Policy Privacy

3. What are your rights regarding personal data?

You can exercise your rights free of charge at any time by using the form available on our main website zeuler.com >> Policies or in the App under Help >> Policies. To exercise your rights, you can also write to us at gdpr@zeuler.com.

You have the following rights regarding Zeuler:
• The right to access your personal data to know what data is being processed and the processing operations performed on them.
• The right to rectify any inaccuracies, where possible, regarding your personal data.
• The right to request the erasure of your personal data, where possible, by submitting a data erasure request.
• The right to request the restriction of the processing of your personal data when the accuracy, legality, or necessity of data processing is in question, in which case we may retain the data for the purpose of presenting or defending against any claims.
• The right to request the portability of your data to another service provider. We will provide you with a copy of your data so that you can provide it to another service provider. If you ask us to do so and it is technically feasible, we will transfer the data directly to the service provider on your behalf.
• The right to object to the processing of your data to address any concerns raised to us through the contact form (website: zeuler.com >> Policies or App: Profile >> Policies) and the right to object to the processing of your data on social media and/or for the purpose of processing your CV. • If you are a User and do not wish to receive marketing communications, you have the right to unsubscribe from any marketing communication by sending an email or using the provided link for this purpose in every commercial communication.
 

Please note that disabling push notifications will also prevent you from receiving notifications about the status of any orders. You can object to profiling at any time by sending an email to gdpr@zeuler.com.

If you believe that Zeuler is in violation of data protection laws:

• We invite you to contact us at the email address gdpr@zeuler.com, informing us of your opinion regarding the matter, in order to resolve the issue as quickly as possible. • You may also report the issue to the Data Protection Authority and file a complaint with this regulatory body to protect your rights.

Please note that there may be certain situations in which the above rights cannot be exercised or effectively executed by Zeuler, for example, if you request the erasure of all your personal data while having a contractual relationship with us.

Notifications and Changes

Considering the constant evolution of Zeuler's activities, this Privacy Policy and Terms of Use are subject to changes. Zeuler will send notifications to all Users, Drivers, Pickers, Candidates, Partners, Investors, Potential customers, and Website visitors regarding significant changes and modifications to these documents via email or any other means that ensures receipt. However, Zeuler will not under any circumstances modify its policies or practices to make them less effective in protecting the personal data of our previously acquired customers.

​

4. Who is the data controller of your data?

The data controller of your personal data in relation to the use of the Zeuler Platform and other Modules is Zeuler S.R.L., with registered office at Viale Luigi Majno 28, 20129, Milan, Italy.
 

Additionally, Zeuler may share the data of users ("Users") or drivers ("Drivers") and pickers ("Pickers") who register on the Platform or individuals who contact Zeuler using the forms available on its Platform with any subsidiary companies in order to provide the services requested by Users through the Platform.

​

5. Useful Information if You are a USER:

5.1 What are the purposes of data processing and the legal basis for processing?

Zeuler will process personal data for the following purposes:

1. Legal obligations.

2. Contractual purposes.

3. Security reasons.

4. Statistical and research purposes.

5. Commercial and marketing purposes.

6. Non-marketing purposes.

Legal Obligations

Zeuler processes your personal data to:
i) detect and investigate fraud and possible offenses committed against our Platform and all users,
ii) comply with legal obligations that require us to retain your data for a specific period of time (please refer to Annex II on data retention),
iii) manage and fulfill your requests to exercise the rights provided by the GDPR and local regulations,
iv) initiate, present, and defend legal actions against any entity of our Group,
v) in all the above cases, Zeuler shall have the right to use any data obtained from you or derived from your activity through our Platform (e.g., conversations between you and the Partner, you and the Driver, you and our Platform using the chat system) in order to present and/or defend against any claims and/or legal actions that may be necessary, and to manage any incidents that occur in relation to User orders.

Such processing is carried out based on our legitimate interest in detecting, investigating, and preventing fraud, as well as fulfilling all legal obligations that Zeuler and the User may be subject to, relating to any applicable regulations (such as consumer rights, RGPD, etc.).

Contractual Purposes
 

Zeuler processes your personal data for the following purposes:
i) Notify you of changes or updates to our services, terms and conditions, privacy policy, cookie policy, and any other substantial company documents that may concern you. Zeuler processes your personal data for the following purposes: i) Enable you to create a personal account,
ii) Provide you with the requested services and any additional features of the Platform,
iii) Identify the nearest Partners and Driver to the delivery point you have indicated (which may involve the use of geolocation services if you have accepted them when prompted by the Platform, as described above),
iv) Manage payment processing and collection on your behalf,
v) Communicate your Order to the selected Partner and keep you updated on the status of your Order,
vii) Assist you in your decisions and use of the service, including the ability to quickly reorder from stores where you have previously ordered or suggest stores based on your previous orders or "popularity" among other users. Additionally, we may assist you in your decisions through filters automatically determined based on your order history, providing specific content on the Platform personalized for you,
viii) Send you the corresponding receipt for your Orders,
ix) Provide customer support to handle any incidents related to your Orders and respond to your questions or requests,
x) Enable direct contact with the Driver assigned to your Order, xi) Be contacted by our Partners in the event of incidents with the Orders,
xii) Process refunds through promotional codes or banking tools,
xiii) Notify you of changes or updates to our services, terms and conditions, privacy policy, cookie policy, and any other substantial company documents that may concern you.

​

Security Reasons

​

Zeuler processes your personal data for the following purposes:
i) Use device data, location data (including geolocation data if you have consented), profile data, usage data, and other data to prevent and detect harmful or unsafe activities (such as payment fraud, identity fraud, account breach, phishing, incentive abuse). In particular, Zeuler uses the IP address of your device to detect fraudulent activity on it and to protect the platform from attackers who may attempt to access your account pretending to be you.
ii) Monitor any actions that may result in fraud or the commission of a crime in relation to the payment method you used; in the event of irregularities being detected, Zeuler reserves the right to retain the provided data and share it with the competent authorities for the purpose of conducting related investigations,

The above-mentioned processing is carried out in the legitimate interest of Zeuler to ensure the security of our platform and to protect the interests and rights of our Users.

iii) Ensure compliance with legal requirements regarding specific products that can be ordered through the Platform (e.g., legal drinking age for alcoholic beverages).

Zeuler processes User data when required by any authority, administration, or court and cooperates with Public Authorities whenever they request information from Zeuler for the purpose of their investigations (e.g., anti-drug projects, anti-fraud projects, anti-terrorism projects).

Statistical and Research Purposes

Zeuler generates statistics based on your personal data for the following purposes:
i) Analyze behaviors, trends, and purchasing characteristics.
ii) Understand how you use our Platform.
iii) Manage and improve the services we offer, including the possibility of adding new or different features and services to enhance the quality of our services.

​

The processing of statistical and research data is carried out in our legitimate interest to understand how our Users interact with our platform, develop new services, and improve the platform and the services provided. Furthermore, these operations allow us to offer an increasingly personalized and satisfying user experience.

​

Commercial and Marketing Purposes

Zeuler processes your personal data for the following purposes:
i) Conduct marketing, communication, research, and development activities.
ii) Analyze and study how to improve our services both offline and on the Platform, using the data provided by you (e.g., in focus groups, reviews, service ratings, satisfaction surveys, feedback of any kind, etc.).
iii) Provide personalized offers, suggestions, opinions, discounts, promotions, deals, and options in the App, via email, or through any other means of communication, including the use of cookies or other advertising technologies on third-party websites or apps, in accordance with our Cookie Policy and only if you have given your consent.
iv) Conduct promotional activities such as the delivery of samples or free products within the order you placed, which may be of interest to promote Zeuler's products or services and those of our Partners.
v) Conduct promotional activities such as contests, lotteries, tenders, quizzes, competitions among users when they have signed up and/or provided their data for such campaigns.
vi) Create a custom audience with Facebook or other providers to reach you or other people with similar characteristics who may be interested in using Zeuler's services; you can manage your privacy settings on Facebook or other third-party platforms.
vii) Use as commercial or marketing material published by you on your social media profiles when Zeuler has been expressly mentioned by you (e.g., through hashtags or @).

​

The processing of information for promotional purposes will be consistently carried out based on our legitimate interest, provided that electronic communications are exclusively transmitted by Zeuler S.r.l., the company responsible for the Zeuler Platform, and in relation to services or products related to the Platform.

We may tailor marketing communications based on the User's activity within our App, including information about previous orders and interactions with the App, online advertising, previous emails, promotions, and so on. However, such personalization is not solely based on automated processes and does not have any legal implications or significant impact on the User.
 

Zeuler may use push notification services on the User's mobile device to send marketing communications. In case the User wishes to unsubscribe from such marketing communications, it is possible to do so through the notification center. It is important to note that disabling push notifications will also prevent receiving updates on the status of ongoing orders.

​

Non-Marketing Purposes

Zeuler processes your personal data for the following purposes:
i) Generate and provide you with receipts for each of your orders placed through our App.
ii) Inform you about any incidents regarding the Platform or the functioning of the services, including incidents related to your orders. Such information may be sent via email, SMS messages, or other messaging applications used by both you and Zeuler.
iii) Notify you of any changes to our Terms and Conditions, Privacy Policy, Cookie Policy, services, and, in general, any non-promotional communications.
iv) Process information on incidents and compensation claims with insurance companies in case you report damages or unforeseen events that may be covered by Zeuler's insurance policy.

These processing activities are carried out based on the contractual obligations arising from the creation of the User's account and the provision of any requested services (e.g., processing personal data to deliver a placed order).

5.2 What type of data do we store about you and how are your personal data collected?

Zeuler holds the following data about you:

1. Information provided directly by you:
1.1. Registration data: Information provided by you when creating an account on the Zeuler Platform, such as username and email.
1.2. User profile information: Information added by you on the Platform to use Zeuler's services, such as mobile number and delivery address. You can view and modify your personal profile data or delivery address information whenever you wish.
1.3. Payment information: Payment information for processing your orders; card data will be handled by our electronic payment service providers, who will receive the data directly from you. Zeuler will only access this information to fulfill requests from any competent authorities. Zeuler offers its users the option to store payment information or card data. In this case, the card data is tokenized (converted into a unique code). This token can be used within the Zeuler platform, allowing Zeuler to facilitate the use of the platform by avoiding the need to enter card data every time you make a payment and providing additional security, as card data is never stored in our systems. You can delete this token at any time in your profile area.
1.4. Additional information: Any information you may provide to Zeuler for other purposes, such as your photograph or billing address if you have requested invoices from Zeuler.
1.5. Information about previous communications with Zeuler: Information provided by you to resolve any inquiries or complaints regarding the use of the platform, either through the contact form (website: zeuler.com>>Policies, App: Help>>Policies), or via email or phone through customer service. 1.6. Information related to any incidents: Information about any party involved in service provision through the Platform for insurance claims or any other actions with insurance companies affiliated with Zeuler.
1.7. Information about conversations with Zeuler: Transcripts and recordings of conversations for incident processing, inquiries, or other consultations that may be conducted to ensure and improve the quality of our services and for security reasons.
1.8. Information about communications: Communications exchanged between you and Drivers or between you and Pickers on the chat system provided on the Platform whenever it is necessary to address any incidents or discussions between Users and Drivers or between Users and Pickers, or to fulfill any requests made by authorities. Zeuler will never access communications unless strictly necessary and will always ensure the privacy of its users and the confidentiality of all information exchanged on its platform.
1.9. Any additional information provided by you in requests, comments, or inquiries.

​

2. Information provided indirectly by Users:
2.1. Data derived from Platform usage: Zeuler collects data derived from your use of the Platform whenever you interact with it.
2.2. Application and device data: Zeuler stores data relating to the device and application used by you to access the services:
i) The IP address you use to connect to the Internet with your computer or mobile phone to prevent fraudulent appropriation or unauthorized access to your account by third parties.
ii) Information about your computer or mobile phone, such as your internet connection, browser type, version, operating system, and device type. iii) Clickstream data (information about your browsing through our website or application, followed links, etc.) of the uniform resource locator (URL), including date and time.
iv) Data from your account: Information about orders placed by you, as well as feedback and/or comments from you.
v) Your browsing history and preferences.
2.3. Data derived from User origin: If you arrive at the Zeuler Platform from an external source (such as a link from another website or from a social network, provided you have authorized it on such websites), Zeuler may collect data about the source from which you arrived.
2.4. Data derived from incident management: If you contact the Zeuler Platform through the contact form (website: zeuler.com>>Policies or App: Help>>Policies), Zeuler Chat, or Zeuler's phone number, Zeuler will collect the messages received in the format used by you and may use and store them to manage current or future incidents.
2.5. Data derived from "cookies": Zeuler uses its own and third-party cookies to facilitate the navigation of its users and for statistical purposes, among others (please refer to the Cookie Policy for more details).
2.6. Geolocation data: Provided you have given your authorization, Zeuler will collect data relating to your location, including real-time geographic location of your computer or mobile device.
2.7. Data from external third parties:
i) Zeuler collects data or personal information from external third parties only if authorized by those parties to share such information with Zeuler. For example, if you create an account through Facebook or Google, these platforms may disclose your personal data present on your Facebook/Google profile (such as name, gender, or age).

ii) If you choose to send us messages through social networks (including Twitter, Facebook, and WhatsApp), we will collect the information provided by you for the purposes stated in this privacy policy, including responding to your request, providing assistance, and resolving issues.

Zeuler has no influence over how these social networks process your personal data. The information collected and the methods of processing are outlined in their respective privacy policies. To understand them, please refer to the following:
i) Twitter: https://twitter.com/en/privacy
ii) Facebook: https://www.facebook.com/privacy/explanation
iii) Whatsapp: https://www.whatsapp.com/legal/updates/privacy-policy/
Please note that Zeuler will do its best to ensure that the above links are up to date, but social networks may change them from time to time.

5.3. Who are the recipients of your data and why do we disclose it?

Zeuler ensures that all business partners, technicians, suppliers, or independent third parties are bound by legally binding promises to treat the shared information in accordance with Zeuler's instructions, this Privacy Policy, and applicable data protection laws. We will not disclose your personal data to third parties who do not act according to our instructions, and no disclosure will result in the sale, rental, sharing, or any other form of disclosure of customer personal data for commercial purposes in violation of the commitments made in this Privacy Policy.

During the execution of an order, data may be shared with:

• The Courier (Driver) who performs the task of picking up and delivering the product.
• The Picker who performs the task of purchasing the product or products at supermarkets.
• The store responsible for selling the product or products if you have requested their purchase. If you directly contact these providers and provide them with your data, Zeuler will not be responsible for the use that the providers make of such data.
• Customer support services contracted by Zeuler to notify you of any incidents or to inquire about the reason for negative feedback; the data will be used to manage any incidents that may occur during the provision of services.
• The payment platform and payment service providers so that the amount can be charged to your account.
• Telecommunication service providers when used for sending communications or order-related incidents.
• Providers who provide satisfaction survey services on behalf of Zeuler.

​

Sharing your data with third parties:

To continue providing the services offered through the Platform, Zeuler may share your personal data with:
• Service providers: Service providers responsible for shipping goods, fulfilling orders, and/or managing delivery incidents will have access to your personal data only as necessary to perform their functions. They are required to treat personal data in accordance with Zeuler's Privacy Policy and applicable data protection laws.
• Payment service providers: When you enter your card number in the App, the data is stored directly by the payment platforms designated by Zeuler, which enable payment to be charged to your account. Payment service providers are selected based on their security measures and, in any case, comply with the security measures provided by payment services legislation and adhere to the Payment Card Industry Data Security Standard (PCI DSS). Zeuler does not store such data under any circumstances.
• Fraud prevention service providers: Zeuler may share your data with service providers specialized in fraud prevention to assess the risk of transactions conducted.
• Anonymization service providers: To prevent misuse of your data by third parties, your data may be anonymized before being provided to service providers collaborating with Zeuler for the execution of requested services. For example, your phone numbers may be passed on to third parties in an anonymous form for the provision of agreed-upon services.
• Security companies, law enforcement, and public safety authorities: Zeuler may disclose personal data of customer accounts if such disclosure is necessary to comply with the law, enforce or apply the Terms of Use, or protect the rights, property, or safety of Zeuler, its users, or third parties. This may include sharing information with other companies or organizations, as well as with law enforcement and public safety authorities, to protect against fraud and reduce credit risk.
• Call center and incident management services: To provide customer service and a call center, assess customer satisfaction, and provide administrative support, your data may be shared with companies located outside the European Economic Area.
• Telecommunication services: In order to provide telephone contact services, Zeuler may engage telecommunication service providers that provide secure lines and systems to contact you.
• Zeuler group companies: In order to provide the services, Zeuler may transfer some of your personal data to subsidiary companies, based on the geographical area where users request services. When you register on the Platform from any country where Zeuler operates, your data is stored in Zeuler's database, located in Europe and owned by Zeuler S.r.l. In the event that there are subsidiary companies located outside the European Economic Area, data will be transferred using tools established by the European Commission and the General Data Protection Regulation (GDPR), ensuring an adequate level of personal data protection, or by using standard contractual clauses approved by the European Commission that guarantee the rights of data subjects.
• Social media links: If you link your Zeuler account to social media or third-party platforms, Zeuler may use the information provided to such social media or third-party platforms in accordance with their respective privacy policies.
• Third parties for commercial communications: Zeuler may share your personal data with third parties associated with Zeuler for commercial communication purposes, subject to explicit and informed consent from you, and provided that you are aware of the purpose and recipient of such sharing.
• Change of ownership: In the event that the ownership of Zeuler changes or the majority of its assets are acquired by a third party, your data may be transferred to acquiring organizations to ensure the continuity of services affected by the data processing.

We reserve the right to acquire or sell business divisions, assets, shares, or legal entities, including the transfer of personal information of individuals. Once acquired by Zeuler, such information will be treated like any other information in accordance with our privacy policy. You acknowledge that such transfers may occur and that we will be authorized to use your personal information for all purposes described in this privacy policy. In the event that control of the data is transferred to a new controller, they will provide users with their own identification information. Zeuler is committed to fulfilling the obligation to inform users of any change in the data controller, if it occurs. This processing will be carried out in accordance with the contract entered into with Zeuler.

• Insurance companies: Zeuler may provide your data to insurers and insurance brokers with whom it collaborates, for the management and processing of claims and losses arising from Zeuler's activities and its affiliated parties.

Your personal information will not be disclosed to third parties, except in the following cases:
i) When necessary to provide the requested services in collaboration with third parties;
ii) If Zeuler has obtained your explicit and unequivocal authorization;
iii) When required by a competent authority in the exercise of its functions (e.g., to investigate, prevent, or take action in relation to illegal activities);
iv) Finally, if required by law.

​

Sharing your data with Zeuler's Partners

Zeuler may also share your data with some of its key Partners under certain conditions:
i) With your explicit consent, which can be obtained through a consent checkbox that may appear (a) on your first order or (b) on every previous order when checking out through the Partner's store. Once consent is given, you can withdraw it at any time by using the contact form (website: zeuler.com >> Policies or App: Help >> Policies).
ii) By having signed a Data Sharing Agreement with the Partner and ensuring compliance with all legal, security, and technical measures.

5.4 How long will we retain your data?

Zeuler will retain your data for the duration of the contractual relationship and, upon its termination, where applicable, for the period established by law to initiate or defend against any legal actions. This period is set for a maximum of ten (10) years to fulfill the legal obligations applicable to Zeuler, including the duty to assist law enforcement as necessary in investigations and the pursuit of crimes for the overriding interest of public security, and to defend or take any action related to civil, criminal, tax, and social security matters. This period may be shorter depending on the applicable legal provision for each data processing purpose, as specified in the retention periods table in Annex I.

​

Regarding anonymous information, ZEULER will comply with the provisions stated in Consideration 26 of the GDPR, which states: "The principles of data protection should therefore not apply to anonymous information, namely information which does not relate to an identified or identifiable natural person or to personal data rendered anonymous in such a manner that the data subject is not or no longer identifiable. This Regulation does not therefore concern the processing of such anonymous information, including for statistical or research purposes."

ANNEX I - GENERAL RETENTION PERIODS