I. Introduction

When you use Ruddy, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices.

This notice describes the personal data we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read this, which highlights key points about our privacy practices.

 

Last modified: August 25, 2020

II. Overview

A. Scope

This notice applies to users of Ruddy’s services anywhere in the world, including users of Ruddy’s apps, websites, features, or other services.

This notice describes how Ruddy and its affiliates collect and use personal data. This notice applies to all users of our apps, websites, features, or other services anywhere in the world. This notice specifically applies to:

  • App users: individuals who request or receive food, or other products and services through Ruddy’s mobile app
  • Business partners: individuals who provide, or submit applications to Ruddy to provide, food or other services

This notice also governs Ruddy’s other collections of personal data in connection with Ruddy’s services. For example, we may collect the contact information of individuals who use accounts owned by Ruddy for Business customers or of owners or employees of Ruddy’s restaurant partners, or we may collect other personal data in connection with our mapping technology and features.
All those subject to this notice are referred to as “users” in this notice.

Our data practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places. Please contact us here or through the addresses below with any questions regarding our practices in a particular country or region.

B. Data controller and transfer

Ruddy and Ruddy OÜ are the data controllers for the personal data collected in connection with use of Ruddy’s services in the European Economic Area and the United Kingdom.

Ruddy is the data controller for the personal data collected in connection with use of Ruddy’s services anywhere else.

Ruddy (Vredelaan 3, 1081 Koekelberg, Belgium) and Ruddy OÜ (Harju maakond, Tallinn, Kesklinna linnaosa, Tartu mnt 67/1-13b, 10115, Estonia) are the data controllers for the personal data collected in connection with use of Ruddy’s services in the European Economic Area and the United Kingdom. 

Ruddy is the data controller for the personal data collected in connection with use of Ruddy’s services anywhere else. We process personal data inside and outside of the United States. The personal data of users outside the United States is transferred on the basis of mechanisms approved under applicable laws, such as the Standard Contractual Clauses.

Questions, comments, and complaints about Ruddy’s data practices can be submitted here.

III. Data collection and uses

A. The data we collect

Ruddy collects:

  • Data provided by users to Ruddy, such as during account creation
  • Data created during use of our services, such as location, app usage, and device data
  • Data from other sources, such as Ruddy partners and third parties that use Ruddy APIs
  • The following data is collected by or on behalf of Ruddy:

    1. Data provided by users. This includes:

    • User profile: We collect data when users create or update their Ruddy accounts. This may include their name, email, phone number, login name and password, diet, weight, height, level of activity, address, profile picture, payment or banking information (including related payment verification information), government identification documents, including driver’s license numbers and images, birthdate, signature, and photo. For more information, please see the section titled “How we use personal data.”
    • Demographic data: We may collect demographic data about users, including through user surveys. In some countries, we may also receive demographic data about users from third parties.
    • User content: We collect the information users submit when they contact Ruddy customer support, provide ratings or compliments for other users or restaurant partners, or otherwise contact Ruddy. This may include feedback, photographs or other recordings collected by users.

    2. Data created during use of our services. This includes:

    • Location data: We collect precise or approximate location data from a user’s mobile device if enabled by the user to do so. For users and business partners, Ruddy collects this data when the Ruddy app is running in the foreground. In certain regions (which do not include the European Union), Ruddy may also collect this data when the Ruddy app is running in the background of the user’s mobile device. Users may use the Ruddy apps without enabling Ruddy to collect location data from their mobile devices. However, this may affect some functionality available in the Ruddy apps. For example, a user who has not enabled location data collection will have to manually select their current location.
    • Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided, order details, nutrition information, date and time the service was provided, amount charged, distance traveled, and payment method. Additionally, if someone uses your promotion code, we may associate your name with that person.
    • Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers. To learn more about these technologies, please see our Cookie Notice.
    • Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.
    • Communications data: We enable users to communicate with each other and Ruddy through Ruddy’s mobile apps and websites. For example, we enable user and restaurants to call, text, or send other files to each other (generally without disclosing their telephone numbers to each other). To provide this service, Ruddy receives some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. Ruddy may also use this data for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our products and services, and for analytics.

    3. Data from other sources. This includes:

    • User feedback, such as ratings, feedback, or compliments.
    • Users participating in our referral programs. For example, when a user refers another person, we receive the referred person’s personal data from that user.
    • Ruddy account owners who request services for or on behalf of other users, or who enable such users to request or receive services through their accounts. 
    • Users or others providing information in connection with claims or disputes.
    • Ruddy business partners through which users create or access their Ruddy account, such as payment providers, social media services, or apps or websites that use Ruddy’s APIs or whose APIs Ruddy uses.
    • Vendors who help us verify users’ identity, background information, and eligibility to work, for regulatory, safety, and security purposes.
    • Publicly available sources.
    • Marketing service providers.

    Ruddy may combine the data collected from these sources with other data in its possession.

    B. How we use personal data

    Ruddy collects and uses data to enable reliable and convenient services. We also use the data we collect:

    • To enhance the safety and security of our users and services
    • For customer support
    • For research and development
    • To enable communications between users
    • To send marketing and non-marketing communications to users
    • In connection with legal proceedings

    Ruddy does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.

    Ruddy uses the data it collects for purposes including:

    1. Providing services and features. Ruddy uses the data we collect to provide, personalize, maintain, and improve our products and services.

    This includes using the data to:

    • Create and update users’ accounts.
    • Verify business partners’ identity, background history, and eligibility to be on our platform.
    • Offer, process, or facilitate payments for our services.
    • Offer, obtain, provide, or facilitate invoicing, or financing solutions in connection with our services.
    • Track and share the progress of orders.
    • Enable features that allow users to share information with other people, such as when users submit a compliment about a restaurant or share ETA and location with their contacts.
    • Enable features to personalize users’ Ruddy accounts, such as creating bookmarks for favorite places, and to enable quick access to previous destinations. We may, for example, present an Ruddy’s user with personalized restaurant or food recommendations based on their prior orders, health and diet preferences. Please see the section of this notice titled “Choice and transparency” to learn how to object to this use of personal data.
    • Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.

    2. Safety and security. We use personal data to help maintain the safety, security, and integrity of our services and users.

    This includes:

    • Screening restaurants before enabling their use of our services and at subsequent intervals, including through reviews of background checks, where permitted by law, to help prevent use of our services by dishonest partners.
    • Using device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities.
    • Violation and non compliance with our Community Guidelines grounds for deactivating users and business partners from all of our platform. 

    3. Customer support. Ruddy uses the information we collect (including recordings of customer support calls with notice to and the consent of the user) to provide customer support, including to:

    • Direct questions to the appropriate customer support person.
    • Investigate and address user concerns.
    • Monitor and improve our customer support responses and processes.

    4. Research and development. We may use the data we collect for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us to improve and enhance the safety and security of our services, improve our ability to prevent the use of our services for illegal or improper purposes, develop new features and products, and facilitate insurance and finance solutions in connection with our services.

    5. Enabling communications between users. For example, a user may message or call a restaurant to confirm a pickup location or a restaurant may call a delivery recipient with information about their order.

    6. Marketing. Ruddy may use the data we collect to market our services to our users. This includes sending users communications about Ruddy services, features, promotions, sweepstakes, studies, surveys, news, updates, and events.

    We may also send communications to our users about products and services offered by Ruddy partners. For example, if a user has placed a food order, we may provide recommendations, promotions, or ads about similar food offered by other Ruddy partners. Although we may send users communications about Ruddy partners’ products and services, we do not sell users’ personal data to, or share it with, such partners or others for purposes of their own direct marketing or advertising, except with users’ consent.

    We may use the data we collect to personalize the marketing communications (including advertisements) that we send, including based on user location, past use of Ruddy’s services, and user preferences and settings.

    We may also send users communications regarding elections, ballots, referenda, and other political and notice processes that relate to our services. For example, Ruddy has notified some users by email of new governmental directive or policies that concerns Ruddy’s products and services.

    7. Non-marketing communications. Ruddy may use the data we collect to generate and provide users with receipts; inform them of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of Ruddy or its partners.

    8. Legal proceedings and requirements. We may use the personal data we collect to investigate or address claims or disputes relating to use of Ruddy’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

    C. Cookies and third-party technologies

    Ruddy and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice.

    Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. Ruddy uses cookies and similar technologies for purposes such as:

    • Authenticating users
    • Remembering user preferences and settings
    • Determining the popularity of content
    • Delivering and measuring the effectiveness of advertising campaigns
    • Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services

    We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.

    Please see our Cookie Notice for more information regarding the use of cookies and other technologies described in this section.

    D. Data sharing and disclosure

    Some of Ruddy’s products, services, and features require that we share data with other users or at a user’s request. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

    Ruddy may share the data we collect:

    1. With other users

    This includes sharing:

    • Order recipients’ first name and order information with the restaurant. We may also share ratings and feedback, or other information to the extent required by law, with the restaurant partner.
    • For those who participate in Ruddy’s referral program, we share certain personal data of referred users, such as their nutritional intake, with the user who referred them, to the extent relevant to determining the referral bonus.

    2. At the user’s request

    This includes sharing data with:

    • Other people at the user’s request. For example, we share a user’s ETA and location with a friend when requested by that user, or a user’s order information when they split the order with a friend.
    • Ruddy business partners. For example, if a user requests a service through a partnership or promotional offering made by a third party, Ruddy may share certain data with those third parties. This may include, for example, other services, platforms, apps or websites that integrate with our APIs; those with an API or service with which we integrate; or restaurant partners or other Ruddy business partners and their users in connection with promotions, contests, or specialized services.

    3. With the general public

    Questions or comments from users submitted through public forums such as Ruddy blogs and Ruddy social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user.

    4. With Ruddy subsidiaries and affiliates

    We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, Ruddy processes and stores data in the EU countries on behalf of its international subsidiaries and affiliates.

    5. With Ruddy service providers and business partners

    Ruddy provides data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:

    • Payment processors and facilitators
    • Cloud storage providers
    • Marketing partners and marketing platform providers, including social media advertising services
    • Data analytics providers
    • Research partners, including those performing surveys or research projects in partnership with Ruddy or on Ruddy’s behalf
    • Vendors that assist Ruddy to enhance the safety and security of its apps
    • Consultants, lawyers, accountants, and other professional service providers
    • Insurance and financing partners
    • Airports
    • Restaurant partners and/or their point of sale providers

    6. For legal reasons or in the event of a dispute

    Ruddy may share users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes sharing personal data with law enforcement officials, public health officials, other government authorities, airports (if required by the airport authorities as a condition of operating on airport property), or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect Ruddy’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. If you use another person’s credit card, we may be required by law to share your personal data, including trip or order information, with the owner of that credit card.

    Please see Ruddy’s Guidelines for Law Enforcement Authorities for more information.

    This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

    7. With consent

    Ruddy may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing.

    E. Data retention and deletion

    Ruddy retains user profile, transaction, and other personal data for as long as a user maintains their Ruddy account.

    Ruddy may retain certain user data after receiving an account deletion request if necessary, such as to comply with legal requirements.

    Ruddy retains user profile, transaction, and other information for as long as a user maintains their Ruddy account. 

    Order recipients may request deletion of their account at any time through the app or through a request by email. Following such requests, Ruddy deletes the data that it is not required to retain for purposes of regulatory, tax, insurance, litigation, or other legal requirements. For example, Ruddy retains location, device, and usage data for these purposes for a minimum of 7 years; while it retains such data, it may also use it for purposes of safety, security, fraud prevention and detection, and research and development. In certain circumstances, Ruddy may be unable to delete a user’s account, such as if there’s an outstanding credit on the account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, Ruddy will delete the account as described above.

    Ruddy may also retain certain information if necessary for purposes of safety, security, and fraud prevention. For example, if Ruddy deactivates a user’s account because of unsafe behavior or security incidents, Ruddy may retain certain information about that account to prevent that user from opening a new Ruddy account in the future.

    F. Grounds for processing

    We only collect and use personal data where we have lawful grounds to do so. These include processing user personal data to provide requested services and features, for purposes of Ruddy’s legitimate interests or those of other parties, to fulfill our legal obligations, or based on consent.

    We collect and use personal data only where we have one or more lawful grounds for doing so. Such grounds may vary depending on where our users are located, but generally include processing personal data:

    a. To provide requested services and features

    In order to provide our services, we must collect and use certain personal data. This includes:

    • User profile data, which we use to establish and maintain user accounts; verify user identity; communicate with users about their orders, and accounts; and enable users to make payments or receive earnings
    • Users location data, which we use to track trips and assist with navigation
    • Usage data, which is necessary to maintain, optimize, and enhance Ruddy’s services, including to determine incentives
    • Transaction information
    • Nutritional information
    • Information relating to customer support

    b. For purposes of the legitimate interests of Ruddy or other parties

    This includes using personal data to maintain and enhance our users’ safety and security. For example, we use personal data to prevent use of our services by users who have engaged in inappropriate or dangerous behavior, such as by retaining data of banned users to prevent their use of Ruddy’s apps.

    This also includes purposes such as combating fraud; improving our services, direct marketing, research, and development; and enforcing Ruddy’s Terms of Service.

    In addition, it includes using personal data to the extent necessary for the interests of other people or the general public, such as in connection with legal or insurance claims, and to protect the rights and safety of others.

    c. To fulfill Ruddy’s legal obligations

    For example, Ruddy is subject to laws and regulations in many cities and countries that require it to collect and retain data about our users’ and to provide copies of such data to the government or other authorities. We collect and use personal data to comply with such laws.

    Ruddy may also share data with law enforcement regarding criminal acts or threats to public safety, or requests by third parties pursuant to legal processes. For more information please get in touch with us by email.

    d. With consent

    Ruddy may collect and use personal data based on the user’s consent. For example, we may collect personal data through voluntary surveys. Responses to such surveys are collected on the basis of consent and will be deleted once no longer necessary for the purposes collected.

    A user who has provided consent to a collection or use of their personal data can revoke it at any time. However, the user will not be able to use any service or feature that requires collection or use of that personal data.

    IV. Choice and transparency

    Ruddy enables users to access and control the data that Ruddy collects, including through:

    • In-app settings
    • Device permissions
    • In-app ratings pages
    • Marketing opt-outs


    Ruddy also enables users to request access to or copies of their data, changes or updates to their accounts, deletion of their accounts, or that Ruddy restrict its processing of user personal data.

    A. Privacy settings

    Settings menus in the Ruddy app for users give them the ability to set or update their location-sharing preferences and their preferences for receiving mobile notifications from Ruddy. For more information about these settings, how to set or change these settings, and the effect of turning off these settings please contact us by email.

    • Location data

    Ruddy uses device location services to make it easier to get to restaurants and order dishes. Location data helps improve our services, including pickups, navigation, and customer support.

    Users may enable or disallow Ruddy to collect location data from their mobile devices.

    • Share Live Location

    Users who have enabled Ruddy to collect location data from their mobile device may also enable Ruddy to share their location with restaurants in order to facilitate pickup and orders.

    Users may enable or disable this feature on their device.

    • Notifications: account and order updates

    Ruddy provides users with order status notifications and updates related to activity on their account. These notifications are a necessary part of using the Ruddy app and cannot be disabled. However, users may choose the method by which they receive these notifications through the settings on their device.

    • Notifications: discounts and news

    Users may enable Ruddy to send push notifications about discounts and news from Ruddy. Push notifications may be enabled or disabled through the settings of their device.

    • Communications from restaurant partners

    Order recipients who have opted in to communications from restaurant partners may stop sharing their data with each restaurant partner in their Ruddy account settings.

    B. Device permissions

    Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. iOS devices notify users the first time the Ruddy app requests permission to access certain types of data and gives users the option to grant or refuse permission. Android devices notify users of the permissions that the Ruddy app seeks before their first use of the app, and use of the app constitutes a grant of such permission.

    C. Ratings look-up

    After every order users and restaurant partners are able to rate each other on a scale from 1 to 5. An average of those ratings is associated with a user’s account and is displayed to other users for whom they provide or receive services.

    This 2-way system holds everyone accountable for their behavior. Accountability helps create a respectful, safe environment for users and restaurant partners.

    D. Marketing opt-outs

    Users may opt out of receiving promotional emails from Ruddy by contacting us by email. Users may also opt out of receiving emails and other messages from Ruddy by following the unsubscribe instructions in those messages. We may still send users who have opted out non-promotional communications, such as receipts for orders or information about their account.

    E. User data requests

    Ruddy provides users with a variety of ways to learn about, control, and submit questions and comments about Ruddy’s handling of their data. To make a request, please contact us by email.

    • Accessing data: Users can ask for an explanation of the data we collect from them and how we use it.
    • Receiving data: Users can ask for a copy of data that Ruddy collects from them with their consent or as necessary to provide our services.
    • Changing or updating data: Users can edit the name, phone number, email address, payment method, and photo associated with their account through the Settings menu in Ruddy’s apps or restaurant portal. They may also ask that Ruddy change or update their data, including if they believe such data is inaccurate or incomplete.
    • Deleting data: Users may request deletion of their account at any time by contacting us via email.
    • Objections, restrictions, and complaints: Users may request that we stop using all or some of their personal data, or that we limit our use of their data. Ruddy may continue to process data after such objection or request to the extent required or permitted by law.

    In addition, depending on their location, users may have the right to file a complaint relating to Ruddy’s handling of their personal data with the data protection authority in their country. For example, users in the European Union and South America may submit such requests to the data protection authorities in the country in which they live.

    V. Updates to this notice

    We may occasionally update this notice. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.

    We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Ruddy apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices. After such notice, use of our services by users in countries outside the European Union will be understood as consent to the updates to the extent permitted by law.