Wedely WeDriver App

Wedely S.à r.l and its affiliates ("Wedely" or the "Company") offer technologies to collaborators who deliver orders from Wedely's restaurants to customers, through the website www.wedely.com (the "Website"), using the “Wedely WeDriver App” (the “Services”).

When you use our services, you entrust us with your information. We know that this is a heavy responsibility and we strive to protect them, while allowing you to keep control of them.

This privacy policy is intended to explain to you the type of information we collect, the reasons why we collect it and how you can update, manage and delete your information.

These Privacy Rules deal with:

• User Accounts and Access to Services
• Information collected
• Reasons why Wedely WeDriver App collects data
• Sharing your information
• Visibility
• Control your personal information
• How is the collected data stored by Wedely WeDriver App?
• How is the accumulated information used by Wedely WeDriver App?
• Information security
• Compliance and cooperation with regulators
• Changes to these Privacy Rules

These Privacy Rules are part of the Wedely Terms of Service ("Conditions of Use" or "Conditions"). Your use of the Services is subject to the Terms of Service, and these Privacy Rules, and indicates your acceptance of them.

To use our Services, you must be at least 18 years old. If not, you are not allowed to download or use our Services.

As part of these Privacy Rules, the term "personal information" refers to information you provide that personally identifies you, including your name, email address or billing information, and, in some cases, information related to your location and itineraries, or other data that may reasonably be associated with such information by Wedely WeDriver App.

Contact Wedely - Reports Related to Privacy Concerns

If you have any questions about these Privacy Rules or if you feel that the use of our Services has infringed your privacy, please contact Wedely at: . For all other requests, answers, questions and complaints, please email them to:

User Accounts and Access to Services

Be aware that when installing the App on your mobile device, Wedely creates an account associated with this mobile device (the "Account"). Once installed, Wedely WeDriver App collects and uses your information, including metadata (as shown below), in accordance with these Privacy Rules. This use may involve the association of your information with your Account.

In that case:

• Wedely WeDriver App associates all your information with your Account and generates a unique identifier, in accordance with these Privacy Rules. This process allows us to offer you a selection of the best orders close to you;
• Apart from the exception listed below, and explained in the "Visibility" section below, your Account and the information associated with it (including your unique identifier) are visible only through the Wedely WeDriver App;
• When you use the App, your approximate location and other information you are likely to provide is visible to Wedely;
• Be aware that access to certain Features of the Services requires the creation of an Account in order to personally identify you;
• Wedely WeDriver App associates all your information of your Account with your email. This relates to information received from all mobile devices running the App, on which you logged in using your email and password;
• Wedely may also establish or impose additional or different means of identification or authentication from time to time, in order to connect and access the Services, or certain features or designated parts of the Services;
• Your login information is your full responsibility. You are fully responsible for the use or misuse of your Account and personal details resulting from the disclosure of your login information to others. You must maintain the absolute confidentiality of your login information and refrain from disclosing it to others. Be sure to change your password regularly, or at least every six months;

Information collected

We want to tell you what types of information you can collect when you use our services.

Wedely collects information to improve the quality of services offered to all of its users, whether it's calculating the best routes, monitoring traffic so you're the right time to leave, or showing you the right announcements when you're using the Wedely WeDriver App. The information collected by Wedely and how it is used depends on your use of our services and your management of privacy settings.

Information you create or provide to us:

• Account information: This is the information required when creating your account, such as your name and gender. Be aware that incorrect or outdated information may compromise Wedely's ability to provide services and contact you when needed. Mandatory fields will be explicitly stated by Wedely WeDriver App. If you don't provide the data required in these fields, you may not be able to use our Services; and/or
• Information you choose to share with Wedely: information you choose to share with Wedely WeDriver App, including the email, your phone number, date of birth, spoken languages, type of car used and files you've imported to the service. You can also add payment information to your account, if necessary. You have the option to provide us with information, including your email address, to receive updates to our services, even if you are not connected to a Wedely WeDriver App Account.
• Communications you make using the Wedely services: If you choose to communicate with other Wedely’s users or third parties via the Wedely WeDriver App, including through instant messages or a phone call to the customer. We may also collect information when you contact Wedely, including when you submit a request, contact the Wedely support team or report a violation or abuse to the abuse team.

Information we collect when you use our services

We collect information about your activity as part of the Services and use it to provide you with the Wedely WeDriver App, including features to personalize your experience. Among other things, we can offer you a selection of best itineraries or destinations in order to deliver orders to customers. The information about your activity we collect may include:

• Detailed information on locations, travel and itineraries. Location and route information is collected in the form of GPS signals (associated with date and time) even when the Wedely WeDriver App is hidden in background, and other information sent by your mobile device on which the App is installed and activated. This location and route information is recorded in the route history of all journeys you have made using the App. You can stop sharing your location at any time by disabling the function in the App. The types of location data we collect depend in part on your device and account settings. For example, depending on the settings of the selected device and/or your account settings, we may collect information about your location and your movements (or your lack of travel).

Metadata (information about your device, browser and app usage)

As soon as you install the App, Wedely WeDriver App collects information about your use of the Services and information about the device on which you installed the Wedely WeDriver App.

• Wedely WeDriver App is likely to collect and record the frequency and duration of your use of the app, the type of your device, the unique identifiers, the type and version of the operating system, battery usage, web pages or third-party applications that you've viewed, used or interacted with via the Wedely WeDriver App, the information you've accessed about our Services, the IP address (Internet Protocol) and domain name used to access the Services, and the geographic location of the device you're using to connect to Wedely.
• We also collect information about how your devices interact with our Services, including error reports, system activity, and the date, time and URL of your request.

Reasons why Wedely collects data

Wedely WeDriver App is likely to use the information collected from you or provided by you for the following purposes:

Providing our services

We use your information to offer our services. Example:

• We use information about your location and itineraries and/or search query history to provide the most suitable orders to your location and help you to optimize your routes or show you traffic alerts, as well as to provide information on sites, restaurants, customers and other delivery locations located near you;

Maintaining and improving our services

• We also use your information to ensure that our services are operating as intended, including monitoring outages or solving problems you report to us. In addition, we use your information to improve the service or to develop new features or services. For example, Wedely can use route information to improve the accuracy of its mapping and navigation data to reduce the battery consumption or increase the quality of the user experience for a specific type of device.

Contact you

• We use your information to send you updates, notifications, orders and additional information about the Services;
• We can also use your information to conduct surveys and questionnaires.

To protect Wedely’s users, the public and for legal reasons

We can also use and process your information and content using a variety of technologies for the following purposes

• To apply Terms of Service or Privacy Rules;
• To contact you in cases where Wedely feels this is necessary;
• To comply with existing laws and assist law enforcement agencies under any applicable legislation, where Wedely has good reason to believe that its cooperation with law enforcement agencies is legally mandated or meets the standards of applicable legal procedures;
• To detect abuse and illegal activity; to detect and prevent fraud, embezzlement, breaches, identity theft and other illegal activities, as well as misuse of the Services;
• To deal with failures and malfunctions;
• To take any action in the event of a dispute, or legal proceedings of any kind between you and the Services, or between you and other users or third parties, regarding or related to the Services;
• For the purposes mentioned in these Privacy Rules and Terms of Service;
• To improve the safety and reliability of our Services, including detecting and preventing security risks and responding to them, as well as solving technical issues that could harm Wedely WeDriver App, our users or the public;
• To create cumulative and/or anonymous data (when this data does not allow the identification of a specific user). See "How is cumulative information used by Wedely?" below;

Any use of your information for any purpose other than those set out in these Privacy Rules will require your explicit consent.

Sharing your information

Personal information you share

Cases in which Wedely shares your information

Wedely does not sell or lease your personal information to third parties.

Wedely will not share your personal information with others without your permission, except for the following purposes and to the extent necessary, at the discretion of Wedely exercised in good faith:

• Where necessary to facilitate and deliver services;
• In the event that Wedely reasonably believes that you have violated the Terms of Service or investigated a potential violation of the latter, or believe that you have exceeded your rights to use the Services, or performed an act or omission that Wedely reasonably considers to be a violation of applicable laws, rules or regulations. Wedely is likely to share your information in these cases, with law enforcement and other relevant authorities, as well as with third parties who may have to deal with the consequences of wrongdoing you are causing;
• If Wedely is obligated or has reasonable grounds to believe that the sharing or disclosure of your information is required by law;
• In the event of a dispute, legal proceedings of any kind between you and Wedely or between you and other users, regarding or related to the Services;
• In all cases where Wedely has reasonable grounds to believe that information sharing is necessary to protect the rights, property or safety of Wedely, our users or the public, as required or permitted by law, including to prevent imminent physical damage or property damage;
• To detect, avoid or treat fraudulent activity, security breaches or any technical problems;
• In the event that Wedely organizes the delivery of the Services within a different framework or through another legal structure or entity, or if Wedely is purchased or merged or merged with another entity, or if Wedely goes bankrupt, provided that these entities agree to be linked to the provisions of these Privacy Rules, taking into account the respective amendments;
• To collect, store, hold and manage your personal information via services based or hosted in the cloud, or via a third party or a party affiliated or linked to Wedely, in a reasonable way to pursue business objectives, which can be installed in the European Union;
• Wedely is also likely to share your personal information with companies or organizations related to or affiliated with Wedely, such as subsidiaries, sister companies and parent companies;

Visibility

Please be aware that your email and some other information will be accessible to other people, Wedely’s employees. Please note that your email will be listed with your information.

Controlling your personal information

You always have the option to review and update certain information by accessing to your "Account" settings.

If you find that the information associated with your Account is not accurate, complete or up-to-date, please make any necessary changes to address it. Keep in mind that any false, incorrect or outdated information may compromise your use of the Services.

Privacy settings

The app's Settings give you quick access to the settings and tools you need to protect your data, and determine how your information is likely to optimize Wedely services.

Other methods of determining what information we collect from Wedely WeDriver App includes device settings: your device may offer options for selecting the information we collect. For example, you can change the location settings on your device.

Delete your information

If you would like us to delete your Account you can send a request at: . Upon receipt of this request, Wedely will make reasonable efforts to remove this information. Be aware, however, that this information may not be removed immediately from our backup systems. We strive to initiate the deletion process immediately after receiving your request. We then initiate a procedure to remove this information from our storage systems in a complete and secure manner. The procedure usually takes two months from the deletion date. As with any deletion process, events such as routine maintenance, unforeseen outages, bugs, or failures in our protocols may delay the processes and timelines set out in these Rules. We have systems designed to detect and correct these problems.

How is the data collected by the Wedely WeDriver App stored?

Depending on the type of data, it can be deleted whenever you want or automatically, or stored for longer periods of time, as needed. This section describes why our retention times differ depending on the type of data.

• Information retained until your Wedely WeDriver App Account is deleted: We can retain certain data as long as your Wedely WeDriver App Account is active if it allows us to understand how users interact with our features and how we can improve our services. We will keep the information on the number of deliveries
• When you delete your Wedely WeDriver App Account, information about the number of deliveries you’ve completed is kept for billing purposes
• Information held for long periods of time for limited purposes: professional requirements and legal obligations may require us to keep certain information, for specific purposes, for long periods of time. When, for example, Wedely Driver App processes a payment made for you, we keep this data for a long time, necessary for tax or accounting purposes. Reasons why we are likely to keep certain data for long periods of time are:
• Security, fraud and abuse prevention
• Financial data archiving
• Compliance with legal or regulatory obligations
• Guarantee of the continuity of our services
• Direct communications with Wedely

How is the accumulated information used by Wedely?

Wedely is likely to use anonymous information, statistical or cumulative (including anonymous location information), in a form that does not identify a specific user, in order to properly ensure the Services, improve the quality of the Services, optimize your experience, create services and features, including personalized services, modify or cancel existing content or service, and pursue other internal, commercial and statistical objectives (such as advertising).

Wedely may also use anonymous, statistical or aggregated information collected on the Services in a form that does not identify a specific user by publishing, disseminating, transmitting or otherwise making this information accessible to Service users, service providers, partners and any other third party.

Information security

Wedely believes that information security is a top priority. Wedely services incorporate powerful security features that protect your information on an ongoing basis. Wedely implements systems, applications and procedures to secure your personal information, minimizing the risk of data being stolen, damaged, lost, or unauthorized access or use. For example, we review our information collection, storage and processing practices, including physical security measures, to protect our unauthorized access systems. In addition, we limit access to personal information to Wedely employees, subcontractors and agents who must access it for processing purposes. Anyone with access to it is subject to strict contractual obligations of confidentiality and is subject to disciplinary action up to and including breach of contract in the event of breach of these obligations.

The information we collect through our services allows us to automatically detect and block threats to your security.

However, these measures do not offer absolute protection. Therefore, although Wedely makes many efforts to protect your personal information, Wedely cannot guarantee and you cannot reasonably expect that Wedely databases will be fully protected from wrongdoing, failures, illegal interceptions or access, or other types of abuse or misuse.

Compliance and cooperation with regulators

We regularly review these Privacy Rules and make sure to treat your information in accordance with it.

Data transfers

We store the data on servers located in Germany and Luxembourg and your information is likely to be processed on servers. The data remains in Europe only.

When we receive a formal written complaint, we respond by contacting the user who made it. We cooperate with the relevant regulatory authorities, including local data protection authorities ( CNPD ) , to resolve any disputes over the transfer of your data that we cannot resolve directly with you.

European requirements

If the European Union (EU) Data Protection Act applies to the processing of your information, we provide the controls described in these rules so that you can exercise your right to request access, update, delete, cancel and limit the processing of your information.

You can also export a copy of your Wedely WeDriver App account data if you want to keep it or export it to another service.

If you would like to export your data you can send a request at: . Upon receipt of this request, Wedely will make reasonable efforts to provide you all the information collected on your account.

Be aware that a Wedely WeDriver App account with a valid email address will be required to access the dashboard and receive the archive of your data.

You also have the right to object to the processing of your information.

We treat your information for the purposes described in these rules and in accordance with the following legal underpinnings:

With your consent

We ask you for permission to process your information for specific purposes, and you are free to retract your consent at any time. You can change your settings at any time, including your Privacy Settings in the app.

When we defend legitimate interests

We process your information to defend our legitimate interests and those of third parties (such as our partners, including advertisers, to provide them with usage statistics), while applying appropriate safeguards that protect your privacy. This means that we process your information in particular to perform the following operations:

• Offer our services, ensure their operation and improve them to meet the needs of our users
• Develop new services and features that are useful to our users
• Understand how individuals use our services (including how they interact with our ads) to ensure and improve the performance of our services
• Personalize our services to provide a better user experience
• Conduct marketing actions to promote our services to users
• Broadcast advertisements to inform users of our services for free
• Identify, avoid or treat fraudulent activities, abuses, security breaches or any technical problems encountered by our services
• Protect the rights, property or security of Wedely WeDriver App, our users or the public, as required or permitted by law
• Conduct research that improves our services for our users and benefits the public
• Fulfill obligations to our partners (e.g. developers and rights holders)
• Enforcing court decisions, including finding possible non-compliance with applicable Terms of Service

When we provide a service

We process your data to provide a service you requested under a contract (including our Terms of Service).

When we comply with legal obligations

We will process your data when we have a legal obligation to do so, for example if we act in the context of legal proceedings.

If you have any questions, please contact Wedely and our data protection department, led by our data protection representative, at: . If you have questions about the rights you are granted under your local legislation, you can contact your local data protection authority.

Changes to these Privacy Rules

Wedely may change the provisions of these Privacy Rules from time to time. Substantial changes will take effect 30 days after the date Wedely released:

• A system message to users to notify them of changes to the Privacy Rules; And
• A notification on the dashboard of the Wedely WeDriver App or any other appropriate web page to explain changes to the Privacy Policy, as well as a comparison of the "old" and "new" versions of the Privacy Policy.

The remaining changes will take effect 7 days after they are originally published on the Website. However, if Wedely amends these Privacy Rules to comply with legal obligations, these changes will take effect immediately as soon as they are originally published, or as required.

You agree to submit to any changes to the provisions of these Privacy Rules. By continuing to use the Services, you consent to the amended terms. If you do not accept the amended terms, you must stop using the Services.