Green Vegetables

Food Angels Privacy Policy

We, Food Angels Eesti OÜ (“Food Angels” or “we”) process personal data of the users of the Food Angels mobile appliation and the visitors of the Food Angels website at www.foodangels.org. This privacy policy (the “Privacy Policy”) explains how we use the personal data we collect from you when you use our services including the Food Angels mobile application or website (together the “Food Angels Platform”).

 

By using the Food Angels Platform, you agree that your personal data will be processed in accordance with this Privacy Policy.

This Privacy Policy covers the following topics: 

  1. Important information and who we are

  2. The data we collect about you

  3. How is your personal data collected?

  4. How we use your personal data

  5. Disclosures of your personal data

  6. International transfers

  7. Data security

  8. Data retention

  9. Your legal rights

  10. Glossary

  11. Description of categories of personal data

  1. Important information and who we are

Food Angels Eesti OÜ is the controller and is responsible for your personal data.

Our full details are:

  • Full name of legal entity: Food Angels Eesti OÜ
     

  • Email address: info@foodangels.org
     

  • Postal address: Retke tee 28-11, 13419 Tallinn, Estonia
     

You have the right to make a complaint at any time to the Data Protection Inspectorate (Andmekaitse Inspektsioon), the Estonian supervisory authority for data protection issues. 

Changes to the privacy policy and your duty to inform us of changes

We keep our Privacy Policy under regular review. 

This version was last updated on 26 May 2020. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email or when you next visit or log onto the Food Angel Platform. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Food Angels Platform.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you. 

Third party links

The Food Angels Platform may, from time to time, contain links to and from the websites of our cooperation partners (including food service providers), partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

2. The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Identity Data.

  • Contact Data.

  • Financial Data.

  • Transaction Data.

  • Device Data.

  • Content Data.

  • Profile Data.

  • Usage Data.

  • Marketing and Communications Data.

  • Location Data
     

We explain these categories of data under ‘Description of categories of personal data below’.We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity and is considered anonymous. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Food Angels Platform feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. How is your personal data collected?

We will collect and process the following data about you:

  • Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the Food Angels Platform, or by corresponding with us (for example, by email or chat). It includes information you provide when you download and/or register to use the Food Angels Platform, make transactions through the Food Angels Platform, enter a competition, promotion or survey and when you report a problem with the Food Angels Platform or our services. 
     

  • Information we collect about you and your device. Each time you visit or use the Food Angels Platform we may automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies.
     

  • Location Data. We also use GPS technology to determine your current location. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
     

  • Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

              Device Data from the following parties analytics providers such as Google and advertising networks as well as search information providers.

              Contact, Financial and Transaction Data from providers of technical and payment services (e.g Stripe);

              Identity and Contact Data from social networking service providers who you use to log onto the Food Angels Platform and from publicly available                     sources such as Commercial Register; and

              Contact, Financial and Transaction Data from restaurants, cafes, shops and other establishments which offer food and beverages and are                                   registered as food service providers on the Food Angels Platform and which you transact with.

              Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service                             searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to                       us.

Cookies

We do not currently use cookies but we may start using cookies in the future in order to, for example, distinguish you from other users of the Food Angels Platform, the distribution platform (Appstore or Google Play) and to remember your preferences. This will help us to provide you with a good experience when you use or browse the Food Angels Platform and also allows us to improve the Food Angels Platform. When we start using cookies, you will be notified either by email or when you next visit or use the Food Angels Platform.

4. How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances: 

  • Where you have consented before the processing.
     

  • Where we need to perform a contract we are about to enter or have entered with you.
     

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
     

  • Where we need to comply with a legal or regulatory obligation. 
     

Please see ‘Glossary’ below to find out more about the types of lawful basis that we will rely on to process your personal data. 

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us. 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

Purposes for which we will use your personal data

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5. Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table above:

  • External Third Parties as set out in the ‘Glossary’ below.
     

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
     

6. International transfers

Some of our external third parties may be based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
     

  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
     

  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

7. Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Food Angels Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. 

We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.

8. Data retention 

We keep basic information about our users (including Contact, Identity, Financial and Transaction Data) for as long as is permitted by law and necessary for the provision of our services. By way of an example:

  • Information relating to orders is kept for up to three years after completion of the order unless we delete your account sooner
     

  • Information necessary for accounting purposes is kept for up to seven years after completion of the order
     

  • If we reasonably suspect that a user has committed an administrative or criminal offence or fraud or provided false information, we may keep the information for up to 10 years.

In some circumstances you can ask us to delete your data: see ‘Your legal rights’ below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the Food Angels Platform for a period of three years then we will treat the account as expired and your personal data may be deleted.

9. Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data. 

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you.
     

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
     

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
     

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
     

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a) if you want us to establish the data's accuracy;

(b) where our use of the data is unlawful but you do not want us to erase it;

(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
     

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
     

You also have the right to ask us not to continue to process your personal data for marketing purposes. 

You can exercise any of these rights at any time by contacting us at info@foodangels.org

10. Glossary

  • Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or opt-in to processing for a specific purpose. You can withdraw your consent at any time by contacting us. 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). 

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
 

  • External third parties

Restaurants, cafes, shops and other establishments which offer food and beverages and are registered as food service providers on the Food Angels Platform and which you transact with.

Service providers who provide data storage, IT and system administration services or payment processing. We use Stripe for payment processing. According to Stripe, Stripe Inc. is certified under the EU-U.S. and the Swiss-U.S. Privacy Shield Framework and adheres to the Privacy Shield Principles in connection with personal data transfers from the EEA, the UK and Switzerland.

Social networking service providers such as Facebook and Google where you choose to connect to the Food Angels Platform through such third party service.

Professional advisers including lawyers, bankers and auditors who provide consultancy, banking, legal and accounting services.

Estonian Tax and Customs Board, regulators and other authorities based who require reporting of processing activities in certain circumstances.
 

11. Description of categories of personal data

  • Identity Data: full name, telephone number, address and e-mail address.

  • Contact Data: billing address, email address and telephone numbers.

  • Financial Data: payment card details. However, we do not store payment card details.

  • Transaction Data: includes the items ordered, accepted and/or rejected, order price and payment history, pick-up information (including time of order and pick-up time window and pick-up location), food preferences and any special requests or requirements of users (such as, for example, cooking preferences, allergies and other dietary restrictions where the user provides such information etc). 

  • Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.

  • Content Data: includes information stored on your Device, including friends' lists, login information, photos, videos or other digital content, check-ins.

  • Profile Data: includes your username and password, purchase history, your preferences, feedback and survey responses.

  • Usage Data: includes details of your use of any the Food Angels Platform including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

  • Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences. 

  • Location Data: includes your current location disclosed by GPS technology.