WORLD OF MOUTH PRIVACY STATEMENT
World of Mouth Oy (“WoM”, “we”) provides a restaurant guide platform available through a mobile application and the website www.worldofmouth.app (jointly the “WoM Services”).
Our Privacy Statement explains, for example, the types of personal data we process concerning the users and visitors of the WoM Services, the potential users of the WoM Services as well as the contact persons of the restaurants reviewed in the WoM Services. This Privacy Statement also explains how we process your personal data and how you may use your rights as a data subject (e.g. right to object, right of access).
In this Privacy Statement, the word “you” may refer to any of the aforementioned individuals. The word “User” refers to the registered user of the WoM Services. To the extent necessary, the contact person of a restaurant reviewed in the WoM Services is separately referred to as the “Contact”.
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 WoM Services. We will not make substantial changes to this Privacy Statement or reduce your rights under this Privacy Statement without providing a notice thereof.
1. CONTROLLER’S CONTACT DETAILS
Name: World of Mouth Oy, Company ID: 2954703-4, Correspondence address: c/o N2 Pursimiehenkatu 29-31 A, 00150 Helsinki, E-mail address: email@example.com, www.worldofmouth.app
2. PERSONAL DATA PROCESSED AND SOURCES OF DATA
The personal data collected and processed by us can be divided into three general data categories: User Data, Analytics Data and Restaurant Data.
User Data is personal data collected directly from you or other Users of the WoM Services. We may collect User Data from you in a variety of ways, including when the User registers to or use the WoM Services or when you subscribe to a newsletter or communicate with us.
User Data that is necessary in order to use the WoM Services
The following personal data collected and processed by us is necessary in order for a proper performance of the contract between the User and us as well as for the compliance with our legal obligations.
When the User registers to the WoM Services and creates a user account, the User needs to provide us with the following information:
- full name
- email address
App Store and Google Play as our merchants of record will collect your payment details (such as the number and the expiration date of your payment instrument) in connection with the purchases to our subscriptions you make through them.
User Data you give us voluntarily
We may also collect and process the following User Data provided voluntarily:
- user’s picture
- other information the user provides either when creating a user account or later when modifying his/her account profile
- information the User provides when using WoM Services (such as reviewing the restaurants of his/her choice)
- your marketing opt-ins and opt-outs
- information you provide in correspondence with us.
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 WoM Services:
- device Information. We collect the following information relating to the technical device you use when using the WoM Services: device and device identification number, device IMEI
- IP address
- browser type and version
- operating system
- Internet service providers
- usage Information. We collect information on your use of the WoM
Services, such as:
- time spent on the WoM Services
- interaction with the WoM Services
- information on your orders made through the WoM Services
- the URL of the website you visited before and after visiting the WoM Services
- the time and date of your visits to the WoM Services
- the sections of the WoM Services you visited
- the products you searched for while using the WoM Services
Restaurant Data is personal data of Contacts collected from publicly available sources. Restaurant Data may include the following information:
- first and last name
- email address
- other public contact information
We use various technologies to collect and store Analytics Data and other information when you visit the WoM Services, including cookies and web beacons.
You may also change your cookie preferences at our website.
A web beacon is a technology that allows identifying readers of websites and emails e.g. for identifying whether an email has been read.
3. PURPOSES AND LEGITIMATE GROUNDS FOR THE PROCESSING OF YOUR PERSONAL DATA
There are several purposes for the processing of your personal data by WoM:
To provide the WoM Services
WoM processes personal data of the User to be able to offer the WoM Services to the User under the contract between the User and WoM.
We also use the data for example to handle the User’s payments or subscription data or any refunds (where applicable). If you contact our customer service, we will use the information provided by you to answer your questions or solve your complaint.
For our legal obligations
We process 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
WoM 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 communication and marketing
WoM may process your personal data to contact you regarding the WoM Services and to inform you of changes relating to them. Your personal data are also used for the purposes of marketing the WoM Services to you.
For quality improvement and trend analysis
We may also process information about your use of the WoM Services to improve the quality of the WoM Services e.g. by analyzing any trends in the use of the WoM 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
We process personal data of the User to perform our contractual obligations towards the User 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. We also process personal data of Contacts based on our legitimate interest whilst fulfilling our contractual obligations towards the Users. 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 WoM Services, you may be requested to grant your consent for the processing of personal data. In this event, you may withdraw your consent at any time.
4. TRANSFER TO COUNTRIES OUTSIDE EUROPE
WoM 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 your 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 WoM 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 WoM’s organization unless one of the following circumstances applies:
For the purposes set out in this Privacy Statement and to authorized service providers.
We may provide your personal data to our affiliates or to authorized service providers who perform services for us (including data storage, accounting, sales and marketing) to process it for us and to payment service providers to process User’s payments to us.
When data is processed by third parties on behalf of WoM, WoM 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 WoM 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 WoM 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 WoM, you 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 WoM 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 you notice when your personal data are transferred or become subject to a different privacy statement if your personal data is concerned.
With your explicit consent
We may share your personal data with third parties outside WoM when we have your explicit consent to do so. You have the right to withdraw this consent at all times.
6. STORAGE PERIOD
WoM does not store your personal data longer than is legally permitted and necessary for the purposes of this Privacy Statement. The storage period depends on the nature of the information and on the purposes of processing. The maximum period may therefore vary per use.
Most personal data relating to a User’s user account with the WoM Services will be deleted after a period of 1 year has lapsed after the User has deleted its user account with the WoM Services. Thereafter, a part of the personal data relating to a User’s user account with the WoM 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 WoM Services will be deleted within a period of 5 years after the User has deleted its user account with the WoM Services, with the exception of personal data required in certain rare situations such as legal proceedings.
With the exception of Analytics Data relating to the Users, we will store Analytics Data for a period of 10 years.
We will store Restaurant Data for as long as the restaurant in question is listed in the WoM Services.
7. YOUR RIGHTS
Right to access
You have the right to access and be informed about your personal data processed by us. You may request a copy of your personal data. In addition, we give Users the possibility to view certain data through their user account with the WoM Services.
Right to withdraw consent
In case the processing is based on a consent granted by you, you may withdraw the consent at any time. Withdrawing a consent may lead to fewer possibilities to use the WoM 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. Users can correct or update some of their personal data through their user account in the WoM Services.
Right to erasure
You may also ask us to delete your personal data from our systems. We will comply with such 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 WoM 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 WoM 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 WoM 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 above mentioned 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 your identity. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.
8. DIRECT MARKETING
You have the right to prohibit us from using your 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 unsubscribe possibility offered in connection with any direct marketing messages.
9. LODGING A COMPLAINT
In case you consider our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection. In Finland, the local supervisory authority is the Data Protection Ombudsman (https://www.tietosuoja.fi).
10. 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 WoM 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 your privacy, we will inform you and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.