Effective Date: 1/18/2024

HAMRA ENTERPRISES PRIVACY POLICY

1. Introduction Thank you for viewing the privacy policy (the “Privacy Policy”) of Hamra Enterprises, LLC and its subsidiaries and affiliated companies, including, without limitation, Hamra Employees Reaching Out, Inc. (hereinafter, collectively referred to as “Hamra”, “our”, “us” or “we”).  Hamra, through its various operating entities, is a franchisee of Wendy’s, Panera Bread, Noodles & Company and Caribou Coffee.  This Privacy Policy describes how we collect, use and share information, including information we may collect at our restaurant locations, information we may collect when you interact with our websites (www.hamraenterprises.com and https://hamraheroes.org/), social media sites and handles, mobile applications, email and online services (all such online sites and applications are referred to herein as the “Sites”), and information that we may collect when you interact with Hamra personnel (collectively, all of the foregoing online and offline interactions are referred to herein as the “Services”).  By using Hamra’s Services, you consent to Hamra’s information collection, use, and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree and consent, please discontinue use of Hamra’s Services.
2. SCOPE OF THIS PRIVACY POLICY This Privacy Policy explains Hamra’s privacy practices – the information we collect through our Services, how we use and protect that information, the types of information we share with others, the choices and legal rights (where applicable) that you have about the collection, use and sharing practices of information you submit through our Services, details regarding our use of third-party cookies and other tracking technologies, and our commitment to protecting your privacy.  We also include specific disclosures for residents of certain states.  We want you to have all the information you need to make informed decisions before you use our Services. We are committed to safeguarding your privacy. This Privacy Policy applies to any information we collect when you use the Services.  It also applies anywhere it is linked.  However, it does not apply to non-Hamra websites, services, and applications that may link to the Services or be linked to or from the Services. This Privacy Policy does not address, and we are not responsible for the privacy or other practices of any third parties.  Any information that you provide to a third party or that you post to a third-party website or service is governed by the applicable third party’s terms and privacy policy.  We encourage you to review the privacy policies on those websites and applications directly to understand their privacy practices. Our Sites are intended for U.S. audiences only. If you are visiting our Sites from outside of the U.S., communications with our Sites will necessarily result in the transfer of information across international boundaries. If you are located in the European Economic Area (“EEA”), your data may be transferred from the EEA to countries, including the U.S., which do not have data protection laws comparable to those in the EEA. By visiting our Sites and communicating electronically with us, you consent to your data being transferred to and processed by Hamra and its partners and service providers in the U.S. and other counties outside of the EEA as set out in this Privacy Policy and subject to the laws of the U.S. Please do not use our Sites if it is illegal to do so in your country. In this Privacy Policy, “personal information” refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you.
3. WHAT INFORMATION DOES HAMRA COLLECT?

TYPES OF INFORMATION THAT WE COLLECT OR MAY COLLECT

When you use our Services, Hamra or a third party vendor acting on our behalf, may collect your information. This generally happens in one of three ways – you provide us with information, we collect information through automated methods, or we collect information from other sources. There are some situations in which it is necessary for us to collect your information in order to provide a Service to you or to meet legal requirements. Without limiting the foregoing, we may collect the following types of personal information:
  • We, and our service providers, collect a variety of information that you voluntarily provide to us when you use or otherwise engage with the Services, apply for a job with us, request catering from us (whether directly or through third party software provided by our Franchisor), complete a survey administered by us or on our behalf, make a fundraising or donation request, contact us, provide us with feedback and/or submissions, make a press inquiry, or otherwise interact with us, including, without limitation the following information: your first name, last name, telephone number, postal address and/or zip code, email address, phone number, date of birth, age, gender, demographic information, dining preferences, resume and education information, and any other information that you choose to provide.
  • If you place an order, we will collect your financial payment details (e.g. your credit/debit information). 
  • When you engage with us and the Services, we collect certain commercial information, including information regarding the items that you view and order and information about your preferences, such as how frequently you wish to receive marketing and promotional communications from us. 
  • If you choose to access our social network pages, or connect or otherwise link to our Sites with your own social network page, we may collect social network profile information that you have made publicly available through your social network account settings.
  • If you post in a public space on the Sites or otherwise choose to make your personal information public on or through the Services, we may collect or obtain such information.  If you choose to share personal information through the Services, please understand that we cannot control the actions of third parties who may have access to or collect this information. 
  • If you use the mobile application of our franchisor or other third-party partners, information such as your user ID, your location and restaurants near you may be collected and shared with us so that we can perform the Services.
  • Our Sites may use web beacons, cookies and other similar technologies to store and understand more information about you, such as site usage, and to monitor site traffic and usage patterns to improve site functionality.  Please see the Cookies and Other Similar Technologies section below for more information concerning such technologies.
  • We may automatically collect site usage information when you visit our Sites (for example, when you submit information for in-kind donations and fundraising requests).  The information that we collect may include your domain name, Internet protocol (IP) address, mobile device model, internet service provider, site access times, websites that referred you to us, web pages within our Sites that you visit. Hamra may also monitor your activities, preferences, and transactional data relating to your use of our Sites and log this information. This information may be used to diagnose technical problems with the Sites or other problems. 
  • When you use our Sites, we may also automatically infer general location information (e.g., city, state) based on your IP address, or when using our mobile app or the mobile app of our franchisor or third-party partners, through GPS information (if you elect to give the app permission to access your location).  
  • Like most websites, our Sites gather traffic patterns, site usage information and other aggregated data in order to evaluate our visitors’ preferences and the effectiveness of our Sites. This aggregate usage data does not identify you individually. We may share anonymous, aggregated statistics about visitors to our Sites with others, or may allow others to collect aggregate data through our Sites. 
  • If you are one of our service providers or suppliers, we collect information from you in our accounts payable and facilities tracking systems. 
  • We may collect video surveillance at our stores, headquarters or other locations that we own with or without sound as permitted by law. Otherwise, we do not collect audio, visual, thermal, olfactory or biometric information.  
  • We may receive personal information about you from third parties that supplements the information we collect directly from you and/or through automated means. The personal information that we receive from third parties may include demographic information (e.g., your age, gender, zip code, marital status, education level, occupation, etc.) and information about your lifestyle, preferences and interests, and purchase history and tendencies. This personal information may, for example, come from individuals (e.g. your family, friends, or other personal contacts) who provide personal information to us because they think that you may be interested in the Services; third party data providers, including data aggregators and data brokers, that collect personal information about consumers from various sources and provide us with information relating to you; or  publicly available sources and databases.
Please also see the “How and Why We Collect Your Personal Information” chart found in the “California Residents” section of this Privacy Policy.

COOKIES AND OTHER SIMILAR TECHNOLOGIES

Like many other online service providers, we (and our service providers and partners), may use cookies, pixels, tags, and other technologies, which may be provided by third parties, on our Sites to enable certain functionality, to enhance your user experience, for security and fraud detection and prevention, as well as to collect usage information about our Sites and the emails that we send and to personalize content and provide more relevant ads and information, as applicable.  We may combine the information we collect via these technologies with other information, including Personal Information. 

  • Cookies.  Cookies are small text files that are placed on your computer or device when you visit certain websites. Some cookies enable you to log-in to our Services or save certain settings and preferences, while others allow us to track usage and activities on our Services, personalize content, or deliver more relevant ads. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The “Help” tab on the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you block cookies, however, certain features on our Sites may not be available or function properly.  You can learn more about cookies, how they work, and how to manage them at www.allaboutcookies.org. 
  • Pixel Tags and Embedded Script (AKA clear GIFS and Web Beacons.  Pixel tags are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, pixel tags are embedded invisibly on web pages. We may use these, in connection with our Sites to, among other things, track the activities of the users of our Services, improve ads, personalize and manage content, and gather usage information about our Sites. We may also use these in HTML emails to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
  • Third-Party Analytics Tools.  Our Sites use automated devices and applications operated by third parties, such as Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Sites and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and you can opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.  
  • Opt Out of Interest-Based Advertising. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms.  Third parties may be able to collect information, including Personal Information, about your online activities over time and across different websites or online services when you use the Services. Third parties may use cookies and other similar technologies to collect or receive information from our Site and elsewhere on the Internet and use that information to provide you with targeted ads. If you would like to opt-out of such advertising practices on the particular device on which you are accessing this Privacy Policy, please go to http://optout.aboutads.info/. The Network Advertising Initiative also offers a means to opt-out of a number of advertising cookies. Please visit http://www.networkadvertising.org to learn more. Note that opting-out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted-out will no longer deliver ads tailored to your preferences and usage patterns.  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. Please also note that even if you choose to opt out of receiving interest-based advertising, you may still receive advertising, but the advertisements you see may be less relevant to you.

4. HOW DOES HAMRA USE PERSONAL INFORMATION?

Hamra may use personal information collected to:

  • operate, maintain and improve the Services and our business, including to enhance your experience as a customer in our restaurant locations and to personalize your experience as a user of the Services;
  • provide you with customer service, including, without limitation, responding to your customer service inquiries and requests, posting your comments related to our products and services on our social network pages, and taking other actions in response to your questions, comments or activity on our Site;
  • process, manage and fulfill orders;
  • communicate with you about special offers, services, and promotions for our brand, affiliates or third party partners that may be of interest to you;
  • communicate with you about your orders, purchases, and program participation;
  • communicate with your about fundraising and donations;
  • provide you with personalized services, including directing you to the nearest Hamra restaurant based on your location, or providing you with specialized offers based on your Site activity or prior visits to our restaurants;
  • to conduct research, surveys, and analytics and to otherwise measure the effectiveness of the Services and our online and offline marketing and advertising efforts;
  • help monitor and maintain the security and integrity of the Services as well as our systems and networks, and to detect, prevent, investigate, and protect you, our business, and others from fraud, unauthorized transactions, and other unlawful or unsafe activity;
  • to comply with applicable law and respond to requests and communications from law enforcement authorities or other government officials;
  • in connection with the evaluation, negotiation, and/or completion of a business transaction (e.g. a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets), whether as a going concern or as part of any bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred or is otherwise relevant to the evaluation, negotiation, or completion of the transaction; and
  • as otherwise described in this Privacy Policy, such as in the “How and Why We Collect Your Personal Information”  chart found in the “California Residents” section of this Privacy Policy, or per any applicable program terms, or as otherwise explained to you at the point of information collection. 
Please note that we may combine personal information that we collect with information from other sources and use the combined information for the purposes described in this Privacy Policy. We will also you your personal information at your direction or with your consent. Finally, we may use your personal information as we believe reasonably necessary or appropriate to protect our rights, privacy, safety, property, and/or those of others.

5. DOES HAMRA SHARE PERSONAL INFORMATION?

Hamra will not disclose your personal information to third parties, except as provided below. We may share your personal information under the following limited circumstances:

  • We may share your personal information with our affiliates and franchisor entities for purposes consistent with this Privacy Policy and/or other business and operational purposes.
  • We may share your personal information with companies that provide services to us, such as credit card processors, gift card service providers, website hosts, email vendors, fraud investigators, and other companies that help us provide Services or market and advertise our brand; however, such companies may only use that information to provide Services on our behalf.
  • If you have provided information to us in interactive or other questionnaires, Hamra may provide the information collected in such questionnaires to its advertising sponsors to assist their targeting and marketing efforts. Hamra may also provide aggregate statistical data based on the information you provide via the questionnaires to affiliates, business partners, or advertisers. However, other than as stated in this paragraph, Hamra does not knowingly or intentionally disclose to third parties any specific information collected via advertising questionnaires.
  • We may share aggregated, de-identified and anonymous information that does not identify you with third parties, including, without limitation, with marketing agencies, media agencies, and analytics providers.  These other companies will not be able to relate this data to identifiable individuals.  
  • We may share your personal information to our research partners, including those that perform surveys or research projects in partnership with us or on our behalf.
  • We may share your personal information as required or permitted by law, including sharing with governmental agencies, law enforcement, or authorized third parties, in response to verified requests relating to a criminal investigations or alleged illegal activity or any other activity that may expose us, you or any other party to legal liability.
  • We may share your personal information in response to a legal process, when required to comply with laws, to combat fraudulent or criminal activity, to investigate, detect and prevent illegal acts, to enforce our agreements and corporate policies, and the terms of use of the Sites, and to protect the rights, property and safety of Hamra, our employees, agents, customers, or others, or to allow us to pursue available remedies or limit damages that we may sustain.
  • We may share your personal information in the event of a merger, acquisition, financing, sale of assets, liquidation or other similar transaction.
  • We will only share your personal information with other parties at your direction or with your consent.
  • We may disclose your personal information for other reasons that we will describe at the time of information collection or prior to disclosing your information. 

6. HOW DOES HAMRA SECURE PERSONAL INFORMATION?

Hamra takes reasonable steps to maintain appropriate physical, technical and administrative security to help prevent loss, misuse, unauthorized access, disclosure or modification of personal information. Although we implement reasonable security measures on our Services, you should be aware that we cannot guarantee the security of your information submitted via the Internet.  It is your responsibility to make sure that your passwords and account registration information are secure and not shared with third parties. 

7. Information Retention

We will retain your personal information as long as necessary to fulfill the purposes outlined in this Privacy Policy (including to satisfy our legal or reporting requirements), unless a longer retention period is required or allowed under law.  To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of the personal information; the purposes for which we use the personal information; whether we can achieve the purposes through other means; and the applicable legal requirements.  If we de-identify information, we will maintain and use the information in de-identified form and not attempt to re-identify the information except as required or permitted by law.

8. HOW DOES HAMRA TREAT INFORMATION FROM CHILDREN?

Hamra does not intend for any portion of the online Services to be accessed or used by children under the age of 13, nor does Hamra intend to collect any personally identifiable information from children under the age of 13.  If we obtain knowledge that a child under the age of 13 has provided us with personally identifiable information, we will promptly delete such information in accordance with applicable law. If you are between the ages of 16 and 18, please ensure that you use the Services with the permission of a parent or guardian.  

9. WHAT CHOICES DOES HAMRA OFFER ABOUT PERSONAL INFORMATION?

You may contact us by filling out the Consumer Data Request form found here or writing to us as provided in the “Contact” section below  if you wish to view, edit or delete your personal information from our database, and we will use commercially reasonable efforts to accommodate your request in a prompt manner, and, in any event, within any timeframe required by applicable laws and to the extent required by applicable laws.  For residents of certain states, please see the “State Specific Notices” section below that is applicable to your state for additional options and specifics with respect to your legal rights. 

If you no longer wish to receive promotional emails from us, you may opt-out from receiving future emails from Hamra by following the instructions for unsubscribing in the promotional emails we send you or by contacting us by filling out the Consumer Data Request form found here  or writing to us as provided in the “Contact” section below.

 

If you no longer wish to receive SMS messages from us, you may opt-out from receiving future SMS messages from Hamra by or replying “Stop” in an SMS message to us or by contacting us by filling out the Consumer Data Request form found here  or writing to us as provided in the “Contact” section below.

You may be able to manage how your browser handles cookies by adjusting your browser’s privacy or security settings as described in more detail above. If you set your browser to reject cookies, please note that you may not be able to access certain features on our Sites.

When you download our Franchisor’s mobile app, you may be able to manage how your mobile device shares certain information with our Franchisors (and subsequently with us) by adjusting your mobile device’s privacy or security settings. In particular, you may elect whether to share location information with the mobile app to access the mobile app’s location-based services.  

Please note that any information you choose to provide in a public setting, such as on Hamra social network pages, is not only provided to Hamra but may also be shared publicly. Use caution when posting or sharing information on social networking sites. You may also be able to manage the sharing of certain personal information when you connect with us through social networks by adjusting the privacy or security settings of your social network accounts.

Other choices may be presented to you in certain communications. 

10. state specific notices

we may choose or be required by law to provide different or additional notices relating to the processing of personal information about residents of certain countries, regions, or U.S. states, notwithstanding, that we do not currently have restaurant locations in such states.  Additional notices that may be applicable to you are listed below. 

CALIFORNIA RESIDENTS

California Consumer Privacy Notice

The California Consumer Privacy Act (as amended by the California Privacy Rights Act and together with related regulations the “CCPA”) is a state law intended to enhance privacy rights and Consumer protection for residents of California. This California notice supplements the other parts of our privacy policy and provides additional information for California Consumers. In the event of a conflict between any other Hamra policy, statement, or notice and this California notice, this California notice will prevail as to California Consumers’ rights under the CCPA. Capitalized terms defined in the CCPA that are used in this California notice shall have the same meaning as in the CCPA. Unless otherwise noted, the disclosures contained within this California notice cover our activities in the prior 12 months from the Effective Date as well as our current practices. The CCPA defines Personal Information as information that identifies, relates to, describes, is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular Consumer or household.  Under the CCPA, California Consumers have certain rights that they may exercise independently or through an authorized agent. CCPA rights requests are subject to an identification and verification process. We will not fulfill a CCPA request unless we have been provided sufficient information for us to reasonably verify the identity of the requestor and the validity of the request. We will not discriminate against you if you exercise any of the rights provided by the CCPA. We encourage you to take an active role in the management of your privacy.

California Consumer Privacy Act

In accordance with CCPA’s requirements, this notice describes our collection, use, and disclosure, and the sources and purposes thereof, of California Consumers’ Personal Information, as well as the rights California Consumers have under the CCPA. This California notice applies to California Consumers that visit our restaurants or otherwise use our Services. If you are a California resident and you would like to view our purposes for processing each category of Personal Data we collect, please review the chart titled “How and Why We Collect Your Personal Information” , which is found below. For more information on how we process Sensitive Data, please see the “Sensitive Personal Information” which is found below.

How and Why We Collect Your Personal Information 

We collect the categories of Personal Information about California Consumers that are indicated in the chart below. Note that the specific pieces of Personal Information we collect about you may vary depending on the nature of your interactions with us, and may not include all of the examples listed.  Please also note that the disclosures below may also apply to Colorado residents. Finally, please note that as of the date of this Privacy Policy, we do not have any restaurant locations in California or Colorado and therefore, some of the examples of information that we collect will not apply to you unless you have visited one of our locations in another state or interacted with us. 

Category of Personal Information

Business Purposes for Collection, Use, and Disclosure

(1) Identifiers such as name, address, email address, birthdate, online identifiers, or other similar identifiers. 

  • Enhance your experience with our Services by remembering your log-in status and viewing preferences from a previous use of our Services
  • Respond to your requests
  • Provide customer service
  • Give you information about your account
  • Manage web traffic
  • Manage your purchases
  • Administer surveys, rewards, and promotions
  • Guide decisions about Hamra’s or third-party products, websites, applications, services, tools, and communications

(2) Personal Records – such as phone number or payment card information.

  • Respond to your requests
  • Provide customer service
  • Give you information about your account
  • Manage your purchases
  • Improve our products and Services
  • Payment processing
  • Gift card support

(3) Characteristics of protected classifications under California or federal law such as age, gender or race and ethnicity.

  • Personalize your experience by providing content through our Services, including targeted advertising that we believe may be of most interest to you
  • Inform marketing practices
  • Deliver content relevant to your interests on our Services and on Sites

(4) Customer Account Details/ Commercial information such as purchase history or tendencies.

  • Personalize your experience by providing content through our Services, including targeted advertising that we believe may be of most interest to you
  • Provide customer service
  • Give you information about your account
  • Manage your purchases

(5) Internet or other electronic network activity information such as IP address, device identifiers, device advertising identifiers, mobile network, operating system details, language preferences, referring URLs, length of visits, anonymous traffic data, pages viewed, and information regarding interactions with our services or advertisements.

  • Enhance your experience with our services by remembering your log-in status and viewing preferences from a previous use of our Services
  • Guide decisions about Hamra’s products, websites, applications, services, tools, and communications
  • Operations

(6) Geolocation data such as real-time information about the approximate location of your device (GPS and network-based).

  • To determine which restaurant is closest to you to ensure you place your order from the right restaurant or to provide you relevant offers or promotions.

(7) Sensory Data such as video footage at our restaurants

  • For security and liability purposes.
  • To aid in investigations of incidents at our restaurants

We may also collect Personal Information about you that does not directly fit within one of the categories defined by the CCPA. For example, we collect information you provide such as information about a restaurant visit or transaction when you contact us or interact with us on social media or other websites or mobile apps.

All of the categories of Personal Information described in the above chart may also be disclosed for the following purposes:

  • Prevent, detect, and investigate fraud, security breaches, and potentially prohibited or illegal activities
  • Comply with applicable laws and regulations
  • Provide our Services
  • Help detect and prevent potentially illegal acts, violations of our policies, fraud, and/or data security breaches

Sensitive Personal Information  

we may collect the following categories of Sensitive Personal Information:

  • precise geolocation directly from your device if you agreed for your location settings to be utilized to determine which restaurant is closest to you, to ensure you place your order from the right restaurant, and to provide you relevant offers or promotions. We only disclose your precise geolocation to our service providers acting on our behalf.
  • race and ethnicity data from you when you respond to surveys in order to better understand our customers. We only disclose your race and ethnicity data to our service providers acting on our behalf.
  • health data directly from you in order to communicate with you regarding a food safety incident.
Note that the specific pieces of Sensitive Personal Information we collected about you may vary depending on the nature of your interactions with us and may not include all of the categories listed above.

Categories of Recipients with whom Personal Information is Disclosed

We may disclose Personal Information as described above in Section 5, “Does Hamra Share Personal Information?”. 

Sources of Personal Information 

We may collect Personal Information directly from you, your devices or browser, vendors that assist us with providing our services and running our internal business operations, social media platforms, and other data vendors.

Retention of Personal Information 

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information (which includes the categories of Personal Information set forth in the charts and sections above) for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal obligations, or as necessary to resolve disputes. To determine the appropriate retention period for Personal Information, we consider applicable legal requirements, the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes we process your Personal Information for, and whether we can achieve those purposes through other means. We will maintain certain types of Personal Information for a limited duration.

Selling and Sharing of Personal Information

We may Sell and/or Share with Third Parties for analytics purposes the following categories of Personal Information:

  • Identifiers
  • Internet or other electronic network activity information
  • Geolocation data
We may Sell and/or Share this Personal Information for analytics purposes to Third Parties. The Third Parties to whom this Personal information may be Sold and/or Shared are analytics vendors. When we use the term Sell, Sold, or Sale we mean for valuable consideration and not monetary value.  We offer you the ability to opt-out of these Sales and Sharing as set forth in the “Opt Out” Section below.

Consumer Rights

The CCPA gives California Consumers certain rights:

  • Right to know about Personal Information Collected, Disclosed, Shared, or Sold.  You have the right to know about your Personal Information that we are currently maintaining and have Collected and disclosed in the 12-month period prior to the date you submit your request. You also have the right to obtain a transportable copy of such Personal Information. Requests of this nature may be made no more than twice in a 12-month period. Please note that we retain Personal Information for various time periods in accordance with applicable law and our internal recordkeeping policies and procedures. 
  • Right to Know. California Consumers have the right to request more information regarding the following:  
  • The categories of Personal Information we have Collected about you 
  • The categories of sources from which the Personal Information was Collected 
  • Our Business or Commercial Purposes for Collecting, Selling, or Sharing your Personal Information 
  • The categories of Third Parties to which we disclosed your Personal Information 
  • The categories of Personal Information we Sold or Shared about you and the categories of Third Parties to which each category of Personal Information was Sold or Shared 
  • The categories of Personal Information we disclosed about you for a Business Purpose and the categories of recipients to which it was disclosed 
  • The specific pieces of Personal Information we have Collected about you 
  • Right to request deletion of Personal Information.  You may request that we delete your Personal Information that we have Collected directly from you and are currently maintaining. Please note, however, that we may have a legal basis for retaining certain Personal Information under the CCPA, despite your request. Requests of this nature may be made no more than twice in a 12-month period. 
  • Right to opt-out of the Sale and Sharing of Personal Information.  We do not currently engage in Sales and/or Sharing of Personal Information via tracking technologies such as cookies and SDKs through our Sites, but we do use analytics tools, such as Google Analytics.  You have the right to opt-out of the Sale and Sharing of your Personal Information in the context of cookies or other tracking technologies.  Please see the Third-Party Analytics Tools  section above for instructions on how to opt out of the tracking technologies used by Google Analytics.  If we ever do engage in Sales and/or Sharing of Personal Information via tracking technologies such as cookies and SDKs through our Sites, then to opt out of such technologies on our Sites, please click here .  You may also opt out of the Sale and/or Sharing of your Personal Information via cookies and other tracking technologies through an opt-out preference signal. In order to process your request through an opt-out preference signal, you must use a browser supporting the preference signal. If you choose to use an opt-out preference signal, you will need to turn it on for each browser and each device you use.  

 

  • Right to correct Personal Information.  You may request that we correct Personal Information that we maintain about you if you believe such Personal Information is inaccurate. We may request documentation from you in connection with your request. We will also require you (or your agent) to be verified before honoring your correction requests. 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 of your sensitive Personal Information. We do not use Sensitive Personal Information for the purpose of inferring characteristics about you, or for any other reasons besides the permitted Business Purposes. For this reason, we do not treat the Sensitive Personal Information we Collect as being subject to a “limit use of Sensitive Personal Information request” and, therefore, we do not offer a way for you to submit such a request. 
  • Right to non-discrimination for the exercise of your privacy rights. We will not discriminate against you if you choose to exercise any of the privacy rights described above. 

Exercise CCPA Rights

You may submit CCPA-related requests to Hamra by reaching out to us via the methods provided in Section 12 below.  Please note that before we can fulfill your request, we must be able to verify your identity. We will ask you to provide your email and will use a verification link pushed out through email or will otherwise attempt to verify that we have a record of you in our systems. If we cannot verify your identity, we may not be able to fulfill your request.  You may authorize an agent to make CCPA-related requests on your behalf. To fulfill requests made by authorized agents, you must provide Hamra with enough information such that we can verify the authority of the agent, such as complete notarized affidavits that identify the authorized agent and confirm that you have authorized them to act on your behalf.  Parents of minor children may submit a birth certificate of the child in lieu of an affidavit, in order to make requests on the child’s behalf.  

Financial Incentive Program

We do not offer any financial incentives as those are defined under the applicable data protection laws.

Shine the Light 

California law permits customers in California to request certain details about how their personal information is shared with third parties, and in some cases affiliates, if personal information is shared for those third parties’ or affiliates’ own direct marketing purposes. We do not share personal information with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. 

Californians may request information about our compliance with this law by contacting us using the Consumer Data Request Form found here.  

or by sending a letter to:

Hamra Enterprises

1855 S. Ingram Mill Road, Suite 100

Springfield, Missouri 65804

Attn: Privacy Request/Shine the Light

Any such request must include your name and “California Shine the Light Privacy Rights Request” in the first line of the description and, if sent by mail, must include your street address, city, state, and zip code. Please note that “Shine the Light” rights and CCPA rights are granted by different laws and must be exercised separately.

California Minors

California residents under the age of 18 who have registered to use the Services, and who have posted content or information on or through the Services, can request that such information be removed by contacting us using the Consumer Data Request Form found here  or by sending a letter stating that they personally posted such content or information and detailing where the content or information is posted, to:

Hamra Enterprises

1855 S. Ingram Mill Road, Suite 100

Springfield, Missouri 65804

Attn: Privacy Request/Minor

We will make a reasonable, good faith effort to remove the content from prospective public view or anonymize it so the minor cannot be individually identified. However, this removal process cannot ensure complete or comprehensive deletion from the Internet. For instance, third parties may have republished the content or archived copies of it may be stored by search engines or other parties that we do not control.

RESIDENTS OF CERTAIN COVERED STATES WITH PRIVACY LAWS

This section provides additional information for residents of Colorado, Connecticut, Utah and Virginia (each a “Covered State”) that may use our Services, including how to exercise the rights available under Covered State privacy laws.  The following provisions shall apply to our collection of your Personal Data only to the extent that we are subject to such laws, it being noted that we do not currently have restaurant locations in any of the Covered States.  In addition, to the extent that additional states pass privacy laws similar to those of the Covered States that would apply to us or where we have restaurant locations, then such states shall be considered “Covered States”. Capitalized terms defined in Covered State privacy laws that are used in this section shall have the same meaning as in the applicable law.  Please note that some of the privacy laws may only be applicable to certain business entities that meet certain thresholds, therefore,  we may not be subject to certain state’s privacy laws if we do not meet the applicable threshold, if any, under such applicable law.  

You can learn more about the Personal Data that we process in the “What Information Does Hamra Collect?”  section of this Privacy Policy and the purpose for processing such Personal Data in the “How Does Hamra Use Personal Information?” section above. You can also learn more about our disclosure of Personal Data and the categories of Third Parties we disclose Personal Data to in the “Does Hamra Share Personal Information?” section above. If you would like to view our purposes for processing each category of Personal Data we collect, please review the chart titled “How and Why We Collect Your Personal Information”  which is located in the “Residents of California” section of this Privacy Policy. For more information on how we process Sensitive Data, please see the “Sensitive Personal Information”  section which is located in the “Residents of California” section of this Privacy Policy.  

We do not currently process your Personal Data for Targeted Advertising. If, however, our practices change in the future, then depending on which Covered State you are a resident of, you may have the right to opt out of the Processing of your Personal Data for Targeted Advertising, as described below.  If any of our advertising and analytics practices are considered a “Sale” under certain state privacy laws, such as the Colorado Privacy Act and the Connecticut Data Privacy Act, then, if you are a resident of a Covered State that considers such practices to be a “Sale”, you can opt out of the “Sale” of your Personal Data, which may overlap with your right to opt out of Targeted Advertising.  We may disclose Personal Identifiers, Internet Usage Data and Geolocation Data to analytics vendors. 

If you are a resident of a Covered State, and if we are subject to the laws of that Covered State, then subject to certain conditions and restrictions set out in the applicable laws of your Covered State, some or all of the following rights may be applicable to you with regard to your Personal Data:

  • Right to Access. You have the right to know the Personal Data that we may hold about you and access such Personal Data.
  • Right to Correct. You have the right to request that we correct inaccuracies in your Personal Data (taking into account the nature of the information and the purpose(s) for which we are processing it).
  • Right to Delete. You have the right to request that we delete certain Personal Data that we have collected from or obtained about you.
  • Right to Withdraw.  You have the right to withdraw any previous consent that you have given to us to use your personal information (where applicable).
  • Right to Opt Out of Sales. Although we do not Sell Personal Data in exchange for money, nor do we participate in Targeted Advertising, there is the possibility that some of our practices may be considered a “Sale” under certain state privacy laws, such as the Colorado Privacy Act and the Connecticut Data Privacy Act. If you are a resident of a Covered State that considers such practices to be a “Sale”, you have the right to opt-out of the Sale of Personal Data, which may overlap with your right to opt out of Targeted Advertising. You can opt out of Sales by submitting to us a privacy request as provided below.  We do not Sell your Personal Data as defined under Virginia privacy law, and as such this right is not applicable.
  • Right to Opt Out of Targeted Advertising. We do not engage in Targeted Advertising and as such this right is not applicable.  
  • Right to Opt Out of Profiling. You have the right to opt out of our processing of Personal Data for the purposes of profiling. We do not currently engage in profiling, but to the extent that our practices change in the future, such profiling will not result in decisions that produce legal or similarly significant effects concerning your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements, and as such this right is not applicable.
  • Right to Appeal. If you reside in Colorado, Connecticut or Virginia, or any other Covered State that provides for a right to appeal, if you are unsatisfied with our actions related to the exercise of one of your privacy rights above, you may appeal our decision by contacting us as provided in Section 12 below and putting in the subject line “U.S. State Privacy Rights Request Appeal”.  If you are unsatisfied with the way that we have handled your appeal, you have the right to complain to your state’s Attorney General. 
Residents of Covered States may submit their privacy requests by sending an email or a letter to the address provided in the Contact Us section below. Please note that, depending on the nature of your request, you may be asked to provide information to verify your identity before your request can be processed. We will use commercially reasonable efforts to authenticate the identity of the consumer submitting a request, or, if you use an agent to make the request, as may be permitted under certain Covered States laws, then we will use commercially reasonable efforts to authenticate your identity and the agent’s authority to act on your behalf. We will confirm receipt of your request and respond to your request as soon as we reasonably can and no later than legally required.  Please note that our response may be that we are not subject to the laws of the particular Covered State. For example, the Utah Consumer Privacy Act only applies to certain business entities that meet certain thresholds. As of the date of this Privacy Policy, we would not meet those thresholds. If you choose to exercise any of the privacy rights described above, you will not receive discriminatory treatment from us.

Nevada Residents

Under Nevada law, Nevada residents may opt out of the “sale” of their personal information, where the information is exchanged for monetary consideration. We do not engage in such activity; however, if you are a Nevada resident, you may submit a request to opt out of potential future sales under Nevada law by contacting us as provided in Section 12 below.  Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

HAMRA EMPLOYEES IN ILLINOIS

If you are a current or former employee of Hamra and a resident of Illinois and want a copy of Hamra’s publicly available Biometric Data Privacy Policy, it is available by clicking here.

[ADD A LINK TO BIOMETRIC POLICY IN ONLINE HANDBOOKS AT “here”]

11. Modifications to this Privacy Policy

From time to time, we may change or modify this Privacy Policy to reflect changes in our practices with respect to the collection, use, and disclosure of personal information and/or changes in applicable law. The “Effective Date” at the top of this page indicates when this Privacy Policy was last revised. If we make changes, we will revise the “Effective Date” at the top of this Privacy Policy. We encourage you to review this Privacy Policy periodically to remain informed about our information handling and privacy practices. Your continued use of our Services following the posting of any changes will mean that you accept those changes. To the extent any provision of this Privacy Policy is found by a court of competent jurisdiction to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

12. Contact Us

If you have any questions regarding this Privacy Policy or our information handling practices or would like to exercise any of the rights with respect to same outlined in this Privacy Policy, please full out the Consumer Data Request Form found here  or write to us at 1855 S. Ingram Mill Rd. Springfield, Missouri 65804, Attn:  Privacy Request.