Schlotzsky’s Privacy Policy

Last Updated: July 1, 2023

Schlotzsky’s Franchisor SPV LLC, Schlotzsky’s Stores LLC, and their affiliates (collectively, “Schlotzsky’s,” “we,” “our,” “us”) value your privacy. In this Privacy Policy, we describe how we collect, use, and process the personal information we obtain about people who use our websites or mobile apps, browse or purchase our products, apply to become franchisees, or who otherwise interact with us online or offline (collectively, our “Services”). This Privacy Policy does not apply to any websites or mobile apps that are created, run, or controlled by independently owned or operated Schlotzsky’s franchisees or any other third party.

This Privacy Policy and our Cookie Policy describe our collection, use, and disclosure of personal information. By downloading, using, creating an account on, or registering for our Services, or by otherwise providing your personal information to us, you are agreeing to this Privacy Policy and our Terms and Conditions.

In this Privacy Policy, “personal information” (a/k/a “personal data”) means any information that Schlotzsky’s processes that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular person or household.

PERSONAL INFORMATION WE COLLECT ABOUT YOU

We may collect personal information directly from users of our Services. You can use some parts of our Services without registering or directly submitting your personal information to us, but we may automatically collect certain information about your use of our Services through cookies and other tracking technologies.

Information We Collect Directly From You. To use some features of our Services (for example, to sign up for rewards programs, enter contests, make a purchase, or request a franchise kit from us), you must register with us or otherwise provide us with your personal information. We also may collect personal information that you enter through our Services or provide to us in other ways, such as through email or text message. The types of personal information that we collect from you will depend on your interactions with us and how you use our Services, but may include:

• personal details, such as full name, mailing address, email address, phone number, and other contact information;
• purchase transaction information, such as information about the products you buy, billing address, method of payment, and payment details;
• location data; and
• other personal information you choose to provide to us.

Information We Collect Automatically. We, and the vendors we work with, may also collect other information about your use of our Services using automated tools. For example, cookies and other passive information collection technologies enable us to compile aggregate statistics concerning use of our Services, analyze trends, enhance the security of our Services, deliver content and advertisements, and otherwise administer and improve our Services. This information may include your browser type, language preference, operating system, device identifier, device type, access time, Internet Protocol (IP) address, the URLs of websites you visited before and after visiting our websites, the web search that landed you on our websites, the length of your visits to our websites, and the links you click and pages you visit within our websites. You can set your browser not to accept cookies, to remove cookies, or to notify you when you are sent a cookie, giving you the opportunity to decide whether or not to accept it. However, please note that if you disable the use of cookies on your computer, some functionality of our websites will not work. Please see our Cookie Policy for more information.

Your web browser may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. Like many websites, our websites are not designed to respond to “Do Not Track” signals received from browsers.

We may use certain third-party web analytics services to help us understand and analyze how visitors use our Services and to serve advertisements on our behalf across the Internet. We have implemented Google Analytics Advertising features such as dynamic remarketing, interest-based advertising, audience targeting, behavioral reporting, demographics and interests reporting, user segment analysis, device reporting, display advertising, and video ads reporting. We may use cookies and other identifiers to deliver advertisements, create a profile of you, measure your interests, personalize content, and detect your demographics, location, or device. For more information on how Google Analytics uses data, visit www.google.com/policies/privacy/partners/. To opt out of Google Analytics and advertising cookies, visit myadcenter.google.com and tools.google.com/dlpage/gaoptout/.

We use Hotjar, a service provider, to help us understand and analyze how visitors use our services, and to improve the services. Hotjar may collect the following types of information from users of our websites:

• device IP Address
• device screen size
• device type (unique device identifiers)
• browser information, geographic location (country only)
• preferred language used to display our website

Hotjar stores the above information in a pseudonymized format. Hotjar does not use this information to identify individual users, or match or link the information with other information about users. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For more information regarding Hotjar's collection and use of information, please visit Hotjar's privacy policy here.

Information We Collect About Your Location. Our Services may access and collect your geolocation information to facilitate our provision of Services, such as to provide you with information about stores near you. We also may use information about the location of the device you are using to help us understand how our Services are being used and to deliver more relevant advertising. For most mobile devices and computer systems, you are able to withdraw your permission for us to collect this information through your device or web-browser settings.

Information We Collect From Others. We may collect personal information about customers, prospective franchisees, and current franchisees from our affiliated companies, franchisees, service providers, and third parties. We also may collect information about any comments or reviews you post about us on third-party websites. When submitting information to a third party, you are subject to that third party’s terms of use and privacy policies. Schlotzsky’s may combine information about you that we already have with information we obtain from third parties. If you submit someone else’s personal information to us, you represent that you have been authorized to provide this information to us.

HOW WE USE YOUR INFORMATION

We may use your personal information to:

• communicate with you, including to respond to your questions and requests, provide you with documentation or communications you have requested, send you notices about our Services, offer customer support, or contact you for information or after-sales support;
• process your orders or purchases;
• market and advertise our products, including to send you news, updates, special offers and promotions, and targeted advertising;
• personalize our content, including to make recommendations to you about our Services, to tailor the information we send or show you, and to offer location-based customizations and personalization based on your purchase history or past interactions with our Services;
• monitor and analyze trends, usage, and the activities of users of our Services to better understand how our users access and use our Services in order to improve them, respond to user preferences, and for other research purposes;
• improve our Services and notify you about important updates;
• perform business analyses or for other business purposes, such as evaluating transactions and involving our Services;
• facilitate, manage, personalize, and improve our partnership and franchisee relationships;
• identify, prevent, investigate, and take other actions with respect to suspected or actual fraud or illegal activity or other activity that violates our policies;
• ensure the security and integrity of our personal information processing;
• protect our rights, property, or safety and that of our users and our confidential and proprietary information;
• comply with applicable laws, rules, regulations, and legal processes as well as our company policies, including to respond to claims asserted against us and to enforce or administer terms and agreements; and
• achieve other purposes, with your consent (when required).

HOW WE DISCLOSE YOUR INFORMATION

We may disclose your personal information within our company, with our affiliates, with our business partners and franchisees, and with our vendors. We also may disclose your personal information to:

• provide you with products or services, such as when we use a payment processor or app developer;
• better respond to your inquiries;
• advertise or market our products and services;
• perform marketing research and for sales, support, and service-related purposes;
• protect rights, property, life, health, security, and safety;
• respond to legal process, including to disclose personal information to a court, legal authority, opposing party in litigation, our legal counsel, or other advisors in connection with a judicial proceeding, court order, subpoena, or other legal process;
• negotiate or complete any proposed or actual merger, purchase, sale, or any other type of acquisition or other transaction, including a transfer of all or a portion of our business to another organization;
• disclose personal information with your consent or at your direction; and
• achieve any other purpose consistent with our statements in this Privacy Policy or otherwise allowed by applicable law.

We may disclose your personal information to comply with applicable law, such as in response to requests from law enforcement agencies, regulators, other public authorities, courts, and third-party litigants in connection with legal proceedings or investigations.

Any information, including personal information, that you post on any public areas of our Services, such as reviews, comments, and photos, may be available to, and searchable by, all other users. Reviews also may be publicly accessible.

LINKS TO OTHER WEBSITES

Our Services may include links to other websites that we do not own or operate. This Privacy Policy does not apply to those websites, which may have their own privacy policies that you should review to understand how they may collect, use, or disclose your personal information. We are not responsible for the content or privacy practices of any linked websites that are not under our control.

SOCIAL FEATURES

Certain features of our Services may permit you to interact with social media networks operated by unaffiliated parties, for example, if you “like” or “follow” us on those platforms (“Social Features”). If you choose to “like” or share content or post information using Social Features, that information may be publicly displayed, and the party operating the social media platform may receive information about you and your use of our Services. Similarly, if you interact with us through Social Features, we may have access to information about you from the social media platform. In addition, we may track when you like us, follow us, or share our content through Facebook, Twitter, or other social media platforms.

Please note that if you mention Schlotzsky’s, or comment about or in response to us, in your post on a social media platform, that platform may allow us to publish your post on our Services or public social media pages or otherwise use your post about us. You should review the terms, policies, and settings of these platforms to learn more about their data practices and adjust your settings accordingly.

USER-GENERATED CONTENT

Any content you post to our Services or public social media pages (“User-Generated Content”) may be visible to and searchable by all users or the general public, and we may not be able to prevent such content from being used in a manner that violates this Privacy Policy, the law, or your personal privacy. For instance, third parties may have republished your User-Generated Content, or it may have been archived by search engines and others that we cannot control. We may revise such User-Generated Content, remove it, or combine your User-Generated Content with other information we have collected about you and use it as described in this Privacy Policy. All User-Generated Content is subject to our Terms and Conditions.

In addition, we may collect information from you when you contact us or when you submit a review, comment, or other content to our Services or on our social media pages. We may choose to disclose the personal testimonials of our customers, including your name, on our Services or with our affiliates, our business partners and franchisees, and our vendors. If you wish to update or delete your testimonial, you can contact us at privacy@schlotzskys.com.

SECURITY OF YOUR PERSONAL INFORMATION

We maintain appropriate safeguards designed to protect personal information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, no data security measures can guarantee 100% security. We encourage you to safeguard your passwords, ID numbers, and other information you use to access our Services.

OUR RETENTION OF YOUR PERSONAL INFORMATION

We retain personal information for as long as necessary or permitted for the purposes described in this Policy or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:

• your personal information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
• your personal information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the personal information was collected;
• the personal information is reasonably necessary to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
• we are otherwise required or permitted to keep your personal information by applicable laws or regulations.

Where personal information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention practices, please contact us using the contact details below.

YOUR CHOICES

Updating Your Information. If you wish to update the personal information you have provided to us, you may do so by logging in to your account or by contacting us through our Contact Us form. Please note that outdated copies of information that you have updated may remain viewable in cached and archived pages for a period of time, and we may maintain records in our systems of this information as well.

Marketing Emails. You may opt out of marketing email communications by following the opt-out instructions contained in any email you receive from us or by submitting your request here . Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt out of marketing email communications, we may still send you administrative emails about your account or any product you have requested or received from us.

Text Messages. You have the choice to opt-in to receiving text messages and alerts on the mobile phone number(s) you disclose to us. Once you opt-in, we may send you text messages (i) regarding your account and your orders; (ii) about our products and promotions (including advertisements, sales, and special offers); (iii) to investigate or prevent fraud; and (iv) to alert you in the event of an issue with any of your purchases. You do not have to opt-in to text messages and alerts to use and enjoy our website or products. If you opt-in, standard text messaging charges may apply. You may choose to opt-out of our text messages and alerts at any time by sending us a text message from your mobile phone with the word STOP, STOP ALL, END, QUIT, CANCEL or UNSUBSCRIBE, and we will unsubscribe you from text communications.

Mobile App. If you no longer wish to provide us with information through one of our mobile apps, you may delete or deactivate your account through the app or our website. Please see our Terms and Conditions for instructions.

PRIVACY OF CHILDREN

Our Services are not intended for children, and we do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child, we will delete it in accordance with applicable law.

ADDITIONAL INFORMATION FOR FRANCHISEES

If you submit your personal information to request more information from us about our franchise opportunities, we may use that information to contact you to discuss our franchise opportunities. We may ask that you complete our franchise application, which requests the following additional types of personal information from you, including:

• franchise ownership details and history;
• financial information, including details of current assets and liabilities, annual income, investments, mortgages, insurance, ACH information, and any history of bankruptcy;
• driver’s license, state ID, social security, and passport numbers;
• criminal history (if any).

We may disclose the information provided in our franchise application with our affiliated brands and vendors as needed to process your franchise application, including to run background checks and to determine creditworthiness.

If you provide personal information related to other people, such as your spouse, investment partners, or personal references, as part of the franchise application process, you guarantee that you do so with the knowledge and permission of those people. We may use any information you provide to contact those people and disclose it, as necessary, with our affiliated brands and vendors during the franchise application process.

SUPPLEMENTAL NOTICE FOR COLORADO RESIDENTS

As a supplement to the other information provided throughout this Privacy Policy, we provide the following additional information as a notice to consumers in Colorado.

How and Why We Collect Personal Information.

CATEGORY OF PERSONAL INFORMATION	CATEGORIES OF SOURCES	PURPOSES FOR COLLECTION
Identifiers, including name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, or other similar identifiers	Directly from you Automatically when you use our Services Advertising networks Internet service providers Data analytics providers Social networks Vendors that help us to fulfill and deliver orders, process payments, support our promotions, contests, gift cards, loyalty programs, and sweepstakes, and provide communications, marketing or other services on our behalf Our affiliated brands and companies Franchisees Data brokers	Processing your purchases of or requests for products or services Communicating with you To support our contests, promotions, loyalty programs, coupons, and sweepstakes Customer service Marketing and advertising To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes To help maintain the safety, security, and integrity of our Services, databases and other technology assets, as well as your account, orders, and deliveries Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity Tailoring our content or otherwise personalizing the Services
Personal records, including name, signature, physical characteristics or description, address, telephone number, employment, credit or debit card number, other financial information (including gift cards)	Directly from you Automatically when you use our Services Advertising networks Internet service providers Data analytics providers Social networks Vendors that help us to fulfill and deliver orders, process payments, support our promotions, contests, gift cards, loyalty programs, and sweepstakes, and provide communications, marketing or other services on our behalf Our affiliated brands and companies Franchisees Data brokers	Processing your purchases of or requests for products or services Communicating with you Supporting our contests, promotions, loyalty programs, coupons, and sweepstakes Customer service Marketing and advertising To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes To help maintain the safety, security, and integrity of our Services, databases and other technology assets, as well as your account, orders, and deliveries Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity Tailoring our content or otherwise personalizing the Services
Characteristics of protected classifications, including gender, age, and date of birth	Directly from you Our affiliated brands and companies Data analytics providers Data brokers	Communicating with you To support our contests, promotions, loyalty programs, coupons, and sweepstakes Marketing and advertising To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes Customer service To help maintain the safety, security, and integrity of our Services, databases and other technology assets, as well as your account, orders, and deliveries Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity
Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	Directly from you Automatically when you use our Services Advertising networks Data analytics providers Social networks Vendors that help us to fulfill and deliver orders, process payments, support our promotions, contests, gift cards, loyalty programs, and sweepstakes, and provide communications, marketing or other services on our behalf Our affiliated brands and companies Franchisees Data brokers	Processing your purchases of or requests for products or services Communicating with you Supporting our contests, promotions, loyalty programs, coupons, and sweepstakes Customer service Marketing and advertising Tailoring our content or otherwise personalizing the Services Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity
Internet or other electronic network activity information, including browsing history, search history, and information regarding interactions with our websites, applications, or advertisements	Directly from you Automatically when you use our Services Advertising networks Internet service providers Data analytics providers Social networks Franchisees Vendors that help us to fulfill and deliver orders, process payments, support our promotions, contests, gift cards, loyalty programs, and sweepstakes, and provide communications, marketing or other services on our behalf	To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes To help maintain the safety, security, and integrity of our Services, databases and other technology assets, as well as your account, orders, and deliveries Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity Marketing and advertising Tailoring our content or otherwise personalizing the Services Customer service
Geolocation data, including the location of the consumer inferred from IP address or mobile app usage	Automatically when you use our Services Advertising networks Internet service providers Data analytics providers Social networks Vendors that help us to fulfill and deliver orders, and provide communications, marketing or other services on our behalf	Processing your purchases of or requests for products or services Customer service Marketing and advertising To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes To help maintain the safety, security, and integrity of our Services, databases and other technology assets, as well as your account, orders, and deliveries Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity Tailoring our content or otherwise personalizing the Services
Audio, electronic, visual, thermal, olfactory, or similar information, including recorded phone calls and in-store video surveillance	Directly from you Automatically when you use our Services. For example, if you interact with us by phone or video Franchisees	Processing your purchases of or requests for products or services Customer service To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes To help maintain the safety, security, and integrity of our Services, databases and other technology assets, as well as your account, orders, and deliveries Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity
Professional or employment-related information	Directly from you	Supporting our contests, promotions, loyalty programs, coupons, and sweepstakes Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity
Inferences reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, aptitudes	Inferred from other categories of personal information we collect Data analytics providers Our affiliated brands and companies	To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes Tailoring our content or otherwise personalizing the Services Marketing and advertising Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity

In addition to the purposes described above, we may use and disclose any category of personal information we collect to comply with law, cooperate with and respond to law enforcement requests, or as otherwise required by applicable law, court order, or governmental regulations; to maintain appropriate records for internal administrative purposes; to protect our rights and interests and those of our franchisees, to resolve any disputes, to enforce this Policy or any of our other policies, to protect the rights or property of another, or to prevent harm; and to evaluate or conduct a merger, sale, or other acquisition of some or all of our organization or its assets.

Disclosure of Personal Information. The following charts summarize how we disclose personal information. Although we do not sell personal information in exchange for money, some of the ways in which we share personal information for advertising or disclose personal information to our affiliated brands and franchisees may be considered “sales” under the Colorado Privacy Act.

The first chart below shows the categories of personal information that we share for purposes of targeted advertising or otherwise “sell” for non-monetary consideration. The second chart describes the categories of personal information we disclose for a business or commercial purpose.

Sales and Sharing of Personal Information

CATEGORY OF PERSONAL INFORMATION	CATEGORIES OF THIRD PARTIES TO WHICH SOLD OR SHARED	PURPOSES FOR SELLING / SHARING
Identifier	Our affiliated brands and companies Franchisees Advertising partners and social media platforms	Analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of Focus Brands and its affiliated companies, brands, and franchisees Co-marketing, targeted advertising, remarketing, and customized advertising content
Personal records	Our affiliated brands and companies Franchisees Advertising partners and social media platforms	Analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of Focus Brands and its affiliated companies, brands, and franchisees Co-marketing, targeted advertising, remarketing, and customized advertising content
Characteristics of protected classifications	Our affiliated brands and companies Franchisees Advertising partners and social media platforms	Analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of Focus Brands and its affiliated companies, brands, and franchisees Co-marketing, targeted advertising, remarketing, and customized advertising content
Commercial information	Our affiliated brands and companies Franchisees Advertising partners and social media platforms	Analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of Focus Brands and its affiliated companies, brands, and franchisees Co-marketing, targeted advertising, remarketing, and customized advertising content
Internet or other electronic network activity information	Our affiliated brands and companies Advertising partners and social media platforms	Analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of Focus Brands and its affiliated companies, brands, and franchisees Co-marketing, targeted advertising, remarketing, and customized advertising content
Geolocation Data	Our affiliated brands and companies Advertising partners and social media platforms	Analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of Focus Brands and its affiliated companies, brands, and franchisees Co-marketing, targeted advertising, remarketing, and customized advertising content
Inferences	Our affiliated brands and companies Franchisees	Analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of Focus Brands and its affiliated companies, brands, and franchisees Co-marketing, targeted advertising, remarketing, and customized advertising content

Disclosures for a Business or Commercial Purpose

CATEGORY OF PERSONAL INFORMATION	CATEGORIES OF RECIPIENTS	PURPOSES FOR DISCLOSURE
Identifier	Franchisees Our affiliated brands and companies Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies	Processing your purchases of or requests for products or services Performing services on our behalf (e.g., fulfilling and delivering orders, processing payments, supporting our promotions, contests, gift cards, loyalty programs, and sweepstakes, and providing communications, technical, analytical, web hosting, cloud hosting and mobile application support, or other services on our behalf) As part of the support we provide to franchisees Providing advertising and marketing services Short-term, transient use, including, but not limited to, non-personalized advertising Auditing, related to ad impressions Ensuring security and integrity of personal information Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity
Personal records	Franchisees Our affiliated brands and companies Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies	Processing your purchases of or requests for products or services Performing services on our behalf (e.g., fulfilling and delivering orders, processing payments, supporting our promotions, contests, gift cards, loyalty programs, and sweepstakes, and providing communications, technical, analytical, web hosting, cloud hosting and mobile application support, or other services on our behalf) As part of the support we provide to franchisees Providing advertising and marketing services Short-term, transient use, including, but not limited to, non-personalized advertising Auditing, related to ad impressions Ensuring security and integrity of personal information Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity
Characteristics of protected classifications	Franchisees Our affiliated brands and companies Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies	Performing services on our behalf (e.g., fulfilling and delivering orders, processing payments, supporting our promotions, contests, gift cards, loyalty programs, and sweepstakes, and providing communications, technical, analytical, web hosting, cloud hosting and mobile application support, or other services on our behalf) As part of the support we provide to franchisees Providing advertising and marketing services Short-term, transient use, including, but not limited to, non-personalized advertising Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity
Commercial information	Franchisees Our affiliated brands and companies Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies	Processing your purchases of or requests for products or services Performing services on our behalf (e.g., fulfilling and delivering orders, processing payments, supporting our promotions, contests, gift cards, loyalty programs, and sweepstakes, and providing communications, technical, analytical, web hosting, cloud hosting and mobile application support, or other services on our behalf) As part of the support we provide to franchisees Providing advertising and marketing services Short-term, transient use, including, but not limited to, non-personalized advertising Auditing, related to ad impressions Ensuring security and integrity of personal information Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity
Internet or other electronic network activity information	Our affiliated brands and companies Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies	Processing your purchases of or requests for products or services Performing services on our behalf (e.g., fulfilling and delivering orders, processing payments, supporting our promotions, contests, gift cards, loyalty programs, and sweepstakes, and providing communications, technical, analytical, web hosting, cloud hosting and mobile application support, or other services on our behalf) Providing advertising and marketing services Short-term, transient use, including, but not limited to, non-personalized advertising Auditing, related to ad impressions Ensuring security and integrity of personal information Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity
Geolocation Data	Our affiliated brands and companies Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies	Processing your purchases of or requests for products or services Performing services on our behalf (e.g., fulfilling and delivering orders, processing payments, supporting our promotions, contests, gift cards, loyalty programs, and sweepstakes, and providing communications, technical, analytical, web hosting, cloud hosting and mobile application support, or other services on our behalf) Providing advertising and marketing services Short-term, transient use, including, but not limited to, non-personalized advertising Auditing, related to ad impressions Ensuring security and integrity of personal information Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity
Audio, electronic, visual, thermal, olfactory, or similar information	Our affiliated brands and companies Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies	Performing services on our behalf (e.g., providing communications, technical, analytical, web hosting, cloud hosting and mobile application support, or other services on our behalf) Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity
Professional or employment-related information	Our affiliated brands and companies Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies	Performing services on our behalf (e.g., supporting our promotions, contests, gift cards, loyalty programs, and sweepstakes, or other services on our behalf) Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity
Inferences	Our affiliated brands and companies Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies	Performing services on our behalf (e.g., providing communications, technical, analytical, web hosting, cloud hosting and mobile application support, or other services on our behalf) Providing advertising and marketing services Auditing, related to ad impressions Ensuring security and integrity of personal information Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity

Privacy Rights

If you are a consumer who lives in Colorado, you have the right to submit certain requests relating to your personal information as described below. To exercise your rights, please submit a request through our webform or email us at privacy@schlotzskys.com. To opt out of targeted advertising, go to the Your Privacy Choices link in the cookie banner or the footer of the website where you want to opt out. Please note that we may need to authenticate your identity before your request can be processed. For authentication, you will be asked to log into your account or to provide 2-3 pieces of personal information that we will match against our records.

Right to Access and Data Portability. You have the right to confirm whether we are processing your personal information, to access your personal information, and to obtain a copy of personal information you provided to us in a portable format.

Right to Correct. You have the right to request that we correct inaccuracies in your personal information, taking into account the nature of the personal information and our purposes for processing it.

Right to Delete. You have the right to request that we delete your personal information, subject to exceptions.

Right to Opt Out. You have the right to opt out of the following uses of your personal information: (i) targeted advertising; (ii) the sale of personal information; and (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. We do not sell personal information in exchange for money or engage in practices that qualify as profiling producing legal or similarly significant effects under applicable state privacy laws. To opt out of targeted advertising and/or non-monetary “sales” of personal information, please submit a request as outlined above. If you are an authorized agent submitting an opt-out request on behalf of a consumer where allowed by law, please follow the instructions provided above and within our webform. We use commercially reasonable efforts to authenticate the identity of the consumer to whom the request relates and the authorized agent’s authority to act on the consumer’s behalf.

Right to Appeal. Sometimes we are unable to process requests relating to your personal information, in which case, your request will be denied. If your privacy rights request has previously been denied by us and you believe we denied it in error, you may appeal for reconsideration of your request using our webform.

Please note that if you make a privacy rights request, we will retain a record of your request for recordkeeping purposes.

Loyalty Program Disclosures for Colorado Residents

The purpose of this section is to notify Colorado consumers about how we use personal information in connection with our Rewards program. You have the right to delete your personal information associated with your Rewards account; however, if you delete your personal information, we will be unable to link your rewards to your account, and therefore you will be unable to receive benefits from the program.

The chart below identifies the categories of personal information collected through our Rewards program that we sell or process for targeted advertising, and the third parties who receive these categories of personal information.

Categories of Personal Information	Third Parties
Identifiers Personal records Gender Commercial information/purchase records Inferences	Advertising Partners Franchisees Loyalty Program Partners as described below

The chart below identifies our loyalty program partners, and the program benefits provided by each partner.

Loyalty Program Partner	Benefits Provided
Schlotzsky’s Franchisees	Points, discounts, and other rewards associated with our rewards program
Partner Businesses	Enhanced or additional rewards or discounts
AARP	Enhanced or additional rewards or discounts for AARP members

For more information about how we process your personal information, please click here.

Additional Information for Nevada Residents

Nevada law provides residents the right to opt out of the “sale” of “covered information” to third parties, including but not limited to name, address, social security number, telephone number, email address, and other information through which a person may be contacted. Our uses of your personal information are not sales under Nevada law. If you have any questions or if you would like to receive notice by email in the event we should engage in “sales” of personal information under Nevada law in the future, please contact us using the contact information provided below.

INTERNATIONAL USERS

Schlotzsky’s is based in the United States. If you are using our Services outside the United States, please be aware that personal information we obtain about you may be transferred to and processed in the United States or other jurisdictions outside your own. Your personal information may be accessible by public authorities where it is processed. By using our Services and providing your personal information, you acknowledge that your personal information may be transferred to and processed in jurisdictions other than your own. Please be aware that the data protection laws and regulations that may apply to your personal information transferred to the United States or other countries may be different from the laws in your country of residence.

NOTICE TO EUROPEAN ECONOMIC AREA AND UNITED KINGDOM RESIDENTS

As a supplement to the information provided throughout this Privacy Policy, we provide the following information as a notice to residents of the European Economic Area (“EEA”) of their rights under the European Union’s General Data Protection Regulation and residents of the United Kingdom (“UK”) of their rights under the United Kingdom’s General Data Protection Regulation.

Schlotzsky’s Stores LLC is the data controller for customer personal information collected through our Services. Schlotzsky’s Franchisor SPV LLC is the data controller with respect to the data of franchisees, prospective franchisees, and franchisee applicants it collects or otherwise processes. You may be required to provide certain personal information, such as your contact information and payment details, in order to use our Services and place an order for our products.

Legal Bases for Our Personal Information Processing. Your personal information is processed under the following legal bases:

• The processing is necessary for us to provide you with the services you request or to respond to your questions.
• We have a legal obligation to process your personal information, such as compliance with applicable tax laws or other government regulations or compliance with a court order or binding law enforcement request.
• We have a legitimate interest in processing your personal information and our reasons for using your personal information outweigh the potential prejudice to your data protection rights. In particular, we have a legitimate interest in the following instances:
• To analyze and improve the safety and security of our Services, including by implementing and enhancing security measures and safeguards and protecting against fraud, spam, and other abuses;
• To maintain and improve our Services;
• To operate and promote our Services, to advertise and provide you with information and communications about our Services that are tailored to, and in accordance with, your preferences; and
• To protect our legal rights, prevent misuse of our Services, perform on a contract, or comply with other legal obligations.
• You have consented to our processing of your personal information. When you consent, you may change your mind and withdraw your consent at any time by emailing us at privacy@schlotzskys.com.

Your Privacy Rights. You may ask us to take the following actions with respect to your personal information:

• provide you with information about our processing of your personal information and access to your personal information;
• update or correct inaccuracies in your personal information;
• delete your personal information;
• transfer a copy of your personal information to you or a third party of your choice; and
• stop or restrict our processing of your personal information.

You may submit these requests by emailing us at privacy@schlotzskys.com. We may require specific information from you to help us verify 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 any legal restrictions on disclosing this information.

Submitting a Complaint. If you would like to submit a complaint about our use of your personal information or our response to your request regarding your personal information, you may contact us at privacy@schlotzskys.com or submit a complaint directly to the data protection authority in your jurisdiction. If you reside in the EEA, you can find information about your data protection authority here. If you reside in the UK, you may file complaints with the Information Commissioner’s Office here.

Transfers of Your Personal Information. When you directly provide your personal information through our Services, you acknowledge that your personal information is being provided by you to a company based in the United States. The laws that apply to personal information protection in the United States differ from those applicable in the EEA and the UK. If it is necessary for us to transfer personal information out of the EEA and the UK, we do so by using suitable data transfer safeguards, such as the standard contractual clauses approved by the European Commission, which impose data protection obligations on parties to the transfer. You may obtain additional information about our data transfer mechanisms by contacting us at privacy@schlotzskys.com.

NOTICE TO RESIDENTS OF CANADA

Your Privacy Rights. You have the following rights with respect to your personal information:

• access to your personal information;
• verify or correct inaccuracies in your personal information;
• delete your personal information; and
• where you have provided your consent to the collection, use, transfer, or other processing of your personal information, withdraw your consent under certain circumstances.

You may submit these requests by email to us at privacy@schlotzskys.com. We may require specific information from you to help us verify 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 any legal or regulatory restrictions on disclosing this information. Please note, if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain any impact to you to help you with your decision.

CHANGES TO THIS POLICY

We may update or modify this Privacy Policy from time to time at our discretion. We will indicate changes to this Privacy Policy by updating the “Last Updated” date at the beginning of the Privacy Policy. Please review this Privacy Policy periodically and especially before you provide any personal information to us. Your continued use of our Services after any update will constitute your acceptance of our changes.

CONTACT US

If you have questions about this Privacy Policy or Schlotzsky’s privacy practices, please contact us at privacy@schlotzskys.com or by mail at 5620 Glenridge Drive NE, Atlanta, GA 30342.