Snarf’s Worldwide Holding Company, LLC Privacy Policy

Thank you for visiting the websites eatsnarfs.com and snarfburger.com. To simplify the language in this Privacy Policy, the term “we” or “us” means Snarf’s Worldwide Holding Company, LLC, the operator of the eatsnarfs.com and snarfburger.com websites, and a provider of the Snarf’s digital ordering app and the promotional programs of Snarf’s and Snarfburger businesses. “You” means the person visiting or otherwise using or participating in the eatsnarfs.com or Snarfburger.com website, digital ordering app, or promotional programs.

We are committed to protecting your privacy. This Privacy Policy applies to the eatsnarfs.com and snarfburger.com websites and governs data collection and usage at all eatsnarfs.com and snarfburger.com pages and services (except as expressly indicated herein), through the Snarf’s digital ordering app, and any Snarf’s promotional programs (the “Services”).

Please read this Privacy Policy. Personal information of all users is collected, used and disclosed as described in this Privacy Policy.

AUTOMATIC COLLECTION AND USE OF NON-PERSONAL INFORMATION

As with most websites and apps, when you visit eatsnarfs.com or snarfburger.com, or use any of the other Services, we automatically collect and store the following, non-personally identifiable information:

• The date and time of the visit
• The originating IP address
• The type of browser, platform, and operating system used (if provided by the browser)
• The object requested
• Completion status of the request
• Pages visited and items clicked
• Sites visited immediately before and after our website
• User actions and behaviors

This automatically collected information is used by us to measure the number of visitors to the different areas of eatsnarfs.com, snarfburger.com, and other aspects of the Services, and to assist us in making the Services more useful to users. This includes analyzing these logs periodically to determine the traffic through our servers, the number of pages served, the advertisements viewed, and the demand for certain areas of eatsnarfs.com or snarfburger.com and topics of interest. We and third party service providers may use tracking data related to your use of the Services to remember any information to avoid the need for re-entry of data, to provide customer content or information to you, including targeted advertising, to diagnose and address any technical issues, to detect fraudulent or unauthorized use, or to otherwise enhance our services. All of our logs may be preserved indefinitely by us, used at any time and in any way deemed necessary by us, and disclosed to any third party without your knowledge or consent. This automatically collected data may be linked to personally identifiable information that you enter on our website. We may share any non-personally identifiable information, such as the information automatically collected when you visit eatsnarfs.com or snarfburger.com, with any third party without your knowledge or consent. We may share any linked personally identifiable information in the manner described below under the heading “USE AND SHARING OF YOUR PERSONAL INFORMATION.”

We do not currently observe web browsers’ “do not track” signals, and we will track your navigation of our website regardless of whether this preference is indicated.

USE OF COOKIES

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We may use cookies on eatsnarfs.com and snarfburger.com to keep track of certain information you may enter, to enable certain features of the websites, to record session data regarding your visit to our websites, and to personalize your experience on our websites. We may also use cookies to maintain user session identity if you log in to any portion of our websites.

Further, we may use cookies to determine aggregate usage data such as the automatically collected information described above, to assess the technical function of our websites, and to generally help us gauge the effectiveness of our websites.

The cookies themselves will not contain any personally identifiable information, but they may be linked to any personally identifiable information that you enter on our websites.

COLLECTION OF YOUR PERSONAL INFORMATION

As part of our normal business practice, we engage in communication with the general public, and our potential and existing customers. As part of that process, it is often necessary or desirable for us to collect personal information. For example, you may provide us your personal information when you order products or services, register for an account or membership (including to our rewards program), post feedback, a review, or a testimonial, send us a text or other message, subscribe to our communications, enter a contest, redeem a promotion, or use any other part of our Services or engage in other transactions with us.

The information that you may be asked to provide and that we collect may include:

• Your name;
• Your demographic information including age and gender;
• Your mailing address;
• Your billing address;
• Your delivery address for orders placed;
• Your current location (including IP address data);
• Your e-mail address;
• Your phone number;
• Payment details such as credit card or debit card information;
• Your username and password for any accounts you establish with us;
• Your visit information and purchase history (including dates, times, locations, and amounts and nature of purchases);
• Loyalty program and other promotional program participation data;
• Photos, video and audio recordings, and text content that you share with us through any of the Services or via e-mail or text;
• Social media account and content;
• Any information that you provide by filling in forms on our websites, including when registering for any promotion or services;
• Any information you provide to us in a survey; and
• Error logs and similar notifications related to the Services.

Your choice to submit this personal information is completely voluntary. By entering your personal information through the Services or otherwise providing us with your personal information, you are providing your consent for us to use your information for the purposes described below and, if you are a current customer of ours, for purposes of enabling us to fulfill our obligations to you.

In addition to the foregoing personal information that you voluntarily provide, we will obtain the following information from sources other than you, which we may link to the personal information you provide us:

• Social media network posts and other information – If you contact or engage with us through social media, such as by “liking” us, following our account, or making a post on our page, tagging us, or otherwise tied to any of our accounts or pages, on Facebook, Twitter, or any other social media networks, we will receive and have the ability to access the information you post and information about you which you permit the social media network to share under your settings and terms with the social media network.
• Authentication Services – We may require that you access our Services through use of a third party authentication service, such as signing in through a social media account or through your mobile telephone sign-in procedures. The data we receive will be dependent on the third party authentication service provider.
• Other third parties – We may receive personal information from third parties, such as parties involved in the development and operation of our promotional programs and digital ordering app, and our marketing partners.
• Other public sources – We may collect personal information that is available publicly, such as through online sources.

USE AND SHARING OF YOUR PERSONAL INFORMATION

We may use and share the personal information that you provide and that we collect as follows:

1. We may use this voluntarily provided information for purposes of fulfilling orders in-store or online, responding to your immediate request or feedback, taking, delivering, and otherwise fulfilling your orders, verifying your authority to enter certain sections of eatsnarfs.com and snarfburger.com, processing a charge for purchases you make, to offer you other products or services that we believe may be of interest to you, for future contact and communication with you, and to fulfill any other purpose for which such information was provided.

2. If you join our rewards program, our other loyalty or promotional programs, or any other program that involves the use of e-mail or text messaging, we will use the information you provide to send you promotional communications in accordance with the terms of those programs, track your visits to Snarf’s or Snarfburger locations, market to you, and fulfill any rewards under the applicable program.

3. We may also contact you via surveys to conduct research about your opinion of current products and services or of potential new products and services that may be offered.

4. We may use your personal information to analyze our customer base and improve, develop, monitor, and tailor product and service offerings accordingly, including compiling and analyzing statistical information.

5. We occasionally hire other companies to provide limited services on our behalf, such as handling the processing and delivery of products and services, customer support, payment transactions, providing advertising services, administering contests, promotions, or loyalty programs, or performing statistical analysis of our services. We will only provide those companies the personal information they request or reasonably need for the purpose of delivering the services, fulfilling your orders and other requests, enforcing those third parties’ rights against us, and complying with applicable laws. They are required to maintain the confidentiality of your information and are prohibited from using that information for any other purpose. We may also authorize them to use any of your data on an aggregated and anonymized basis for any of their business purposes, including to improve their services. The categories of personal information shared with such parties may include all of the personal information we collect (as described in the “COLLECTION OF YOUR PERSONAL INFORMATION” section above).

6. We may share your personal information with our affiliates who may use the information in the same manner as permitted for us under this Privacy Policy. We may transfer your personal information to a successor entity or individual upon a merger, consolidation, or other reorganization or sale of substantially all assets of the applicable business, in which we participate. We may also transfer your personal information between different offices of ours for internal management and administrative purposes. The categories of personal information shared with such parties may include all of the personal information we collect (as described in the “COLLECTION OF YOUR PERSONAL INFORMATION” section above).

7. We may access and/or disclose your personal information if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on us, or on eatsnarfs.com or snarfburger.com; (b) protect and defend our rights or property, including to the Services; (c) enforce this Privacy Policy or our Terms of Use; or (d) act under exigent circumstances to protect the personal safety of users of the Services or the public.

8. We may share any personal information that you provide or make available for the purpose of it being shared, such as any personal information in any blog entry, testimonial, or social media post on, tagging, or otherwise relating to any of our accounts or pages. When you engage with us on social media or otherwise provide any such content, you are authorizing us to use that content.

9. We may use your personal information for purposes of fraud control.

10. We may share any personal information in any other situation in which you approve or consent to the sharing. The categories of personal information shared with such parties may include all of the personal information we collect (as described in the “COLLECTION OF YOUR PERSONAL INFORMATION” section above), to the extent that you approve or consent.

Except as described above, we do not sell, rent or lease our customer lists to third parties.

We will store any personal information that you provide to us solely through the Services in a secure location, until such time as you request that we delete your personal information as set forth in the “Control Your Personal Information” section below or until such time as we deem such personal information no longer useful in our normal business operations. In deleting or disposing of your personal information, we will use commercially reasonable efforts to ensure the protection of your personal information. Personal information we have collected may be stored and processed in the United States or any other country in which we or our affiliates, subsidiaries or agents maintain facilities, and by using the Services or otherwise providing personal information, you consent to any such transfer of information outside of your country.

See the following third party service provider policies and terms, which may differ from the terms hereof:

1. Olo’s Privacy Policy and Terms of Use related to Olo’s collection and usage of information related to digital ordering services.

2. The Punchh Privacy Policy related to Punchh’s usage of information through the Snarf’s Rewards program.

3. The ezCater Terms of Service and Privacy Policy related to ezCater’s usage of information through the Snarf’s or Snarfburger catering order placement page.

4. Card Market’s website for information related to Card Market’s usage of information through the Snarf’s and Snarfburger gift card sales

5. Shopify’s Terms of Serviceand Privacy Policy related to Shopify’s collection and usage of information based on online purchases of Snarf’s merchandise.

CONTROL YOUR PERSONAL INFORMATION

For personally identifiable information we maintain as part of our mobile application or loyalty program, you may request that we delete any of that personally identifiable information. In some circumstances, we may not be required to honor your request for deletion – for example, if we need to hold on to your information to protect the security or functionality of our operations, to service your account, or to comply with legal obligations. However, note that your request to delete personal information from the app or loyalty program will result in the termination of your participation and involvement in any rewards or other loyalty program offered by us because the operation of the program is tied to the participants’ identities, contact information, and program participation/purchase history data.

Except to the extent set forth above and as required under any applicable state laws as discussed below, we do not currently maintain a process for a user to review or request deletion of or changes to the personally identifiable information submitted. However, if any of the personal information that you provide to us changes, or if you no longer desire for us to retain your personal information for the purposes set forth in this Privacy Policy, you may request the correction, update or deletion of such information by contacting us by any of the means set forth at the bottom of this Privacy Policy.

For any request to delete or change information, please be sure to provide complete account information so we can identify you in our records. We will consider the request, but are not obligated to delete or change any information provided (subject to the statements above related to the app and loyalty program, and any state law requirements, as discussed below).

You may stop the delivery of future promotional e-mails from us by responding directly to any e-mail you receive with a request to remove you from the mailing list.

SECURITY OF YOUR PERSONAL INFORMATION

We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure; to detect unauthorized access thereof; to monitor our systems for vulnerabilities; and record and retain system information to enable security audits and investigations. For example, we store the personal information you provide on computer systems with limited access that are located in controlled facilities, or with third party hosting companies or other agents who have similar conditions. However, no method of transmission over the Internet, or method of electronic storage, is 100 percent secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. Any transmission of personal information to us is at your own risk.

THIRD PARTY WEBSITES

Eatsnarfs.com, snarfburger.com, and other portions of the Services may contain links to websites not controlled or operated by us, including those of other private entities and organizations. Please be aware that when you follow a link to another website, you are then subject to the privacy policy or statement of the new website. We do not take responsibility for, nor make any claim or representation as to the privacy policy or statement of any other website. We recommend that you review the privacy policy or statement of any other website before submitting personal information to the controller or operator of such website. We encourage you to review the privacy statements of websites you choose to link to from the Services so that you can understand how those websites collect, use and share your information. We are not responsible for the privacy statements or other content on such third party websites.

CHILDREN UNDER 13 AND 18

The services are not directed at children under 13 years old, and we do not knowingly collect information from children under 13 years old. If you are under 13 years of age, you should not use eatsnarfs.com, snarfburger.com, or any other part of the Services for any purpose. For any residents of California under the age of 18 using the Services, we will permit removal of any information submitted upon the user’s request.

E-MAIL OR TEXT COMMUNICATION

By sending an electronic mail or text message to us, for example, by sending an e-mail requesting information on our services, you may be sending us personally identifiable information. In these cases, we may retain the information as long as necessary to accurately respond to your request. Please be aware that e-mail and text messaging are not necessarily secure from interception or misdirection. For your own protection you may want to communicate sensitive information to us using a method other than e-mail or text.

TERMS OF USE

By using the Services, you are bound to the Snarf’s Terms of Use . You can access those Terms of Use separately through eatsnarfs.com and snarfburger.com.

CHANGES TO THIS POLICY

We will occasionally update this Privacy Policy to reflect new developments and company and customer feedback. If there are material changes to this policy or in how we will use your personal information, we will post them to this page or a similar page regarding privacy on eatsnarfs.com and snarfburger.com. We encourage you to periodically review this policy to be informed of how we are using and protecting your information.

STATE SPECIFIC CONSUMER PRIVACY ACT PROVISIONS

The following terms are contained in the privacy laws of the designated states, and they shall apply to the extent such laws are found to apply to us and to you:

Colorado Resident Rights

If you are a Colorado resident, you have the rights set forth in this section pursuant to the Colorado Privacy Act (the “Colo. CPA”). Please see the “Colo. CPA - Exercising Your Rights” subsection below for instructions regarding how to exercise these rights.

If there are any conflicts between this section and any other provision of this Privacy Policy (not including other provision that expressly applies to residents of other states), and if you are a Colorado resident and Colo. CPA applies, the portion that is more protective of personal information shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at .

For purposes of this Section, “personal information” means information that is linked to or reasonably linkable to an identified or identifiable individual.

We do not request and do not knowingly collect any personal information that constitutes “Sensitive Data” under the Colo. CPA.

Colo. CPA - Personal information Sales Opt-Out and Opt-In

We do not currently sell your personal information, or engage in Targeted Advertising or Profiling using your personal information (within the meaning of the Colo. CPA).

Colo. CPA – Access

You have the right to request confirmation as to whether we are processing your personal information and to access that personal information. This includes the right to access such information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. This right may be exercised no more than twice per calendar year.

Colo. CPA – Deletion

You have the right to request that we delete the personal information that we have collected about you. However, note that your request to delete personal information will result in the termination of your participation and involvement in any rewards or other loyalty program offered by us because the operation of the program is tied to the participants’ identities, contact information, and program participation/purchase history data.

Colo. CPA – Correction

You have the right to request that we correct any inaccuracies in the personal information that we maintain related to you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

Colo. CPA - Exercising Your Rights

To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are either the person about whom we have collected personal information or are an agent authorized by that person, including without limitation your name and email address, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use personal information provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt, although we may extend this time to the extent permitted by the Colo. CPA. We will not charge you a fee for making a Valid Request once per calendar year, although we may charge you a fee to the extent permitted by the Colo. CPA for the second or subsequent request in a calendar year.

You may submit a Valid Request (i) by e-mail to , (ii) by calling 720-389-7920, or (iii) by mailing a printed request addressed to Snarf’s Worldwide Holding Company, LLC 2762 Walnut Street, Denver, Colorado 80205.

If we refuse to take action on a request, you may also appeal this decision by the same methods, in which case you must provide adequate information to identify the refused request. We will generally respond to a valid appeal within 45 days of receipt, although we may extend this time to the extent permitted by the Colo. CPA Any concerns about the rejection of any such appeal may be directed to the Colorado Attorney General’s Office.

Colo. CPA - We Will Not Discriminate Against You for Exercising Your Rights Under the Colo. CPA

We will not discriminate against you for exercising your rights under the Colo. CPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the Colo. CPA. (However, we may offer different prices, selections of goods and services, and other benefits for voluntary participation in our loyalty or rewards programs to the extent permitted under the Colo. CPA.)

EUROPEAN UNION ADVISORY

The Services are not directed at individuals in the European Union and we do not currently knowingly collect any personally identifiable information from individuals in the European Union.

INTERNATIONAL USE

We make no representations that this Privacy Policy is appropriate for locations outside of the United States, or whether access to the Services and the provision of information through the Services from such locations is permitted. Those who choose to use the Services and provide us with information from such other locations do so on their own initiative and are responsible for compliance with applicable local laws.

CONTACT US

If you have any questions, suggestions, or requests regarding our Privacy Policy, please contact us in any of the following ways:

By e-mail: security@eatsnarfs.com

By telephone: 720-389-7920

By mail: Snarf’s Worldwide Holding Company, LLC 2762 Walnut Street

Denver, Colorado 80205

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