California Consumer Privacy Act
Effective as of January 1, 2020
We have collected the following categories of California Personal Information within the last 12 months from the sources listed below:
(a) Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. This category of information is collected from you, your devices, and third parties such as Linked Sites, your family and friends, Franchised Operators and Licensees, and public databases.
(b) Personal information described in subdivision (e) of Section 1798.80 (California customer records statute), such as a name, address, telephone number, credit card number, debit card number, or other financial information. This category of information is collected from you, your devices, and Franchised Operators and Licensees.
(c) Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. This category of information is collected from you, your devices, and Franchised Operators and Licensees.
(d) Internet or other similar network activity, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with a website, application, or advertisement. This category of information is collected from you and your devices.
(e) Geolocation data, including physical location or movements. This category of information is collected from you and your devices.
(f) Sensory data, including electronic, visual, or similar information. This category of information is collected from you and third parties such as Linked Sites and Franchised Operators and Licensees.
(g) Inferences, such as a profile about a consumer’s preferences, characteristics, and behavior, drawn from information we collect and insights we receive from third parties such as our marketing and advertising partners and data analytics providers.
For each of the above categories, we use the California Personal Information for a variety of business purposes such as:
Audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf;
Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same;
Debugging to identify and repair errors in our systems;
Short-term, transient use including contextual customization of ads;
Providing services on our behalf or on behalf of another, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services;
Conducting internal research to develop and demonstrate technology;
Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide; and
We may also use the information we collect for our own or our service providers’ other operational purposes, purposes for which we provide you additional notice, or for purposes compatible with the context in which the California Personal Information was collected.
We do not sell and, within the last 12 months, we have not sold, California Personal Information.
Your California Privacy Rights
If you are a California consumer, you have certain rights related to your California Personal Information, including:
The right to request that we disclose to you:
the specific pieces of California Personal Information we have collected;
the categories of California Personal Information we have collected about you;
the categories of sources from which the California Personal Information is collected;
our business or commercial purpose for collecting or selling California Personal Information; and
the categories of third parties with whom we share California Personal Information.
The right to request that we delete California Personal Information about you, which we have collected from you.
You may request to exercise these rights by:
Calling us at 1-972-941-3150
Or writing to us at Twin Restaurant Holding, LLC, Attn: Legal Department, 5151 Belt Line Road, Suite 1200, Dallas, TX 75254
As required under applicable law, please note that we will take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide your email address to verify your identity in response to exercising requests of the above type. You will, therefore, need access to your email account to receive our communications necessary to process your request. Please make sure to check your spam inbox to ensure these important communications are not missed. We may limit our response to your exercise of the above rights as permitted under applicable law.
We may not discriminate against you because of your exercise of any of the above rights or any other rights, subject to the rights and the obligations under the California Consumer Privacy Act, including by:
Denying you goods or services;
Charging different prices or rates for goods or services, including through the use of discounts, loyalty program, or other benefits or imposing penalties;
Providing you a different level or quality of goods or services; or
Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by law that can result in different prices, rates, or quality levels. Any 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.
Under California law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. We will require the agent to provide proof of that written permission. As permitted by law, we may require you to verify your own identity in response to a request, even if you choose to use an agent.
You may contact us with questions and concerns about our privacy policies or practices by contacting us using any of the methods listed in the “Contact Us” Section.
California Do Not Track
California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings. However, we do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed.