DATA PRIVACY NOTICE

Last updated February 2022

This is the Data Privacy Notice of The Halal Guys, Inc. (“THG,” “The Halal Guys,” or the “Company”).  We provide our products and services to you using our website and mobile application (together, the “Website”).  The website may ask for and collect your personal information in order to provide you with our services, enhance your experience, and provide you with other relevant information about our offerings.  This Privacy Notice applies to activities the Company engages in on its website and activities that are offline or unrelated to the website, and it applies to all personal information we collect about our customers.  We are providing this notice to explain our information practices and the choices you can make about the way your information is collected and used.  The Halal Guys is the sole owner of the information collected on its website, and is the “data controller” for the purposes of Europe’s General Data Protection Regulation (“GDPR”).  The contact details to reach our Data Protection Officer can be found in the “Contact Us” section of this Privacy Notice.

The Company is committed to protecting the information that our customers, employees, suppliers, and others have entrusted to us.  This Privacy Notice sets forth the principles that govern our treatment of personal information.  We expect all employees and those with whom we share personal information to adhere to this Privacy Notice.

Information for California residents can be found in the section below titled California Privacy Notice.

Information for Canadian residents can be found in the section below titled Canadian Privacy Notice.

Information for residents of the European Economic Area can be found in the section below titled European Privacy Notice.

If you are outside Canada or the United States, by using our websites, purchasing our products, or providing your information to us, your personal information will be transferred to and stored in Canada and/or the United States.

1. PERSONAL INFORMATION WE COLLECT AND USE

Personal Information You Provide

Your privacy is important to us, and we take care to only collect the information we need, and only if we need it.  The types of personal information we collect from you will depend on how you are interacting with us using our website and services.  For example, we may collect different information from you when you place an order, or if you apply for a franchise.  Depending on how you interact with our website, we may collect the following personal information about you:

• To respond to your questions, requests, or communications, including any feedback or requests relating to our website and services, we may collect your name, email address, phone number, any other identifier by which you may be contacted online or offline, and any other information you choose to provide to us.
• When you create a membership account, we will collect your name, membership card number, email address, phone number, order history, favorite orders, birthday, social media name, and any other information you choose to provide to us.
• When you place an order or make a purchase, we will collect your precise geolocation with your permission, as well as your name, email address, phone number, and payment card information.
• To give you information about our products and services, we may collect your name, email address, phone number, order history, and favorite orders.
• When you enter a sweepstakes, contest, or promotion, we may collect your name, email address, phone number, social media name, birthday, or any other identifier by which you may be contacted online or offline.  If you do not want us to contact you about sweepstakes, contests, promotions, or promote our products or services, you may opt out of receiving these communications at any time in your account profile by unchecking the relevant boxes.  If we have sent you a promotional email, you can opt out by return email or by using the unsubscribe link at the bottom of the email.
• When you post or publish information on our website or transmit information to other users of our website or third parties, we will collect your name, email address, and any other information you choose to provide, post, or publish.
• When you apply for a job using our website, we will collect your name, email address, phone number, resume, desired position, and restaurant location.
• When you apply for a franchise using our website, we will collect your name, email address, company name, phone number, date of birth, citizenship information, marital status, spouse’s name, number of dependents, address, employment information, education information, home ownership information, debt and asset information, income information, information about liabilities, and information specific to your interest in becoming a franchisee.

Information Collected From Your Devices

We may collect the following information automatically from your devices when you use our website or services:

• When you use our website to place an order, we will collect your precise geolocation with your permission.
• For data analytics, including to audit, research, and conduct analysis in order to maintain and improve our services and to protect people who use our services, we may use cookies and similar technologies to collect log information (including IP address, browser type, domain names, access times, referring website addresses, app usage, events that occur within the app, performance data, and download sources) and device information (including computer or mobile device used to access the website, hardware model, operating system, and device identifiers).

We do not knowingly collect any personal information from individuals under 18 years of age, and therefore do not use or disclose it to third parties.

Personal Information Provided by Others

Depending on how you interact with our website, we may collect cookies and browsing data from our service providers.  This includes online activity information and browsing and usage information.  When you use our website or services, we may collect the following information from third parties:

• To integrate with third-party apps and services, such as social media websites and applications, we will collect your unique identifiers, first and last name, phone number, and email address.
• When you engage with us on social media, we may collect your social media usernames, posts, and media (video, audio, images) from the social media platform.
• Third party websites and social media services.  Our website may include links to third party websites or social media services where you may be able to post comments, reviews, or other information.  We may monitor comments and reviews regarding us, our products, or our website that you publicly post on social media or customer review sites.  In addition, please note that your use of these third party websites or social media services may result in those sites collecting information about you.  We are not responsible for these third party websites or social media services and you should review their privacy policies to make sure you understand the information that may be collected, used, and shared by those sites.

Other Ways We Use The Information We Collect

In addition to the uses we identified above, we may also use any of the information for the following purposes:

• To enforce our agreements, including agreements with you when you use our website and services;
• To operate, evaluate, and improve our business, including improving and personalizing the experience for you and others, to complete and maintain records of transactions with individual customers following use of our website or services;
• For safety and security, by making sure third parties protect your information, monitoring the technical functioning and security of our network;
• For legal and compliance, including complying with applicable laws, regulations, and legal obligations; and
• To protect the rights or property of the Company, its employees, and people who use its website or services.

2. COOKIES AND SIMILAR TECHNOLOGIES

Our website uses cookies, web beacons, java scripts, and similar technologies to automatically collect certain information about your activity relating to your visit to our website.  These technologies collect your Internet Protocol (IP) address, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.  We use this data to analyze trends, administer our website, track users’ movements through our website, and gather demographic information about our user base as a whole.  We may receive reports based on these technologies on an individual or aggregated basis.

A “cookie” is a small text file that websites send to your computer or device other Internet-connected device to identify your browser or to store information or settings in the browser. A “web beacon”, also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

We use these automated technologies to collect information about your devices, browsing actions, and usage patterns. The information we obtain in this manner includes information on your interaction with a website, application, or advertisement, your Internet Protocol (IP) address, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.  Our website uses first-party cookies (served directly by our website domain when you visit our website) and third-party cookies (served by a third-party website when you visit our website and our marketing partners’ websites).  We and other third parties may collect information about your online activities over time and across different sites and services when you visit our website.

Behavioral Tracking/Third Party Cookies

We allow third party vendors and advertisers to set their own cookies on and through our website. We have no control over the practices of those third parties and are not responsible for their technology or tracking. We encourage you to review the policies of such persons or entities on their websites.

We use third-party analytics services on our website, including Google Analytics.  To learn more about Google Analytics, visit: https://policies.google.com/technologies/partner-sites.

We use AdWords Remarketing through Google which connects the activity on our website with the AdWords advertising network and the DoubleClick cookie to serve you with relevant advertising material when you leave our website.  That cookie collects information about your browsing history. To opt out of this tracking, please see https://support.google.com/ads/answer/2662922?hl=en.

We also use Google Analytics Advertising.  This includes (i) Remarketing with Google Analytics; (ii) Google Display Network Impression Reporting; (iii) DoubleClick Campaign Manager integration; and (iv) Google Analytics Demographics and Interest Reporting.  Google uses cookies to track activity performed by Google Analytics and its AdWords or DoubleClick cookie. To opt-out please see https://tools.google.com/dlpage/gaoptout/.

Your Internet browser may let you restrict or disable certain types of cookies.  Without cookies, you may not be able to use all of the options on our website.

We may also use JavaScript to help our website, especially pictures, function better.  You can turn JavaScript on or off in your browser functions, but if you turn it off, you may not be able to use all of the options on our website.

Sometimes we use technology to collect the information that your browser uses to auto-fill.  You can stop this technology by turning it off in your browser, and you will still be able to use all of the options on our website.

We do not control third parties’ collection or use of your information to serve interest-based advertising.  However, these third parties may provide you with ways to choose not to have your information collected or used in this way.  You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.

Do Not Track Signals

Some web browsers allow you to turn on Do Not Track (“DNT”), which sends signals to websites you visit, telling those sites that you do not want your online activities to be tracked. Our website currently is not designed to respond to DNT signals received from web browsers.

3. HOW WE SHARE PERSONAL INFORMATION

We may share information about you with third parties as indicated below:

Affiliates: We may share your personal information with our affiliates, subsidiaries, and franchisees if we need to, in order to maintain our business and provide products and services to you.  If we share your information, we will share only the information that is necessary and we will take reasonable steps to make sure that third parties take prudent steps to protect your information.

Service Providers, Suppliers, Agents, and Business Partners: Other companies sometimes provide certain services to us or on our behalf (e.g., maintenance, IT support, human resources, analysis, development, security, orders and delivery).  Unless we tell you differently or as described elsewhere in this Privacy Notice, our service providers are not permitted to use your information except to assist us.

Third Party Integrations: Your use of our website and services will sometimes involve integrations with other third-party platforms or applications, such as Facebook or Apple.  We will share your information with that third party so that you are able to make full use of our website and services, including those integrations.

Compliance with Legal Obligations: We may need to disclose certain information to auditors, government authorities, law enforcement, regulatory agencies, our legal counsel, third party litigants and their counsel, or other authorized individuals in order to comply with laws that apply to us, or other legal obligations such as contractual requirements.

Changes in Business Structure/Ownership: We may disclose or transfer your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of the Company’s business, assets, or ownership interest (including any bankruptcy or similar proceedings).

THG does not sell any individuals’ personal information, including children under 16, to anyone and does not share personal information with third parties for those parties’ commercial use.  

4. CALIFORNIA PRIVACY NOTICE

“Legal Categories” of Personal Information

The law requires us to tell you about the personal information we collect about you in a certain way – specifically, we need to tie it back to “legal categories” of personal information that are listed in the law.  To do this, we bundled up the information we gave you above in this Privacy Notice and matched the different types of personal information we collect about you with the legal category.  To make things easier to understand, we’ve put this information in a chart that shows you four things:

1. The legal category of personal information,
2. Examples of the types of personal information included in each legal category,
3. The purpose for why we collect and use your personal information for each legal category; and
4. The business purposes for which we share your personal information and with whom.

We’ve included these things in the California Privacy Chart at the end of this Privacy Notice.  At the end of the California Privacy Chart, we also included a list of Information We Disclose for a Business Purpose.

Your Rights and Choices

For all personal information that we collect about you, you may have the following rights or choices that we will accommodate where your requests meet legal and regulatory requirements and do not risk making our other data less secure or changing our other data.  You may also designate an authorized agent to make a request on your behalf.

• Know, Erase: You may have the right to know what information is being collected about you, to access your personal information, to receive a copy of your information, and to know whether your personal information is disclosed and to whom.  You also may request that we erase your information.  If you have questions about your information or want to ask us to erase your information, please contact us using the methods in the Contact Us section below.
• Opt Out of Sale: You may have the right to ask us not to sell your personal information.  We do not sell your personal information, but if you wish to make a request, we are happy to confirm that we do not sell your personal information.
• Access: If you would like to request that we provide a copy of your information to you, please contact us using the methods in the Contact Us section below.
• Non-Discrimination:  You have the right not to receive discriminatory treatment by the Company because you exercise your privacy rights.  If you have any questions, please contact us using the methods in the Contact Us section below.

How to Make a Request:  If you would like to make a request, please contact us using the information in the “Contact Us” section of this Privacy Notice.  Please include your name, email, phone number, and the specific type of request you would like to make (a request to know, erase, opt out of sale, or access).

Responding to Requests: Your request will be evaluated to determine whether the requested change meets legal regulatory requirements and does not risk making our other data less secure or changing our other data.  If we aren’t able to honor any part of your request, we will tell you that in our response, as well as the reason(s) we cannot do so.

Verifying Your Identity: To protect you and your information, we may ask you to confirm certain information before we honor your request.  For example, if you make a request, we will ask you to confirm your email address and phone number.  For certain requests, we will use a combination of your email address, phone number, zip code, and/or birth date to verify your identity, so that we can help protect your information.  If you designate an authorized agent to make a request on your behalf, we may require you to verify your identity and provide the authorized agent’s identity and contact information to us.

5.CANADIAN PRIVACY NOTICE

If you are a Canadian resident, this section describes some of the additional rights you have and explains how to exercise those rights.  These rights only apply to personal information and not to information that is not personally identifiable.

Correcting or Changing Your Information

If your personal information changes and you need to update it with us, you can do so by logging into your account with us (if you have one) and making any changes to the information stored there.  Likewise, if you believe the information we have about you is incorrect, you can challenge the accuracy of that information and ask us to correct it.  If you would like to make a request, you can contact us using one of the methods in the “Contact Us” section of this Privacy Notice.

Opting Out of Marketing Communications

If you wish to opt out of marketing communications you can do so any time.  If you would like to make a request, you can click the link at the bottom of the marketing email you received, or you can contact us using one of the methods in the “Contact Us” section of this Privacy Notice..

Access to Your Information

If you want to access the personal information we have collected about you and how it is used or disclosed by us, please contact us using one of the methods in the “Contact Us” section of this Privacy Notice.  After confirming your identity, we will generally provide the requested information at no charge to you unless we have a legal basis to charge you a reasonable fee (in which case we will notify you in advance of the approximate cost of processing your request).  If we are unable to provide you with your personal information, we will tell you why.

Right to Make a Complaint

You have a right to complain to us about our personal information practices, and you can do so using one of the methods in the “Contact Us” section below.  We will evaluate your complaint and will contact you if we need further information to resolve it.  In addition, you may have the option of complaining to the Office of the Privacy Commissioner of Canada or to your province or territory’s privacy commissioner.

How to Make a Request

If you would like to exercise your rights or make a request, you can do so by contacting us using the information in the “Contact Us” section of this Privacy Notice.  Please include your name, email, phone number, and the specific type of request you would like to make.

Responding to Requests

If you wish to amend, correct, update, or delete personal information we have collected about you or to opt-out of any programs to which you have previously opted-in, we will attend to your request and make any necessary revisions, generally within 30 days after receiving your request.  We reserve the right not to change your information if we believe the rights of another individual might be violated.

6. EUROPEAN PRIVACY NOTICE

This section of our Privacy Notice applies to residents of the European Economic Area (EEA).

International Data Transfers

THG primarily stores the personal information we collect in the United States.  To facilitate THG’s  global operations, staff who work for THG and/or our service providers may transfer and access such personal information from locations around the world.  This will involve transferring your personal information outside the EEA.

We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Notice.

Whenever we transfer your personal information out of the EEA, we will ensure one of the following safeguards is implemented:

• We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission; or
• We may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe; or
• We will ensure there is some other protection in place which has been approved by the European Commission as giving personal information the same protection it has in Europe.

Your Privacy Rights

Under certain circumstances, individuals within the European Economic Area have rights under data protection laws in relation to your personal information as set out below:

• Request accessto your personal information, to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correctionof the personal information that we hold about you if it is inaccurate or incomplete.
• Request erasureof your personal information where there is no good reason for us continuing to process it.  You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law.
• Object to processingof your personal information where we are relying on a legitimate interest (or those of a third party) and you feel it impacts on your fundamental rights and freedoms.  You also have the right to object where we are processing your personal information for direct marketing purposes.  In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processingof your personal information if: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transferof your personal information to you or to a third party in a structured, commonly used, machine-readable format.  Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Complain to a government regulator if you are not satisfied with our response, depending on your location.

Legal Bases For Processing

This section describes some of the legal bases we rely on to process your personal information. We may process your personal information for more than one legal basis depending on the specific purpose(s) for which we are using your personal information, including the following legal bases:

• Contracts.  Where we need to perform the contract we are about to enter into or have entered into with you, including to provide you products or services.
• Legitimate Interests.  Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. The following are non-exhaustive examples of where THG relies on legitimate interest to process personal information:
  • THG has a legitimate interest in processing personal information during the employee recruitment process and for keeping records of the process.  Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job.
  • THG has a legitimate interest in processing personal information relating to our existing customers in order to manage our business relationship and provide communications and information that may be of interest, including marketing communications.
  • THG has a legitimate interest in using cookies as outlined in this Privacy Notice.
• Legal Obligations.  Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal information.

Data Retention

We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

7. HOW WE PROTECT YOUR PERSONAL INFORMATION

We strive to take appropriate security measures to help safeguard your personal information from unauthorized access and disclosure.   For example, only authorized employees are allowed to access personal information, and they may only access it for permitted business functions.   We also use technology to protect your information, including encrypting sensitive personal information that is transferred to or from our systems.

In general, we keep your information for as long as we need it to carry out the purposes described in this Privacy Notice, and as necessary to comply with our records-management policies and laws that apply to us.  We also keep your information when we need to comply with other legal obligations we might have, such as in connection with a lawsuit, complaint, or investigation.

While we cannot guarantee that loss, misuse, or alteration will never occur, we use reasonable efforts to prevent it.  Please keep in mind that no method of storage or transmission over the Internet is completely secure, so your use of our services and provision of information to us is at your own risk.

Our website may contain links to other sites on the Internet that are owned and operated by third parties.  The information practices of those websites linked to our website are not covered by this Privacy Notice.  We are not responsible for the privacy policies of other websites to which our website links.

8. CHANGES TO THIS NOTICE

We reserve the right to modify or change this Privacy Notice at any time.  When we make a material change to this Privacy Notice, we will inform you by changing the date on this page noting when the Privacy Notice was last updated.

9. CONTACT US

For questions regarding this Privacy Notice or to submit any of the requests mentioned above relating to your personal information, contact us using any of the following options:

The Halal Guys Inc.
26-44 Borough Pl.
Woodside, NY 11377

Email
info@thehalalguysny.com

Telephone
(347)527-1505

California Privacy Chart

* We may also collect your information to comply with laws or regulations or with legal requests that don’t fit into one of the categories we’ve described for you, or to enforce our rights, prevent fraud, and protect our systems, users, and customers.

+ We share the following categories of information about you for business purposes: