Personal Data Protection Policy

The purpose of this Personal Data Protection Policy is to describe how W | D | S Wendy’s/Dunkin’/Subway Application processes the information and data you provide to us. With this document, we would like to share with you on what basis and purpose we collect and process your personal data and by what legal and technical means we protect them. By accepting the personal data protection policy, you acknowledge and declare that you understand and agree to the processing of your personal data in accordance with this policy.

  1. About Us

References to Wendy’s/Dunkin’/Subway in the Personal Data Protection Policy mean references to “W-Geo Restaurants” LTD (a limited liability company established in accordance with the legislation of Georgia, I/C: 405404076), “WND” LLC (a limited liability company established in accordance with the legislation of Georgia, I/C: 405599605), “KIOSK GEORGIA” LTD (a limited liability company established in accordance with the legislation of Georgia, I/C: 405404003), “SubGeorgia” LLC (a limited liability company established in accordance with the legislation of Georgia, I/C: 405620831) (hereinafter “The Company” or “We”). In this policy, we define the purposes and means of personal data processing.

  1. Who is this document intended for?

This document is intended for use by Wendy’s/Dunkin’/Subway customers [including past and/or future customers] or anyone who has expressed an interest in a particular product.

  1. How do we collect data?

Your data is collected for us:

as a result of your registration on the Wendy’s/Dunkin’/Subway App “W&D” (unless you operate the App as a guest, in which case you will not be able to place an order);

  1. What is the purpose of processing your personal data?

Purposes of our processing of your personal data: 

⮚      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.

  1. What data do we process?

The information and data that we may collect, store, use and process about you may include the following data:

⮚      Personal data:

Details of the user’s personal page (account/profile):

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 and last name, e-mail address, date of birth, telephone number, gender.

⮚      Log-in history and orders:

In order to improve the functionality of the services and provide a better user experience, we collect technical information transmitted by your device [for example, the history of orders you have made, what language you prefer, login time, etc.].

  1. How long do we keep your personal data?

Wendy’s/Dunkin’/Subway ensures a consistent and high level of protection and security of your personal data.  

We keep your data for the period necessary to achieve the purpose of the processing. Your data will be stored in accordance with the purposes set out in this policy, law and regulatory documents.

  1. Who do we share your data with?

We may share your personal data with the Wendy’s/Dunkin’/Subway group and others listed below as necessary when there are grounds for processing the data to comply with our legal or contractual obligations:

●        your legal representative;

●        to law enforcement authorities, regulators or other bodies defined by law;

●        third parties with whom you ask (or allow us) to share your data;

●        to third parties with whom sharing information is necessary to ensure the delivery of the products you have requested (for example, banks);

●        Service providers – companies that provide services to us or provide services on our behalf;

●        to any third party provided for by law.

  1. How do we ensure the security of your personal data?

We pay great attention to the introduction and implementation of measures to protect your personal data. We have introduced appropriate physical, technical and organizational security measures to prevent unauthorized access and to ensure the correct use of the information we collect.

To protect our users’ personal information, we use standard control procedures and measures, such as, for example:

⮚      encrypted connection;

⮚      authentication and access control;

  1. Online security

Although we take all necessary measures to ensure information security, in an environment of rapid advances in technology, we do not accept responsibility for the actions of persons who unauthorizedly access, misuse or compromise our servers. (Although we take all necessary measures for information security, in the conditions of rapid technological development, we do not accept responsibility for the actions of persons who make unauthorized access, misuse or hack servers.) We make no warranties, express, implied or otherwise, except that we take every precaution to prevent such intrusion.

  1. You have the right to:

⮚      receive information about the data processed about you;

⮚      request correction, update and/or addition of erroneous, inaccurate and/or incomplete data;

⮚      request termination, deletion or destruction of data processing;

⮚      demand back consent, which is the basis for data processing; to demand back consent, you can contact us at the following e-mail address: office-assistant@wendys.ge.

  1. Terms of Use

Your use of the Wendy’s/Dunkin’/Subway App (except if you are accessing the page as a guest) means you agree to our use of your Personal Data. The Personal Data Protection Policy is an integral part of the application terms and conditions.

  1. Your Obligations

In order to receive services, it is necessary for us to have complete and correct information about you, therefore, please notify us in case of changes in your contact or other information.

  1. Contact Us

Contact us at office-assistant@wendys.ge if you have questions or would like to receive more information about how we process your personal data.

Appendix N1Written consent of the data subject to the processing of personal data:

I consent to the processing of my personal data, namely: first and last name, email address, phone number, gender, date of birth, other information and/or data, the processing of which is permitted by the legislation of Georgia, gives a possibility of personal identification and is necessary for the purpose 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 voluntarily, of my own free will and serves my interests.

By marking/confirming the specified consent in electronic form, you confirm that you agree with this Personal Data Protection Policy and that the information you provide is accurate and truthful. The information is provided by you voluntarily and for this, you have all rights and permissions stipulated by the legislation.