PURPOSE
AS USUAL and any affiliate is a controller of your private information and is committed to
protecting and respecting your privacy. We respect your data and your privacy is important to us.
This Privacy Policy sets out how we collect, store, process, transfer, share and use data that
identifies or is associated with you ("personal information") and information regarding our use of
cookies and similar technologies.
We operate an online application for ordering food and beverages more specifically coffees and
related food products (the "AS USUA App Service") which AS USUAL App makes available as a service to
vendors through our website at www.asusu.al and to end users through our mobile application that is
available to download on your device (the "App").
You have the right to object to some of the processing which AS USUSAL carries out. More information
about your rights and how to exercise these is set out in the “Your rights” section of this notice.
INFORMATION WE USED TO PROVIDE OUR SERVICES
Users of our Service (“Users”) may provide a variety of information to us through the Service. We
collect a variety of information from various sources, including our Users, that you voluntarily
submit directly to us when you use the AS USUAL App Service when filling in a form on the App
Service, purchase a product, correspond with us by phone, e-mail or otherwise, subscribe to our
mailing lists, newsletters or other forms of marketing communications, or use some other feature of
the AS USUAL App Service.
This information may include, for example, your contact and payment details. If you choose not to
provide such personal information, we may not be able to provide those parts of our App Service to
you or respond to your other requests.
INFORMATION WE COLLECT ABOUT YOU AUTOMATICALLY
We collect automatically information when you purchase something or use our services. This includes
preferred store visited, preferred order, using our websites or app, read our emails, engage with us
joining our AS USUAL community or corresponding with us. We typically collect this information
through a variety of tracking technologies, including cookies, web beacons, embedded scripts,
location-identifying technologies, file information, and similar tracking technologies.
We may link or combine the personal information we collect about you and the information we collect
automatically. This allows us to provide you with a personalized experience regardless of how you
interact with us.
In particular:
• We keep information you give us directly such as contact details (including name, email, address
and telephone number), comments, date of birth, gender, locations, frequency of visits, feedback,
marketing opinions and competition entries.
• We record and analyze store, web and app visits, details of your purchases, including when you
purchase or use e-Gifts, and where you take advantage of our promotions.
• If there is an incident, we log information about it.
• If you engage with us online via our websites or app, our cookies and similar technologies will
capture your IP address, your location, and record how you use the site or app to help improve it
and improve your user experience, where your browser settings or permission allows for this.
• If you post information online about us or provide feedback, we keep a record.
• If you contact us directly and complain or give feedback, receive compensation, or enter a
competition, we will record details and all related information (including that you provide to us)
such as emails, letters, phone calls, date of birth to our product customer information helplines
including those operated by third parties as detailed below.
• Some features and functionality in AS USUAL App require that you provide your location. If you
have location services turned on, whenever you use AS USUAL App on your mobile device, we use your
geographic coordinate (e.g., latitude and longitude) to find your current location and initiate the
notification of your “as usual” orders, also we use your geographic coordinate to calculate how
close you are to the shop, so the shop is notified of your arrival to deliver your order to you. We
will only process your location with your express permission and you location is never stored in our
servers. If you have persistent background location turned on, we will obtain your device’s location
even if you are not using the Apps. Your location is never stored on our servers and is never shared
with others, except with your consent or as permitted under this Privacy Policy.
We may also anonymize and aggregate any of the personal information we collect (so that it does not
directly identify you). We may use anonymized information for purposes that include testing our IT
systems, research, data analysis, improving the AS USUAL App Service and developing new products and
features. We may also share such anonymized and aggregated information with others.
HOW LONG WILL WE STORE YOUR PERSONAL INFORMATION
We will only retain your personal information for as long as necessary to fulfil the purposes we
collected it for, including for the purposes of our legitimate business interests and satisfying any
legal or reporting requirements.
We always look to keep your data for the minimum time in line with data protection principles and
our processes.
For example, we keep:
• Personal information related to products and services purchased historically, including Gift cards
and eGifts, for as long as the personal data is required in order for us to fulfil our contract with
you, as long as required to service any related warranty and for 6 years from performance of our
contract with you.
• Records of payment information in line with tax law and audit requirements.
• Customer feedback and correspondence with our customer services teams for up to 2 years
afterwards, depending on the nature of the interaction and any applicable law, such as health and
safety. This enables us to respond to any questions or complaints.
• We may show advertisements on your social network newsfeed and to other people like you for 2
years after our last contact from you.
• Information to maintain records according to rules that apply to us.
If you unsubscribe from marketing communications, we keep a record of this request indefinitely to
ensure we do not send you direct marketing again.
We may keep your data for longer if we cannot delete it for legal, regulatory, or technical reasons.
RECIPIENTS OF PERSONAL INFORMATION
We may share your personal information with the following entities:
• Companies that perform services for us, with us, or on our behalf, including without limitation
advertising and data platforms and companies (or those working with our customers and business
partners), providers of technical infrastructure and technical and customer support, hosting
providers, billing support and payment providers, and data enhancement platforms.
• Business and data partners, in the course of creating new data services and solutions,
• In any other circumstance where we have your consent or are otherwise permitted by law to share
it. We may share your personal information with third parties as required by law or if we reasonably
believe that such action is necessary to (i) comply with the law and the reasonable requests of law
enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including
our Terms of Service; and/or (iii) exercise or protect the rights, property, or personal safety of
AS USUAL App, its users or others.
• Purchasers and third parties in connection with a business transaction: your personal
information may be disclosed to third parties in connection with a transaction, such as a merger,
sale of assets or shares, reorganization, financing, change of control or acquisition of all or a
portion of our business.
MARKETING AND ADVERTISING
From time to time, we may contact you with information about our products and services, including
sending you marketing messages and asking for your feedback on our products and services.
Most marketing messages we send will be via the AS USUAL App Service in the form of push
notifications. For some marketing messages, we may use personal information we collect about you to
help us determine the most relevant marketing information to share with you. You can unsubscribe
from receiving promotional email communications from us by switching marketing push notifications
off via the profile settings page on the AS USUAL App Service (you can switch these back on at any
time via the same process). We make every effort to promptly process all unsubscribe requests. You
may not opt out of service-related communications (e.g., account verification, transactional
communications, changes/updates to feature of the AS USUAL App Service, technical and security
notices).
We will only send you marketing messages if you have given us your consent to do so. You can
withdraw your consent at a later date by updating your preferences via your account profile settings
on the AS USUAL App Service.
STORING AND TRANSFERRING YOUR PERSONAL INFORMATION
Security:
We implement appropriate technical and organizational measures to protect your personal information
against accidental or unlawful destruction, loss, change or damage. All personal information we
collect
will be stored by our cloud hosting provider on secure servers. We will never send you unsolicited
emails or contact you by phone requesting your account ID, password, credit or debit card
information or
national identification numbers.
International Transfers of your Personal Information:
The personal information we collect may be transferred to and stored in countries outside of the
jurisdiction you are in where we and our third-party service providers have operations. If you are
accessing our AS USUAL App Service from any country, your personal information will be processed
including in third party cloud providers.
In the event of such a transfer, we ensure that: (i) the personal information is transferred to
countries recognized as offering an equivalent level of protection; or (ii) the transfer is made
pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European
Commission; or (iii) such transfer shall be to a third party that is a member of a compliance scheme
recognized by the European Commission as offering adequate protection for the rights and freedoms of
data subjects, such as the EU-U.S. Privacy Shield. If you wish to enquire further about these
safeguards used, please contact us using the details set out at the end of this Privacy Policy.
COOKIES AND SIMILAR TECHNOLOGIES USED ON OUR APP:
Our App uses cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like
HTML5 (together "cookies") to distinguish you from other users of our App. This helps us to provide
you with a good experience when you browse our App and also allows us to monitor and analyze how you
use and interact with our App so that we can continue to improve our App. It also helps us and our
advertising partners to determine products and services that may be of interest to you, to serve you
targeted advertisements.
Cookies are pieces of code that allow for personalization of our App experience by saving your
information such as user ID and other preferences. A cookie is a small data file that we transfer to
your computer’s hard disk for record-keeping purposes.
Although we do our best to honor the privacy preferences of our users, we are unable to respond to
Do Not Track signals set by your browser at this time.
We use the following types of cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our AS USUAL
App Service. They include, for example, cookies that enable you to log into secure areas of our AS
USUAL App Service, use a shopping cart or make use of e-billing services.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to
see how visitors move around our AS USUAL App Service when they are using it. This helps us to
improve the way our AS USUAL App Service works, for example, by ensuring that users are finding what
they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our AS USUAL App Service.
This enables us to personalise our content for you, greet you by name and remember your preferences
(for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our AS USUAL App Service, the pages you have
visited and the links you have followed. We will use this information to make our AS USUAL App
Service and the advertising displayed on it, and the marketing messages we send to you more relevant
to your interests. We may also share this information with third parties who provide a service to us
for this purpose.
Third party cookies. Please be aware that advertisers and other third parties may use their own
cookies tags when you click on an advertisement or link on our AS USUAL App Service. These third
parties are responsible for setting out their own cookie and privacy policies.
The cookies we use are designed to help you get the most from the AS USUAL App Service but if you do
not
wish to receive cookies, most browsers allow you to change your cookie settings. Depending on your
mobile device and operating system, you may not be able to delete or block all cookies. Please note
that
if you choose to refuse all cookies you may not be able to use the full functionality of our AS
USUAL
App Service. These settings will typically be found in the “options” or “preferences” menu of your
browser. In order to understand these settings, the following links may be helpful, otherwise you
should
use the “Help” option in your browser for more details.
For mobile users, you have controls in your device Operating System that enables you to choose
whether to allow cookies or share your advertising ID with AS USUAL App or our advertising service
providers.
If you would like to find out more about cookies and other similar technologies, please visit
www.asusu.al. We and our third-party partners may also use cookies and tracking technologies for
advertising purposes. For more information about tracking technologies, please see Section 12 below.
Please note that deleting or blocking cookies may not be effective for all types of tracking
technologies, such as Local Storage Objects (LSOs) like HTML5.
INTEREST BASED ADVERTISING
We participate in interest-based advertising and use third party advertising companies to serve you
targeted advertisements based on your browsing history and use of the AS USUAL App Service. We may
share, or we may permit third party online advertising networks, social media companies and other
third party services to collect information about your use of the AS USUAL App Service over time so
that they may play or display ads on the AS USUAL App Service, on other websites, apps or services
you may use (including Facebook), and on other devices you may use.
Typically, but not always, this information is collected through cookies and similar tracking
technologies. These third parties may collect, or we may share, mobile identifiers, such as the ID
for Advertising for iOS (IDFA), Google Advertising ID, as well as your device’s IP address,
information about other applications on your device, your location, information about your use of
the AS USUAL App Service, email address or hashed data and information about which advertisements
you have seen or clicked on.
We participate in interest-based advertising and use third party advertising companies to serve you
targeted advertisements based on your browsing history and use of the AS USUAL App Service. We may
share, or we may permit third party online advertising networks, social media companies and other
third party services to collect information about your use of the AS USUAL App Service over time so
that they may play or display ads on the AS USUAL App Service, on other websites, apps or services
you may use (including Facebook), and on other devices you may use.
Typically, but not always, this information is collected through cookies and similar tracking
technologies. These third parties may collect, or we may share, mobile identifiers, such as the ID
for Advertising for iOS (IDFA), Google Advertising ID, as well as your device’s IP address,
information about other applications on your device, your location, information about your use of
the AS USUAL App Service, email address or hashed data and information about which advertisements
you have seen or clicked on.
We and our third-party partners use this information to make the advertisements you see online more
relevant to your interests, as well as to provide advertising-related services such as reporting,
attribution, analytics and market research.
We may also use certain forms of display advertising and other advanced features through Analytics.
These features enable us to use first-party cookies and third-party cookies or other third party
cookies together to inform, optimize, and display ads based on your past visits to the AS USUAL App
Service.
We and our third-party partners may also link your various devices so that content you see on one
device can result in relevant advertising on another device. We do this by collecting information
about each device you use when you are logged in to the AS USUAL App Service. We may also work with
third party partners who employ tracking technologies, or the application of statistical modelling
tools, to determine if two or more devices are linked to a single user or household. We may share a
common account identifier (such as user ID) with third party advertising partners to help recognize
you across devices. We and our partners can use this cross-device linkage to serve interest-based
advertising and other personalized content to you across your devices, to perform analytics and to
measure the performance of our advertising campaigns.
You may be able to limit the use of these identifiers for interest-based advertising on a particular
device through the settings on your device by selecting “limit ad tracking” (iOS) or “opt out of
interest based ads” (Android). You may also be able to opt-out of some, but not all, interest-based
ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the
mobile App Choices app.
To learn more about interest-based advertising and how you may be able to opt-out of some of this
advertising, you may wish to visit:
• Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices
• DAA’s resources at www.aboutads.info/choices; and/or
• Your Online Choices at www.youronlinechoices.eu.
Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s or
Your Online Choices’ online resources will only opt you out from receiving interest-based ads on
that specific browser or device, but you may still receive interest-based ads on your other devices.
You would need to perform the opt-out on each browser or device you use.
Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you
delete cookies, change your browser settings, switch browsers or devices, or use another operating
system, you will need to opt-out again.
Please note that opting out of interest-based advertising does not mean you will no longer see
advertising on your device – it just means that adverts may no longer be tailored to your interests.
Control Over your Information
You may update your profile information, such as your contact information, and may change some of
your data sharing preferences on your Account page/by emailing us at info@asusu.al.
LINKS TO THIRD PARTY SITES
The AS USUAL App Service may contain links to and from third party websites, including those of
other users, our partner networks, advertisers, partner merchants, news publications, retailers and
affiliates.
OUR POLICY TOWARDS CHILDREN:
The Service is not intended for use by children under the age of 13.
CONTACT US:
Please contact info@asusu.al if you have any questions, comments and requests regarding this Privacy
Policy.