Privacy Policy
Last Updated: June 18, 2025
GoTo Foods LLC values your privacy. In this Privacy Policy, we describe how we collect, use, and otherwise process the personal information we obtain about people who use our website and the services we make available through our website, who apply to become franchisees of our brands, or who otherwise interact with us online or offline (our “Services”). By downloading, using or registering for our Services, or by otherwise providing your personal information to us, you are agreeing to this Privacy Policy and our Terms and Conditions.
This Privacy Policy does not describe the privacy practices of any independently owned or operated franchises of our brand, or any other third party. Nor does it apply to personal information collected about our employees or job applicants.
GoTo Foods is affiliated with several brands. The terms “we,” “our,” and “us” in this Privacy Policy refer to GoTo Foods LLC, as the controller of personal information, together with our family of brands. Additional information about how our brands use and protect your personal information can be found in each brand’s privacy policy:
- Auntie Anne’s®: www.auntieannes.com/privacy
- Carvel®: www.carvel.com/privacy
- Cinnabon®: www.cinnabon.com/privacy
- Jamba®: www.jamba.com/privacy
- Moe’s®: www.moes.com/privacy
- McAlister’s Deli®: www.mcalistersdeli.com/privacy
- Schlotzsky’s®: www.schlotzskys.com/privacy
California residents, please click here for our Notice at Collection under the California Consumer Privacy Act.
PERSONAL INFORMATION WE COLLECT ABOUT YOU
In this Privacy Policy, “personal information” (a/k/a “personal data“) means any information that GoTo Foods processes that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular person or household. Generally, we collect the following categories of personal information, which we use for the business or commercial purposes shown. The personal information we collect about you may vary depending on the nature of your relationship and interactions with us.
CATEGORY OF PERSONAL INFORMATION | CATEGORIES OF SOURCES | PURPOSES FOR COLLECTION |
---|---|---|
Identifiers and personal records, including name, alias, postal address, telephone number, signature, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, physical characteristics or description, social security number, driver’s license number, passport number, or other similar identifiers, insurance policy number, education, employment, employment history, bank account information, credit or debit card number, or other financial information. This category includes information described in Cal. Civ. Code § 1798.80(e) | Directly from you Through technologies in use on our Services Internet service providers Data analytics providers Vendors that provide services on our behalf Our affiliated brands and companies Our brands’ franchisees Data brokers
| To provide operational support for our brands, affiliated companies, and our brands’ franchisees To perform analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of GoTo Foods, our brands, affiliated companies, and our brands’ franchisees Communicating with you Marketing and advertising To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes To help maintain the safety, security, and integrity of our Services, databases and other technology assets, as well as your account, orders, and deliveries Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity Tailoring our content or otherwise personalizing the Services As part of our application process for prospective franchisees of our brands |
Internet or other electronic network activity information, including browsing history, search history, and information regarding interactions with our websites, applications, or advertisements. Geolocation data inferred from IP address | Directly from you Through technologies in use on our services Internet service providers Data analytics providers Vendors that provide services on our behalf Our affiliated brands and companies | To provide operational support for our brands, affiliated companies, and our brands’ franchisees To perform analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of GoTo Foods, our brands, affiliated companies, and our brands’ franchisees To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes To help maintain the safety, security, and integrity of our Services, databases and other technology assets, as well as your account, orders, and deliveries Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity Marketing and advertising Tailoring our content or otherwise personalizing the Services Customer service |
Audiovisual Information | Directly from you Through technologies in use on our Services. For example, if you interact with us by phone or video Our affiliated brands and companies Our brands’ franchisees | To provide operational support for our brands, affiliated companies, and our brands’ franchisees Customer service To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes To help maintain the safety, security, and integrity of our Services, databases and other technology assets, as well as your account, orders, and deliveries Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity As part of our application process for prospective franchisees of our brands |
Professional or employment-related information | Directly from you Data analytics providers | As part of our application process for prospective franchisees of our brands Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity |
Characteristics of protected classifications, including gender, age, and date of birth | Directly from you Our affiliated brands and companies Data analytics providers Data brokers
| To provide operational support for our brands, affiliated companies, and our brands’ franchisees To perform analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of GoTo Foods, our brands, affiliated companies, and our brands’ franchisees |
Inferences reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, aptitudes | Inferred from other categories of personal information we collect Data analytics providers Our affiliated brands and companies
| To perform analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of GoTo Foods, our brands, affiliated companies, and our brands’ franchisees To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes Tailoring our content or otherwise personalizing the Services Marketing and advertising As part of our application process for prospective franchisees of our brands Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity |
Personal information that reveals a Social Security, driver’s license, state identification card, or passport number | Directly from our brands’ franchisees and prospective franchisees Our affiliated brands and companies
| As part of our application process for prospective franchisees of our brands |
Precise Geolocation data, | Our affiliated brands and companies | To provide operational support for our brands, affiliated companies, and our brands’ franchisees To perform analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of GoTo Foods, our brands, affiliated companies, and our brands’ franchisees Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity |
In addition to the purposes described above, we may use and disclose any category of personal information we collect to comply with law, cooperate with and respond to law enforcement requests, or as otherwise required by applicable law, court order, or governmental regulations; to maintain appropriate records for internal administrative purposes; to protect our rights and interest and those of our franchisees, to resolve any disputes, to enforce this Policy or any of our other policies, to protect the rights or property of another, or to prevent harm; and to evaluate or conduct a merger, sale, or other acquisition of some or all of our organization or its assets.
Additional Information for Our Brands’ Franchisees
GoTo Foods collects and otherwise processes personal information about our brands’ franchisees in support of our individual brands. If you submit your personal information to request more information from our brands about franchise opportunities, we may use that information to contact you to discuss our brands’ franchise opportunities. We may ask that you complete our brands’ 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 brands’ franchise application to our 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 brand’s 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 share it, as necessary, with our brands and vendors during the franchise application process.
COOKIES AND OTHER TRACKING TECHNOLOGIES
We, and the vendors we work with, may also collect other information about your use of our Services using automated tools such as cookies, pixels and software development kits. These tools enable us to compile statistics about the use of our Services, analyze trends, enhance the security of our Services, deliver content and advertisements, and otherwise administer and improve our Services. The information collected through tracking technologies may include your browser type, language preference, operating system, device identifier, device type, access time, Internet Protocol (IP) address, the URLs of websites you visited before and after visiting our websites, the web searches that landed you on our websites, the length of your visits to our websites, and the links you click and pages you visit within our websites. You can set your browser not to accept cookies, or to notify you when you are sent a cookie, giving you the opportunity to decide whether or not to accept it. However, please note that if you disable the use of cookies on your computer, some functionality of our website will not work.
Analytics. We may use certain third-party web analytics services to help us understand and analyze how visitors use our Services and to serve advertisements on our behalf across the Internet. We may use cookies and other identifiers to deliver advertisements, measure your interests, personalize content, and detect your demographics, location, or device. We have implemented Google Analytics Advertising features such as dynamic remarketing, interest-based advertising, audience targeting, behavioral reporting, demographics and interests reporting, user segment analysis, device reporting, display advertising, and video ads reporting. For more information on how Google Analytics uses data, visit www.google.com/policies/privacy/partners/. To opt out of Google Analytics and advertising cookies, visit myadcenter.google.com and tools.google.com/dlpage/gaoptout/.
Online Advertising. We and the third parties we contract with may use tracking technologies to gather interest-based information to customize the ads you see. This information may include data collected while you are on our website and data from other sources. One of the tools we use for this purpose is Google Ads, which is an advertising service provided by Google. Google uses cookies and other identifiers, in combination with its own data, to show you ads based on your usage of our websites. You can personalize the ads you receive or opt out of ads from Google by visiting the Google Ads Settings page. Additional options for opting out of interest-based advertising can be found here and here.
Do Not Track Signals. 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.
OUR RETENTION OF 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 reasonable 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.
HOW WE DISCLOSE YOUR INFORMATION
We may disclose your personal information within our company, and to our affiliates (including our brands), our brands’ franchisees, our business partners, and our vendors.
Disclosures for Business or Commercial Purposes. The following chart describes how we disclose personal information to our affiliated brands and companies, our brands’ franchisees, and service providers for business or commercial purposes.
CATEGORY OF PERSONAL INFORMATION | PURPOSES FOR DISCLOSURE |
---|---|
Identifiers Personal Records Commercial information | Providing operational support for our brands, affiliated companies, and our brands’ franchisees Providing analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for our brands, affiliated companies, and our brands’ franchisees Services performed on our behalf (e.g., providing communications, technical, analytical, web hosting, cloud hosting, and other services on our behalf) Advertising and marketing services (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising Auditing related to ad impressions Ensuring security and integrity of personal information Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity As part of our application process for prospective franchisees of our brands |
Internet or other electronic network activity information Geolocation data | Providing operational support for our brands, affiliated companies, and our brands’ franchisees Providing analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for our brands, affiliated companies, and our brands’ franchisees Services performed on our behalf (e.g., providing communications, technical, analytical, web hosting, cloud hosting, and other services on our behalf) Advertising and marketing services (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising Auditing related to ad impressions Ensuring security and integrity of personal information Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity |
Audiovisual information | Providing operational support for our brands, affiliated companies, and our brands’ franchisees Services performed on our behalf (e.g., providing communications, technical, analytical, web hosting, cloud hosting, and other services on our behalf) Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity |
Professional or employment-related information | Providing operational support for our brands, affiliated companies, and our brands’ franchisees Services performed on our behalf (e.g., providing communications, cloud hosting, and other support for our brands’ franchise relationships) Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity As part of our application process for prospective franchisees of our brands |
Characteristics of protected classifications | Providing operational support for our brands, affiliated companies, and our brands’ franchisees Providing analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for our brands, affiliated companies, and our brands’ franchisees Services performed on our behalf (e.g., providing communications, technical, analytical, web hosting, cloud hosting, and other services on our behalf) Advertising and marketing services (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity |
Inferences | Providing operational support for our brands, affiliated companies, and our brands’ franchisees Providing analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for our brands, affiliated companies, and our brands’ franchisees Services performed on our behalf (e.g., providing communications, technical, analytical, web hosting, cloud hosting, and other services on our behalf) Advertising and marketing services (except for cross-context behavioral advertising) Auditing related to ad impressions Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity As part of our application process for prospective franchisees of our brands |
Personal information that reveals a Social Security, driver’s license, state identification card, or passport number | Services performed on our behalf (e.g., providing communications, cloud hosting, and other support related to our brands’ franchise relationships) Ensuring security and integrity of personal information Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity As part of our application process for prospective franchisees of our brands |
Precise geolocation data | Services performed on our behalf, and on behalf of our brands and affiliated companies (e.g., fulfilling and delivering orders, processing payments, supporting promotions, contests, gift cards, loyalty programs and sweepstakes, and providing communications, technical, analytical, web hosting, cloud hosting and mobile application support) Providing advertising and marketing services (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising Auditing related to ad impressions Ensuring security and integrity of personal information Debugging to identify and repair errors that impair existing intended functionality |
Targeted Advertising, Sales, and Sharing of Personal Information. GoTo Foods does not directly sell personal information or directly engage in targeted / cross-context behavioral advertising. For more information on the advertising practices used by our brands and their sales and sharing of personal information, please see the brands’ privacy policies, which are linked at the top of this page. If you are a resident of a covered U.S. state, more information on your opt-out rights can be found below.
Other Disclosures of Personal Information. 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.
UPDATING YOUR INFORMATION
If you wish to update your personal information, please contact us using the contact information provided below. If you would like to update your information with one of our brands, you may do so by logging in to your account with the appropriate brand, following the instructions in the relevant brand’s privacy policy (linked at the beginning of this Privacy Policy), or by contacting the relevant brand through the Contact Us page on each brand’s website.
LINKS TO OTHER WEBSITES
Our Services include links to websites operated by our service providers that are designed to provide specific features or content (for example, sites supporting online orders or gift card purchases), and may also include links to third-party websites. When you click a link on our site that includes an external link symbol, you are leaving our site and navigating to a site operated by another company. Third-party websites have their own privacy policies that you should review to understand how they may collect, use, or disclose your personal information. We are not responsible for the content or privacy practices of any linked websites that are not under our control. Our brand gift cards are sold online by CashStar, a Blackhawk Network business (“CashStar“). For CashStar’s Privacy Policy, please click here. If you would like to adjust your cookie settings on the gift card sales website, please use the controls provided by CashStar on that site. To submit a privacy rights request to CashStar, please click here.
SECURITY OF YOUR PERSONAL INFORMATION
At no cost to you, 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.
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 your personal information, you may do so by logging in to your account with the appropriate brand, following the instructions in the relevant brand’s privacy policy (linked at the beginning of this Privacy Policy), or by contacting the relevant brand through the Contact Us page on each brand’s website.
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 OUR BRANDS’ FRANCHISEES
GoTo Foods collects and otherwise processes personal information about our brands’ franchisees in support of our individual brands, who each remain the controller of information submitted throughout the brands’ franchising process. If you submit your personal information to request more information from our brands about franchise opportunities, we may use that information to contact you to discuss our brands’ franchise opportunities. We may ask that you complete our brands’ 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 brands’ franchise application with our 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 brand’s 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 share it, as necessary, with our brands and vendors during the franchise application process.
Supplemental Notice For Residents of Covered States
As a supplement to the other information provided throughout this Privacy Policy, we provide the following additional information as a notice to consumers in California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah and Virginia, as well as California business contacts. Information for consumers who interact with our brands is found within our brands’ Privacy Policies, which are linked at the top of this Policy. If you work for us, please see our California Employee Privacy Notice for additional disclosures. California job applicants can find additional disclosures in our California Applicant Privacy Notice.
How and Why We Collect Personal Information. GoTo Foods may, and in the previous twelve (12) months, has collected and used the following categories of personal information:
CATEGORY OF PERSONAL INFORMATION | CATEGORIES OF SOURCES | PURPOSES FOR COLLECTION |
---|---|---|
Identifiers, including name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers | Directly from you Automatically when you use our Services Internet service providers Data analytics providers Vendors that provide services on our behalf Our affiliated brands and companies Our brands’ franchisees Data brokers
| To provide operational support for our brands, affiliated companies, and our brands’ franchisees To perform analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of GoTo Foods, our brands, affiliated companies, and our brands’ franchisees Communicating with you Marketing and advertising To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes To help maintain the safety, security, and integrity of our Services, databases and other technology assets, as well as your account, orders, and deliveries Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity Tailoring our content or otherwise personalizing the Services As part of our application process for prospective franchisees of our brands |
Personal records, including name, signature, 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 or debit card number, other financial information (including gift cards) This category includes information described in Cal. Civ. Code § 1798.80(e). | Directly from you Automatically when you use our Services Internet service providers Data analytics providers Vendors that provide services on our behalf Our affiliated brands and companies Our brands’ franchisees Data brokers
| To provide operational support for our brands, affiliated companies, and our brands’ franchisees To perform analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of GoTo Foods, our brands, affiliated companies, and our brands’ franchisees Communicating with you Marketing and advertising To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes To help maintain the safety, security, and integrity of our Services, databases and other technology assets, as well as your account, orders, and deliveries Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity Tailoring our content or otherwise personalizing the Services As part of our application process for prospective franchisees of our brands |
Characteristics of protected classifications, including gender, age, and date of birth | Our affiliated brands and companies Data brokers
| To provide operational support for our brands, affiliated companies, and our brands’ franchisees To perform analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of GoTo Foods, our brands, affiliated companies, and our brands’ franchisees |
Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies | Directly from you Automatically when you use our Services Internet service providers Data analytics providers Vendors that provide services on our behalf Our affiliated brands and companies Our brands’ franchisees Data brokers
| To provide operational support for our brands, affiliated companies, and our brands’ franchisees To perform analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of GoTo Foods, our brands, affiliated companies, and our brands’ franchisees Communicating with you Customer service Marketing and advertising Tailoring our content or otherwise personalizing the Services As part of our application process for prospective franchisees of our brands Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity |
Internet or other electronic network activity information, including browsing history, search history, and information regarding interactions with websites, applications, or advertisements | Directly from you Automatically when you use our Services Internet service providers Data analytics providers Vendors that provide services on our behalf Our affiliated brands and companies Our brands’ franchisees
| To provide operational support for our brands, affiliated companies, and our brands’ franchisees To perform analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of GoTo Foods, our brands, affiliated companies, and our brands’ franchisees To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes To help maintain the safety, security, and integrity of our Services, databases and other technology assets, as well as your account, orders, and deliveries Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity Marketing and advertising Tailoring our content or otherwise personalizing the Services Customer service |
Geolocation data, including location inferred from IP address | Automatically when you use our Services Internet service providers Data analytics providers Vendors that provide services on our behalf Our affiliated brands and companies | To provide operational support for our brands, affiliated companies, and our brands’ franchisees To perform analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of GoTo Foods, our brands, affiliated companies, and our brands’ franchisees Marketing and advertising To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes To help maintain the safety, security, and integrity of our Services, databases and other technology assets, as well as your account, orders, and deliveries Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity Tailoring our content or otherwise personalizing the Services |
Audio, electronic, visual, thermal, olfactory, or similar information | Directly from you Automatically when you use our Services. For example, if you interact with us by phone or video Our affiliated brands and companies Our brands’ franchisees | To provide operational support for our brands, affiliated companies, and our brands’ franchisees Customer service To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes To help maintain the safety, security, and integrity of our Services, databases and other technology assets, as well as your account, orders, and deliveries Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity As part of our application process for prospective franchisees of our brands |
Professional or employment-related information | Directly from you | As part of our application process for prospective franchisees of our brands Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity |
Inferences reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, aptitudes | Inferred from other categories of personal information we collect Data analytics providers Our affiliated brands and companies
| To perform analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of GoTo Foods, our brands, affiliated companies, and our brands’ franchisees To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes Tailoring our content or otherwise personalizing the Services Marketing and advertising As part of our application process for prospective franchisees of our brands Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity |
Among the categories of personal information listed above, the following categories of sensitive personal information we collect may be considered “sensitive” under some state privacy laws:
CATEGORY OF SENSITIVE PERSONAL INFORMATION | CATEGORIES OF SOURCES | PURPOSES FOR COLLECTION |
---|---|---|
Personal information that reveals a Social Security, driver’s license, state identification card, or passport number | Directly from our brands’ franchisees and prospective franchisees Our affiliated brands and companies | As part of our application process for prospective franchisees of our brands |
In addition to the purposes described above, we may use and disclose any category of personal information or sensitive personal information we collect to comply with law, cooperate with and respond to law enforcement requests, or as otherwise required by applicable law, court order, or governmental regulations; to maintain appropriate records for internal administrative purposes; to protect our rights and interests and those of our brands’ franchisees, to resolve any disputes, to enforce this Policy or any of our other policies, to protect the rights or property of another, or to prevent harm; and to evaluate or conduct a merger, sale, or other acquisition of some or all of our organization or its assets.
Our Retention of Personal Information. We keep the categories of personal information described above for as long as necessary or permitted for the purposes described in this Policy or otherwise authorized by law. More details about our retention practices are set forth above.
Disclosure of Personal Information. The following charts summarize how we disclose personal information. Although we do not sell personal information in exchange for money, some of the ways in which we share personal information for advertising or disclose personal information to our affiliated brands and their franchisees may be considered “sales” or “sharing” under some state privacy laws. We do not have actual knowledge that we sell or share the personal information of anyone under 16 years of age.
The first chart below shows the categories of personal information that we share for purposes of targeted / cross-context behavioral advertising or otherwise “sell” for non-monetary consideration. The second chart describes the categories of personal information we disclose for a business or commercial purpose.
Sales and Sharing of Personal Information
CATEGORY OF PERSONAL INFORMATION | CATEGORIES OF THIRD PARTIES TO WHICH SOLD OR SHARED | PURPOSES FOR SELLING / SHARING |
---|---|---|
Identifiers | Our affiliated brands and companies Our brands’ franchisees | Providing analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of GoTo Foods, our brands, affiliated companies, and our brands’ franchisees |
Personal records |
||
Characteristics of protected classifications |
||
Commercial information |
||
Internet or other electronic network activity information |
||
Geolocation Data |
||
Professional or employment-related information |
||
Inferences |
Disclosures for a Business or Commercial Purpose
CATEGORY OF PERSONAL INFORMATION | CATEGORIES OF RECIPIENTS | PURPOSES FOR DISCLOSURE |
|
---|---|---|---|
Personal Information |
|||
| Identifiers | Our brands’ franchisees Our affiliated brands and companies Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies
| Providing operational support for our brands, affiliated companies, and our brands’ franchisees Providing analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for our brands, affiliated companies, and our brands’ franchisees Services performed on our behalf (e.g., providing communications, technical, analytical, web hosting, cloud hosting, and other services on our behalf) Advertising and marketing services (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising Auditing, related to ad impressions Ensuring security and integrity of personal information Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity As part of our application process for prospective franchisees of our brands |
Personal records | Our brands’ franchisees Our affiliated brands and companies Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies
| Providing operational support for our brands, affiliated companies, and our brands’ franchisees Providing analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for our brands, affiliated companies, and our brands’ franchisees Services performed on our behalf (e.g., providing communications, technical, analytical, web hosting, cloud hosting, and other services on our behalf) Advertising and marketing services (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising Auditing, related to ad impressions Ensuring security and integrity of personal information Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity As part of our application process for prospective our brands’ franchisees |
|
Characteristics of protected classifications | Our brands’ franchisees Our affiliated brands and companies Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies
| Providing operational support for our brands, affiliated companies, and our brands’ franchisees Providing analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for our brands, affiliated companies, and our brands’ franchisees Services performed on our behalf (e.g., providing communications, technical, analytical, web hosting, cloud hosting, and other services on our behalf) Advertising and marketing services (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity |
|
Commercial information | Our brands’ franchisees Our affiliated brands and companies Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies
| Providing operational support for our brands, affiliated companies, and our brands’ franchisees Providing analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for our brands, affiliated companies, and our brands’ franchisees Services performed on our behalf (e.g., providing communications, technical, analytical, web hosting, cloud hosting, and other services on our behalf) Advertising and marketing services (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising Auditing, related to ad impressions Ensuring security and integrity of personal information Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity As part of our application process for prospective franchisees of our brands |
|
Internet or other electronic network activity information | Our brands’ franchisees Our affiliated brands and companies Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies
| Providing operational support for our brands, affiliated companies, and our brands’ franchisees Providing analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for our brands, affiliated companies, and our brands’ franchisees Services performed on our behalf (e.g., providing communications, technical, analytical, web hosting, cloud hosting, and other services on our behalf) Advertising and marketing services (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising Auditing, related to ad impressions Ensuring security and integrity of personal information Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity |
|
Geolocation data | Our brands’ franchisees Our affiliated brands and companies Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies
| Providing operational support for our brands, affiliated companies, and our brands’ franchisees Providing analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for our brands, affiliated companies, and our brands’ franchisees Services performed on our behalf (e.g., providing communications, technical, analytical, web hosting, cloud hosting, and other services on our behalf) Advertising and marketing services (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising Auditing, related to ad impressions Ensuring security and integrity of personal information Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity |
|
Audio, electronic, visual, thermal, olfactory, or similar information | Our brands’ franchisees Our affiliated brands and companies Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies
| Providing operational support for our brands, affiliated companies, and our brands’ franchisees Services performed on our behalf (e.g., providing communications, technical, analytical, web hosting, cloud hosting, and other services on our behalf) Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity |
|
Professional or employment-related information | Our affiliated brands and companies Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies | Providing operational support for our brands, affiliated companies, and our brands’ franchisees Services performed on our behalf (e.g., providing communications, cloud hosting, and other support for our brands’ franchise relationships) Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity As part of our application process for prospective franchisees of our brands |
|
Inferences | Our brands’ franchisees Our affiliated brands and companies Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies
| Providing operational support for our brands, affiliated companies, and our brands’ franchisees Providing analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for our brands, affiliated companies, and our brands’ franchisees Services performed on our behalf (e.g., providing communications, technical, analytical, web hosting, cloud hosting, and other services on our behalf) Advertising and marketing services (except for cross-context behavioral advertising) Auditing, related to ad impressions Ensuring security and integrity of personal information Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity As part of our application process for prospective franchisees of our brand |
|
Sensitive Personal Information |
|||
| Personal information that reveals a Social Security, driver’s license, state identification card, or passport number | Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies | Services performed on our behalf (e.g., providing communications, cloud hosting, and other support related to our brands’ franchise relationships) Ensuring security and integrity of personal information Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity As part of our application process for prospective franchisees of our brands |
California Privacy Rights
If you are a California resident, you have the right to submit requests relating to your personal information in accordance with the California Consumer Privacy Act (“CCPA”) and other California privacy laws. Although the individual brand(s) with which you may interact control the personal information they collect about you, there are some circumstances in which GoTo Foods may operate as an independent business with respect to personal information that may be transferred to us by our brands. If you would like to submit a request regarding personal information controlled by one of our brands, please follow the instructions set out in the brand’s privacy policy. If you would like to submit a request to GoTo Foods, please follow the instructions below.
Right to Opt Out of Sales and Sharing. You have the right to direct us not to sell or share your personal information. Although we do not sell personal information in exchange for money, some of the ways in which we disclose personal information to our affiliated brands and their franchisees may be considered “sales” or “sharing” under California law. If you wish to opt out of these transfers of your personal information, you may submit an opt-out request by clicking here, or by calling us toll-free at 844-395-4356. Although our website is configured to recognize the Global Privacy Control (GPC) browser signal, we generally are unable to connect the information we receive from your browser with the personal information we receive from our brands. As such, if you wish to opt out of transfers of personal information from us to our affiliated brands and companies that may be classified as sales or sharing, please submit a request as outlined above.
Right to Know. You have the right to know:
- The categories of personal information we have collected about you, including:
- The categories of sources from which the personal information was collected
- Our business or commercial purposes for collecting (or selling or sharing—if applicable) your personal information
- The categories of recipients to which we disclose personal information
- The categories of personal information about you that we sold, and for each category identified, the categories of third parties to which we sold that particular category of personal information; and
- The categories of personal information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of personal information.
- The specific pieces of personal information we have collected about you.
Deletion. You have the right to request that we delete personal information that we collected from you, subject to certain exceptions. In response, we will delete, and instruct any applicable service providers or contractors to delete, your personal information, unless an exception applies. Where we use deidentification to satisfy a deletion request, we commit to maintaining and using the information in deidentified form and will not attempt to reidentify the information.
Correction. If you believe that personal information we maintain about you is inaccurate, you may submit a request for us to correct that information. Upon receipt of a verifiable request to correct inaccurate personal information, we will use commercially reasonable efforts to correct the information as you direct.
Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose sensitive personal information for purposes to which the right to limit use and disclosure applies under the CCPA.
Non-Discrimination Rights. You have the right not to be discriminated against for exercising any of your CCPA rights. This means that, consistent with California law, we will not deny providing our products or services to you, charge you different prices or provide a different level or quality of products or services to you unless those differences are related to the value of your personal information.
- How to Submit a Privacy Rights Request to GoTo Foods. You can submit your request using the online request form found here or call us toll-free at 844-395-4356. You are not required to create an account with us to submit a request.
- Only you, or someone you authorize to act on your behalf, may make a request related to your personal information. If you designate an authorized agent to make a request on your behalf, you will still need to verify your identity directly with us before your request can be processed. An authorized agent may submit a request on your behalf using the webform or toll-free number listed above.
Certain CCPA privacy rights requests are subject to a verification process. If you submit a request to know, request to delete, or request to correct, you will be asked to provide 2-3 pieces of personal information that we will match against our records to verify your identity. We will not fulfill a CCPA privacy rights request unless we have been provided sufficient information for us to reasonably verify that the requestor is the person about whom we collected the personal information or that person’s authorized agent. Please follow any instructions provided and promptly respond to any follow-up inquiries so that we may confirm your identity.
Privacy Rights for Consumers in Covered States Other Than California
If you are a consumer who lives in Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah or Virginia, you have the right to submit certain requests relating to your personal information as described below. Although the individual brand(s) with which you may interact control the personal information they collect about you, there are some circumstances in which GoTo Foods may operate as an independent controller with respect to personal information that may be transferred to us by our brands. If you would like to submit a request regarding personal information controlled by one of our brands, please follow the instructions set out in the brand’s privacy policy. If you would like to submit a request to GoTo Foods, please follow the instructions below.
How to Submit a Privacy Rights Request to GoTo Foods. To exercise your rights, please submit a request through our webform. Please note that we may need to authenticate your identity before your request can be processed. For authentication, you will be asked to provide 2-3 pieces of personal information that we will match against our records.
Right to Access and Data Portability. You have the right to confirm whether we are processing your personal information, to access your personal information, and to obtain a copy of personal information you provided to us in a portable format. Oregon consumers may also request a list of third parties to which we disclosed personal information.
Right to Correct. You have the right to request that we correct inaccuracies in your personal information, taking into account the nature of the personal information and our purposes for processing it.
Right to Delete. You have the right to request that we delete your personal information, subject to exceptions.
Right to Opt Out. You have the right to opt out of the following uses of your personal information: (a) targeted advertising; (b) the sale of personal information; and (c) profiling in furtherance of decisions that produce legal or similarly significant effects concerning your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. We do not sell personal information in exchange for money or engage in practices that qualify as profiling producing legal or similarly significant effects under applicable state privacy laws. To opt out of targeted advertising and/or non-monetary “sales” of personal information, please submit a request as outlined above. If you choose to use a browser-based opt-out signal, such as the Global Privacy Control, you will be opted out of cookie-based sales or sharing of personal information and will need ot turn it on for each browser you use. If you are an authorized agent submitting an opt-out request on behalf of a consumer where allowed by law, please follow the instructions provided above and within our webform. We use commercially reasonable efforts to authenticate the identity of the consumer to whom the request relates and the authorized agent’s authority to act on the consumer’s behalf.
Right to Appeal. Sometimes we are unable to process requests relating to your personal information, in which case, your request will be denied. If your privacy rights request has previously been denied by us and you believe we denied it in error, you may appeal for reconsideration of your request using our webform.
Please note that if you make a privacy rights request, we will retain a record of your request for recordkeeping purposes.
Additional Information for Nevada Residents
Nevada law provides residents the right to 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.
INTERNATIONAL VISITORS
GoTo Foods 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.
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.
CHANGES TO THIS POLICY
We may update or modify this Privacy Policy from time to time at our discretion. We will indicate changes to this Privacy Policy by updating the “Last Updated” date at the beginning of the Privacy Policy. Please review this Privacy Policy periodically and especially before you provide any personal information to us. Your continued use of our Services after any update will constitute your acceptance of our changes.
CONTACT US
If you have questions about this Privacy Policy or GoTo Foods privacy practices, please contact us at [email protected] or by mail at 5620 Glenridge Drive NE, Atlanta, GA 30342.