PRIVACY POLICY
The Foozo Site https://foozo.lu (the “Site”) is owned by Grouplunch Luxembourg S.à r.l. (“we”, “us”, “Foozo” and “our”); with its official registered business address located at 7 Rue de Bitbourg, 1273 Luxembourg, operating under the RCS Number B210936 and its VAT No LU 29131417.
This privacy policy has been compiled to better serve those who are concerned with how their personal information / personal data is being used online. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect, or otherwise handle your personal information.
This Privacy Policy informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. We use your data to provide and improve the service. Service means the Foozo website operated by Grouplunch Luxembourg S.à r.l..
Please note that Grouplunch Luxembourg S.à r.l. is operating under the business name “Foozo”.
We comply with the General Data Protection Regulation of 2018 (GDPR), (EU) 2016/679. By using the service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.
PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT THEM
Personal information you provide to us (PII standing for personal identifiable information or personal data). Personal information you may provide to us through the service or otherwise includes:
- Personal data, personal information such as your name, email and mailing addresses, phone number.
- Registration data, such as information that you or your employer provides to register for an account or sign up. Moreover you might provide data via third party log-in software such as (but not limited to) “google” or “facebook/meta” direct login applications.
- Profile data, such as your username and password that you may set to establish an online account with us and your interests and preferences.
- Marketing data, such as the email address or contact details that we use to send marketing communications and your preferences for receiving communications about our activities.
- Purchase data, including your order history and information needed to process and fulfil your order, including order details, billing address, and delivery address.
- Banking data you provide when making a bank wire or engaging in a SEPA contract
- Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.
- Automatic collection. We and our service providers may automatically log information about you, your computer or mobile device, and your activity occurring on or through the Sites, such as:
- Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, the website you visited before browsing our site, and general location information such as city, state, or geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
- Cookies and similar technologies. Some of our automatic data collection is facilitated by cookies and similar technologies. See our Cookie Policy for more information. Please note that we only collect such information if permitted by law and necessary to provide you a flawless customer experience. Please see further in the next section how such data is put to use.
HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:
Performance of delivery service. We may use your personal information to:
- provide, operate, and improve the service
- establish and maintain your account on the service;
- communicate with you about the service, including by sending you announcements, updates, security alerts, and support and administrative messages;
- analyse your activity on the sites so that we can administer, support, improve and develop our business and for statistical and analytical purposes and to help us to prevent fraud; and
- detect, investigate, report and seek to prevent fraud or crime;
- provide customer support and maintenance for the service;
Direct Marketing. We may use your personal information to send you Foozo-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Your choices section below. Where we think you are using your account for business purposes and your company may be interested in our professional service options, where appropriate, we may contact you (by email or telephone) to let you know about this service. We do this as it’s in our legitimate business interests. You have the right to object to receiving these types of communications, which you can do by responding to our emails to unsubscribe or by contacting us using the contact details in this Privacy Policy.
For research and development. We may use your personal information for research and development purposes, including to analyse and improve the service and our business.
To create anonymous data. We may create aggregated, de-identified or other anonymous data records from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyse and improve the service and promote our business.
To comply with laws and regulations. We use your personal information as we deem necessary or appropriate to comply with applicable laws, legal requests, and legal process, such as responding to subpoenas or requests from government authorities.
For compliance, fraud prevention and security. We may use your personal information and disclose it to law enforcement, government authorities and private parties if we deem it necessary or appropriate for: legal claims); (b) verify the compliance of our internal processes with legal and contractual requirements; (c) apply the terms and conditions that govern the service; and (d) protect, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyber-attacks and identity theft.
With your agreement. In some cases, we may specifically ask for your consent to collect, use or share your personal information, for example where required by law.
HOW WE SHARE YOUR PERSONAL INFORMATION
We may share your personal information with the following third parties and as described in this Privacy Policy or at the time of collection.
Service providers. Businesses and individuals who provide services on our behalf or help us operate the Service or our business (such as order fulfilment, shipping, payment processing, customer support, hosting, analytics, email delivery, marketing, database management services, returns handling and fraud risk and mitigation).
Our restaurant partners. Restaurant partners must download and print order information for our drivers. This information is only available on the day of the order and for printing. Restaurant partners cannot download information about users who have previously placed orders.
Third-party platforms. Social networks and other third-party platforms that you connect to the Service, for example when you use options to access the service by connecting to a social networking platform. Please note that we do not control the use of your personal information by third parties.
The public. Other users of the service and the public when you disclose personal information for public use. For example, you may be able to review a product you have purchased on a social media platform, if your name will be displayed along with the content you submit, the usage of such data is then under the control of the platform you used to express the review publicly. We do not control how other users, or third parties use the personal information you make available to them. Please note that any information you post publicly may be cached, copied, captured on screen, or stored elsewhere by others (for example, search engines) before you have a chance to edit it or to delete it.
Professional advisers. Professional advisers, such as lawyers, bankers, auditors, and insurers, where applicable as part of the professional services they render to us.
Authorities and others. Law enforcement, government authorities and private parties as we believe in good faith to be necessary or appropriate to comply with the law or for the compliance, fraud prevention and security purposes described above.
YOUR CHOICES
Access or update your account information. If you have opened an account with us, you can view and update certain personal information in your account profile by logging into the account.
Choose not to share your personal information. If you do not provide the information, we need to provide the service, we may not be able to provide the service or certain features to you. We will tell you what information you must provide to receive the service when we request it.
DELETION OF DATA AND INFORMATION
If a user wishes to delete his account, he must send an email with this request to hello@foozo.lu. Once an account is deleted, we will erase the user data associated with their account, including their logins and personal information. The order history and related information will be kept for a period required by law to comply with tax controls and audits.
OTHER SITES AND SERVICES
The sites may contain links to other websites and online services operated by third parties. These links do not constitute an endorsement or representation that we are affiliated with any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of other websites and online services that you use.
SECURITY EFFORTS
The security of your personal information is important to us. We use several organizational, technical, and physical safeguards designed to protect the personal information we collect. However, the security risk is inherent in all Internet and information technologies, and we cannot always guarantee the security of your personal information.
INTERNATIONAL DATA TRANSFERS
Foozo is headquartered in Luxembourg and may have service providers in other countries. Your personal information may be transferred to other places outside of your country or other government jurisdiction where privacy laws may not be as protective as those in your jurisdiction.
GENERAL DATA PROTECTION REGULATION (GDPR)
If you are from the European Economic Area (EEA), Foozo’s legal basis for collecting and using the personal information described in this privacy policy depends on the personal data we collect and the specific context in which we collect it.
Foozo may process your personal data because:
- We must perform a contract with you
- You have given us permission to do so
- Processing is in our legitimate interests, and it is not overridden by your rights
- For payment processing purposes
- To comply with the law
DATA RETENTION
Foozo will only retain your personal data for as long as necessary for the purposes set out in this privacy policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
Foozo will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period, except when such data is used to enhance security or to improve the functionality of our service, or when we are legally required to retain such data for longer periods.
DATA TRANSFER
Your information, including personal data, may be transferred to and stored on computers located outside of your state, province, country or other governmental jurisdiction where data protection laws may differ from those in your jurisdiction.
Your consent to this privacy policy followed by your submission of such information represents your agreement to this transfer.
Foozo will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and no transfer of your personal data will take place to any organization or country unless there are adequate controls in place, including the security of your data and other personal information.
Legal requirements for the disclosure of data
Foozo may disclose your personal data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Foozo
- To prevent or investigate possible wrongdoing in connection with the service
- To protect the personal safety of users of the service or the public
- To protect against legal liability
Security of data
The security of your data is important to us. We are however unable to guarantee a 100% secure transmission of data at any given point in time due to the nature of the internet and its constant development. We do our best in the frame of our possibilities and latest standards to protect your data.
Your rights under the GDPR
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Foozo aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal data.
If you wish to be informed what personal data we hold about you and if you want it to be removed from our systems, please contact us under hello@foozo.lu.
In certain circumstances, you have the following data protection rights, the below extract is not exhaustive to your rights. In order to understand all rights proposed under GDPR please refer to https://gdpr-info.eu/:
- The right to access, update or to delete the information we have on you. Whenever made possible, you can access andupdate your personal data directly within your account settings section. If you are unable to perform these actions yourself or would like to delete your data, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your personal data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where Foozo relied on your consent to process your personal information.
Please note that we will ask you to verify your identity before responding to such requests.
You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
Service Providers
We may employ third party companies and individuals to facilitate our service to provide the service on our behalf, to perform service-related services or to assist us in analysing how our Service is used.
These third parties have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
PAYMENTS
In order to offer standardized ways to process payments online, we use third-party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their privacy policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
The payment processors we work with are Six payment services and Payconic:
The Payconic privacy policy can be viewed at:
https://www.payconiq.com/Privacy_EN_Business.pdf
The Six payment services privacy policy can be viewed at: https://www.six-payment-services.com/en/services/legal/privacy-statement.html
CHILDREN’S PRIVACY
Our service does not address anyone under the age of 18.
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.
CHANGES TO THIS PRIVACY POLICY
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and / or a prominent notice on our service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
CONTACT US
If you have any questions about this Privacy Policy, please contact us: hello@foozo.lu