EatyPal privacy statement
Wildstyle Ltd. and certain EatyPal group companies (“EatyPal”, “we”) process personal data of their users (or “you”, a natural person using the EatyPal Service) of EatyPal’s food ordering services (“EatyPal App”) and the visitors of the website EatyPal.com (“Website”) .
In this Privacy Statement, the word “EatyPal Services” refers jointly to the Website and the EatyPal App. In this Privacy Statement, the word “User” or “you” refers jointly to our and our group companies’ customers, representatives, potential customers and the users of the EatyPal 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 (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 substantial 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 the processing of personal data carried out by EatyPal.
Wildstyle Ltd., registry number 11225707, official address Mustjõe 45, 10617 Tallinn, Estonia
In Cambodia: The Desk, Chamkar Mon Tonle Bassac, 206 D Preah Norodom Blvd (41), Phnom Penh 12301
2. 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.
2.1. User Data
User Data is personal data collected directly from you on behalf of which you are using the EatyPal Services, as the case may be. We may collect User Data from our Users in a variety of ways, including, after the conclusion of a service agreement when Users register to the EatyPal 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 EatyPal Services.
2.1.1. User Data that is necessary in order to use the EatyPal Services
The following personal data collected and processed by us is necessary in order for the proper performance of the contract between you and us as well as for our legitimate interest whilst fulfilling our contractual and our legal obligations.
When you register for EatyPal 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 products via the EatyPal Services, however not stored by EatyPal, since EatyPal uses a third party payment service provider for the processing of payments).
2.1.2. User Data you give us voluntarily
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)
● 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, we process certain personal data third party service providers provide about you.
If you connect or login into 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.
2.2. Analytics Data
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 EatyPal Services:
2.2.1. Device Information.
We collect the following information relating to the technical device you use when using the EatyPal Services:
● device and device identification number, device IMEI
● IP address
● browser type and version
● operating system
● Internet service providers
● advertising identifier of your device
● visitor identifier
2.2.2. Usage Information.
We collect information on your use of the EatyPal Services, such as:
● time spent on the EatyPal Services
● interaction with the EatyPal Services
● information on your orders made through the EatyPal Services
● the URL of the website you visited before and after visiting the EatyPal Services
● the time and date of your visits to the EatyPal Services
● the sections of the EatyPal Services you visited
● the products you searched for while using the EatyPal Services
3. Purposes and legitimate grounds for the processing of your personal data
There are several purposes of the processing of your personal data by EatyPal:
3.1.1. To provide the EatyPal Services and carry out our contractual obligations (legal ground: performance of a contract and legitimate interest)
EatyPal processes your personal data to be able to offer the EatyPal Services to you under the contract between you and EatyPal.
We use the data for example to handle your payments or any refunds (where applicable) and to provide our partners (the kitchens and our delivery 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.
3.1.2. For our legal obligations (legal ground: compliance with a legal obligation)
EatyPal processes data to enable us to administer and fulfill our obligations under the 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)
EatyPal 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
3.1.3. For customer communication and marketing (legal ground: legitimate interest)
EatyPal processes your personal data to contact you regarding the EatyPal Services and to inform you of changes relating to them. Your personal data are also used for the purposes of marketing the EatyPal Services to you.
3.1.4. For quality improvement and trend analysis (legal ground: legitimate interest) We may also process information about your use of the EatyPal Services to improve the quality of the EatyPal Services e.g. by analyzing any trends in the use of the EatyPal 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
3.2. Legal grounds for the processing
EatyPal processes your personal data to perform our contractual obligations 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 EatyPal 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.
We only share your personal data within the organization of EatyPal 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 EatyPal’s organization unless one of the following circumstances applies:
4.1. For the purposes set out in this Privacy Statement and to authorized service providers To the extent that third parties (such as the kitchens which prepare your order, our delivery partners who deliver your order) need access to personal data in order for us to perform the EatyPal Services, we provide such third parties with your data. Furthermore, 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 your payments to us.
When data is processed by third parties on behalf of EatyPal, EatyPal 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 EatyPal Services, the processing is typically based on their policies and standards.
4.2. For legal reasons and legal processes
We may share your personal data with third parties outside EatyPal 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 EatyPal, the Users or the public as far as in accordance with the law. When possible, we will inform you about such processing.
4.3. For other legitimate reasons If EatyPal 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.
4.4. With your explicit consent We may share your personal data with third parties outside EatyPal 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.
5. Storage period
EatyPal does not store your personal data longer than is legally permitted and necessary for the purposes of providing the EatyPal Services or the relevant parts thereof. The storage period depends on the nature of the information and on the purposes of the processing. The maximum period may therefore vary per use.
Most personal data relating to a User’s user account with the EatyPal Services will be deleted after a period of 90 days have lapsed after the User has deleted its user account with the EatyPal Services. Thereafter, a part of the personal data relating to a User’s user account with the EatyPal 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 EatyPal Services will be deleted within a period of 10 years after the User has deleted its user account with the EatyPal 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 EatyPal Services for a period of 90 days.
6. Your rights
6.1. 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 EatyPal Services or request a copy of your personal data.
6.2. Right to withdraw consent In case the processing is based on the 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 EatyPal Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
6.3. 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 EatyPal Services.
6.4. 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.
6.5. 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 EatyPal 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 EatyPal Services.
6.6. Right to restriction of processing You may request us to restrict the 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 EatyPal Services.
6.7. 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.
6.8. 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
7. 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 EatyPal Services or the unsubscribe possibility offered in connection with any direct marketing messages.
8. 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. Alternatively, the User may lodge a complaint with the local supervisory authority for data protection of the User’s country of domicile.
9. 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 EatyPal 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 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.
Phone: +855 10 561 207