Effective as of May 2, 2023
2. Categories of Personal Information We Collect and Process
We collect and process the following categories of personal information in the course of providing the Services:
(a) Identifiers, such as a real name, physical address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
(b) Commercial information, including payments information, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
(c) Internet or other similar network activity, including, but not limited to, browsing history, search history, browser settings like language preference, and information regarding your interaction with a website, application, or advertisement.
(d) Sensory data, including electronic, visual, or similar information.
(e) Inferences, such as a profile about a consumer’s preferences, characteristics, and behavior, drawn from information we collect and insights we receive from third parties such as our marketing and advertising partners and data analytics providers.
(f) Sensitive personal information, such as account login information allowing access to an account, in each case as further described above in the relevant categories. If you win a promotional prize or sweepstakes, we may also collect your W9 information, including FEIN or SSN for legal compliance. Please note we do not collect sensitive personal information for the purpose of inferring characteristics about you.
3. How We Use Your Information
We use all categories of personal information described in the “Categories of Personal Information We Collect and Process” Section, on its own and combined with other information we collect about you, for the following purposes:
(a) Providing our products or services to you
We use identifiers and commercial information to process your orders and payments and for operation of our business.
(b) Communicating with you
We use identifiers, commercial information, internet or other similar network activity, and inferences to communicate with you regarding our products, services, events, promotions and other offers and respond to your inquiries, comments, feedback, stories, or postings.
(c) Customizing and improving your experience
We use your information to tailor our products, services, promotions, communications and the Services so that they are more useful and relevant to you, such as through targeted advertising and messaging personalization.
(d) Creating and managing your accounts with us
We use your information to create and manage your accounts (e.g., Pennycake accounts, registration for events, ordering, payments, contests, promotions, etc.) and administer your participation in our programs, events and other offerings.
(e) Getting to know our customers
We use your information to better understand your preferences and provide and improve support related to our product and service offerings and marketing efforts. For example, we may use your information to:
· develop our products, services, promotions, and other offers;
· respond to your requests, suggestions, and other communications;
· improve our Services and business operations; and
· conduct research and analysis for marketing, business and other operational purposes.
(f) Marketing and advertising
(g) Fraud detection, security, legal enforcement and compliance
We use your information to protect the security and integrity of our business and the Services, for enforcement of our agreement with you, for example, and our compliance with our applicable law.
4. How We Disclose Your Information
To perform our Services, we may disclose any category of your personal information within Chick-fil-A and to third parties as necessary to complete your order, to provide our products and services, for purposes described in the “How We Use Your Information” Section, or with your consent. However, we do not sell your personal information to third parties.
We may disclose your information to the following types of parties:
(a) Within Chick-fil-A
We disclose personal information within Chick-fil-A to provide our products, services, promotions and other Services to you and for our marketing purposes, in accordance with applicable law. We may also disclose personal information within Chick-fil-A at your direction or request.
(b) Service providers
We may also disclose the personal information we collect to our analytics vendors and partners to develop aggregate analysis and business intelligence for our advertising and marketing purposes. For example, we use personal information to create custom audiences and measure the success of promotions.
(c) Other entities
We may also disclose personal information as may be necessary to detect security incidents and fraudulent or illegal actions or to protect the safety, property, or other rights of Chick-fil-A, and our employees, customers, visitors, users, service providers, or any other person or entity; to comply with law, a court order, or other legal process (which may include access by courts, law enforcement or governmental authorities in the US or other jurisdictions), or in connection with a legal investigation; to enforce any applicable terms and conditions and other agreements; as otherwise may be required or permitted by applicable law; or in accordance with your consent.
5. Your Privacy Rights
You may have the following rights, in each case to the extent set out in applicable law:
· The right to confirm whether we process personal information about you and request access to such personal information.
· The right to correct inaccuracies in certain personal information we may hold about you; and
The right to request that we delete personal information collected from or about you. Note, processing your deletion request will result in the elimination of your Pennycake account.
You may request to exercise these rights by:
· Calling us toll-free at Chick-fil-A CARES (1-866-232-2040); or
· Completing our privacy rights request form available here.
If your rights request is denied, you may lodge an appeal with us. The response to your rights request will inform you of any appeal rights you may have and how you may exercise them.
We do not sell personal information, but if you wish to opt out of our targeted advertising or disclosure of personal information for cross-context behavioral advertising, each as defined under applicable law, please visit our Cookie Preference Center, located in the footer of Pennycake.com.
As required under applicable law, we will take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide your first name, last name, email address, the amount of your last transaction and the date of your last transaction to verify your identity in response to exercising requests of the above type. We may limit our response to your exercise of the above rights as permitted under applicable law. When you submit a request to exercise your rights described above, we will use the information you provide to process your request and to maintain a record of your request and our response, as permitted under applicable law.
Under applicable law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. We will require the agent to provide proof of that written permission. To the extent permitted by law, we may require you to verify your own identity in response to a request, even if you choose to use an agent.
If you are an authorized agent submitting a request on behalf of a consumer, please complete our rights request form available here.
6. Information Security
We seek to keep your personal information secure by implementing reasonable technical, administrative, and physical safeguards to help us protect such information from unauthorized access, use, and disclosure. When we collect or transmit sensitive information such as a credit card number, we endeavor to use industry standard methods to protect that information. We also ask our third-party service providers to use reasonable security measures to protect your information from unauthorized access, use and disclosure. However, please be aware that no method of electronically transmitting or storing information is ever completely secure.
8. California Do Not Track
California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings. We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. However, we respond to the GPC signals as the opt out preference signal as described in our Cookie and Interest-Based Advertising Policy to.
9. Children's Privacy
The Online Services are not intended for children under the age of 13, without parental or legal guardian consent. We do not knowingly collect personal information from users in this age group. If you believe your child has provided personal information to us, please contact us via the email listed in the “Contact Us” Section and we will work to delete it.
10. Contact Us
· If you are a resident of the United States (excluding Puerto Rico), by visiting the website at <http://www.chick-fil-a.com/Connect/Contact-Us-CARES> or calling us at 1-866-232-2040. You may also contact us by emailing us at email@example.com.
If you are a resident of Puerto Rico, by emailing us at firstname.lastname@example.org.