Privacy Policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and service users.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

1.4 In this policy, "we", "us" and "our" refer to WASO LTD. For more information about us, see Section 9.

2. How we use your personal data

2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.

2.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our website and a 3rd party analytics tracking system (Google Analytics, see 8.2). This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.3 We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you (upon sign-up). The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.4 We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address and, where provided, your mobile telephone number for SMS communications. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.5 We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include number of past purchases, date of purchases, preferred meals, amongst others. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.6 We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.7 We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

2.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

2.9 We may process information that you provide to us for the purpose of subscribing to our marketing communications, including your name, email address, mobile telephone number and, where applicable, your username, account identifier or other contact details for messaging platforms such as WhatsApp, LINE, Instagram Direct and Facebook Messenger (“marketing messaging channels”). We may use this information to send you news, offers, promotions, product updates and other marketing communications about WASO’s products and services. We will send marketing communications through a particular messaging channel only where you have explicitly opted in to receive them through that channel. For traditional channels like email or SMS, we will do so based on your consent or where otherwise permitted by applicable law (such as the soft opt-in for existing customers). The legal basis for this processing is your consent or our legitimate interests, depending on the channel. You may withdraw your consent at any time by using the unsubscribe option provided in the relevant message, replying “STOP” where that option is available, updating your communication preferences, or contacting us using the details in Section 9.

2.10 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.11 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.12 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.13 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.14 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

2.15 We may process your contact details, including your email address, mobile telephone number and, where applicable, your contact details for messaging platforms, to send you transactional or service-related communications. These may include order confirmations, delivery updates, payment or account notifications, responses to customer-service enquiries, and messages needed to provide our services to you. We may send these service-related communications by email, SMS, telephone or messaging platforms where necessary to perform our contract with you, to respond to your request, or for our legitimate interests in administering our business and providing customer support. Service-related communications are separate from marketing communications. You may opt out of marketing communications at any time, but we may still need to send you essential service-related messages concerning your order, account or delivery.

2.16 We may process your name and postal address for the purpose of sending you catalogues, discount coupons or other marketing materials by post. Legal basis: our legitimate interests in promoting our products and services. You may object to this processing at any time (see Section 7).

2.17 The legal basis for data processing is Article 6(1)(f) of the UK GDPR. Our legitimate interests lie in the proper presentation of our services, the protection of our systems, and the prevention of unauthorized access to our website. If the data processing is carried out for the purpose of fulfilling a contract, the legal basis is Article 6(1)(b) of the UK GDPR.

2.18 We may process identity data provided by Google when you choose to register or sign in using "Sign in with Google" ("Google sign-in data"), namely your email address, name and Google account identifier. Google sign-in data may be processed for the purposes of authenticating you and operating your account; see Section 10. The legal basis for this processing is the performance of a contract between you and us and, where applicable, your consent.

3. Providing your personal data to others

3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.3 Financial transactions relating to our website and services are handled by our payment services provider, Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://stripe.com/gb/privacy.

3.4 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

3.5 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.6 We may share your postal address with trusted fulfilment partners solely for the purpose of printing and dispatching our direct-mail pieces under strict confidentiality agreements.

4. International transfers of your personal data

4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2 We and our other group companies have offices and facilities in Japan. The European Commission has made an "adequacy decision" with respect to [the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

4.3 The hosting facilities for our website are situated in the United Kingdom. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

4.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5. Retaining and deleting personal data

5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on what is needed for the usage of such data as outlined in Section 2.

5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

5.5 When you ask us to delete your account, we will delete or anonymise your personal data, including any Google sign-in data, subject to the exceptions in this Section 5. As a seller of consumer goods, we may be required to retain certain information — for example, order and transaction records for tax and accounting purposes — for a period required by applicable law.

6. Amendments

6.1 We may update this policy from time to time by publishing a new version on our website.

6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3 We may notify you of changes to this policy by email or SMS.

7. Your rights

7.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) no fee, unless your request is manifestly unfounded or excessive, in which case we may charge a reasonable administrative fee; and
(b) the supply of appropriate evidence of your identity. For this purpose, we will usually accept a photocopy of your passport plus an original copy of a utility bill showing your current address.

7.2 We may withhold personal information that you request to the extent permitted by law.

7.3 You may instruct us at any time not to process your personal information for direct marketing purposes, including marketing by email, SMS, post, telephone or direct message through messaging platforms or social-media services. We will honour your request without undue delay and in any event within one month.

7.4 Where we rely on your consent to send marketing communications, you may withdraw that consent at any time. You may do this by following the unsubscribe instructions in the relevant message, replying “STOP” where available, changing your communication preferences, or contacting us using the details in Section 9.

7.5 You may opt out of marketing communications for one channel without opting out of all marketing communications. For example, you may choose to stop receiving WhatsApp messages while continuing to receive marketing emails, if you have separately agreed to receive them.

7.6 You have the right to access, rectify, erase, or restrict the processing of your personal data in accordance with Articles 15 to 18 of the UK GDPR. Where applicable, you also have the right to data portability under Article 20.

7.7 Where processing is based on our legitimate interests (Article 6(1)(f)), you have the right to object to such processing under Article 21. In such cases, processing will only continue if we can demonstrate compelling legitimate grounds.

7.8 Where the legal basis for processing is consent under Article 6(1)(a) or Article 9(2)(a), you may withdraw your consent at any time without affecting the lawfulness of prior processing.

7.9 You also have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner’s Office (ICO).

8. Cookies used by our service providers

8.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

8.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

9. Our details

9.1 This website is owned and operated by WASO LTD.

9.2 We are registered in [England and Wales] under registration number 08908471, and our registered office is at 73-74 Vallance Road, London, United Kingdom, E1 5BW

9.3 Our principal place of business is at 5 Gales Gardens, London E2 0EJ .

9.4 If you consider that our processing infringes data-protection laws, you may lodge a complaint with the Information Commissioner’s Office (ICO), United Kingdom. You can contact the ICO via https://ico.org.uk/ or by post at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

10. Sign in with Google

10.1 Where we make it available to you, you can register for and sign in to your WASO account using "Sign in with Google", an authentication service provided by Google. The rest of this Section 10 applies where this option is available to you and you choose to use it.

10.2 When you choose to sign in with Google, we access basic profile information from your Google account, namely your email address, name and Google account identifier. We only access information covered by the permissions you grant during the Google sign-in process.

10.3 We use this information solely to create and authenticate your WASO account, to log you in and to communicate with you about your account. We do not use Google user data for advertising or for any purpose unrelated to providing our services.

10.4 We store your email address, name and Google account identifier in our user database in order to maintain your account. This data is retained in accordance with Section 5.

10.5 We do not share Google user data with third parties, except where necessary to provide our services or where required by law, as described in Section 3.

10.6 Our use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

10.7 You can revoke the access that you have granted to WASO at any time through your Google Account settings at https://myaccount.google.com/permissions. You may also request deletion of your WASO account by contacting us using the details in Section 9; we will handle your personal data as described in Section 5.

10.8 The legal basis for processing data obtained through Sign in with Google is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract (Article 6(1)(b) of the UK GDPR) and, where applicable, your consent (Article 6(1)(a) of the UK GDPR).

11. Credit

11.1 This policy was created using SEQ Legal (seqlegal.com).