Thank you for using the application “Driver” Wora (“Wora Driver”) that you have downloaded on your mobile phone to execute as a driver (the “Driver”) the activities and services of products’ transportation and delivery on behalf of Wora S.r.l., with its registered office in Via A. Albricci n. 8 (the “Company” or “Wora”) and in favor of Wora’s clients.
Pursuant to Regulation (EU) 2016/679 (General Data Protection Regulation – “Regulation”) and – if and when applicable – Italian Legislative Decree no. 196/2003 “Codice in materia di protezione dei dati personali” (“Privacy Code”), we hereby inform you that Wora will, as a data controller (the “Controller”), process all the personal data regarding you (whether an individual company or a professional), your contractual contacts, managers, partners, administrators and everyone belonging to your staff.
Wora is pleased to provide this information to those who have downloaded and use the Wora Driver (the “Data Subjects”). Please be assured that Wora uses its best efforts to protect the privacy of Data Subjects.
Legal basis and scope of the data processing
Your personal data will be collected and processed by the Company, as Controller, as further explained below:
- to comply with contractual and pre-contractual obligations: within the purpose of managing the activities and services of products’ transportation and delivery on behalf of Wora and for the fulfillment of every obligation linked to such activities;
- by virtue of your consent (optional and revocable at any time): for the specific collection, analysis, elaboration of any personal data deriving from using Wora Driver (geolocalization included);
- to comply with a legal obligation: for the purposes connected with obligations prescribed by the applicable laws, regulations and EU legislation, as well as any disposition coming from a legitimate authority and from supervisory or control bodies;
- according to a legitimate interest of the Company: (i) for the defense of any right or interest of the Company before a court or any other authority or body, with expressed inclusion of whoever in charge of credit recovery; (ii) for the communication of personal data, anonymized, to third parties for everything concerning the purposes and areas of the execution of the activities and services of products’ transportation and delivery on behalf of Wora (in particular, for the study of the driving style, the routes taken and the types of roads traveled, for statistical and research purposes).
By using Wora Driver, you agree to the terms of this Policy. Whenever you submit information via Wora Driver, you consent to the collection, use and disclosure of the information in accordance with this Policy.
By using Wora Driver, you hereby consent to the data processing.
Types of information we collect and how it is used
When registering on, or using, Wora Driver, you may be asked to enter your name, email address, mailing address, telephone number and/or other details. Wora Driver gathers such personal information only when voluntarily submitted by you.
However, if you do not agree or consent to submission of such information, you will not be allowed to register yourself or use any functions on our app which require such personal information to be submitted.
In addition to the above – and considering that the installation of Wora Driver on your device will keep track of live geolocalization, delivery routes, clients’ rating, number of accepted, canceled or completed orders – the Company will, subject to your consent, collect and process all the data coming from Wora Driver utilization.
By using Wora Driver, the Company will – only in the event of direct activation of the geolocalization function on your device and during your actual service hours only – receive information related to your device’s geographic location, including a unique identifier code linked to your device, in order to correctly manage the service and provide the users with useful information about the status of the requested delivery.
The Controller will use such obtained data within the unique purposes of (i) informing the user (whose order request you accepted) about the current status of the order itself and (ii) allowing the user to contact you in the event of problems.
Sharing of personal information
Personal information that you submit to, or collected by, Wora Driver may be disclosed to a third party such as our vendors/suppliers and/or agents, who are employed to provide some of our services, to meet the purpose for which it was submitted.
In addition, when you visit or use Wora Driver, we may collect certain information by automated means. The information we collect may include your Internet Protocol (IP) address, computer/mobile device operating system and browser type, type of mobile device, the location of mobile device, the Unique Device Identifier (UDID) or Mobile Equipment Identifier (MEID), the network carrier or any other information about your mobile device, the address of a referring website (if any), and the pages you visit on our website. We may use this information to operate, maintain, and manage Wora Driver and to provide services such as technical support. We provide additional information regarding our use of “cookies” in this Policy below.
When using the Wora Driver additional information is collected when you place an order online. This information assists in the delivery to your door and to verify your online payment. The internet order system also stores information about your order to help you remember and re-order the same menu in future.
Mobile devices and location information
As explained above, Wora Driver may collect precise information about the location of your mobile device using technologies such as GPS, Wi-Fi, or cell tower proximity.
For most mobile devices, you are able to withdraw your permission for HRPL to acquire this information on your location through the device settings. If you have questions about how to disable your mobile device’s location services, we recommend you contact your mobile device service provider or the device manufacturer. If you would like us to delete location information we have collected, please contact us at the email or postal address listed below. Please note that the applications may not function properly following deletion, and that we may be required by law to retain certain information.
Wora Driver does not sell personal information to third parties, though, with your permission, such personal information may be, subject to compliance with this Policy, transferred, shared or disclosed to third parties including third parties service providers outside Wora. Such personal information may be transferred, shared or disclosed securely via modern cryptography (e.g. over HTTPS). In case personal information is shared, transferred or disclosed to third party service providers, it shall be done so only for the purpose of personalizing your online using experience. Wora Driver reserves the right to use or disclose any information as needed to satisfy any law, regulation or legal request, to protect the integrity of the sites, to fulfil your requests, or to co-operate in any law enforcement investigation or an investigation on a matter of public safety.
To participate as a driver on behalf of Wora, you must permit the Wora Driver Services to access location services through the permission system used by your mobile operating system (“Platform”) or browser. Just in case you are executing your services on behalf of Wora, we may collect the precise location of your device when Wora Driver is running in the foreground or background of your device. We may also derive your approximate location from your IP address. We use your location information to verify that you are present in your preferred region or city when you begin or engage in a delivery, connect you with delivery opportunities in your zone, and track the progress and completion of your Deliveries. You can enable the location tracking feature through the settings on your device or Platform or when prompted by Wora Driver. If you choose to disable the location feature through the settings on your device or Platform, Wora Driver will not receive precise location information from your device, which will prevent you from being able to trip and receiving delivery opportunities in your area.
Wora Driver will not collect, use or disclose sensitive information except with your specific consent.
Children’s privacy notice
Wora understands the importance of privacy to visitors to and users of our Wora Driver. We are especially committed to protecting the privacy of children who visit or use our Online Services. For this reason, people of underage are not allowed to download Wora Driver.
Wora Driver will take reasonable steps to ensure that the personal information collected is accurate, complete and up-to-date. You can access and edit/modify your personal information (i.e. name, postal address and contact details at any time). Wora will take reasonable steps to protect personal information from misuse, loss and unauthorized access, modification or disclosure.
Data Subject’s Rights
Under the Regulation, any Data Subject is entitled to exercise specific rights. Consequently, within the scope of the data collection performed by the Company – as described in this Policy – you may exercise the following rights:
- right of access: the right to obtain a confirmation on whether or not your personal data are being processed and, in such hypothesis, to access such data and any specific information concerning the processing – i.e. the scope, the kinds of data currently under processing, any data recipient or recipient category, storage times (or the criteria beyond it), the existence of the right to request rectification or cancellation, limitation or opposition to the processing, the right to file a complaint to the “Autorità di Controllo” (the “Supervisory Authority”) and information concerning the origin of the data; the existence of any automated decision-making process on your data.
- right of rectification: the right to request and obtain rectification of your personal data and/or the integrate them if incomplete;
- right of cancellation: the right to have your data erased without undue delay whether – among other conditions – (i) such data are not necessary to the purposes they were collected for; (ii) consent making the basis for the processing has been revoked (provided it was the only basis and there is no other legal basis for such processing); (iii) you object either the processing (as further explained below) and there is no other legitimate reason for the processing to override your objection or the processing is aimed at marketing or marketing-targeted profiling operations; (iv) your data are being unlawfully processed; (v) your data must be erased under a legal obligation. This right shall not apply whether the processing is necessary – among others – for the fulfillment of a legal obligation or for the assessment, exercise or defense of a right in court;
- right of limitation: under the circumstances displayed at Section 18 of the Regulation you have the right to obtain the limitation of data processing;
- right of portability: right to receive your data in a structured, commonly used, readable by an automatic device and ready to transmit format, so that you can transfer them to another Controller within the hypothesis in which data processing is based upon consent or is related to particular categories of consent-based data processing or the latter is based on the execution of a contract and is performed automatically;
- right of objection: the right to object at any time the processing based on a Controller legitimate interest, unless the latter gives evidence of (i) legitimate and binding reasons beyond the processing that may prevail over the interests of the Data Subject; (ii) the assessment, exercise and defense of a right in court.
In addition, you have the right to file a complaint to the Supervisory Authority (www.garanteprivacy.it) under the circumstances displayed at Section 77 of the Regulation – in other words, when you believe your data to be processed in violation of the provisions of the Regulation itself.
Should you need any other information and/or should you exercise your rights, including consent revocation, you can reach to the Controller at the following addresses: Wora S.r.l., Milan Registered Office, Via Albricci n. 8; PEC: firstname.lastname@example.org.
With regard to the Company’s costumers details you may collect, you – as processor (the “Processor”) – undertake to:
- not to process the collected data for any scope other than those necessary contacting the user for order delivery or the Company’s staff for any issue management related;
- comply with the obligations set forth under Section 28 of the Regulation;
- always respect the confidentiality of the data you have access to, without them being disclosed to any third party without a prior written authorization by the Controller;
- apply adequate safety measures to the processed data and to any system used to collect and storage the data (i.e. password protection, access control to the system based on proceeding needs);
- not to use sub-processors without a prior written authorization by the Company. In any case, said sub-processors shall be proven compliant with the current legislation;
- cooperate with the Company should any request to exercise the Data Subject’s rights come from users of the Wora Driver. For this purpose, the Controller will notify the Company within 12 (twelve) hours about any received request;
- cooperate with the Company to ensure compliance with the adequate technical and organizational measures taken;
- provide written communication about any security breach in the used systems within 12 (twelve) hours from its occurrence;
- following the Company’s request, delete or return any data used by Wora Driver.
We may associate personal information with a cookie file in those instances.
With most internet browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. If you want to do this, refer to your browser instructions or help screen to learn more. If you disable all cookies, you may not be able to take advantage of all the features of our sites.
If we change our Policy, we will post the revised version here, so we suggest that you check here periodically for the most up-to-date version of our Policy. Your continued use of the sites will be deemed acceptance of the Policy.
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