Orderello Privacy Policy

Overview – the key information you should be aware of

(A).        Who we are: We are Orderello Technology BV.  Our company number is registered in the Company Register of Aalst (Belgium) with registry number 757.465.377.  Our registered office is located at Geraardsbergsestraat 220, B0101, 9300 Aalst, Belgium (hereafter "Orderello"). Orderello is the controller of your personal information and is responsible for your personal information.  All references in this policy to:

1.           "Company", "our", "us" or "we" refer to Orderello;

2.           "our website", refers to the website owned by us at https://www.orderello.com  and 

3.           "our app" refers to our native smartphone application, the Orderello app or the corresponding web platform, which can be downloaded at the Apple and Google App Stores or consulted via app.orderello.be or other extensions as .com, .nl, .eu, .fr, .de .

(B).        Our values and what this policy is for: We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information.  We also want you to know your rights in relation to your information which you can find in section 6 below. 

In line with these values, this privacy policy tells you what to expect when we collect and use personal information about you.  We have tried to make it easy for you to navigate so you can find the information that is most relevant to you and our relationship with you. 

We are always looking to improve the information we provide to our customers and contacts so if you have any feedback on this privacy policy, please let us know using our contact details in section 12 below.

(C).        Who this policy applies to:  This policy applies to:

1.           Visitors to our website www.orderello.be;

2.           Users of  our app  app.orderello.be or other extensions as .com, .nl, .eu, .fr, .de;

Depending on our relationship, we will collect and use your information in different ways.  Please click on the links above to find out the information that we collect about you and how we use this information.

(D).        What this policy contains: This privacy policy describes the following important topics relating to your information (you can click on the links to find out more):

1.           How we obtain your personal information;

2.           Collection of your personal information and how we use it;

3.           Our legal basis for using your personal information;

4.           How and why we share your personal information with others;

5.           How long we store your personal information;

6.           Your rights;

7.           Marketing;

8.           Where we may transfer your personal information;

9.           Risks and how we keep your personal information secure;

10.         Links to other websites;

11.         Changes to this privacy policy; and

12.         Further questions and how to make a complaint.

(E).         Your rights to object: You have various rights in respect of our use of your personal information as set out in section 6.  Two of the fundamental rights to be aware of are that:

1.           you may ask us to stop using your personal information for direct-marketing purposes.  If you exercise this right, we will stop using your personal information for this purpose.

2.           you may ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person's, legitimate interest. 

You can find out more information in section 6.

(F).         What you need to do and your confirmation to us: Please read this privacy policy carefully to understand how we handle your personal information. By engaging with us in the ways set out in this privacy policy, you confirm that you have read and understood the entirety of this privacy policy, as it applies to you.

The detail – the key information you should be aware of

1.           How we obtain your personal information

1.1         You may provide us with your personal information voluntarily.  We may also receive information about you from third parties such as marketing agencies, market research companies, our suppliers, public websites and public agencies, which we refer to as "third party sources" or "suppliers" throughout this policy. 

1.2         You may give us personal information about yourself by using the online forms provided on our website, or by registering to use our app or through pop-up questions, in-app games or surveys. This includes, for example, where you provide your personal information to us in order to receive information or services from us.

2.           Collection of your personal information and how we use it 

Please go to the section or sections below that best describes our relationship with you to find out the information that we collect about you and how we use this information.  We refer to this as "personal information" throughout this policy.

2.1         Visitors to our website

(a)          What personal information we collect about you

We may collect and use any of the following information about you:

(i)           your name and surname;

(ii)          your email address;

(iii)         your telephone number;

(iv)         your business name;

(v)          the type of cash register you use (optional);

(vi)         information provided when you correspond with us;

(vii)        any updates to information you provide to us;

(viii)       personal information we collect about you or that we obtain from our third party sources;

(ix)         the following information created and recorded automatically when you visit our website:

(A)         Technical information. This includes: the Internet Protocol (IP) address used to connect your computer to the internet address; the website address and country from which you access information; the files requested; browser type and version; browser plug-in types and versions; operating system; and platform. We use this personal information to administer our website, to measure the efficiency of our systems and to undertake an analysis on the locations from which people access our webpages; and

(B)          Certain information about your visit and your behaviour on our website through specific cookies (for example, the pages that you click on).  This may include the website you visit before and after visiting our website (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads. Further information thereon can be found in our Cookie Policy.

(b)          How we use your personal information

We will collect, use and store the personal information listed above for the following reasons:

(i)           to allow you to access and use our website;

(ii)          to receive enquiries from you through the website about our services;

(iii)         for improvement and maintenance of our website and to provide technical support for our website;

(iv)         to ensure the security of our website;

(v)          to recognise you when you return to our website, to store information about your preferences, and to allow us to customise the website according to your individual interests; and

(vi)         to evaluate your visit to the website and prepare reports or compile statistics to understand the type of people who use our website, how they use our website and to make our website more intuitive (such details will be anonymised as far as reasonably possible and you will not be identifiable from the information collected).

Please see the sections below for more details about how we use your personal information.

(c)          A word about cookies

As part of our website and the corresponding web platform, we will use cookies, which are small files placed on your internet browser when you visit our website or use our web platform. We use cookies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences. 

Where we use cookies, you may block these at any time. To do so, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our website or to use all the functionality provided through our website or web platform. More information on which cookies we use and how and for which purposes we use cookies, is provided in our Cookie Policy. Our Cookie Policy also clarifies how you can disable cookies.

2.2         Users of our app

(a)          What personal information we collect about you:

Our app may collect any of the following information about you on our behalf  (and we may use any of the following information in the ways explained below):

(i)           The unique identifier of your mobile device;

(ii)          your email address (optional);

(iii)         your age;

(iv)         your gender (optional);

(v)          information about the services we provide to you such as the specific products you order through the app and information about your specific preferences, the amount of your(s) order and the timestamps of your order(s);

(vi)         depending on whether you have accepted the use of cookies, the information as further described in the Cookie Policy;

(vii)        information you provide to us as part of in-app surveys or in-app games.

(b)          How we use your personal information

We will collect, use and store the personal information listed above for the following reasons:

(i)           to allow you to access and use our app and our services;

(ii)          to receive feedback from you through the app about our services;

(iii)         for improvement and maintenance of our app and to provide technical support for our app;

(iv)         to recognise you when you return to our app, to store information about your preferences, and to allow us to customise our app according to your individual interests;

(v)          to evaluate your use of our app and prepare reports or compile statistics to understand the type of people who use our app, how they use our app and to make our app more intuitive (such details will be anonymised as far as reasonably possible and you will not be identifiable from the information collected);

(vi)         if it is in our legitimate interests for business development and marketing purposes (including through personalised in-app advertisements), to contact you via our app with information about our services which either you request, or which we feel will be of interest to you;

(vii)        to compile anonymous statistics on the consumption of specific products based on age and, to the extent you have provided such information, gender; and

(viii)       for our own legal defence purposes or for compliance with a legal obligation incumbent upon us.

Please see the sections below for more details about how we use your personal information.

(c)          Source of personal information. 

We receive your personal information from our app, which collects the information from you through the app.

(d)          Purchases made through our app.

When using our app, you may receive payment requests for your orders. Such payment transactions are processed by a third party payment services provider and subject to the terms and conditions and privacy policy of such payment services provider. With regard to such payment transactions, we will only disclose the amount payable by you to the third party payment service provider. The financial transaction for your order is concluded once the third party payment service provider confirms to us that the payment transaction has been successfully completed.

3.           Legal basis for use of your personal information

3.1         We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:

(a)          our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the terms of use of our website and our app which you accept by browsing our website or using our app); or

(b)          our use of your personal information is necessary for complying with our legal obligations (for example, for health and safety purposes); or

(c)          where neither (a) nor (b) apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). Our legitimate interests are to:

(i)           run, grow and develop our business;

(ii)          operate our website and our app;

(iii)         carry out marketing, market research and business development;

(iv)         for internal administrative purposes.

If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this balancing test by using the contact details at section 12.

3.2         We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time after giving it, as described below).

3.3         If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us at unsubscribe@orderello.com and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide associated services to you.

4.           How and why we share your personal information with others

4.1         We may share your personal information where it is in our legitimate interests to do so for internal administrative purposes (for example, for corporate strategy, compliance, auditing and monitoring, research and development and quality assurance).   

4.2         We will share your personal information with the following third parties or categories of third parties:

(a)          our end-customers such as hotels, bars and restaurants to the extent that you use our app to place your order(s) in such hotel, bar or restaurant. In such case, we will share your order information personal information processed through our app and, if provided by you, your e-mail address (see section 2.2 (ii) and (v) above) with the end-customer concerned;

(b)          companies that assist in our marketing, advertising and promotional activities;

(c)          analytics and search engine providers that assist us in the improvement and optimisation of our services, our website and our app; and

(d)          third party IT service providers such as providers of app development services and hosting services or providers of third party solutions such as cash registers with which the app could integrate and provided that such sharing is necessary for the performance of (i) their services to Orderello or (ii) the services of Orderello.

4.3         Any third parties with whom we share your personal information are limited (by law and by contract) in their ability to use your personal information for any purpose other than to provide services for us. We will always ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this privacy policy and applicable laws.

4.4         We will also disclose your personal information to third parties:

(a)          where it is in our legitimate interests to do so to run, grow and develop our business:

(i)           if we sell any business or assets, we may disclose your personal information to the buyer of such business or assets;

(ii)          if substantially all of our or any of our affiliates' assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets;

(b)          if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;

(c)          in order to enforce or apply our terms of use, our terms and conditions for customers or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or

(d)          to protect the rights, property, or safety of our app, our staff, our customers or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection.

4.5         We may also disclose and use anonymised, aggregated reporting and statistics about users of our website, our app and services for the purpose of internal reporting or reporting to parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.

4.6         Except as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us and we will stop doing so.

5.           How long we store your personal information

We keep your personal information for no longer than necessary for the purposes for which the personal information is processed.  The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

In any event and, with regard to the personal information processed through our website, we will retain such data for a period of two years, after which such data will be deleted. To the extent that you would subscribe to marketing communications and newsletters through our website, we will process your personal data in relation thereto up to the moment that you unsubscribe to such newsletter or marketing communication further to section 7 below.

With regard to the personal information processed through the app, the maximum retention period of your personal data will be the duration of the legal prescription period for contractual claims under Belgian law.

6.           Your rights

6.1         You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at info@orderello.com at any time. You have the following rights:

(a)          Right of access.  You have a right of access to any personal information we hold about you.  You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the United Kingdom or the European Economic Area ("EEA").

(b)          Right to update your information.  You have a right to request an update to any of your personal information which is out of date or incorrect.

(c)          Right to delete your information.  You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances.  You can ask us for further information on these specific circumstances by contacting us using the details in section 12.

We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort.  You can ask us who the recipients are, using the contact details in section 12.

(d)          Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances.  You can ask us for further information on these specific circumstances by contacting us using the details in section 12. 

We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort.  You can ask us who the recipients are using the contact details in section 12.

(e)          Right to stop marketing: You have a right to ask us to stop using your personal information for direct marketing purposes.  If you exercise this right, we will stop using your personal information for this purpose.

(f)           Right to data portability: You have a right to ask us to provide your personal information to a third party provider of services. 

This right only applies where we use your personal information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.

(g)          Right to object.  You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person's legitimate interest. 

6.2         We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims. 

6.3         If an exception applies, we will tell you this when responding to your request.  We may request you provide us with information necessary to confirm your identity before responding to any request you make. 

7.           Marketing

7.1         We may collect and use your personal information for undertaking marketing by email and telephone.

7.2         We may send you certain marketing communications (including electronic marketing communications) if it is in our legitimate interests to do so for marketing and business development purposes or if you have consented to receive such electronic marketing information.

7.3         However, we will always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your personal information to any third party for such marketing. 

7.4         If you wish to stop receiving marketing communications, you can contact us by email unsubscribe@orderello.com.

8.           Where we may transfer your personal information

8.1         Your personal information may be used, stored and/or accessed by staff operating outside the EEA working for us or suppliers. Further details on to whom your personal information may be disclosed are set out in section 4.

8.2         If we provide any personal information about you to any such non-EEA members of our group or suppliers, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this privacy policy.  These measures may include the following permitted in Articles 45 and 46 of the General Data Protection Regulation:

(a)          in the case of US based entities, entering into European Commission approved standard contractual arrangements; or

(b)          in the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.

8.3         Further details on the steps we take to protect your personal information, in these cases is available from us on request by contacting us by email at privacy@orderello.com at any time.

9.           Risks and how we keep your personal information secure

9.1         The main risk of our processing of your personal information is if it is lost, stolen or misused.  This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.

9.2         For this reason, Orderello is committed to protecting your personal information from loss, theft and misuse.  We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures (which, for example, include Orderello personnel receiving training on data protection).

9.3         In the course of provision of your personal information to us, your personal information may be transferred over the internet.  Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our website or our app and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.

10.         Links to other websites

Our website or our app may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third party websites or any association with their operators. This privacy policy only applies to the personal information that we collect or which we receive from third party sources, and we cannot be responsible for personal information about you that is collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.

11.         Changes to our privacy policy

We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be posted on our website and our app and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

12.         Further questions and how to make a complaint

12.1       If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact privacy@orderello.com. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.

12.2       In accordance with Article 77 of the General Data Protection Regulation, you may also make a complaint to the Information Commissioner's Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place.  Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.

The practices described in this privacy policy statement are current as of 01/05/2021