Who we are
SC Fast Order SRL (hereinafter „Fast Order”, „we”, „us” or similar)) is a limited liability company duly incorporated and registered in Romania, having its registered office at 3.5 Campul Painii Street, Cluj-Napoca, Cluj, Romania, registered with the Trade Registry under no. J12/1083/2017, sole registration code 35524490.
We take your privacy extremely seriously and this notice of personal data processing describes our policies and practices regarding our collection and use of your personal data – such as what data we collect, why we collect it, and what we do with it, and sets forth your privacy rights.
Please read this Privacy Notice carefully to understand how we handle your personal information.
2. How we collect your personal data
Personal Data may be collected or accessed in a number of ways, including:
1. directly from you (from your form input data on the Website or Applications);
2. observed by us when you navigate on our Website or Applications (cookies, IP, website navigation, etc.);
2.1 Data provided by you directly
As a visitor, you do not have to submit any personal data in order to use the Website or Applications. However, in order to use our service, you will need to share your address or location so that we can determine what services and restaurants are available to you.
In addition, personal data that are specifically and voluntarily provided by visitors may be collected through the Website or Applications, as follows:
1. 2.1.1 Create account
Our Website and Applications use forms by which you may create an account, that include fields such as first and last name, email address and password. You have the option to log in via Facebook, in which case we gain access to the smallest data set they provide that includes the data we are processing namely email address, name, and profile image.
We process this data under the legal basis of performing a contract with users, in order to enable you to easily log into our Website or Applications and place orders. This data will be kept for the duration of existence of the user account, until the user deletes / inactivates the account.
2. 2.1.2 Place an order
When you order through our Website or Applications, we might also ask for your delivery address details, telephone number, payment information, and any preferences (e.g. meal preferences) you have for your order.
We process this data under the legal basis of performing a contract with users, in order to:
1. ensure orders are processed and delivered to you,
2. communicate with you regarding orders,
3. take payment and give refunds,
4. provide you customer care and support,
5. prevent and detect fraud, and
6. keep you informed on our services.
3. This data is stored for the duration of existence of your account.
4. 2.1.3 Apply as a candidate for employment
When you apply for a job with Fast Order by sending us an e-mail at the address indicated in our dedicated career section on the Website, we will process the data you send us in your applications or CV, such as personal details, working experience, education and other relevant details.
We process this data under the legal basis of performing a contract and we will use this information to assess your applications. This data is stored for 6 months after the termination of the selection process.
5. 2.1.4 Contact form or registration of complaints
Our Website and Applications also gives you the ability to send us a message via the contact form and to submit a complaint via the dedicated section. The data that you input in the contact form is processed based in our legitimate interest to respond to your inquiry and/or to keep a record of your complaint, request, and the like. This data is stored for 3 years after resolution of the complaint.
Please note that user generated content posted through the Website or Applications, such as service/restaurant reviews and certain social networking posts (e.g. menu items or restaurants you share) may be viewed by the general public. Accordingly, Fast Order cannot ensure the privacy of any personal data included in such user generated content.
6. 2.1.5 Participation at surveys, competitions and promotions
When you participate at surveys, competitions and promotions organized via our Website or Applications, we process your data relevant to such event in order to run the event, confirm users’ registration, draw conclusions of surveys and select winners of competitions. This data is stored for 3 years.
In addition, we can use any of the data indicated at this point 2.1 under our legitimate interest, for providing you with the best appropriate content for the Website or Applications, emails and newsletters, to improve and promote our products and services and for administrative, fraud detection and legal purposes.
We do not use your data to send you marketing communications unless you expressly opt in for such communication. Even in such cases we make sure that you have an easy to use option to unsubscribe (withdraw your consent) at any time, either in the communication itself or by contacting us as indicated in Section 8.
2.2 Use of the Website and Applications
The Website and Applications collect certain information automatically and store it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of the Website or Applications, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our Website and Applications, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.
On each subsequent visit to the Website, the browser searches for cookies. If the browser finds cookies, it sends the information stored by the cookie to the Website.
The Website downloads cookies onto your computer, tablet or mobile phone which are strictly necessary for the functioning of the Website, such as cookies which ensure that you can retrieve information on the Website quickly, and cookies which are strictly necessary to provide a service which has explicitly been requested by you, such as a cookie which remembers your cookie settings, or cookies that remember the content of your “shopping cart” while you browse the Website.
To download cookies which are not strictly necessary, such as cookies for gathering statistical information, Fast Order needs your prior consent.
If you have adjusted your cookie settings so that websites are not permitted to place cookies on your computer, this Website may not be able to download the cookie which remembers whether or not you consented to the placing of cookies.
If so, you will be asked to indicate your cookie preferences each time you visit the Website.
If you do not wish to be asked about your cookie preferences each time you visit this Website, you need to adjust your browser’s cookie settings.
3. How we share information
We will disclose your personal data only for the purposes and to those third parties, as described below. We will take appropriate steps to ensure that your personal data are processed, secured, and transferred according to applicable law.
3.1 Disclosure to Fast Order group companies
Your personal information may be shared with any company that is a member of our group, which includes our ultimate parent company based in the USA, where we consider that it is in our legitimate interests to do so for internal administrative purposes (e.g. storage of data, CRM), or for auditing and monitoring of our internal processes.
We may also share your personal information with our group companies where they provide products and services to us, such as information technology systems.
Access to your personal information is limited to those employees who need to know the personal information, and may include their potential managers and their designees, as well as employees in the marketing, information technology and security departments.
3.2 Disclosure to third parties
We will share the strictly necessary parts of your personal data, on a need-to-know basis with the following categories of third parties:
1. Partner Restaurants and Delivery Providers, to whom Fast Order shares orders content, special instructions, first and last name, delivery address, and telephone number, to the extent necessary to process those orders
2. Companies that provide products and services to us (processors), such as:
1. media agencies, such as those organizing promotional campaigns and those administering the Website or Applications;
3. infrastructure agencies (other parties that handle the email newsletter, SMS marketing or other kinds of marketing, client support or sales activities in our name);
4. information technology systems suppliers and support, including email archiving, telecommunication suppliers, backup and disaster recovery and cyber security services.
3. companies involved in the operation of our Website or Applications, where they are not providing a service for us.
4. other parties such as public authorities and institutions, accountants, auditors, lawyers and other outside professional advisors, where their activity requires such knowledge or where we are required by law to make such a disclosure.
We will also disclose your personal information to third parties:
1. If you request or authorize so;
2. to persons demonstrating legal authority to act on your behalf;
3. where it is in our legitimate interests to do so to run, grow and develop our business:
1. if we sell any business or assets related to the Website or Applications you are subscribing to, we may disclose your personal information to the prospective buyer of such business or assets, in order to ensure that the activity continues as a going concern;
2. if Fast Order or substantially all of its assets are acquired by a third party, in which case personal information held by Fast Order will automatically be one of the transferred assets;
4. 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 officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
5. 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
6. to protect the rights, property or safety of Fast Order, our employees, customers, suppliers or other persons.
Some of these recipients (including our affiliates) may use your data in countries which are outside of the European Economic Area. Please see Section 4 below for more detail on this aspect.
3.3 Restrictions on use of personal information by recipients
Any third parties with whom we choose to share your personal information pursuant to the above are limited (by law and by contract) in their ability to use your personal information for the specific purposes identified by us. We will always ensure that any third parties with whom we choose to share your personal information are subject to privacy and security obligations consistent with this Privacy Notice and applicable laws. However, for the avoidance of doubt this cannot be applicable where the disclosure is not our decision.
Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, if applicable, obtaining your consent.
4. Transfers of information outside of the European Union
The personal information may be processed by staff operating outside the EEA working for us, other members of our group or third-party data processors for the purposes mentioned above.
If we provide any personal information about you to any such non-EEA members of our group or third-party data processors, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Notice. These measures include:
● in the case of US based service providers, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further https://www.privacyshield.gov/welcome), or
● in the case of service providers based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.
Further details on the steps we take to protect your personal information in these cases is available from us on request by contacting us (see section 9 below) at any time.
5. Your rights
As a data subject you have specific legal rights relating to the personal data we collect from you. Fast Order will respect your individual rights and will deal with your concerns adequately.
1. Right to withdraw consent: Where you have given consent for the processing of your personal data, you may withdraw your consent at any moment.
2. Right to rectification: You may obtain from us rectification of personal data concerning you. We make reasonable efforts to keep personal data in our possession or control which are used on an ongoing basis, accurate, complete, current and relevant, based on the most recent information available to us. In appropriate cases, we provide self-service internet portals where users have the possibility to review and rectify their personal data. For instance, you can edit the name, phone number and email address associated with your account through the Settings menu of our Website or Applications.
3. Right to restriction: You may obtain from us restriction of processing of your personal data, if
○ you contest the accuracy of your personal data, for the period we need to verify the accuracy,
○ the processing is unlawful and you request the restriction of processing rather than erasure of your personal data,
○ we do no longer need your personal data, but you require them for the establishment, exercise or defense of legal claims, or
○ you object to the processing while we verify whether our legitimate grounds override yours.
4. Right to access: You may ask from us information regarding personal data that we hold about you, including information as to which categories of personal data we have in our possession or control, what they are being used for, where we collected them, if not from you directly, and to whom they have been disclosed, if applicable.
We will provide you with a copy of your personal data upon request and, you can download your data regarding your account, your orders and
5. Right to portability: As of May 25th 2018, you have the right to receive your personal data that you have provided to us, and, where technically feasible, request that we transmit your personal data (that you have provided to us) to another organization.
These are rights you have if:
○ we process your personal data by automated means,
○ we base the processing of your personal data on your consent, or our processing of your personal data are necessary for the execution or performance of a contract to which you are a party;
○ your personal data are provided to us by you, and
○ the transmission of your personal data does not adversely affect the rights and the freedoms of other persons.
6. You have the right to receive your personal data in a structured, commonly used and machine-readable format.
Your right to receive your personal data must not adversely affect the rights and the freedoms of other persons. This may be the case if a transmission of your personal data to another organization also involves the transmission of the personal data of other (non-consenting) individuals.
Your right to have your personal data transmitted from us to another organization is a right you have if such transmission is technically feasible.
7. Right to erasure: You have the right to request that we delete the personal data we process about you. We must comply with this request if we process your personal data, unless the data is necessary:
○ for exercising the right of freedom of expression and information;
○ for compliance with a legal obligation that binds us;
○ for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes; or
○ for the establishment, exercise or defense of legal claims.
8. Right to object: You may object – at any time – to the processing of your personal data due to your particular situation, provided that the processing is not based on your consent but on our legitimate interests or those of a third party. In this event we shall no longer process your personal data, unless we can demonstrate compelling legitimate grounds and an overriding interest for the processing, or for the establishment, exercise or defense of legal claims. If you object to the processing, please specify whether you also wish the erasure of your personal data, otherwise we will only restrict it.
You may always object to the processing of your personal data for direct marketing that was based on our legitimate interest, regardless of any reason. If the marketing was based on your consent, you can withdraw consent.
9. Right to lodge a complaint: You can lodge a complaint to the data protection supervisory authority
○ Time period: We will try to fulfill your request within 15 days. As of May 25th 2018, the period is 30 days and it may be extended due to specific reasons relating to the specific legal right or the complexity of your request. In all cases, if this period is extended, we will inform you about the term of extension and the reasons that led to it.
○ Restriction of access: In certain situations, we may not be able to give you access to all or some of your personal data due to statutory provisions. If we deny your request for access, we will inform you of the reason for the refusal.
○ No identification: In some cases, we may not be able to look up your personal data due to the identifiers you provide in your request. In such cases, where we cannot identify you as a data subject, we are not able to comply with your request to execute your legal rights as described in this section, unless you provide additional information enabling your identification. We will inform you and give you the opportunity to provide such additional details.
○ Exercise your legal rights: In order to exercise your legal rights, please contact us in writing (including electronically) at the contact details provided in section 8 below.
Fast Order is committed to protecting personal information from loss, misuse, disclosure, alteration, unavailability, unauthorized access and destruction and takes all reasonable precautions to safeguard the confidentiality of personal information, including through use of appropriate organizational and technical measures. Organizational measures include physical access controls to our premises, staff training and locking physical files in filing cabinets. Technical measures include use of encryption, passwords for access to our systems and use of anti-virus software.
In the course of provision of your personal data 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 between you and us over the internet is not completely secure. As such, we cannot guarantee the security of your personal information transmitted to us over the internet 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 unauthorized access to it.
7. Changes to our Privacy Notice
We reserve the right, at our discretion, to modify our privacy practices and update and make changes to this privacy notice at any time. For this reason, we encourage you to refer to this privacy notice on an ongoing basis. This privacy notice is current as of the date which appears at the top of the document. We will treat your personal data in a manner consistent with the privacy notice under which they were collected, unless we have your consent to treat them differently.
8. Contact information
Please direct your questions regarding the subject matter of data protection and any requests in the exercise of your legal rights to the following contact details: firstname.lastname@example.org
3-5 Campul Painii street, 5th floor, postal code 400124, Cluj-Napoca, Cluj, Romania.
We will investigate and attempt to resolve any request or complaint regarding the use or disclosure of your personal information.
If you are not satisfied with our reply, you may also make a complaint to the National Supervisory Authority for Processing of Personal Data. You can find further information about the process at: http://dataprotection.ro/?page=procedura_de_solutionare_a_plangerilor
requests relating to our use of your information are welcomed and should be addressed to: email@example.com