YOUR PRIVACY RIGHT

Last updated 06/25/2024

PRIVACY POLICY

Last updated: June 25^th, 2024

Fazoli’s System Management (“Fazoli’s,” “we,” “us,” “our”) offers casual Italian-American cuisine at dine-in locations and through full-service catering.

This Privacy Policy explains how we collect, use, and share the personal information that we gather on the subdomains and websites on https://fazolis.com/ (the “Sites”), through our mobile applications (the “Apps”), and through other interactions with you, including through customer service communications (collectively, “Services”). A reference to “Fazoli’s,” “we,” “us,” or “our” is a reference to Fazoli’s Management Services. and its relevant affiliates in the collection, use, sharing, or other processing of personal information.

Our Services may contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these websites.

Information regarding our collection and use of franchisee information is found near the end of this Privacy Policy, under the “Franchisee Information” section.

Please to learn more about our Privacy Policy:

Information We Collect
How We Use Your Information
How We Share Your Information
How We Respond to ‘Do Not Track’ Signals
Cookies
Privacy Rights & Additional Disclosures for Certain U.S. Residents
Children’s Privacy
Change of Control
Data Security & Retention
International Transfers
Policy Updates
Franchisee Information
Notice of Financial Incentive
Contact Information

1. Information We Collect

Information You Give Us. You may give us information by signing up for an online account, entering information through our online forms or surveys, inputting information while using our Services, contacting us through our chat service, or contacting us by phone or email for information or customer service.

The categories of information include:

Identifiers, such as real name, postal address, Internet Protocol address, email address, or other similar identifiers.
Categories of personal information described in Section 1798.80(e) of the California Civil Code, such as name, address, or telephone number.
Characteristics of protected classifications under federal or California law, such as age.
Commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
Geolocation data.
Visual information, including photos and video surveillance.
Inferences drawn from the above categories of information.

The categories of sensitive information include:

Account log-in, in combination with any required security or access code, password, or credentials allowing access to the account.

Information We Automatically Collect.

Like many website operators, we collect information that your browser sends whenever you visit our Sites. This includes log data, such as your computer’s IP address, browser type, browser version, the pages of our Sites that you visit, the time and date of your visit, the time spent on those pages and other statistics, and whether you reached our page via a social media or email campaign. This information may be collected via several technologies, including cookies, web beacons, clear GIFs, canvas fingerprinting and other means, such as Google Remarketing and Facebook Pixel. You can control cookies in your browser to enable or disable them.
Some of our devices will collect IP address, log-in credentials, connectivity details and locations. This is used for device control and management.

Information We Collect From Third Parties. If you access our Sites through third parties (e.g., Facebook or Google), or if you share content from our Sites to a third-party social media service, the third-party service will send us certain information about you if the third-party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third-party service.

2. How We Use Your Information

We use your personal information for the following purposes:

To provide you with our Services, which includes:
maintaining and servicing accounts,
providing customer service,
processing and fulfilling orders and transactions,
verifying customer information,
processing payments, and,
providing advertising or marketing services to you.
To provide analytic services, such as analyzing customer usage and improving services offered.
To conduct market research and project planning.
To detect security incidents, protect against fraudulent or other criminal activity, debug and repair errors, and maintain the overall quality and safety of our Services.
To share your website visitor activity, through website cookies, with third-party marketing partners to market our Services on our Sites and other websites that you may visit.
To fulfill our legal and financial obligations.
To provide you with employment opportunities.

Marketing. We may use your personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe instructions provided in any email we send, or you can contact us using the contact details provided in the “Contact Information” section below. You will still continue to receive service-related messages concerning products and services you have purchased (unless we have indicated otherwise).

3. How We Share Your Information

To Users or the Public with Your Consent. We may share your information with other users or the public with your consent.

Affiliates and Service Providers. We share your information with our third-party service providers, affiliates, and any subcontractors as required to offer you our products and Services. The service providers we use help us to:

Run, operate, and maintain our Services through third-party platforms and software tools;
Offer and maintain our rewards program;
Perform crash analytics;
Run email and mobile messaging campaigns;
Perform marketing analytics;
Provide measurement services and targeted ads (you can opt out of these services at websites such as http://www.aboutads.info/choices and http://www.youronlinechoices.eu/);
Administer live events, competitions, sweepstakes, and promotions, including eligibility and prize fulfilment;
Provide payment attribution; and,
Provide technical and customer support.

Some external service providers may also collect information directly from you (for example, a payment processor may request your billing and financial information) in accordance with their own privacy policy. These external service providers do not share your financial information, like credit card number, with us, but may share limited information with us related to your purchase, like your zip code.

Aggregated Data. We may also aggregate or otherwise strip information of all personally identifying characteristics and may share that aggregated, anonymized data with third parties or publish it. This data does not personally identify you and helps us to measure the success of our Sites and its features and to improve your experience. We reserve the right to make use of any such aggregated data as we see fit.

Third Party Marketing and Advertising Organizations. With respect to website cookies, we share your information with third-party marketing and advertising partners to market our Services on our Sites and other websites that you may visit.

Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your personal information to comply with any legal obligation, to enforce or apply our terms and conditions and other agreements, to protect our rights, property, or safety, or to protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

4. How We Respond to ‘Do Not Track’ Signals

Some browsers provide you with a way to signal that you do not want your browsing activity to be tracked. The Services may not currently respond to all Do Not Track (“DNT”) or similar signals, as we are awaiting consensus from the Internet policy and legal community on the meaning of DNT and the best way to respond to these signals.

5. Cookies

To make our Sites and Services work properly, we sometimes place small data files called cookies on your device. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, shopping cart, or other preferences) over a period of time, so you do not have to keep re-entering them whenever you come back to the site or browse from one page to another.

Google Analytics. We may use Google Analytics. We use the information we get from Google Analytics only to improve the Sites. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Please refer to Google’s Privacy Policy for more information. You may also choose to download the Google Analytics opt-out browser add-on.

You may wish to restrict the use of cookies. Please be aware that some of the features of our Sites may not function correctly if you disable cookies. Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful:

Personalized Advertising. We may also use targeted advertising cookies, such as Google Ads, to deliver tailored advertising on our Sites and other websites that you may visit. You can learn more about how to control advertising cookies by visiting the Network Advertising Initiative’s Consumer Opt-Out link, the DAA’s Consumer Opt-Out link for browsers, or the DAA’s opt-out link for mobile devices. Please note that electing to opt-out will not stop advertising from appearing in your browser or applications and may make the ads you see less relevant to your interests.

6. Privacy Rights & Additional Disclosures for Certain U.S. Residents

Several jurisdictions grant state residents certain rights and disclosures. We provide the following information to further help you understand your potential privacy rights. If you would like to exercise any rights or inquire as to whether such rights are available to you, please email us at social@fazolis.com.

Request for Information or Deletion. Residents of certain U.S. states have the right to know whether we are processing your personal information, and in some instances, you have the right to request that we disclose to you the categories listed below for the preceding 12 months. We have the right to request verification of your identity for all requests for information. In responding to this right, we shall provide to you:

The categories of personal information we collect about you.
The categories of sources from which your personal information is collected.
The business or commercial purpose(s) for collecting, selling, sharing, or disclosing your personal information, and the categories of personal information disclosed for such purpose(s).
The categories of third parties with whom we share your personal information.
The categories of personal information we have sold, if any, about you and the categories of third parties to whom your personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
The specific pieces of personal information we have collected about you.

In addition, you may have the right to request we delete your personal information.

Request for Correction. Residents of certain U.S. states have the right to request the correction or rectification of inaccurate information in the resident’s personal information.

Request for Portable Data. Residents of certain U.S. states have the right to receive, in certain circumstances, a portable format of their personal information that allows the data to be transmitted to another entity.

Limiting the Use of Sensitive Personal Information. Residents of California have the right to direct us to use or disclose sensitive personal information only for providing goods or services, or as otherwise minimally permitted under applicable law. However, we do not use or disclose sensitive personal information for any purpose other than providing our goods and services to you, or as otherwise minimally permitted under applicable law.

Third Party Marketing. If you are one of our customers, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes. To make such a request, please contact us using the contact details provided in the “Contact Information” section below.

Automated Processing & Profiling. Residents of certain U.S. states have the right to opt out of the processing of personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.

Right to Equal Service & Price. You have the right to receive equal service and price, even if you exercise a privacy right.

Verification Process for Exercising Rights. To protect our consumers’ privacy, we verify privacy rights requests to ensure that only you (or your authorized agent) can exercise rights pertaining to your personal information. As part of our verification process, we may request you to submit additional information.

If you are an authorized agent wishing to exercise rights on behalf of a state resident, please contact us using the information at the bottom of this Privacy Policy and provide us with a copy of the consumer’s written authorization designating you as their agent. We may need to verify your identity and place of residence before completing your rights request.

Appeal Process. If we do not decide to act in response to your request to exercise a right, we will provide a timely response detailing the reasons for not taking the action and, depending on your jurisdiction, any rights that you may have to appeal our decision.

7. Children’s Privacy

The Sites are not directed at individuals under the age of 13. We do not knowingly collect personal information from children under 13. If you become aware that a child has provided us with personal information, please contact us using the contact details provided at the end of this Privacy Policy. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information.

8. Change of Control

Personal information may be transferred to a third party because of a sale, acquisition, merger, reorganization, or other change in control. If we sell, merge, or transfer any part of the business, part of the sale may include your personal information.

9. Data Security & Retention

We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information. However, no website, application, or transmission can guarantee security. Thus, while we have established and maintain what we believe to be appropriate technical and organizational measures to protect the confidentiality, security, and integrity of personal information obtained through the Services, we cannot ensure or warrant the security of any information you transmit to us.

We retain information from or about you for so long as necessary to fulfill the purposes outlined in this Privacy Policy. When the information is no longer necessary for these purposes, we delete it or keep it in a form that does not identify you, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

10. International Transfers

Any data that you provide to us may be accessed, shared, or processed by our offices, located in the United States, and service providers located in the United States, if such data transfer is necessary for the specific purpose for which you submitted your data (such as the provision of goods or services under a written contract). This may entail the transfer of your personal information across international borders. The data protection standards may differ and be lower than the standards enforced in your jurisdiction.

11. Policy Updates

This policy may be periodically updated. We encourage you to periodically review this Privacy Policy to ensure you are familiar with the most current version. Please review carefully before submitting personal information to our Services. The date the Privacy Policy was last updated is indicated at the top of this page.

12. Franchisee Information

If you are interested in becoming a franchisee, please visit the “Franchise” portion of our Site.

Information We Collect. Visitors may request franchise information by completing the request form accessed through the “Franchise” portion of our Site. The request form requires the name, address, email address, and phone number of interested parties, along with information relevant to franchise opportunities, such as net worth, available investment amount, and preferred location.

Site visitors desiring to apply for a Fazoli’s franchise may complete the franchise application located on the franchisee site. This application by necessity requires the submission of a considerable amount of personal information, including personal financial information, including without limitation: name, address, email, birthdate, Social Security Number, spouse’s name, birthdate and Social Security Number, financial asset descriptions and amounts, information regarding citizenship or resident alien status, employment history, criminal record, and information relative to credit history such as past or current bankruptcy or litigation.

Please note that if you apply for a restaurant position, you may be submitting your application information to a franchisee organization. Our franchisees may have their own data collection and use practices that are not governed by this Privacy Policy.

How We Use Your Information. The information you submit on the franchise application is provided under Secure Socket Layer (SSL) encryption. We may also collect information about you from third party public and private sources, including those that you consent to as part of the franchise application (namely, reference checks, credit reports, criminal and other investigative reports). As enhanced by these sources, the personal information you provide is used internally by Fazoli’s to assess your fitness to obtain a Fazoli’s franchise and to communicate with you throughout the process. In the process of acting upon an application, we may disclose to an employment or other reference provided by you or described in your employment history that you have made an application for a franchise. The information provided as part of the franchise application will not be sold or shared with third parties and will be held and protected as stated generally in this Privacy Policy for all personally identifiable information collected by us.

Should you desire to withdraw an application for a Fazoli’s franchise, amend your prior application, or have your personal information deleted from our systems, please contact us as noted below under “Contact Information,” and we will act upon your request as appropriate. Please note, however, that in certain circumstance we may still retain your information in our files in order to resolve disputes, enforce our Terms of Use, or due to technical and legal requirements involving our information systems and operations.

13. Notice of Financial Incentive

This Notice of Financial Incentive (“Notice”) applies to Fazoli’s System Management (“Fazoli’s,” “we,” “us,” “our”). Please read this Notice carefully to learn about the financial incentives we offer relating to the collection, use, retention, sale, or disclosure of your personal information, and to learn about your rights regarding our financial incentives for your personal information.

Incentives Offered

Fazoli’s offers programs, benefits, free products, discounts, and other incentives to consumers relating to the collection, use, retention, sale, or disclosure of your personal information (our “rewards program”). Examples of these programs include surveys, limited-time promotions, sweepstakes, rewards programs, discounts on products or services, and more.

Specifically, by agreeing to opt in to our rewards program, you will receive rewards points for every dollar spent on qualifying purchases at participating locations. Points may be accumulated and redeemed for purchases of eligible Fazoli’s products. Participants may also receive other periodic rewards, such as exclusive offers, personalized experiences, or content connected to their use of our rewards program.

Categories of Personal Information Involved

Our rewards program may involve the following categories of personal information from customers who participate:

Identifiers, such as real name, email address, phone number, birth date, or other similar identifiers.
Commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer’s interaction with a website, application, or advertisement.
Geolocation data.
Inferences drawn from the above categories of information.

Our rewards program does not involve the selling or sharing of personal information for targeted advertising.

We are providing you with this information so that you may make an informed decision on whether to participate in our programs.

Who Receives Your Personal Information

Personal information provided under the rewards program may be shared with the following third parties:

Analytics companies; and,
Third-party advertisers.

To provide you with the rewards program, we use the following rewards program partners to provide you with the benefits listed:

Punchh: Offer management, loyalty, and real-time capture of transactional data.

Our financial benefits programs reward you for being a valued customer who trusts us with your personal information. To access these programs, benefits, discounts, free products, and other incentives, you can opt in through your account profile. Learn more about our use of your personal information by reviewing our Privacy Policy above and by reviewing our rewards program terms here.

If you email us, please indicate your clear intent to opt in to these benefits programs. Alternatively, feel free to contact us with any questions regarding our financial benefits program.

How to Opt Out of Incentives

Opting in to get these benefits does not mean you are locked into them for life. If you change your mind, you can easily opt out. Participation in our promotional and benefits programs is always optional, and you can terminate program participation at any time by contacting us at social@fazolis.com.

Additional Disclosures

We respect your decision to opt in to our financial benefits program, and we strive to provide financial benefits worth your time and attention. While it is extremely difficult to assign a monetary value to the personal information that we collect, we believe that, based on our reasonable estimates, the value of your personal information is reasonably equal to or greater than the value we provide with our financial benefits program.

We arrived at this conclusion by analyzing market trends and similar financial benefits programs, and comparing these factors against our good-faith estimate of what we receive from your personal information.

14. Contact Information

If you wish to contact us or have any questions about or complaints in relation to this Privacy Policy, please contact us at the following contact details:

Email: social@fazolis.com

Mailing address: 2470 Palumbo Drive, Lexington, KY 40509