This Policy describes how information obtained from California consumers, including visitors to the www.carlsjr.com website and any other related websites controlled by Carl’s Jr. (“Website”), Carl’s Jr. mobile application (“Application”), and Carl’s Jr. company-owned and franchised-locations, where applicable (“Locations”) is collected, used, sold, and disclosed by Carl’s Jr. Restaurants LLC and its parents, subsidiaries, franchisees and affiliates, and their respective stockholders, directors, officers, employees, agents, successors and assigns (collectively, “Carl’s Jr.,” “we,” “us,” or “our”). This Policy also explains how you can make requests of Carl’s Jr. to know about your personal information, delete your personal information and opt-out of the sale of your personal information. Please note that this Policy applies to information collected by Carl’s Jr. and/or independently owned and operated franchised locations, where applicable, and supplements the information contained in Carl’s Jr.’s Privacy Policy, available here.
For ease of reference, you may click on any of the following links to jump to one of the sections addressed below:
California’s Shine the Light Law
California’s Consumer Privacy Act
1. California Residents’ Rights Under the California Consumer Privacy Act
2. Categories of California Consumers’ Personal Information Collected, Sold, or Disclosed
3. Methods for Submitting CCPA Requests to Carl’s Jr.
4. Verification Process
5. Authorized Agents
6. Response Timing and Format
7. Do Not Sell My Personal Information
8. Financial Incentive Offers
9. Metrics Regarding CCPA Requests and Responses During the Previous Calendar Year
10. Children Under the Age of 13
11. Contact Us for More Information
CALIFORNIA’S SHINE THE LIGHT LAW
o The sources of that Personal Information by category.
o The business or commercial purpose(s) for collecting or selling that Personal Information.
o The categories of third parties with whom we shared that Personal Information.
o The specific pieces of Personal Information collected about you.
o Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity.
o Debug to identify and repair errors that impair existing intended functionality of our systems.
o Exercise a legal right provided for by law, including exercising or ensuring free speech rights.
o Comply with the California Electronic Communications Privacy Act (California Penal Code sections 1546 to 1546.4).
o Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest if:
the research adheres to all other applicable ethics and privacy laws;
deleting the Personal Information is likely to make the research impossible or seriously impair it; and
you provided informed consent during the initial data collection.
o Enable our internal use in a manner that you would reasonably expect based on your relationship with us.
o Comply with our legal obligations.
o Otherwise use your Personal Information internally in a lawful manner that is compatible with the context in which you provided the information.
You may elect to opt-in to the sale of Personal Information after opting-out. In the event that a transaction requires the sale of your Personal Information as a condition of completing the transaction, we will inform you of this and provide instructions on how you can opt-in.
• The rights of California consumers who are less than 16 years of age
Carl’s Jr. does not intend to provide goods or services to, or collect information from, California consumers who are less than 16 years of age. We do not have any actual knowledge that we sell the personal information of consumers who we actually know are less than 16 years of age.
In particular, we have collected the types of Personal Information indicated in the chart below in the last twelve (12) months:
Category Examples Collected
Category |
Examples |
Collected |
|
Name, signature, address, telephone email, account name, Social Security number, driver’s license number, passport number, online identifier, IP address |
YES |
|
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. |
YES |
|
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). |
YES |
|
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|
YES |
|
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, face prints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. |
NO |
|
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement |
YES |
|
Physical location or movements |
YES |
|
Audio, electronic, visual, thermal, olfactory or similar information |
YES |
|
Current or past job history or performance evaluations |
YES |
|
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. |
NO |
|
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
YES |
We have obtained the Personal Information listed above from the following sources:
• Directly from you. For example, from your use of the Application, forms you complete on our Website or Application, online ordering, job applications or the purchase of products such as gift cards.
• Indirectly from you. For example, through your interaction on our Website, our Application or with our advertisers.
• Information from other sources. We may get information about you from other sources such as social media sites if you tag or direct message Carl’s Jr.
We may have collected, shared and/or sold the Personal Information described above for one or more of the following business or commercial purposes in the last twelve (12) months:
• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request ask a question about our products, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product such as a gift card, we will use that information to process your payment and facilitate delivery.
• To provide, support, personalize, and develop our Website, Application, products, and services.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website and Application experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website and./or Application, third-party sites, and via email or text message (with your consent, where required by law).
• To create and manage Customer Accounts and administer your participation in our programs, services and other offerings.
• To consider your application for employment.
• To prevent fraud or to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To protect the rights and interests of us and/or our independently owned and operated franchisees, such as to resolve any disputes, to enforce this Policy or any other policy, to protect the rights or property of others, or to prevent harm.
• To evaluate prospective franchisees of ours.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
• Personal Identifiers. Recipients of this information may include: Our affiliates (including Carl’s Jr. Restaurants LLC) and parent company and its and their respective franchisees, service providers, cloud platform providers, business partners and third parties.
• Personal information categories listed in the California Customer Records statute. Recipients of this information may include: Our affiliates (including Carl’s Jr. Restaurants LLC) and parent company and its and their respective franchisees, service providers, cloud platform providers, business partners and third parties.
• Protected classification characteristics under California or federal law. Recipients of this information may include: Our affiliates (including Carl’s Jr. Restaurants LLC) and parent company and its and their respective franchisees, service providers, cloud platform providers, business partners and third parties.
• Commercial information. Recipients of this information may include: Our affiliates (including Carl’s Jr. Restaurants LLC) and parent company and its and their respective franchisees, service providers, cloud platform providers, business partners and third parties.
• Internet or similar network activity. Recipients of this information may include: Our affiliates (including Carl’s Jr. Restaurants LLC) and parent company and its and their respective franchisees, service providers, cloud platform providers, business partners and third parties.
• Geolocation. Recipients of this information may include: Our affiliates (including Carl’s Jr. Restaurants LLC) and parent company and its and their respective franchisees, service providers, cloud platform providers, business partners and third parties.
• Sensory Data. Recipients of this information may include: Our affiliates (including Carl’s Jr. Restaurants LLC) and parent company and its and their respective franchisees, service providers, cloud platform providers, business partners and third parties.
• Professional or employment related information. Recipients of this information may include: Our affiliates (including Carl’s Jr. Restaurants LLC) and parent company and its and their respective franchisees, service providers, cloud platform providers, business partners and third parties.
• Inferences drawn from other information. Recipients of this information may include: Our affiliates (including Carl’s Jr. Restaurants LLC) and parent company and its and their respective franchisees, service providers, cloud platform providers, business partners and third parties.
We may have shared or sold the Personal Information listed above with the following categories of third parties in the last twelve (12) months:
• Our affiliates (including Carl’s Jr. Restaurants LLC) and parent company and its and their respective franchisees, service providers, cloud platform providers, business partners and third parties.
• Online Request Form. You may submit a request to know by completing the online CCPA Consumer Request to Know Form located on our privacy page here or a request to delete by completing the online CCPA Consumer Request to Delete Form located on our privacy page here.
• Toll-Free Telephone Call. You may submit requests by calling our toll-free CCPA Request Hotline at 1-800-227-5757. A member of our team will acknowledge your request and guide you through the verification process within ten (10) business days.
See the “Do Not Sell My Personal Information” section below for more on how to submit a request to opt-out of the sale of Personal Information.
• Your first and last name
• Your e-mail address
• Your telephone number
If you submit either a request to know specific pieces of Personal Information collected, or a request to delete sensitive, irreplaceable, or otherwise valuable Personal Information, you (or your authorized agent, if applicable) will be required to provide a signed declaration affirming your identity (or your authorized agent’s identity, if applicable). The declaration is included on the online CCPA Consumer Request to Know Form and online CCPA Consumer Request to Delete Form, both located here.
An authorized agent is either a natural person or a business entity registered with the California Secretary of State that a consumer has authorized to act on his or her behalf.
You may use an authorized agent to submit a request to know, to delete or to opt-out. You may make such a designation by providing the agent with written permission to act on your behalf. We will require the authorized agent to provide either (1) a power of attorney; or (2) proof of your signed permission. In addition to proof of your written permission, we may require you to verify your own identity and directly confirm that you provided the agent permission to submit the request.
We will confirm receipt of a request from you within ten (10) business days. This confirmation will provide information about how we will process the request, including a description of our verification process and an approximation of when we will send you a substantive response.
• Substantive Response
We will respond to a verifiable request from you within forty-five (45) calendar days. If we cannot respond in that time, we will notify you in writing that we need an additional forty-five (45) calendar days and explain the reason for the needed additional time.
If you have an account with us, we will respond to that account. If you do not have an account with us, we will deliver the written response by mail or e-mail, at your option.
Any disclosures we provide will cover only the 12-month period preceding our receipt of your verifiable request. If we cannot comply with your request, we will explain why. If you have requested to know specific Personal Information we collected (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 a 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 and provide you with a cost estimate before completing the request.
• Acting upon opt-out requests
We will act upon an opt-out as soon as commercially reasonable, but no later than fifteen (15) business days from the date we receive the request.
If you are a California consumer and wish to opt-out of the sale of your Personal Information, you may submit an opt-out request by clicking on the following link: https://privacy.ckr.com/. You may also submit an opt-out request via the other methods described above in Section 3, including the toll free telephone number or in-store form.
You have the right to receive equal service and price and not be discriminated against if you exercise any of your CCPA rights. However, from time to time we may offer certain financial incentives, as permitted by the CCPA that can result in different prices, rates, or quality levels of our products and/or services. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Summary of Financial Incentives Offered.
From time to time, Carl’s Jr. offers coupons, specials, and other discounts to consumers who have opted-in to receive marketing material from us by providing us with certain Personal Information. Consumers may also participate in our free loyalty/rewards program – the Carl’s Jr. My Rewards program (the “Program”). You will be enrolled in the Program only after you provide prior opt-in consent. Participation in the Program gives consumers the opportunity to accrue points to earn food items with qualifying purchases. The Program collects and retains members’ Personal Information in order to keep track of the points you have accrued and/or purchases you have made.
Material Terms of Financial Incentives.
When we offer a financial incentive or participation in our Program, the offer will include an explanation of the material terms of the incentive. The nature and value of any such offer or financial incentive may differ depending on what information we collect and use and whether you choose to enroll in the Program. Whether you consent to the financial incentive and/or to enroll in our Program and whether you choose to allow us to collect and use other types of Personal Information about you affects how we communicate with you and the types and frequency of offers that you may receive. Most financial incentives that we offer and the Program will involve one or more of the following categories of Personal Information:
Name, email address, zip code, password, birthday, order history, purchase history, and physical address.
How to Provide Opt-In Consent to Financial Incentive.
Participation in our financial incentive and Program requires your prior opt-in consent. You can opt-in to participate in the financial incentives or Program by checking the box agreeing to the Program’s Terms and Conditions and our Privacy Policy when you sign up for the Program or otherwise indicate your consent when you request information from us.
How to Revoke/Withdraw Consent to Financial Incentive.
You make revoke your consent to any financial incentive (or opt-out) at any time by emailing us at privacy@ckr.com.
Please note that if you are a California consumer and submit a CCPA-related deletion request, we will ask you to confirm that you want to terminate your Program membership (and My Rewards account). If you choose to retain your Program membership, Carl’s Jr. will continue to use your personal information to provide the Program and related services or as otherwise permitted by applicable law.
Value of California Consumers’ Personal Information.
We do not assign a monetary value to the Personal Information that we collect and strive to only use that information to further our business in accordance with this Policy. To the extent that we are required to assign a monetary value to your Personal Information, it is equal to the value of the discount or financial incentive that we have provided to you.
California residents over 13 but under 16 years of age may have additional rights regarding the collection and sale of their Personal Information. Please see “The rights of California consumers who are less than 16 years of age” section above for more information.
• Toll-free call: 1-800-227-5757
• Email: privacy@ckr.com
When contacting our customer service, please include in the communication or have available the information listed under the “Verification Process” section above. If using an authorized agent, please include in the communication or have available proof of authorization.