Last Updated: March 17, 2020
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.
Olo complies with the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from the EU and/or Switzerland. Please visit our Privacy Shield Statement for more information on our Privacy Shield certification.
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 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 legitimate user 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.
- share your address and contact information with third-party fulfillment providers, including without limitation, delivery service providers, and the Brand Company or its third-party fulfillment providers may communicate with you (via telephone call, text message, or email) regarding your order.
(b) Creation of Non-Identifiable Data. Olo may create de-identified information records from personal information by excluding certain information (such as your name) that makes the information personally identifiable to you. Olo may use this information, in a form that does not personally identify you to analyze request patterns and usage patterns to enhance Olo’s products and services. Olo reserves the right to use and disclose non-identifiable information to third parties in its discretion.
DISCLOSURE OF YOUR PERSONAL INFORMATION
BECAUSE OLO DOES NOT CONTROL THE PRIVACY PRACTICES OF THE BRANDED COMPANY, YOU SHOULD READ AND UNDERSTAND THE BRANDED COMPANY’S PRIVACY POLICIES.
SAFEGUARDS AND RETENTION
We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements.
We have record retention processes designed to retain personal information for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business requirements.
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, Update, or Correct Your Information. Subject to limited exceptions under applicable law, you may request to review, correct inaccuracies, and/or update your personal information in Olo’s custody and control by submitting a request to firstname.lastname@example.org or by writing to us at the contact information set out below. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.
(f) Opting Out of Email and SMS Communications. If you have signed-up to receive our email marketing communications, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the email or other electronic communication. Alternatively, you can opt out of receiving our marketing communications by contacting us at the contact information under “Contact Us” below. 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.
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 data 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 should visit the Branded Company’s website for further information on how to submit a request or, if applicable, opt out of the Branded Company’s sharing of the customers’ personal data with third parties for those parties’ direct marketing purposes.
[Insert contact title/position]
One World Trade Center, 82nd Floor
New York, NY 10007 USA
NOTICE TO CALIFORNIA USERS
We are providing this supplemental privacy notice to California users on behalf of the Branded Company, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”). Please note that as a service provider handling personal information on behalf of the Branded Company, Olo is not required to provide a CCPA notice. This notice does not apply to individuals with whom Olo engages in the individuals’ capacity as representatives of businesses that may provide services to Olo, or to which Olo may provide its services including any user who visits www.olo.com, which is designed only for businesses and not for individuals’ use in their personal or household capacity.
The CCPA grants California residents the following rights.
- Information. You can request information about how the Branded Company has collected, used and shared your personal information through the Olo Services during the past 12 months.
- Access. You can request a copy of the personal information that Olo maintains about you on behalf of the Branded Company.
- Deletion. You can ask to delete the personal information that Olo maintains about you on behalf of the Branded Company
- Opt-out of sale of your personal information. While Olo does not allow the Branded Company to sell personal information through the Olo Services, we offer instructions on how to limit online tracking.
Please note that the CCPA limits these rights by, for example, prohibiting businesses from providing certain sensitive information in response to an access request and limiting the circumstances in which they must comply with a deletion request.
You are entitled to exercise the rights described above free from discrimination.
Here is how you can submit requests:
- To request access to or deletion of personal information, visit the Branded Company’s website.
- To learns how to limit tracking visit Online Tracking Opt-out Guide.
- Identity verification. CCPA requires verification of the identity of the individual submitting the request. For identity verification requirements, visit the Branded Company’s website.
- Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf.