Privacy Policy
The purpose of this Personal Data Protection Policy is to describe how Wendy’s/Dunkin’/Subway processes the information and data you provide to us. With this document, we would like to share the legal basis and purpose for obtaining and processing your personal data, and what legal and technical means we use to protect it. By accepting the Personal Data Protection Policy, you acknowledge and state that you understand and agree that your personal data may be processed in accordance with this policy.
1. About Us
1. About Us
References to Wendy’s/Dunkin’/Subway in this Personal Data Protection Policy mean references to LLC “W-Geo Restaurants” (a limited liability company established in accordance with the legislation of Georgia, ID: 405404076), LLC “Viendi” (a limited liability company established in accordance with the legislation of Georgia, ID: 405599605), LLC “Dan Georgia” (a limited liability company established in accordance with the legislation of Georgia, ID: 405404003), LLC “Sabgeorgia” (a limited liability company established in accordance with the legislation of Georgia, ID: 405620831) (hereinafter referred to as “the Company” or “we”). With this policy, we define the purposes and means of personal data processing.
2. Who is this document intended for?
This document is intended for customers (including former and/or future) of Wendy’s/Dunkin’/Subway or any other person who has expressed interest in a specific product.
3. How do we collect data?
We collect your data: As a result of your registration on the Wendy’s/Dunkin’/Subway “W&D” application (except when you operate the application as a guest, although in this case you will not be able to place an order);
4. What is the purpose of processing your personal data?
- The purposes of processing your personal data by us are:
- Ensuring your use of Wendy's/Dunkin'/Subway products;
- Providing you with information about new Wendy's/Dunkin'/Subway products;
- Implementation of marketing activities;
- Providing information about our brands and products.
5. What kind of data do we process?
The information and data about you that we may collect, store, use, and process may include the following data:
- Personal Data: User's personal page (account/profile) details: When you open (register) a user account (personal page/profile) and use the services of Wendy's/Dunkin'/Subway, for the processing/fulfillment of your order/request and for the purposes set forth in this Personal Data Protection Policy, we ask you to provide specific personal data about you, such as: first name and last name, email address, date of birth, phone number, gender.
- Log-in History and Orders: For the purpose of improving the functionality of the services and sharing a better experience with the user, we collect technical information transmitted by your device (e.g., history of orders you have placed, which language you prefer, time of entry, etc.).
6. How long do we store your personal data?
Wendy's/Dunkin'/Subway ensures the consistent and high-quality protection and security of your personal data. We store your data for the period necessary to achieve the purpose of processing. Your data will be stored in accordance with the purposes provided by this policy, law, and regulatory documents.
7. With whom do we share your data?
If necessary, when there are grounds for data processing, and to fulfill obligations under the law or contract, we may share your personal data with the Wendy's/Dunkin'/Subway group and other persons listed below:
- Your legal representative;
- Law enforcement authorities, a regulator, or other bodies defined by law;
- Third parties to whom you ask (or allow) us to share your data;
- Third parties for whom the sharing of information is necessary to ensure the delivery of the products requested by you (e.g., banks);
- Service providers – companies that provide services to us or provide services on our behalf;
- Any third party provided for by law.
8. Joint Controllers
Essence of Joint Processing As noted in this document, to ensure the operation of the Wendy’s/Dunkin’/Subway application and the provision of uninterrupted service to customers, your personal data is jointly processed by the four companies in the group:
- LLC "W-Geo Restaurants" (ID: 405404076)
- LLC "Viendi" (ID: 405599605)
- LLC "Dan Georgia" (ID: 405404003)
- LLC "Sabgeorgia" (ID: 405620831) The companies are joint controllers because they jointly determine the purposes and means of processing your personal data.
Purposes and Legal Basis for Joint Processing:
- Ensuring your use of products.
- Implementation of marketing activities and provision of information about new products.
- Improvement of service functionality.
- The basis for processing is your Consent and/or Fulfillment of the contract (order processing/fulfillment).
Essence of the Distribution of Responsibilities among Joint Controllers Each company is responsible for receiving, processing, fulfilling the order within its own brand (Wendy’s Dunkin’ or Subway) and processing the related log-in and order history data. All joint controllers of the group are jointly responsible for ensuring the rights of the data subject, regardless of which company the customer contacts.
9. How do we protect the security of your personal data?
We pay great attention to the implementation and execution of measures for the protection of your personal data. We have implemented appropriate physical, technical, and organizational security measures to prevent unauthorized access and to ensure the correct use of the information we collect. To protect the personal information of our customers, we use standard control procedures and means, such as, for example: Ø Encrypted connection; Ø Authentication and access control;
10. Online Security
Despite taking all necessary measures for information security, in the conditions of rapid technological development, we do not take responsibility for the actions of individuals who carry out unauthorized access, misuse, or breach servers. We make no express, implied, or other warranties, except that we will take every precaution to prevent such intrusion.
11. You have the right to:
- Receive information about the data processed about you;
- Request the correction, update, and/or addition of erroneous, inaccurate, and/or incomplete data;
- Request the termination of data processing, deletion, or destruction;
- Withdraw consent, which is the basis for data processing; to withdraw consent, you can contact us at the following email address: office-assistant@wendys.ge .
12. Terms of Use
Your use of the Wendy's/Dunkin'/Subway application (except if you are operating on the page as a guest) means that you agree to our use of your personal data. The Personal Data Protection Policy is an integral part of the application terms and conditions.
13. Your Obligations
To receive the service, it is necessary to have complete and correct information about you, so please notify us if your contact or other information changes.
14. Contact Us
Contact us at office-assistant@wendys.ge if you have questions or would like more information on how we process your personal data.
Annex N1: Data Subject's Written Consent to Personal Data Processing:
I declare my consent to the processing of my personal data, namely: first name and last name, email address, phone number, gender, date of birth, other information and/or data whose processing is permitted by the legislation of Georgia, allows for my personal identification, and is necessary for the purposes of purchasing products from Wendy’s/Dunkin’/Subway . I also consent to the collection, recording, organization, storage, modification, recovery, demand back, use, blocking, deletion, or destruction of my personal data. This consent is given by me freely, of my own free will, and serves my interest. By electronically marking/confirming this consent, you confirm that you simultaneously agree to this Personal Data Protection Policy, that the information provided by you is accurate and true data. The information was provided at your own wish and for this you have all the rights and permissions provided by law.
