September 3, 2019
INTERNATIONAL DATA TRANSFERS AND PRIVACY SHIELD
If you are a non-U.S. user of the Services, by using the Services and providing us with data, you acknowledge and agree that your personal information may be processed outside the country in which it was collected, including the United States, where laws regarding processing of personal information may be less stringent than the laws in your country. By providing your data, you acknowledge such transfer.
THE TYPES OF INFORMATION OLO COLLECTS
Olo collects information from you in various ways when you access or use the Services. Olo collect personal information from you in the following ways:
(a) Personal Information You Provide to Us. For example:
- Olo may collect personal information from you, such as your first and last name, address, e-mail, telephone number and when you create an account (“Account”).
- The Services allow you to store preferences such as your location, recent orders and favorite menu items in order to make it more convenient for you to place additional orders in the future.
- When you order menu items from the Branded Company on our Services, Olo will collect all information necessary to complete the transaction, including your name and payment information. Olo may store this information on our servers, in order to make it easier for you to place orders for the Branded Company’s menu items in the future. Olo does not store your payment information on our servers, but stores a secure “token” that helps facilitate a secure payment transaction on the Branded Company Services.
- If you provide feedback or contact Olo via email, Olo will collect your name and email address, as well as any other content included in the email, in order to send you a reply.
- Olo also collects other types of personal information that you provide voluntarily, such as any information requested by Olo if you contact Olo via email regarding support for the Services.
(b) Personal Information Collected Via Technology. Olo collects certain information from you automatically when you access and use the Services as described below:
- Information Collected by our Servers. To make the Services more useful to you, Olo servers (which may be hosted by a third party service provider) collect information from you, including the referring/exit pages, your browser type, domain name, date/time stamp for your visit and your Internet Protocol (IP) address (a number that is automatically assigned to your computer or device when you use the Internet). Olo uses this information to analyze trends, administer the Services, monitor for fraudulent activities using fraud management tools, and better tailor the Services to users’ needs.
- Mobile Services. We may also collect information from your mobile device if you have downloaded a Branded Company’s Application. This information is generally used to help deliver the most relevant information to you. Examples of information that may be collected and used include your general geographic location, how you use the Application(s), and information about the type of device you use. In addition, in the event the Application crashes your mobile device, Olo will receive information about your mobile device model, software version and device carrier, to identify and fix bugs and otherwise improve the performance of the Application. This information is sent to Olo as aggregated information. The aggregated information is not traceable to any individual and cannot be used to identify an individual.
(c) Facebook and other Social Networking Services. The Services may allow users to access Facebook and other social networking sites (each, an “SNS”) to interact with and share their experiences with the Branded Company’s products and services with their friends. If you are not a registered user of the Services, you can create an Account by clicking on “Sign In” using Facebook or another SNS that we support, and then entering your SNS login credentials. In this case, Olo may receive information from Facebook or another SNS to make it easier for you to create an Account on the Services. Once you register on the Services and connect with Facebook or another SNS, you will be able to automatically post recent activity back to Facebook or the other SNS. The information that your Facebook or other SNS account provides to Olo may depend on the privacy settings you have with that SNS, so please consult the SNS’s privacy and data practices.
(d) Location Information.If you have enabled location services on your phone and agree to the collection of your location when prompted by the Services, Olo will collect your location information when you use the Services; for example, to locate those restaurants and locations of the Branded Company that are near you or when you “check in” via the Services. If you do not want Olo to collect this information, you may decline the collection of your location when prompted, or adjust the location services settings on your device.
HOW OLO USES YOUR INFORMATION
(a) General Use. In general, Olo uses your personal information to respond to your requests as submitted through the Services, to provide you the Services you request, or to help serve you better. Olo uses your personal information in the following ways:
- facilitate the creation of, and secure and maintain your Account;
- identify you as a user and not a potential fraudster in Olo’s system;
- provide improved administration of the Site, Application and Services;
- provide the Services you request;
- improve the quality of experience when you interact with the Site, Application and Services;
- send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
- send you administrative e-mail notifications, such as security or support and maintenance advisories;
- call or send you an SMS message about your order status or any issues with your order (e.g., food being prepared); and,
- send surveys, offers, and other promotional materials related to the Services at the Branded Company’s request or direction.
(b) Creation of Anonymous Data. Olo may create anonymous information records from personal information by excluding information (such as your name) that makes the information personally identifiable to you. Olo may use this anonymous information, aggregated with other anonymized user information, to analyze request patterns and usage patterns to enhance Olo’s products and services. Olo reserves the right to use and disclose anonymous information to third parties in its discretion.
DISCLOSURE OF YOUR PERSONAL DATA
BECAUSE OLO DOES NOT CONTROL THE PRIVACY PRACTICES OF THE BRANDED COMPANY, YOU SHOULD READ AND UNDERSTAND THE BRANDED COMPANY’S PRIVACY POLICIES.
A NOTE ABOUT CHILDREN
The Services are not directed towards individuals under the age of 13, and Olo does not intentionally gather personal information about visitors who are under the age of 13. Furthermore, Olo does not intentionally allow visitors under the age of 18 to register for the Services. If a child under 13 submits personal information to Olo and Olo learns that the personal information is the information of a child under 13, Olo will attempt to delete the information as soon as possible. If you believe that Olo might have any personal information from a child under 13, please contact Olo at: One World Trade Center, 82nd Floor, New York, NY 10007.
LINKS TO OTHER SITES
YOUR CHOICES REGARDING YOUR INFORMATION
You have several choices regarding use of information on the Services.
(a) Cookies. If you decide at any time that you no longer wish to accept cookies from the Services for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser’s technical information. If you do not accept cookies, however, you may not be able to use all or portions of the Services or all functionality of the Services. If you have any questions about how to disable or modify cookies, please let Olo know at the contact information provided below.
(b) De-Linking SNS. If you decide at any time that you no longer wish to have your SNS account (e.g., Facebook or Twitter) linked to your Account, then you may close your account with the Branded Company. Please refer to the privacy settings of the SNS to determine how you may adjust our permissions and manage the interactivity between the Services and your social media account or mobile device.
(c) Application. You can stop all collection of information by the Application by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.
(d) How We Respond to Do Not Track Signals. Some web browsers transmit “do not track” signals to the websites and other online services with which your web browser communications. There is currently no standard that governs what, if anything, websites should do when they receive these signals. Olo currently does not take action in response to these signals. If and when a standard is established, Olo may revise its policy on responding to these signals.
(e) Access or Correct Your Information. You may request to review and update the information Olo maintains about you by submitting a request to email@example.com.
(f) Opting Out of SMS Communications. If you provide your phone number through the Services, Olo may send you notifications by SMS, such as to alert you of a problem with your order or to notify you that your delivery is on its way. You may opt out of SMS communications by unlinking your mobile phone number through the Site.
(g) Opting Out of Location Tracking. If you initially consented to the collection of geo-location information through the Services, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. Please note, however, that if you withdraw consent to Olo’s collection of location information, you may no longer be able to use some features of the Services.
NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS
(AS PROVIDED BY CALIFORNIA CIVIL CODE SECTION 1798.83)
A CALIFORNIA RESIDENT WHO HAS PROVIDED PERSONAL DATA TO A BUSINESS WITH WHOM HE/SHE HAS ESTABLISHED A BUSINESS RELATIONSHIP FOR PERSONAL, FAMILY, OR HOUSEHOLD PURPOSES (A “CALIFORNIA CUSTOMER”) MAY REQUEST INFORMATION ABOUT WHETHER THE BUSINESS HAS DISCLOSED PERSONAL INFORMATION TO ANY THIRD PARTIES FOR THE THIRD PARTIES’ DIRECT MARKETING PURPOSES. IN GENERAL, IF THE BUSINESS HAS MADE SUCH A DISCLOSURE OF PERSONAL DATA, UPON RECEIPT OF A REQUEST BY A CALIFORNIA CUSTOMER, THE BUSINESS IS REQUIRED TO PROVIDE A LIST OF ALL THIRD PARTIES TO WHOM PERSONAL DATA WAS DISCLOSED IN THE PRECEDING CALENDAR YEAR, AS WELL AS A LIST OF THE CATEGORIES OF PERSONAL DATA THAT WERE DISCLOSED. CALIFORNIA CUSTOMERS MAY REQUEST FURTHER INFORMATION ABOUT OLO’S COMPLIANCE WITH THIS LAW BY E-MAILING CACUSTOMER@OLO.COM. PLEASE NOTE THAT OLO IS REQUIRED TO RESPOND TO ONE REQUEST PER CALIFORNIA CUSTOMER EACH YEAR AND IS NOT REQUIRED TO RESPOND TO REQUESTS MADE BY MEANS OTHER THAN THROUGH THIS E-MAIL ADDRESS.
One World Trade Center, 82nd Floor
New York, NY 10007 USA