Privacy Policy

PRIVACY POLICY

Last Revised: December 30, 2019

Split Bread, Inc. (“Company”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe our practices regarding the information we collect from users of our website, located at www.spliteats.com , our other online services, including, but not limited to online ordering, location finder, rewards program, and any application (“App”) provided by or on behalf of the Company, and visitors to our restaurants (“Services”).

A Note About Children. We do not intentionally gather personal information from visitors who are under the age of 13. If a child under 13 submits personal information to the Company and we learn that such personal information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any personal information from a child under 13, please contact us at feedback@spliteats.com.

A Note to Users Outside of the United States. If you are a non-United States user of the Site, by using the Services and providing us with data or information about you, you acknowledge and agree that your information may be utilized and / or shared for the purposes identified in the Privacy Policy. In addition, your information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of information may be less stringent than the laws in your country. By providing your information, you consent to such transfer.

1. How We Collect Your Information. We collect information about you in a variety of different manners including when you:

• provide information to us in connection with a purchase, whether online, through our app, or in one of our restaurants;
• visit one of our restaurants where we have security cameras;
• sign up for our loyalty or rewards program;
• give feedback or contact us via e-mail or telephone;
• access free wireless internet in one of our restaurants;
• interact with our websites, mobile or other apps, social media sites, and other products and services; and / or
• interact with us on social media sites, including, but not limited to Facebook, Instagram, or Twitter.

We also collect information from other sources including from credit card issuers, our payment processor, our loyalty program provider, and delivery services that you utilize to order from our restaurants and which may include, but are not limited to UberEats, Caviar, and DoorDash.

We collect information via technology as well, including:

• Information Collected by Our Servers. To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
• Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Site, track users’ movements around the Site, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Site or the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Data.
• Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.
• Google Analytics. We use Google Analytics to help analyze how users use the Site. Google Analytics uses Cookies to collect information such as how often users visit the Site, what pages they visit, and what other sites they used prior to coming to the Site. We use the information we get from Google Analytics only to improve our Site and Services. Google Analytics collects only the IP address assigned to you on the date you visit the Site, rather than your name or other personally identifying information. We do not combine the information generated through the use of Google Analytics with your Personal Data. Although Google Analytics plants a persistent Cookie on your web browser to identify you as a unique user the next time you visit the Site, the Cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

2. Types of Information We Collect. We may collect the following categories of information from you (all of this information is called “Personal Data”):

• Contact information, such as your first and last name, e-mail address, mailing addresses, delivery address, phone number, and location.
• Payment information, such as credit card number and other payment details.
• Order information, including refund, and reward and / or coupon history.
• Device and browser information including location information, IP addresses, cookies, mobile device ID, and other online identifiers.
• Demographic information such as age and gender.

3. Our Use of Your Information.

In general, Personal Data you submit to us is used either to complete a business transaction with you, respond to requests that you make, or aid us in serving you better. We use your Personal Data in the following ways:

• Administer your Account;
• Fulfill your orders, including by communicating them to our local stores;
• Provide you with Services and customer support;
• Tailor the features of the Site or Services to you;
• Respond to your requests, resolve disputes and/or troubleshoot problems;
• Verify your compliance with your obligations in our terms of use and/or other agreements you may have executed with us; and
• Communicate with you about the Site and the Services.

We may create “Anonymous Data” records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you, this is sometime called de-identifying the Personal Data. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.

3. Disclosure of Your Personal Data. We do not sell your Personal Data. We do disclose your Personal Data as described below and as described elsewhere in this Privacy Policy for business purposes. The categories of Personal Data disclosed for business purposes include all of the categories of Personal Data you provide to us (as described above).

We disclose or share your Personal Data with the following categories of third parties:

• Third Parties Designated by You. When you use the Services, the Personal Data you provide will be shared with the third parties that you authorize to receive such information.
• Third Party Service Providers. We may share your Personal Data with our third party service providers that help us provide Services that we offer you through our Site and/or Services.
• Affiliates. We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.
• Corporate Restructuring. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
• Social Networking Sites. Some of our Services may enable you to post content to social networking sites (“SNSs”) (e.g., Facebook, Instagram, or Twitter). If you choose to do this, we will provide information to such SNSs in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policy of the third party provider of such SNSs. We will not be responsible or liable for: (i) the availability or accuracy of such SNSs; (ii) the content, products or services on or availability of such SNSs; or (iii) your use of any such SNSs.
• Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), Company may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Company; (c) to protect or defend the rights or property of Company or users of the Site or Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our terms of use.

4. Third Party Websites. Our Site may contain links to third party websites. When you click on a link to any other website or location, you will leave our Site and go to another site and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.
5. Your Choices Regarding Your Information.You have several choices regarding use of information on our Services:

• Email Communications. When you create an Account and provide your email address, we will periodically send you administrative e-mails, free newsletters, and e-mails that directly promote the use of our Site or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our terms of use or Privacy Policy. If you wish to opt out of administrative emails, you must delete your account entirely and cease use of the Service.
• If you decide at any time that you no longer wish to accept cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser’s technical information. If you do not accept cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify cookies, please let us know at the contact information provided below.
• Changing or Deleting Your Personal Data. You may review, update, correct or delete the Personal Information in your Account by contacting us. If you completely delete all of your Personal Information, then your account may become deactivated. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes. Please remember, however, if we have already disclosed some of your Personal Data to third parties, we cannot access that Personal Data any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.
• DO-NOT-TRACK DISCLOSURE. The Site does not track your use of the Site over time and across third party websites to provide targeted advertising and therefore does not respond to Do-Not-Track (“DNT”) signals. However, some third party websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such websites, your browser may allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.
• California Privacy Rights. The California Consumer Privacy Act (CCPA) allows California residents, upon a verifiable consumer request, to request that a business that collects consumers’ personal information give California Residents access, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of personal information that the business has collected about such California Resident, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared, subject to a number of exceptions. California residents also have the right to submit a request for deletion of information under certain circumstances. Consistent with California law, if you choose to exercise your rights, we won’t charge you different prices or provide different quality of services unless those differences are related to your information.

As discussed herein, we do not sell Personal Data, but we do disclose Personal Data for business purposes. As such, verifiable individuals who have provided us with or about whom we have been provided Personal Data have the right to request:

• The categories of personal information collected from or about you; and the categories of personal information disclosed about you for a business purpose.
• That we delete the Personal Data it has collected from you, subject to certain legal exceptions, for example, when the personal information is needed to complete a transaction or comply with a legal obligation.

A California resident also has the right to be protected from discrimination for exercising your CCPA rights. Businesses are not permitted to discriminate against you for exercising your rights under the CCPA, including by: (A) denying you goods or services; (B) charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (C) providing you with a different level or quality of goods or services; or (D) suggesting that you will receive a different price, rate, level, or quality of goods or services. Nothing prohibits a business from charging a different price or providing a different level or quality of service if the difference is reasonably related to the value provided to the consumer by the consumer’s data.

For additional information on your rights as a California resident, or to submit a request for personal information under the CCPA, please write to us at the following address:

Split California Privacy Rights
99 Osgood Place, Suite 300
San Francisco, CA 94133

Or call our toll free number: 1-877-930-1619

6. Security of Your Personal Data. We are committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account information. Please do not disclose your Account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while Company uses reasonable efforts to protect your Personal Data, Company cannot guarantee its absolute security.
7. Changes to This Privacy Policy. This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy at http://www.spliteats.com/privacy-policy and we will change the “Last Revised” date above. You should consult this Privacy Policy regularly for any changes.