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Effective December 1, 2020.
Residents of the European Economic Area (“EEA”), which includes the member states of the European Union (“EU”), should consult the sections of this policy relating to the “Rights of EEA Residents” and “International Data Transfers” for provisions that may apply to them.
California residents should consult the section titled “Your California Privacy Rights” for rights that apply to them.
Personal Information That We Collect and How We Use It
We may collect certain Personal Information about you when you visit the Site, establish an account, make a purchase, contact us, order or purchase our Products, including online ordering of food, make reservations, participate in certain special offers, purchase a gift card, join our rewards program, subscribe to our newsletter or publications or otherwise avail yourself of our Services. “Personal Information” is information that may be used to directly or indirectly identify you, including your name, email address, physical address, phone number or other information about you. The majority of such Personal Information is collected when you register with the Site, use our Services, including ordering or purchasing Products, subscribe to updates, sign up for our mailing list, contact customer service or otherwise provide us with your contact information. Some of this Personal Information will be required if you wish to partake in the Services that we provide, including making purchases or orders for Products through the Site.
In general, the type of Personal Information we collect includes, but is not limited to:
- Personal Information necessary to use the Services you have requested or to order our Products;
- Personal Information to contact you to promote our Services, sign up for our newsletter, allow you to participate in our rewards and loyalty programs, or to alert you to special offers or features;
- Un-identifiable and aggregated Personal Information pertaining to your Site visits that help us maintain the appropriate features, functionality and user experience
We and our partners may use that information to maintain regular communication with you as may be needed to inform you of offers, updates and other information regarding us.
Use of Personal Information
We use this Personal Information to: (i) add you to our e-mail lists; (ii) register you for an account and rewards and loyalty programs; (iii) provide the Services you have requested, including processing orders for Products or requests for reservations; (iv) guard against potential fraud; (v) contact you or send you offers; (vi) provide answers to your inquiries or questions; and (viii) maintain regular communication with you as may be necessary to inform you about our Services.
Please note that we use a third party payment processing partner to collect your credit card or other payment information if you choose to purchase our Products online via the Site. If you do make such an online purchase, our payment processing partner will collect your payment information and process your payment. We do not store any credit card information or share it with anyone other than our payment processor. We also do not have access to your full credit card number.
Non-Identifiable Data and Aggregated Personal Information
We or our service providers including Google Analytics may also collect web surfing data related to your use of the Site. Such information may include: your Internet Protocol (IP) address, browser type, and internet service provider (ISP); your operating system; which of our web pages you access and how frequently you access them; referral or exit pages; click stream data; and the dates and times that you visit the Site. This data may be collected using cookies, web beacons, page tags or similar tools. As with cookies, the web surfing information is anonymous, “click stream” transactional data that is not associated with any users as individuals.
Web surfing data and similar information may be aggregated for administrative and analytic purposes. We may, for example, use this aggregated information in the administration of the Site or share it with third parties to improve its usability and to evaluate the success of marketing and advertising campaigns, search engine optimization strategies, operation and effectiveness of pages on our website, and other marketing activities. We also use it to help optimize the Site based on the needs of our users.
We may engage certain third-party ad network service providers, such as Google AdWords, Facebook or Instagram to serve advertisements on our behalf across the Internet and to provide analytics services. These entities may utilize Cookies or other technology (including within the ads) to collect information from you such as your IP address, web browser, pages viewed, time spent on pages, how you use our Website, items you put in your basket, any links you click on, and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content or products, measure the effectiveness of ad campaigns, determine the proper amount of repeat views of a given ad, and deliver advertising and content targeted to your interests on our Sites and other websites (also known as “interest-based advertising”).
How and When Your Information Is Shared With Other Parties
We will not disclose, rent or share your Personal Information with other parties, except as disclosed below.
We work with a number of trusted partners who may perform vital functions as part of our operations. We do not share your Personal Information unless it is necessary to fulfill our responsibilities, including providing information or Services to you.
Additional Sharing of Information
We may engage third parties to help us carry out certain other internal functions such as account processing, client services, or other data collection relevant to our business. For example, we may share information with our payment processors, although we do not store your payment card information in full. Personal Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services.
We may share your Personal Information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your Personal Information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order or legal process. We further reserve the right to disclose any of your Personal Information that we believe, in good faith, appropriate or necessary to take precautions against liability, to investigate and defend against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Site or our services, or to protect the rights, property or personal safety of us, our users, issuers, or others.
We may share or disclose information that we collect from you, including Personal Information, if we are acquired as a result of a transaction such as a merger, acquisition or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy.
We will not share your Personal Information if such sharing is prohibited by applicable privacy and data protection law, including, without limitation, the EEA’s General Data Protection Regulation effective May 25, 2018 or the California Consumer Protection Act (“CCPA”).
From May 25, 2018, all processing of Personal Information of EEA Residents is performed by us in accordance with the General Data Protection Regulation (2016/679) of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of Personal Information and on the free movement of such data (“GDPR”).
Although we are based and operate in the United States and do not provide our Services or Products through the Site to the EEA, we may in some instances obtain the Personal Information of EEA residents. Under the GDPR, we are the controller and co-processor of the Personal Information of EEA Residents. Our purpose for collecting and processing Personal Information from EEA Residents is to provide them with information regarding our Services and Products. We do not, however, ship our products outside the United States from our Site and our restaurants are all located in the United States. The legal basis for collecting Personal Information is your consent to obtain information about our Services or Products. You may withdraw consent from receiving marketing and promotional communications by clicking the “Unsubscribe” link on the communication or contacting us at email@example.com. If EEA Residents do not provide Personal Information to us or withdraw consent for processing such Personal Information, we may not be able to provide such residents with information regarding our Services or Products.
EEA Residents may obtain information about the Personal Information that we hold about them by contacting us at firstname.lastname@example.org.
International Data Transfers
If you are resident outside the United States, including in the EEA, we transfer Personal Information provided by you for processing in the United States. Under the GDPR, we are considered a “controller” and a “co-processor” of the Personal Information of EEA Residents. By providing Personal Information to us for the purpose of obtaining information about our Services, you consent to the processing of such data in the United States. The transfer of your Personal Information to the United States is necessary for the performance of a contract between you and us for obtaining Services. You may always discontinue consent for obtaining information about our products, as outlined in the following section.
Please note that the United States does not have data protection laws equivalent to those in the EEA and other jurisdictions.
Notifications and Communications from Our Site
Communications Regarding Our Services
We will send you email notifications and free newsletters from time to time. Some notifications are communications relating to us and our Services or Products. You may “opt-out” from receiving such communications by following the “Unsubscribe” instructions provided in the e-mail.
Legal or Security Communications
Deleting Your Information
If you want us to delete your Personal Information and your account, please contact us at email@example.com with your request. We will take steps to delete your information as soon as we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.
Personal Information Retention
Links to Other Sites
We take commercially reasonable steps to protect our customers’ Personal Information against unauthorized disclosure or loss. However, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, while we strive to protect user information we cannot ensure or warrant the security of any information you transmit to us or from the Site. You engage in such transmissions at your own risk.
If you believe your Personal Information is being improperly used by us or any third party, please immediately notify us via email at firstname.lastname@example.org.
Children Under 13
Our Sites are restricted to the use of adults over the age of majority in their place of residence. No portion of the Sites is directed to children under the age of 13. Consequently, we do not knowingly collect personal identifying information from any person we know is a child under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 we will delete that information as quickly as possible. If you are a parent or guardian of a child under 13 years of age and you believe your child has provided us with Personal Information, please contact us at email@example.com.
Your California Privacy Rights
The following section pertains to the rights of individuals or households in California (“California consumers”).
- Civil Code Section 1798.83
Under certain circumstances, California Civil Code Section 1798.83 states that, upon receipt of a request by a California consumer, a business may be required to provide detailed information regarding how that business has shared that customer’s Personal Information with third parties for direct marketing purposes. However, the foregoing does not apply to businesses like ours that do not disclose Personal Information to third parties for direct marketing purposes without prior approval or give customers a free mechanism to opt out of having their Personal Information disclosed to third parties for their direct marketing purposes.
- Rights under the CCPA
The CCPA (California Civil Code Section 1798.100 et seq.) provides California consumers with additional rights regarding Personal Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular consumer or household. The categories of Personal Information we collect are generally described above but differ for individual consumers depending on the Services used by such consumers.
Under the CCPA, qualifying California consumers may have the following rights:
Right to Know and Right to Delete.
A California consumer has the right to request that we disclose what Personal Information we collect, use, disclose and sell. A California consumer also has the right to submit requests to delete Personal Information.
When we receive a request to know or delete from a California consumer, we will confirm receipt of the request within 10 business days and provide information about how we will process the request, including our verification process. We will respond to such requests within 45 days.
Right for Disclosure of Personal Information.
A California consumer may also submit requests that we disclose specific types or categories of Personal Information that we collect and share with third parties.
Under certain circumstances, we will not provide such information, including where the disclosure creates a substantial, articulable and unreasonable risk to the security of that Personal Information, customers’ accounts with us, or the security of our systems or networks. We also will not disclose California consumers’ social security numbers, driver’s license numbers or other government-issued identification numbers, financial account numbers, any health insurance or medical identification numbers, or account passwords and security questions and answers.
If you are a California consumer and would like to make any requests under the CCPA, please direct them as follows:
Lawry’s Privacy Compliance,
225 South Lake Avenue, Suite 1150
Pasadena, California 91101
If we receive any request we will use a two-step process for online requests where the California consumer must first, clearly submit the request and then second, separately confirm the request. We will use other appropriate measures to verify requests received by mail or telephone.
In submitting a request, a California consumer must provide sufficient information to identify the consumer, such as name, email address, home or work address, or other such information that is on record with us so that we can match such information to the Personal Information that we maintain. Do not provide social security numbers, driver’s license numbers, account numbers, credit or debit card numbers, medical information or health information with requests. If requests are unclear or submitted through means other than as outlined above, we will provide the California consumer with specific directions on how to submit the request or remedy any deficiencies. If we cannot verify the identity of the requestor, we may deny the request.
- California Do Not Track Disclosures
Although some browsers currently offer a “do not track (‘DNT’) option,” no common industry standard for DNT exists. We therefore do not currently commit to responding to browsers’ DNT signals.
Your Rights and Obligations
We ask that you keep the Personal Information that you provide to us current and that you correct any information you have provided us by contacting us at firstname.lastname@example.org. You represent and warrant that all Personal Information you provide us is true and correct and relates to you and not to any other person.
If you are a resident of the EEA and wish to access or correct the Personal Information that we have about you or have any questions relating to the processing of your Personal Information, please contact us at email@example.com with the subject line “GDPR Data.”
If you use the Site, you are responsible for maintaining the confidentiality of your account and for restricting access to your computer or device, and you agree to accept responsibility for all activities that occur under your account.