Effective Date: June 2, 2021
This Privacy Notice explains how Wendy’s Restaurants of U.K. Limited processes personal data in accordance with the General Data Protection Regulations of the European Union and the United Kingdom (collectively the “GDPR”) in connection with its operations in the United Kingdom. With respect to the personal data processing activities described in this Privacy Notice, Wendy’s acts as the data controller (the entity that determines the purposes and means of the data processing). This Privacy Notice also describes your rights and choices relevant to our processing of your personal data. You may contact us for additional information about our data practices using the contact information at the bottom of this Privacy Notice.
Personal Data We Collect and Process
In our role as a data controller, Wendy’s may collect and process personal data from multiple sources, including information provided directly to us by individuals visiting our restaurants; using our website (www.wendys.com/en-uk) (the “Wendy’s Website”), mobile application (“Mobile App”), and other services, tools, websites, and applications; and otherwise interacting with us (collectively, the “Wendy’s Services”).
Personal data collected and processed through the Wendy’s Services may include:
- Contact Data – name, phone number, email address, or other similar information
- Device Data – information about your electronic devices that interact with the Wendy’s Services, including the type of device, operating system, device settings, and unique device identifier
- Authentication Data – information that allows us to verify the identity of registered Wendy’s account holders, such as account passwords and similar authentication information
- Transaction Data – information related to your purchasing interactions with us, such as your order history and payment details, which may include credit or debit card information, which will be processed by our third-party payment providers acting as independent controllers.
- Other Data We Obtain – information captured by security cameras enabled on our premises and other information from reports regarding food-related incidents and other incidents that may occur in our restaurants
- Other Data You Provide – including data collected via emails and other communications that you send us, such as information about a restaurant visit or transaction when you contact Customer Care or interact with us on social media
- Geolocation Data – location data in order to show you nearby restaurant locations
- Automatically Collected Data
Wendy’s uses various tools and technologies, including those provided by our processors, such as cookies, web beacons, and web server logs, to collect data automatically when you visit the Wendy’s Website, use the Mobile App, or otherwise interact with the Wendy’s Services. Automatically collected data may include:
- Usage Data – details about your access to and use of the Wendy’s Services including logs and other communication data and the resources that you access and use through the Wendy’s Services, which may include referring URLs, time and length of visits, and pages viewed
- Device Data – data about your mobile device and internet connection, including your device's unique device identifier, IP address, operating system, mobile network information, and telephone number
- Stored Information and Files – metadata and other information associated with other files stored on your device
For additional information regarding our use of these online tools and technologies, including your ability to opt out, please review the Cookies and Other Tracking Technologies section below.
- Applicant Data – If you apply for a job through our Careers website, we and our service providers will collect personal data from you in accordance with Wendy’s Applicant Privacy Notice.
Purpose for Processing
We or our third-party processors may process personal data to:
- Contact you, transact with you, provide you the Wendy’s Services (e.g. placing an order for pick up), or to respond to your comments, questions or requests.
- Conduct research and analysis, including focus groups and surveys.
- Facilitate, manage, personalize, and improve our customer relationships.
- Uphold our high standards for food and restaurant quality and safety.
- Comply with NHS test and trace requirements.
- Prevent and address fraud, breach of policies or terms, and threats or harm.
- Ensure the security of our restaurants, computer systems and software, and the personal data we process.
- Comply with applicable legal requirements.
These processing activities are carried out pursuant to the following legal bases:
- The processing is necessary for us to provide you with the Wendy’s Services you request, including pursuant to a contract we have with you or to respond to your inquiries regarding the Wendy’s Services.
- We have a legal obligation to process your personal data, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.
- We have a legitimate interest in using your personal data. For example, we have a legitimate interest in the following cases:
- Analyzing and improving safety and security, including by implementing and enhancing security measures
- Maintaining and improving the Wendy’s Services
- Providing you with certain tailored communications, including developing and promoting our business
- If you have consented to the use of your personal data. When you consent, you can change your mind at any time.
- To protect your vital interests, or those of others.
Disclosure of Personal Data
We may share your personal data:
- With our affiliates or business partners when it is reasonably necessary or desirable, such as to help provide the Wendy’s Services to you or analyze and improve the Wendy’s Services.
- To our agents, vendors, consultants, marketing service providers, and other third-party processors who assist us in providing the Wendy’s Services and perform other functions on our behalf. For example, we may use third parties to provide Customer Care, manage our advertisements on other websites and send marketing and other communications on our behalf. In addition, ordering via our Mobile App and the Wendy’s Website is powered by our third-party processor.
- To abide by applicable law or protect rights and interests. For example, we may disclose your personal data if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property, or interests, or prevent fraud or abuse. Please note that in certain situations Wendy’s may be obligated to disclose personal data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements in the U.S. or another country.
- If we are involved in a business transaction, such as a reorganization, merger, acquisition, or sale of some or all of our assets.
For your convenience, Wendy’s Services may from time to time include links to websites or other services that are owned or operated by third parties. This Privacy Notice does not apply to those websites or services, which may have their own privacy policies or notices that you should review to understand how they may collect, use, or disclose your information. Wendy’s is not responsible for the content or privacy practices of any linked websites or services that are operated by third parties.
Certain platforms, such as third-party social media networks, may permit interactions that you initiate between the Wendy’s Services and third-party services. This Privacy Notice does not apply to those interactions with third-party services. Examples include: “liking” or “sharing” Wendy’s content; logging in to the Wendy’s Services using your third-party service account (e.g., using Facebook Login to sign-in to your Wendy’s account); and to otherwise connect Wendy’s Services to a third-party service.
Cookies and Other Tracking Technologies
On the Wendy’s Services, we utilize online identification technologies—such as cookies, web beacons, or pixels—in accordance with applicable law and requirements. “Cookies” are small text files placed on your device when you visit a website; they store information which is sent back to our servers or those of third parties. As described in more detail below, we use such technologies to:
- Recognize new or past Wendy’s Services visitors;
- Store your password if you have a registered Wendy’s account;
- Improve the Wendy’s Services;
- Integrate with third-party social media websites; and to
- Observe your behaviors and browsing activities over time across multiple websites or other platforms.
Different types of cookies may be used for specific purposes, for example:
- Functional cookies that allow you to use key features of Wendy’s Services, such as retaining your preferences from one visit to the next.
- Performance cookies that collect aggregate information for analytics and marketing purposes, including how visitors use Wendy’s Services and our content, the products that Wendy’s Services visitors view most frequently, and the effectiveness of our and third-parties’ advertising campaigns.
Cookies are either “session” cookies which are deleted when you end your browser session, or “persistent,” which remain until you delete the cookie or the party who served the cookie removes it. Further details concerning the cookies we use on the Wendy’s Services are available here.
Mobile App Disclosures
There are a variety of tracking technologies that may be included in mobile applications. These technologies are not browser-based (like cookies) and cannot be controlled by browser settings.
You can stop all collection of data generated by use of our Mobile App by uninstalling the Mobile App. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain features (e.g., location-based services, push notifications, accessing calendar/contacts/photos, etc.), by adjusting the permissions in your mobile device and/or the Mobile App’s settings. Beware that if GPS precise location services are disabled, other means of establishing or estimating location (e.g., connecting to or proximity to wi-fi, Bluetooth, beacons, or our networks) may persist.
To learn more about how you can control location permissions using your mobile device’s operating system settings, please visit the following links depending on which device you use:
- Android: For Android 6.0 and above: https://support.google.com/googleplay/answer/6270602?hl=en. For earlier versions of Android: https://support.google.com/googleplay/answer/6014972
- iOS: https://support.apple.com/en-us/HT207056
We may use analytics services to analyze our users. Information generated by these services (e.g., your IP address and other Usage Data) may be used for purposes such as evaluating your use of Wendy’s Services, compiling statistic reports on Wendy’s Services activity, and providing other services relating to the Wendy’s Services. This includes the use of Google Analytics, for more information visit here. You can also check the settings on iOS™ devices to see what types of tracking options you can manage.
We will store your personal data for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the personal data was collected, in accordance with our data retention policy, or as may be permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorized use or disclosure of the personal data; the purposes for which we process the personal data and whether we can achieve those purposes through other means; and the applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove personal data from our systems and records or take appropriate steps to properly anonymize it.
Wendy’s takes reasonable measures to protect personal data from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure, so we cannot guarantee the security of your personal data. You are responsible for maintaining the confidentiality of your Wendy’s account password. Never share your Wendy’s password with anyone you do not want to access your account and inform Wendy’s of any need to deactivate an account or password. If you have a security concern about your account, contact Wendy’s by email at GDPRprivacy@wendys.com.
Personal Data Transfers
Personal data may be transferred to Wendy’s in the U.S. or in another country outside of the United Kingdom for processing. Please be aware that the data protection laws and regulations that apply to your personal data in other countries may differ from the laws of the country where you reside. Wendy’s implements appropriate legal mechanisms and other safeguards to protect your personal data. For example, Wendy’s may transfer personal data in accordance with standard contractual clauses approved by the European Commission, which impose data protection obligations on the parties to the transfer. For further information about how we transfer personal data, please contact us by email at GDPRprivacy@wendys.com.
Rights and Choices
EU data subjects have the right to access personal data maintained about them and to impose certain limits on the use and disclosure of such personal data. Subject to certain conditions, you may make the following types of requests:
- Access. You may request that we provide you with information about our processing of your personal data and give you access to your personal data.
- Correct. You may request that we update or correct personal data about you that is inaccurate or incomplete.
- Delete. You may request that we delete your personal data.
- Object. You may object to our reliance on our legitimate interests as the basis for processing of your personal data.
- Restrict. You may request that we restrict the processing of your personal data.
- Transfer. You may request that we transfer a machine-readable copy of personal data you have given us to you or to a third party of your choice.
You also may request at any time that we stop sending you direct marketing communications. We may continue to send you communications related to your Wendy’s account and other non- marketing communications.
You can submit these requests via our webform here or by mailing us at our postal address provided below. We may request specific information from you to help us confirm your identity prior to processing your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.
You also have the right to lodge a complaint with a supervisory authority. You can find information about your data protection regulator here.
We will provide EU data subjects with appropriate opportunities to opt out of our sharing their personal data as required by law and will request opt-in consent prior to using EU personal data for a purpose other than the purpose for which it was originally collected.
For more information about your choices concerning opting out of online behavioral advertising click here.
Wendy’s Services are not intended for children under the age of 16 and we do not knowingly collect information online from children under the age of 16. If we become aware that we have obtained information from a child under the age of 16 we will delete such information in accordance with applicable law.
Data Controller Contact Information
If you have questions about this Privacy Notice or about exercising your data protection rights under the GDPR, please contact our Data Protection Officer by email at GDPRprivacy@wendys.com. You also may write to the following address:
Attn: Data Protection Inquiry
Rutland House, 148 Edmund Street
Birmingham B3 2JR
Changes to this Privacy Notice
Wendy’s reserves the right to modify this Privacy Notice at any time. Changes will be effective immediately upon posting of the revised Privacy Notice, as indicated by the “Last Updated” date at the top of this page. In accordance with applicable law, we will seek your consent to material changes in how we process your personal data. We encourage you to periodically review this page for the latest information on our privacy practices.