Privacy Policy

Effective as of July, 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 WhatToOrder mobile application (the “App”), our web-based menu management portal (the “Menu Manager”) and our web-based data terminal (the “Insight Monitor”).  The App, Menu Manager and Insight Monitor are collectively referred to as the “Platform.


Acceptance of Terms

By visiting, downloading or purchasing our Platform, you are agreeing to the terms of this Privacy Policy.  Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in the applicable Terms of Use or other governing agreement.


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, which may include personal 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.  To register an account on the App, you must provide an email address.  In addition, you have the option of providing three pieces of demographic data on the App: (i) your birthdate, (ii) your home zip code, and (iii) your gender.  To gain access to the Menu Manager and Insight Monitor, you must provide your name, email address, your business or company name and your title.

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 through our Platform, such as to register with us, 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. Payment Information


If you purchase access to the Insight Monitor, to process your payment, you will be required to provide to us certain billing information, which may include a credit card number, expiration date, bank account information, billing address, activation code, and similar information (collectively, “Payment Information”). You authorize our third-party payment vendors to collect, process, and store such Payment Information in accordance with their respective privacy policies.  We reserve the right to change our payment vendors at any time, or to use additional payment vendors, at our discretion. By purchasing  access to the Insight Monitor, you agree to be bound by the terms and conditions and privacy policies of our third-party payment vendors.


  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 if you do some of the core functionality of the Platform, such as a “current location”-based search, will be unavailable to you.

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. Usage Information


We collect details regarding your activty on the App, including search queries, the application of search filters, navigation to various pages on the Platform, menu browsing activity, engagement with individual menu items, rating of locations or individual menu items, navigation to third-party sites such as reservation, delivery and review platforms, as well as other activities (the “Usage Information”).

This Usage Information is aggregated with the Usage Information generated by all other users of the Platform, and made available as part of access to the Insight Monitor.  We have designed the Insight Monitor in such a way that individual user information cannot be identified, and thus we believe your activity on the App will effectively remain anonymous.


  1. Other Information.


In addition to the Personal Information, Payment Information, Geolocational Information and Usage 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”). We may use this information for purposes such as assisting in monitoring and troubleshooting errors and incidents, analyzing traffic, or optimizing the user experience. Such Other Information may include:


a.  From Your Activity and Your Device

We may use information from your activity and your device for purposes such as assisting in monitoring and troubleshooting errors and incidents, analyzing traffic, or optimizing the user experience.

  • 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;
  • 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).


b.  From Cookies

We may collect information using “cookie” and other similar technologies. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive (or other storage medium) so that your computer will “remember” information about your use. We may use both first and third party session cookies and persistent cookies.   Below is a general primer on session and persistent cookies; information collected by cookies depends on its particular purpose.

  • Session Cookies: We use session cookies to make it easier for you to navigate our Platform. A session ID cookie expires when you close the Platform.
  • Persistent Cookies: A persistent cookie remains on your device for an extended period of time or until you delete them. To the extent we provide a log-in portal or related feature on our Platform, persistent cookies can be used to store your passwords so that you don’t have to enter it more than once.Persistent cookies also enable us to track and target the interests of our visitors to personalize the experience on our Platform.

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 some of the features (e.g., storage of your preferences or login credentials) may not operate properly or as intended.


c.  Third-Party Analytics

We may 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.  By accessing and using the Platform, 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


d.  From You.

Additional information that you voluntarily provide to us (either directly or via our social media pages).


e.  Marketing Communications

Although we do not display advertisements on the Platform at this time, we may (now or in the future) share or receive information about you with/from third parties, including, but not limited to, advertising and remarketing providers, or similar partners, for purposes of personalizing or otherwise understanding how you engage with ads or other content and facilitating marketing communications on the Platform that we believe are relevant to you.  These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect information for such purposes, including to tailor, target (i.e., behavioral, contextual, retargeting, and remarketing), analyze, report on, and/or manage advertising campaigns or other initiatives.  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.  Information that we may receive from these third-parties, including through their service providers, may include advertising identifiers, IP addresses, reports, and campaign data. By accessing and using the Platform, you consent to the processing of data about you by these advertisers/remarketing providers in the manner and for the purposes set out in this Privacy Policy.


How the Information May be Used and Shared 

You authorize us to use the Personal Information, the Payment Information, the Geolocational Information, the Usage Information and the Other Information (collectively, the “Information”) to provide and improve our Platform and services; to send you email correspondence (including marketing emails); 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.
  • 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 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.


Communication Preferences

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 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 do so at your own risk.


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 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. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information without their permission.  If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at [email protected], and we will endeavor to delete that information from our databases.


California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact us via email at [email protected].


Do Not Track

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.


Nevada Privacy Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at [email protected] with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.


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.