Last Updated: June 3, 2020
1. Types of Information That May Be Collected
Certain Services may ask you to register an account with us, or otherwise provide information some or all of which may be considered personal information, to us or one of our service providers. We may ask you for some or all of the following types of information via the Sites, sign up for email subscriptions, sign up for or participate in Redemptions, participate in surveys, access various content or features, submit comments or content, or directly contact us with questions or feedback:
- Identifiers and other personal information such as your name, date of birth, billing address, shipping address, email address, telephone number, account number, password, mobile device identification numbers, Internet Protocol address (from which we can derive your general geographic area), and payment card information (solely for fulfillment of any purchases);
- Internet or other electronic network activity, such as information concerning your interaction with the Sites and their content and the devices you use to interact with the Sites, browsing history, and information regarding your interaction with an Internet Web site, application or advertisement;
- Information for Redemptions, including serial numbers, identifies, balances, points, rewards, to sell, issue, redeem, or process other transactions in connection with such Redemptions;
- Demographic information, such as gender;
Other information, such as computer network activity and device identifiers described above may be collected through automated means. Automatic collection of information further may include:
- Your browser type and operating system;
- Sites you visited before and after visiting the Services;
- Pages you view and links you click on within the Services and related websites or apps which are also owned and operated by us, our affiliates, or our business partners, including articles, videos, and photo galleries viewed;
- Information collected through cookies, pixel tags, Local Shared Objects (as defined below), and other similar technologies;
- Information about your interactions with e-mail messages, such as the links clicked on and whether the messages were received, opened, or forwarded; and
- Standard Server Log Information (as defined below).
2. Use of Information
We may use information that we collect through the Services for a variety of purposes, including to:
- Create your account;
- Provide you with the products, promotions, services, newsletters, and information you request and respond to correspondence that we receive from you;
- Manage your contact preferences and requests, including requests concerning how we use your information;
- Conduct and process transactions in connection with the Redemptions;
- Contact you via email and otherwise about your account, products, services, contests, and events that we think might be of interest to you;
- Send you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and subsidiaries and other third parties;
- Provide, maintain, administer or expand the Services, perform business analyses, or for other internal purposes to improve the quality of our business, the Services, and other products and services we offer;
- Customize and personalize your use of the Services;
- Send you notices to comply with applicable laws and regulations;
- As otherwise described to you at the point of collection or pursuant to your consent, or otherwise in the Terms of Service.
We may use your non-personal information (including personal information that has been de-identified and/or aggregated) for any reason at our sole discretion.
3. Sharing of Information
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.
- Service Providers: We may share your information with service providers that perform certain functions or services on our behalf (such as to host the Services, fulfill orders, provide products and services, manage databases, perform analyses, process credit card payments, process Redemptions, provide customer service, develop our Sites, or send communications for us).
- Licensees and Their Subsidiaries and Affiliates: We may share your information with our owners and licensees or any of our/their affiliates.
- Select Business Partners: With your permission, we may share your personal information with select business partners so that they can provide you with special offers, promotional materials, and other materials that may be of interest to you. If you do not elect to have your personal information shared, it will not be shared with such third parties. We take measures to help ensure that our partners protect the confidentiality, integrity, and security of any information we share with them. However, we are not responsible for the privacy practices of our business partners, including any Third-Party Terms on our Sites.
- Third-Party Ad Serving and Audience and Traffic Measurement Services: We may use third-parties to serve advertisements on the Services. These third parties may set their own cookies or similar web technologies to collect information about users’ online activities over time and across different websites and/or apps. You may opt out by sending an email to email@example.com.
- Social Media Engagement and Advertising: We may share information derived from your personal information with social media services (e.g., Facebook, Twitter) to engage with you on accounts you may have on those services or provide targeted advertising to your account.
- Business Transfer: If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the unlikely event of bankruptcy, a business reorganization, or similar event, we may transfer your information as part of such transaction.
- Interactive Features: We may share information with third parties when you post information to a user profile or a public area of the Services, such as a chat room, forum, blog, or other community tool. If you post to these interactive features, it will be publicly available, and you may receive unsolicited messages from other parties. We cannot ensure that parties who have access to such information will respect your privacy. Please exercise caution when using these features.
- Non-personal Information: We may share non-personal information (including personal information that has been de-identified and/or aggregated), such as demographic and usage statistics, with advertisers, sponsors or other third parties for any reason at our sole discretion.
We may also allow third parties to place and read their own cookies, pixel tags, Local Shared Objects, and similar technologies to collect information through the Services. For example, our third-party service providers may use these technologies to collect information that helps us with traffic measurement, research, and analytics.
4. Social Networking Services
We may work with certain third-party social media providers to offer you their social networking services through our Services. For example, you may be allowed to use third-party social networking services, including but not limited to Facebook, Twitter, and others to share information about your experience on our Services with your friends and followers on those social networking services. These social networking services may be able to collect information about you, including your activity on our Services. These third-party social networking services also may notify your friends, both on our Services and on the social networking services themselves, that you are a user of our Services or about your use of our Services in accordance with applicable law and their own privacy policies. If you choose to access or make use of third-party social networking services, we may receive information about you that you have made available to those social networking services, including information about your contacts on those social networking services.
5. Links to Other Sites
We have adopted reasonable and appropriate security procedures to help protect against loss, misuse, and unauthorized access to the information you provide to us. Please note, however, that no data transmission or storage can be guaranteed to be 100% secure. As a result, while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to the Services and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information.
7. Age Restrictions
Access to the Services is limited to residents of the U.S. age of 13 or over, and certain parts of the Sites, such as our “Email Club” are limited to U.S. residents age 18 and over. We do not knowingly collect, use, or disclose personal information from persons under the age of 13. If we are made aware we have collected personal information from a child under 13 years old in a manner that is inconsistent with the Children’s Online Privacy Protection Act, we will delete this information as soon as possible. We do not knowingly share or sell personal information from persons 13 years old or younger.
You may receive promotional emails, newsletters, and similar communications from us or one of our service providers. You may opt out of receiving commercial emails from us by clicking on the opt-out or “unsubscribe” link included in the commercial emails you receive or, if such functionality is enabled in the Services, by notifying us at firstname.lastname@example.org or by calling 888-622-4745. Please note that opt-out requests may take some time to be effective. Your opt-out will not apply to messages that you specifically request or messages that are not commercial in nature. For example, we may contact you concerning any purchases you have made with us or communicate with you regarding a contest you have entered, even if you opt out of receiving unsolicited commercial email messages.
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
10. California Privacy Rights
Attention: General Counsel
Romano’s Macaroni Grill/Sullivan’s Steakhouse
1855 Blake Street, Suite 200
Denver, CO 80202
In some cases, third parties may be able to collect information about a user’s online activities over time and across different websites or apps when he or she uses our Services.
Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, we currently do not take action in response to these signals.
The California Consumer Privacy Act (“CCPA”) provides California residents with specific rights regarding their personal information. This section describes California residents’ CCPA rights and explains how to exercise those rights. If you are a resident of a state other than California, we may respond to requests in ways that differ from responses that are required only under California law.
- Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your request, we will disclose to you:
(a) The categories of personal information we collected about you.
(b) The categories of sources for the personal information we collected about you.
(c) Our business or commercial purpose for collecting or selling that personal information.
(d) The categories of third parties with whom we share that personal information.
(e) The specific pieces of personal information we collected about you.
(d) If we sold or disclosed for a business purpose, two separate lists disclosing: (1) for sales, a list identifying the personal information categories; and (2) for disclosures for a business purpose, a list identifying the personal information categories.
- Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. If an exception applies, we will notify you of the applicable exception.
- Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to email@example.com or by calling 888-622-4745. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a consumer request related to your personal information. You may also make a consumer request on behalf of your minor child.
We will require sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Our processes for verifying requests include matching identifying information that we already have on record to provide services to the customers. We may request additional information from you to complete verification.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
- Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing. To the extent applicable, we will deliver our written response by the same means by which you made the request. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
- Selling of Information
We do not sell your personal information.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
(a) Deny you goods or services.
(b) Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
(c) Provide you a different level or quality of goods or services.
(d) Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
11. Nonconfidential Information
We do not want you to send to us any confidential or proprietary information through email or otherwise. Any information, materials, suggestions, ideas or comments sent to us will be considered non-confidential, and by submitting the same to us, you are giving us the absolute right to use, modify, reproduce, transmit, display and distribute the information for any purpose whatsoever, with no payment or other compensation to you. However, we will not use your name unless we are required by law to identify the source of the materials, information, suggestions, ideas or comments, or unless we first obtain your permission.
12. Contact Us
Attention: General Counsel
Romano’s Macaroni Grill/Sullivan’s Steakhouse
1855 Blake Street, Suite 200
Denver, CO 80202