Privacy Statement

Welcome!

This privacy statement provides information about our privacy practices, including how we collect, use and disclose personal data.

Privacy Rights explains your privacy rights and how to exercise them.

Notice at Collection explains the categories of personal data collected, the purposes for which it will be used, how long it will be retained, and if it is sold or shared.

Where does this privacy statement apply?

This privacy statement applies to your activity on websites and mobile apps, as and when applicable. It also applies to your use of our voice ordering systems at some locations. We’ll collectively call these the “Sites” in this statement. Finally, this privacy statement also applies to personal information we collect by any other manner, including via mail, voicemail, and third-party providers

-If you follow a link on any of our Sites to a third party website – say, to purchase branded gear – you’ll be leaving the realm of this privacy statement. You aren't banished - you can come back anytime, but you should check out the privacy policies of those other websites. We have no control over or responsibility for the privacy practices of these other websites and any personal data that you provide to third parties will be governed by their privacy policies. If you decide to access any of the third party websites linked to from the Sites, you do so entirely at your own risk and we are not liable for any consequences arising from your use of these third party websites.

- If you place an order for delivery through an aggregator App or online ordering through the Sites, your personal data will be forwarded to the delivery service provider (“DSP”) for delivery fulfillment. DSPs are independent businesses from us and they may maintain your personal data as an independent data controller. We do not control or take responsibility for the privacy practices of the DSPs and any personal data forwarded to a DSPs for delivery fulfillment will be governed by their privacy policies. We recommend you review the privacy practices for the DSPs prior to placing a delivery order. -Your personal data may be processed, stored, or viewed in the U.S., Canada, or another country, where privacy laws may be less stringent than the laws of your country, and the government, courts, law enforcement or regulatory agencies of these countries may by law be able to obtain your personal data.

-By using the Sites, you are agreeing to this privacy statement. We may change it and when we do, continuing to use the Sites means you agree to the changes. At the end of this document you can find the date that this privacy statement was most recently updated. If changes are significant or material, we will bring them to your attention through a prominent notice that we consider appropriate, such as by sending you an email or in-app notification.

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Personal Data Collected

When you interact with the Sites, we collect (or may have collected in the preceding 12 months), certain personal data (any information about an identifiable individual) about you in different ways.

Information You Submit

Sometimes we’ll ask for personal data directly from you. If you decide not to give us your data, we won’t be offended, but without it we may be unable to provide the products or services you have requested. Examples of when we collect personal data directly from you include:

Ordering, if you sign up for a digital ordering account via the DQ App (if applicable) or online through the Sites, or use online ordering as a guest user. In addition, some locations may have automated voice ordering systems that are recorded for quality assurance and training purposes.
Communications, if you sign up to receive emails or text messages from us.
Surveys, if you participate in a taste test, product survey, or a survey about your experience at a specific location.

The personal data collected varies depending on how you choose to interact with us, but the general categories include:

Contact information and identifiers, such as your name, postal address, email address, phone number, or social media handle or username.
Commercial information, such as your order details and history.
Audio or visual information, like voice recordings or photos.
Demographic data, like age, gender or birthday.
Preferences, like your favorite DQ® location.
Professional or employment-related information when you are looking at developing or purchasing a franchise.
Sensitive personal information, such as account login/password info, allergens, or, if you win a promotional prize or sweepstakes, your W9 information, including FEIN or social security number.

Information from Third Parties

We may receive personal data from other sources, like:

Third Party Applications. If you choose to create a digital ordering account using a third-party login like Apple, Google, or Facebook, then you are directing the third party to send us data for login. The specific info we get depends on your privacy settings, but generally includes a name, email address, and user ID.
Other Sources, as permitted by applicable law. We may receive additional information about you from our service providers or third parties, such as information to help detect fraud and safety issues, and combine it with information we have about you. However, any payment info goes directly to our payment processor and we don’t ever see it. Additionally, other DQ App users may enter information about you in the birthday reminder feature, which would include your birth month and day, the name they have assigned you in their app, and their relationship to you.

Information Collected Automatically

We automatically collect certain types of data that may qualify as personal data when you use the Sites, services accessed through the Sites, or interact with our ads or communications.

- Device Information

We may collect data from your device, such as an IP Address (“internet protocol address”), which is a unique series of numbers that is assigned by your internet provider to the device you’re using to access the internet. Want to know yours? Type “What’s my IP address?” into most web search tools and you’ll find out! We may collect other data from your device like device type, device ID, device carrier, browser type, operating system, crash data and other stuff like that.

- Geolocation

If you have location services enabled on your mobile device and agree to share your location data when prompted by the DQ App, we’ll have access to your precise location when you’re using the App.

-Cookies (in my Blizzard® Treat?). No, not those kind of cookies.

We or our service providers may use cookies, SDKs, or similar technologies when you visit our Sites. These technologies are collectively referred to as “tracking technologies” in this privacy statement. Tracking technologies are tiny pieces of code that websites send to internet connected devices to identify them or to store data.

-Third Party Analytics

We use analytics service providers like Google Analytics, Google Analytics for Firebase (we have implemented the following Firebase products: Firebase Performance Monitoring, Firebase Remote Config, Firebase A/B Testing, Firebase Crashlytics, and may implement other similar Firebase products in the future), or Snowplow Analytics. Our analytics setup may use tracking technologies on your device (which may include an ID that is recognized as a persistent identifier), IP addresses, device IDs or similar tracking technologies. You can find out more about how Google uses data at this link: https://policies.google.com/technologies/partner-sites.

-Usage Data

Our Sites also collect information about how you use them – things like your order information, browsing history, check-ins, loyalty info, deals redemption, and other stuff like that.

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Children's Data

We know kids are some of our biggest fans! But we want their personal data to stay in the safest place - with them or their parents. We don't intentionally gather personal data about our fans under age 16, and please don't disclose personal data relating to anyone under the age of 16.

How Personal Data Is Used

We use personal data to:

Create and manage your account
Send promotional and marketing messages
Send transactional communications about your accounts or orders
Fulfill products or services
Administer rewards, deals, surveys, sweepstakes, contests, or other promotional activities
Provide customer support or respond if you have contacted us
Analyze, administer, troubleshoot, and improve our Sites, products and services
Monitor for and prevent fraud, abuse, and illegal activities
Perform marketing analysis, targeted marketing, and for other marketing purposes
Personalize and customize the Sites and your DQ experience
Track who is opening our communications
Track your consent choices
Optimize our meu items
Other similar activities consistent with this privacy statement

Sometimes we create anonymous information records by excluding data that makes the info identifiable. We use this anonymous data to analyze request and usage patterns to enhance our Sites, products and services.

How We Disclose Your Personal Data

Personal data that we collect may be, or may have been in the preceding 12 months have been, disclosed for business purposes to the following parties:

One big happy company family. We disclose data to the DQ® family of companies, mostly because we all work together out of the same office spaces and try to streamline where we can. Any use of personal data in the DQ® family of companies will comply with this privacy statement.

Franchisees. As we mentioned earlier, most of our locations are independently owned and operated franchises, which means that sometimes the best one to take care of you is the franchisee who owns your local restaurant! We disclose information to our franchisees to manage products and services provided through the Sites, for them to communicate with you, for safety reasons, to prevent fraud, or for other similar reasons.

Service Providers. We’re actually a pretty small team around here, so we get a little help from our friends. These are companies with pretty specialized skills, and any company that gets personal data will only use it for the services they’ve been hired to provide. These service providers may help us with things like hosting, data management and storage, marketing or remarketing, website or marketing analytics, email services, fan relations services, contest or sweepstakes administration or fulfillment, surveys, product ordering or fulfillment, quality assurance testing, digital ordering services, processing payments, firewall services, technical support, and other similar services. In addition, our service providers may collect any of the information listed in the Information Collected Automatically section while they are providing the services they have been hired to do. And, we may sometimes disclose anonymized or deidentified data to our vendors and other third parties. But note, your mobile telephone number obtained from the text message opt-in on the mobile app won’t be disclosed to service providers for their own marketing purposes.

Advertising Providers. We may allow third party tracking technologies on our Sites to collect personal data as described above in the Information Collected Automatically section in order to serve advertisements on our behalf. The information received from these tracking technologies may be used to collect and build behavioral profiles to deliver targeted advertisements on our Sites and unaffiliated websites.

Police & legal stuff. We will also disclose information in the following situations:

- if required to by law, or as necessary to cooperate with an investigation or defend our family of companies, our vendors, or our franchisees.

- to prevent fraud, a violation of this privacy statement or the terms and conditions for our Sites, in response to subpoenas, warrants, discovery requests, or court orders, in connection with a legal process, or to comply with applicable laws.

- to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a suspected violation of our policies.

New owners. Hey, we’d be just as surprised as the next fan, but if we merge, sell, reorganize our corporate entities, or otherwise dispose of a portion of our business assets, we may pass on your personal data as part of the deal, including at the negotiation stage. You agree that any of our successors may use and disclose the information for the same purposes as described in this statement.

Other Disclosures with Your Consent. We may ask if you would like us to disclose your personal data to unaffiliated third parties who are not described elsewhere in this privacy statement.

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Manage Your Data

-Email. You can click the link at the bottom of any email that comes from us to unsubscribe from or correct your info for that email list. But, we may still email you for transactional purposes for stuff like providing you updates about your orders, receipts, etc., or as otherwise permitted or required by law.

-Digital ordering. You can stop future collection of information by the digital ordering platforms by uninstalling the mobile app or no longer using online ordering. To uninstall the mobile app, use the uninstall process for your mobile device.

-Mobile app location data. If you don’t want the DQ App to collect your location information, you can either decline location collection when downloading the App or disable location services for the DQ App on your device.

-De-linking Third Party Login. If you no longer want your Apple, Facebook, or Google account to be linked to your digital ordering account, visit Apple’s, Facebook’s, or Google's privacy settings to adjust your permissions and to manage how they interact with your DQ digital ordering account. You’ll need to log out of your DQ digital ordering account after adjusting your settings. You can also remove the DQ App from your Facebook settings using one of the following methods:

Web Browser:

Log in to your Facebook account, click on your profile picture, then select "Settings & Privacy" then click "Settings".
Select "Apps and Websites.” Under the "Active" tab, you’ll see a list of apps connected to your Facebook account.
Click "Remove" next to the DQ App. In the pop-up confirmation, you can also select "Delete all activities associated with this app". Click "Remove" to confirm.

Mobile App:

Open the Facebook app on your mobile device.
Tap the menu (☰) in the bottom-right (iOS) or top-right (Android).
Go to "Settings & Privacy" then tap "Settings".
Scroll down to "Apps and Websites".
Under "Active", select the app you want to remove.
Tap "Remove", confirm deletion, and optionally remove all associated data.

-Tracking Technologies. You can manage your browser's cookie settings to control which cookies your browser ingests. This is usually managed through a "Settings" menu. You can also potentially opt-out through your device settings, such as the device advertising setting for mobile apps. Additionally, some of our Sites have a "Do Not Sell or Share My Personal Information" button at the bottom where you can control your tracking technology preferences.

-Deletion, access or correction. If you have rights under applicable privacy laws to request deletion, access to, or correction of your personal data, visit the Privacy Rights section below to find out how you can submit a privacy rights request.

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Privacy Rights

Depending on where you live and the privacy rights applicable to you, you may have some of the rights listed below.

-Access and Portability. To obtain a copy of the personal data we have about you in a portable format.

-Correction. To correct inaccuracies in your personal data.

-Information. To request access to:

The categories of personal data we have collected about you.
The categories of sources from which the data information was collected.
The business or commercial purpose for collecting or selling personal data.
The categories of third parties with whom we disclose personal data.
The specific pieces of personal data we collected about you.

-Deletion. To delete personal data that we have collected about you. We will grant a request to delete information if required by law, but in many situations we may keep personal data to comply with our legal obligations, resolve disputes, enforce our agreements, or for another legally allowed business purpose.

-Non-Discrimination. To not be discriminated against for exercising your privacy rights.

-Sensitive Personal Data. We collect sensitive personal data in limited situations (a great example is geolocation data - you can hop back up to the Personal Data Collected section to see when that might happen).

-Right to Opt-Out. Although we don’t sell personal data in exchange for money or engage in profiling that would be subject to opt-out under applicable law, some of our advertising practices may be considered “sharing” as defined by privacy laws, including that we may engage in targeted (i.e., cross contextual behavioral) advertising. You can find information about how we disclose personal data in the How We Disclose Your Personal Data section above. This personal data may fall into the following categories:

Identifiers. Such as your IP address.
Commercial information. Purchasing history and other similar info.
Internet and other electronic network activity information. Data like browsing or search history.

We don’t have actual knowledge that we sell or share the personal data of consumers under 16 years of age. The categories of third parties to whom we may sell or share these categories of personal data include online advertising networks, marketing companies, and social media companies.

You can opt-out of the sale or sharing of your personal data by clicking the “Do Not Sell or Share My Personal Information” button below. You can also access this by clicking on the "Cookies Settings" link on our cookie banner or by scrolling to the bottom of any page of a Site and clicking the “Do Not Sell or Share My Personal Information” button. Not all our Sites have these options because not all our Sites use tracking technologies that qualify as a sale or share of personal data.

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Notice at Collection

Categories of Personal Data

These are the categories of personal data we may collect from you, depending on how you interact with us. We collect this information from you directly, either when you give it to us or one of our service providers, or automatically when you interact with our Sites.

Identifiers. These identify you as a person, such as your name, postal address, email address, or IP address.
Commercial information. Purchasing history and other similar info.
Internet and other electronic network activity information. Data like browsing or search history.
Geolocation data. Such as location data collected from your device.
Audio and visual information. Stuff like voice recordings when you call fan relations for quality assurance purposes or photos if you provide a photo of yourself when contacting fan relations.
Professional or employment-related information when you are looking at developing or purchasing a franchise.
Inferences. This sounds a little vague, but basically it means that we may take all the information we have about you and make some inferences about your preferences (um, you’d much prefer that Blizzard® Treat flavor oozing with chocolate, amirite?).
Sensitive personal information such as account login/password info, precise geolocation data, allergens, race, and ethnicity. We don’t collect sensitive personal information for the purpose of inferring characteristics about you.

Purposes

We use the personal data we collect as described in the How Personal Data is Used section above.

Data Retention

How long we keep your personal data is dependent on a number of different factors, such as the type of data, the reason we’ve collected it, whether we have an ongoing relationship with you, and other similar reasons. Some data we keep for a relatively short period of time, such as if you complete a survey. Other data we keep for a longer period of time to meet business and legal requirements, for things like tax, accounting, or fraud purposes. And some data we keep until you ask us to delete it, such as if you have a digital ordering account. How long we keep personal data may also change if the information is needed for legal purposes (for something like a legal claim), is required to be retained by law, is needed to exercise our legal rights, or for other similar reasons. Following the expiration of an applicable retention period, we may deidentify, aggregate or anonymize data instead of deleting the data when permitted by applicable law.

Sale of Data

As described in more detail above in the Right to Opt-Out section, while we don’t sell personal data in exchange for money, some of our advertising practices may be considered “sharing” as defined by privacy laws.

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We don’t sell or process sensitive data for targeted advertising.

Categories of Third Parties that Receive Personal or Sensitive Data. We only disclose personal or sensitive data collected in connection with the loyalty program to our processors and not to “third parties.” Personal data will not be provided to data brokers.

List of Loyalty Program Partners and Benefits They Provide. We do not have any “Loyalty Program Partners”

Deletion of Personal Data and Loyalty Program Benefits. If you choose to delete your digital ordering account, we have no way to track rewards points or which deals apply to you, so you will no longer be eligible for rewards and deals.

Sensitive Data Collection for Loyalty Program. We currently don’t collect any sensitive personal data for the loyalty program

Do Not Track

Certain states require us to disclose how we respond to “do not track” signals. On some of our Sites, we have implemented technology to recognize browser level opt-out settings and treat those as a request to opt out of the sale of your personal data. Not all browsers offer a “do not track” signal option and there is currently no industry consensus for how to recognize or respond to a “do not track” signal. On our Sites that have implemented this technology, we will try to honor commercially recognized opt out signals (e.g., Global Privacy Control). Recognition of this signal will only take place with respect to the device or browser that communicates the signal.

Cross-Border Transfer.

Since ADQ's world headquarters are in the United States, this means any personal data you submit to us will be transferred to the U.S. By submitting personal data:

you explicitly consent to the transfer of your personal data to the U.S.;
you understand that no adequacy decision and no adequate safeguards apply to these transfers; and
you understand that U.S. surveillance laws fundamentally clash with EU data protection rights, and that your personal data may become exposed to the U.S. government.

Retention. Our current retention practices are:

any personal data kept in our email system will be deleted after 8 years, subject to legal requirements, retention obligations related to actual or potential litigation, or government investigations; and
for any of your personal data we keep in other systems, we'll use some of the following factors to determine retention: legal requirements to retain data, retention obligations related to actual or potential litigation or government investigations, the date of our last communication together, whether you go on to become a franchisee, the sensitivity of the data, and the purposes for which the data was collected.

Your Rights. You have a variety of rights including the right to request access to, correction of, or deletion of your personal data, to restrict the processing or object to the processing of your personal data, or to get a copy of your personal data in a portable format.

If You Don’t Give Us Your Personal Data. Giving us your personal data is a pre-contractual requirement to be considered for developing a franchise. If you don't give us your personal data, we won't be able to consider you for developing a franchise.

Withdrawal of Consent. You have the right to withdraw consent at any time, without affecting the lawfulness of the processing based on consent before withdrawal.

Security

We have implemented technologies and policies to prevent unauthorized and unintended access, use and disclosure of your personal data. However, the safety of any data on the internet is not always secure. We encourage you to protect your account by using a strong, unique password not re-using passwords across accounts, and keeping your password confidential and secure.