the EU Model Clauses (a set of clauses issued by the European Commission).
5. For how long is your Personal Data stored
Ubbli will retain your Personal Data for as long as you maintain an Account or as needed to provide you the Services. We will also retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
6. Who is responsible for your Personal Data
Ubbli, is the controller of the Personal Data you submit to us and responsible for your Personal Data.
7. Who has access to your Personal Data
Your data may be shared within the Ubbli corporate family of companies that are related by common ownership or control (Ubbli Group). We never pass on, sell or swap your data for marketing purposes to third parties outside the Ubbli group. Data that is forwarded to third parties is only used to provide you with the services mentioned above, for example media services and agencies for distribution of newsletter and credit reference or debt collection agencies for the purpose of credit rating checks, identity checks and debt collection.
Ubbli may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Ubbli, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service or other agreements with Members, or (v) to protect the rights, property or personal safety of Ubbli and its Members.
8. How do we protect your Personal Data
We have taken technical and organizational measures to protect your data from loss, manipulation and unauthorized access. We continually adapt our security measures in line with technological progress and developments. To make card purchases with us as secure as possible, all information is sent in encrypted form. This means that the information is passed through a secure connection and that external parties cannot read your Personal Data. For card purchases, we work with PCP compliant Payment Service Providers that help us to check directly with your bank that the card is valid for purchases. Our Payment Service Providers process your card details according to the international security standards PCI DSS, which was developed by the card companies VISA, MasterCard, Diners, American Express and JCB. This means that your card details are processed with a very high level of security. When you pay by card, we reserve the right to carry out an identity check.
9. What are your rights
You may exercise any of the rights described in this section before by sending a message through our contact form. Please note that we may ask you to verify your identity before taking further action on your request.
9.1 Managing Your Information
You may access and update some of your information through your Account settings. If you have chosen to connect your Ubbli Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.
9.2 Rectification of Inaccurate or Incomplete Information
You have the right to ask us to correct inaccurate or incomplete personal information concerning you and which you cannot update yourself within your Ubbli Account.
9.3 Data Access and Portability
You are entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
9.4 Data Retention and Erasure
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Ubbli Platform to you, you can request that we erase your personal information and close your Ubbli Account. Please note that if you request the erasure of your personal information:
We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Ubbli may keep some of your information for tax, legal reporting and auditing obligations.
Information you have shared with others (e.g., Reviews may continue to be publicly visible on the Ubbli Platform, even after your Account is cancelled). Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
Because we maintain the Ubbli Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
9.5 Withdrawing Consent and Restriction of Processing
You may withdraw your consent at any time by sending a communication to Ubbli. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
9.6 Objection to Processing
You are entitled to object to Ubbli’s processing of your personal information. If you object to such processing Ubbli will no longer process your personal information but may also be required to close your account.
Ubbli can continue processing of personal data for specific purposes if Ubbli can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
Where your personal information is processed for direct marketing purposes, you may, at any time ask Ubbli to cease processing your data for these direct marketing purposes by writing us through our contact form.
10. Business Transfer
If Ubbli undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.
11. Lodging Complaints
You have the right to lodge complaints about the data processing activities carried out by Ubbli before the competent data protection authorities.