Effective Date: January 1, 2023
- European Economic Area and United Kingdom residents please click here to learn more about your privacy rights.
- Residents of Canada please click here to learn more about your privacy rights.
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.
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 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
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.
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 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
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
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
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 firstname.lastname@example.org.
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.
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 at Contact Us. 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. We may send periodic promotional or informational communications to you. You may opt out of such 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 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.
PRIVACY INFORMATION FOR NEVADA RESIDENTS
Nevada residents may 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.
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
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 email@example.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 firstname.lastname@example.org. 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 email@example.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 firstname.lastname@example.org.
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 email@example.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