Privacy Policy

Effective as of April 2020

 WTO Holdings, Inc. (“WTO,” “we,” “us,” or “our”) has designed this privacy policy (“Privacy Policy”) in accordance with the idea that people care deeply about how the information they provide to us is used and shared.  This Privacy Policy relates to the information collection and use practices of WTO in connection with our website, available at (the “Website”), and our WhatToOrder mobile application (the “App”).  The Website and the App are collectively referred to as the “Platform.

Acceptance of Terms

By visiting our Platform, you are agreeing to the terms of this Agreement.  Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use.

The Information We Collect and/or Receive

In the course of operating the Platform and/or interacting with you, WTO will collect (and/or receive) the following types of information. You authorize us to collect and/or receive such information.

  1. Personal Information


We do not collect any personal information from you, unless you provide it voluntarily, such as by registering with us, sending us an e-mail, or interacting with us via our social media pages.  The platforms on which our social media pages reside are operated by third-party social networks and are subject to their terms of use and privacy policies.  If you use such third-party social media platforms, you are authorizing WTO to collect, store, and use, in accordance with this Privacy Policy, any and all information that you agreed could be provided to us through their application programming interface (“API”).  Such information may include, without limitation, your first and last name, username, profile picture, unique identifier and access token, and e-mail address.  All information we collect and/or receive under this section is collectively called “Personal Information.”

  1. Geolocational Information


While you are using the Platform on a mobile device, we may, with your consent, automatically collect geolocational information from your mobile device, wireless carrier, and/or certain third-party service providers.  Such information is collectively called the “Geolocational Information.”  Collection of Geolocational Information occurs only when the Platform is running on your mobile device.  You may decline to allow us to collect Geolocational Information, but because the core functionality of the Platform requires this information, if you decline you will be unable to use the Platform on your mobile device.

The Platform implements Google Maps and Google Places to offer location-enabled services.  By accessing or using the Platform, you agree to be bound by Google’s Privacy Policy (, which may be modified or updated by Google from time to time.  Google’s Privacy Policy is incorporated herein and made a part of this Privacy Policy by this reference.

  1. Other Information.


In addition to the Personal Information and the Geolocational Information, we may automatically collect or receive additional information regarding you and your use of our Platform as well as information regarding your computer or other devices used to access our Platform (collectively, the “Other Information”).  Such Other Information may include:

  a.         From Your Activity

  • IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device;
  • Browser type and language;
  • Referring and exit pages and URLs;
  • Date and time;
  • Details regarding your activity on the Platform, such as search queries, ratings, amount of time spent viewing pages, and other performance and usage data.

b.         From Your Device 

  • Type of device;
  • Advertising Identifier (“IDFA” or “AdID”);
  • Operating system and version (e.g., iOS, Android or Windows);
  • Carrier;
  • Geo-location; and
  • Network type (WiFi, 3G, 4G, LTE).

c.         From Cookies

We may use both session cookies, which expire once you close your web browser, and persistent cookies, which stay on your computer until you delete them and other technologies to help us collect data and to enhance your experience with the Platform.  Cookies are small text files a website can use to recognize a repeat visitor to the website.  We may use cookies for various purposes, including to:

  • authenticate users;
  • personalize your experience;
  • analyze which portions of the Platform are visited or used most frequently; and
  • improve our advertising.

If you do not want WTO to deploy cookies in your browser, you can opt out by setting your browser to reject cookies or to notify you when a website tries to put a cookie in your browser software.  If you choose to disable cookies in your browser, you can still use the Platform, although your ability to use some of the features (e.g., storage of your preferences or login credentials) may be affected.

d.         Third-Party Analytics 

We use third-party analytics services (such as Google Analytics and Google Optimize) to evaluate your use of the Platform, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Platform and mobile and Internet usage.  These third parties use cookies and other technologies to help analyze and provide us the data.  You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.

For more information about Google Analytics, please visit

e.         From You

Additional information that you voluntarily provide to us (either directly or via our social media pages), such as ratings of dishes and other information that does not identify you personally.

Marketing Communications

Although advertising on the Platform is not a material component of our business at this time, we may (now or in the future) facilitate marketing communications on the Platform that we believe are relevant to you.  In order for us to do that, we may share with third parties Other Information about your activity in connection with your use of the Platform.  These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect Other Information for this purpose.  Pixel tags enable us, and these third-parties, to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site.

How the Information is Used and Shared

You authorize us to use the Personal Information, the Geolocational Information, and the Other Information (collectively, the “Information”) to provide and improve our Platform and services; to administer any contests, rewards, and other promotional programs that we decide to implement; to solicit your feedback; and to inform you about products and services that we believe are relevant to you.

You also authorize us to use and/or share Information as described below.

  • You may receive communications regarding products and services through the Platform that originate from third parties. We will endeavor to sort and prioritize these communications based on their perceived relevance and importance to you as determined by WTO.  To be clear, we will not share your Personal Information with third parties (other than our service providers as described below) in connection with these communications.
  • We may employ other companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, customer service, marketing assistance, and administration of reward or promotional programs.  These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.
  • We may analyze certain Geolocational Information and Other Information in anonymized and aggregate form in order to operate, maintain, manage, and improve the Platform and/or any products and services described therein. This aggregate information does not identify you   We may share and/or license this aggregate data to our customers, affiliates, agents, business and promotional partners, and other third parties.  We may also disclose aggregated user statistics in order to describe the Platform and these products and services to current and prospective business partners and investors and to other third parties for other lawful purposes.
  • We may share some or all of your Information with any of our parent companies, subsidiaries, or other companies under common control with us.
  • As we develop our businesses, we might sell or buy businesses or assets.  In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.
  • To the extent permitted by law, we may also disclose the Information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of WTO or others.

Accessing and Modifying Information and Communication Preferences

If you have provided us any Personal Information, you may access, remove, review, and/or make changes to the same by contacting us as set forth below.  In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any WTO marketing e-mail.  We will use commercially reasonable efforts to process such requests in a timely manner.  You should be aware, however, that it is not always possible to completely remove or modify information in subscription databases.  You cannot opt out of receiving transactional e-mails related to the Platform (e.g., requests for support).

How We Protect Your Information

We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.  Please understand, however, that no security system is impenetrable.  We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the Information you supply will not be intercepted while being transmitted over the Internet.  In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Important Notices to Non-U.S. Residents

The Platform and its servers are operated in the United States and elsewhere.   Please be aware that your Information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.  If you are located outside the United States and choose to use the Platform, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.

External Websites

The Platform may contain links to third-party websites.  WTO has no control over the privacy practices or the content of these websites.  As such, we are not responsible for the content or the privacy policies of those third-party websites.  You should check the applicable third-party privacy policy and terms of use when visiting any other websites.


The Platform is not directed to children under the age of 13.  WTO adheres to the Children’s Online Privacy Protection Act (“COPPA”) and will not knowingly collect Personal Information from any child under the age of 13.  We ask that minors (under the age of 13) not submit any Personal Information to us.  If you are under the age of 13, you may use the Platform only with the consent of your parent or guardian.

If a child under the age of 13 has provided us with Personal Information, a parent or guardian of that child may contact us and request that such information be deleted from our records.

California Residents

WTO does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy.  We may change this Privacy Policy from time to time.  Any such changes will be posted on the Platform.  By accessing the Platform after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes.  Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information.  Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, please e-mail us at [email protected] with “Privacy Policy” in the subject line.

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