Effective Date: March 18, 2022
VKC Delights Group LLC dba Twisters Burger and Burritos and our affiliated entities (“Twisters”) respects your concerns about privacy. This Privacy Notice describes the types of personal information we collect via our websites, mobile applications, loyalty program, digital stored value system, and other online programs (“Twisters Online Services”) as well as through your offline interactions with us, including when you connect with us via telephone, at our restaurants and events, through our surveys, and through our third-party sources, including advertising and social media networks. This Notice also describes how we use the information, with whom we share it, the choices available to you regarding our use of the information and the measures we take to protect the security of the information and how you can contact us about our privacy practices.
INFORMATION WE OBTAIN
The types of information we collect about you may include: Contact information, such as name, telephone number, postal address and email address;Payment information, such as credit or debit card number, security code, expiration date and billing address;Purchase history information;Login credentials, such as your username, password, and security questions and answers, and age-verification information, such as your date of birth or whether you are 13 or older;Demographic information, such as ZIP code, birthday and status as a Rewards member;Geolocation information (which may include specific longitude and latitude);Photographs, audio communications or video images; andOther information you choose to provide, such as through “Contact” features or in connection with promotional events.If you are applying for a career opportunity, we may collect information such as your name, email address, mailing address, phone number and job for which you are applying.
AUTOMATED COLLECTION OF INFORMATION
We may collect certain information by automated means, such as cookies, web server logs and other technologies. The information we collect in this manner may include your device IP address, unique device identifier, web browser characteristics, device characteristics, operating system, referring URLs, clickstream data, and dates and times of website visits.
When you use our mobile applications, we also may collect certain information by automated means, such as through device logs, server logs and other technologies. The information we collect in this manner may include the device type used, the mobile operating system, device identifiers and similar unique identifiers, device settings and configurations, IP addresses, battery and signal strength, usage statistics, referring emails and web addresses, dates and times of usage, actions taken on the mobile application, and other information regarding use of the mobile application. In addition, we may collect your device’s geolocation information. Your device’s operating platform may provide you with a notification when the mobile application attempts to collect your precise geolocation (See “Location” section below for more information). Please note that if you decline to allow the mobile application to collect your precise geolocation, you may not be able to use all of the mobile application’s features or the offers available through the mobile application.
HOW WE USE THE INFORMATION WE OBTAIN
We may use the information we obtain about you to: Provide products and services to you;Send you newsletters and other email communications if you sign up to receive them;Administer your participation in surveys, contests, promotions or other programs;Process orders and payment transactions;Manage delivery services;Offer promotions or conduct other marketing efforts;Create and manage your Twisters loyalty program account;Post your comments or statements when you participate on message boards or in our online forums;Provide location-based services to you, such as to help you find a Twisters location or send you notifications or messages based on your location (see “Location” section below for more information);Provide customer support and respond to your inquiries;Customize your experience, such as by providing personalized product information, purchase information, coupons and other offers;Enable your use of social-media functions via our mobile applications, such as sending information or offers to friends and family via the app or other social media — when you use this functionality, you acknowledge and agree that you are permitted to use and provide us with your friend’s or family’s name and e-mail address;Protect against and prevent fraud, unauthorized transactions, claims and other liabilities;If you submit information as a job applicant, evaluate your interest in employment and contact you regarding possible employment and continue to communicate with you regarding employment;We also may use the information in other ways for which we provide specific notice at the time of collection.
THIRD-PARTY ANALYTICS SERVICES
We may use third party analytics services, such as Google Analytics. The analytics providers that administer these services use technologies such as cookies, web beacons and web server logs to help us analyze your use of the Twisters Online Services. The information collected through these means (including IP address) may be disclosed to these analytics providers, and other relevant third parties who use the information to evaluate use of the Twisters Online Services. To learn more about Google Analytics and how to opt out, please visit https://www.google.com/intl/en/analytics/learn/privacy.html or https://support.google.com/analytics/answer/181881?hl=en.
TRACKING AND INTEREST-BASED ADVERTISING
We and third parties may collect information about your online and in-store activities to provide you with advertising about products and services tailored to your interests. This section of our Privacy Notice provides details and explains how to exercise your choices.
We and third parties may use collected information to establish connections among related web browsers and devices (such as smartphones, tablets, and computers) for targeted advertising, analytics, attribution, and reporting purposes. This information may be used to match your browsers or devices if you log into the same online service on multiple devices or if your devices share similar attributes that support an inference that they are used by the same person or household. This means that your online behavior (information about your activity on websites or apps on your current browser or device and your device’s geolocation) may be combined with information collected from your other browsers or devices. For example, this information may be used to deliver an ad on your tablet or smartphone, to limit the number of times you see an ad across your devices, and to help measure the effectiveness of advertising campaigns across devices.
We or our vendors may collect the geolocation (which may include specific longitude and latitude) of your mobile device based upon information identified by your mobile device by, for example, accessing your devices location services, when you allow such access, or by WiFi signals, beacons, Bluetooth or near field communication protocols. We may use and share your mobile device’s geolocation together with personal information or other information to identify your local Twisters restaurant, to provide you with personalized notifications or messaging (for example, that you have a reward available) by email, push notification, online or in-app advertising, or by other means described in this Privacy Notice. See “Opt-Out Choices” section below to opt-out of location collection. If you choose to opt out of location collection, certain functionality of the Twisters Online Services may not be available.
Our websites are not designed to respond to “do not track” signals received from browsers.
INFORMATION WE SHARE
We do not sell, trade, or rent Users personal identification information to others.We may share your personal information with our subsidiaries, trusted affiliates and business partner for the purposes described in this Privacy Notice. We also may share personal information with vendors who perform services on our behalf based on our instructions, including, to conduct analysis and research. We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements.
We may also share personal information with third parties when you use their services together with our services, or when you share information directly through our services. For example, the Twisters Online Services may contain links to third-party websites that incorporate comments and social media features.
In addition, we may disclose information about you (i) if we are required to do so by law or if we believe such action is necessary to comply with legal process, (ii) to law enforcement authorities or other government officials, or (iii) when we believe disclosure is necessary or appropriate to prevent injury, harm or financial loss or in connection with an investigation of suspected or actual illegal activity. We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition or reorganization).
You may opt out of certain targeted marketing practices in web browsers and mobile applications by following the instructions below. Please note that you will need to opt out separately on all of your browsers and devices, as each opt-out will apply only to the specific browser or device from which you opt out. If you delete or reset your cookies or mobile identifiers, change browsers, or use a different device, any opt-out cookie or tool may no longer work and you will have to opt out again. Note that some third parties may also make their own opt-out process available. Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising about Twisters, but the ads will not be targeted based on behavioral information about you. Web Browser Opt-Out. To opt out in web browsers, please visit the Network Advertising Initiative Consumer Opt-Out Page at www.networkadvertising.org/choices, and the Digital Advertising Alliance Consumer Choice page at www.aboutads.info/choices. Although our website does not respond to Do Not Track browser signals, some of our vendors may permit you to opt out using Do Not Track functionality.Mobile Application Opt-Out. To opt out in mobile apps, please download the Digital Advertising Alliance’s AppChoices tool at www.aboutads.info/appchoices and adjust the advertising preferences on your mobile device. For example, to adjust your advertising preferences in iOS, visit the tracking and advertising settings within the Settings functionality of your mobile device; to adjust your advertising preferences in Android, visit the opt-out of interest-based ads settings within the Settings functionality of your mobile device. You can also use the settings within your device to opt out of or turn off push notifications.Location Opt-Out. Most mobile devices allow you to control whether a website or mobile application is allowed to collect your specific longitude and latitude information. For example, Google and Apple provide the following links to instructions on how users can disable location services.For Android devices: https://support.google.com/accounts/answer/3467281?hl=enFor iPhones: https://support.apple.com/en-us/HT207092
Some of the third parties that display our ads on their services may provide you with additional choices to opt out of targeted advertising. For example, social media providers may allow you to control your advertising preferences directly through their services. Please review the privacy policies of the third-party services you use for more information.
YOUR OTHER CHOICES
To unsubscribe from marketing emails, click the “unsubscribe” link found in our marketing email messages. You may also contact us as described in “How to Contact Us” section below to update your preferences, submit a request, or ask questions about this Privacy Notice. You may also update your preferences online through your Twisters online or Rewards account.
The Twisters Online Services are not intended for children under the age of 13 and do not knowingly collect personal information from children under the age of 13. If we become aware that a child under the age of 13 has provided us with personal information, we will delete the information from our records.
HOW WE PROTECT PERSONAL INFORMATION
We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized access, destruction, loss, alteration, disclosure or use.
LINKS TO NON-TWISTERS SITES AND SERVICES
For your convenience and information, the Twisters Online Services may provide links to Non-Twisters websites, apps and services that may be operated by companies not affiliated with Twisters. The privacy practices of the relevant third parties, including details on the information they may collect about you, is subject to the privacy notices of these parties, which we strongly suggest you review. We are not responsible for the content or privacy practices of any websites, apps or services that are not owned or controlled by Twisters.
UPDATES TO OUR PRIVACY NOTICE
This Privacy Notice may be updated periodically to reflect changes in our personal information practices. Changes to the Privacy Notice will be posted on this page. For significant changes, we will notify you by posting a prominent notice on our website indicating at the top of the Privacy Notice when it was most recently updated (for mobile applications, a notice will be posted on the mobile app store page or within the mobile app).
HOW TO CONTACT US
You can contact us with questions about this Privacy Notice by using the “Contact” section of the website.