This Privacy Code is effective as of April 12, 2016.
This Privacy Code outlines Arby's Restaurant Group's Inc. ("Arby's") commitment to you and its commitment to comply with applicable Privacy legislation in Canada which incorporates the following ten (10) principles:
Principle No. 1 - Accountability
We are accountable for the personal information that we collect about you.
We will strive to implement these Principles and will communicate to our employees and other entities acting our behalf through our policies and procedures the need to protect your personal information and our requirements for management of your personal information, as reflected in these Principles.
Our Chief Privacy Officer for Canada has ultimate responsibility for ensuring compliance with these Principles within the organization.
Principle No. 2 - Identifying Purpose
We will only collect personal information that is reasonably necessary for our business activities. For example, we will only collect personal information from customers when they volunteer their information in order to: enter a contest or sweepstakes; to respond to a customer survey; to order gift certificates or gift cards; to participate in a customer loyalty program; agree to receive our promotional communications, such as emails; or to make inquiries of us. Before we collect personal information from you, we will identify the purposes for collecting it.
This Site is intended to provide a unique and entertaining experience for users. We do not require users to register or submit personal information in order to visit the Site and most activities on the Site can be performed without supplying personal information.
Arby’s gathers personal information, such as first and last names, addresses and email addresses, when voluntarily submitted by you. For example, personal information may be collected when you sign up to receive deals and exclusive offers on our Site. In addition, when you visit our Site, we may ask to collect information about your location using technologies such as GPS, Wi-Fi, or cell tower proximity. Arby’s uses this information for location-based services such as locating nearby Arby’s restaurants or identifying special offers that may be of interest to you. When you visit our Site, you may choose not to allow Arby’s to use your physical location. If you would like us to delete location information we have collected, please contact us at the email or postal address listed below. Please note that the Site may not function properly following deletion and that we may be required by law to retain certain information.
We may use personal information in sweepstakes, contests or promotional activities, including:
- to register you for those activities, to verify that you comply with the published rules and to notify you if you are a winner;
- for coupon, premium or prize delivery;
- to publicize the names and, where applicable, likenesses of winners;
- for notification of special offers; and
- to ensure that we comply with applicable laws.
The personal information you disclose for these and similar activities may be shared with third parties, such as those who may administer the activity for us and shipping companies who may deliver a prize or premium. We will inform you at the time we are collecting the personal information that such collection is a requirement for participation.
We may also use your personal information for the following purposes:
- to personalize and enhance our Site and your Site experience;
- to send you personalized information about our Site via email;
- to send you advertising or promotional material from us, our advertisers or business partners; and
- to contact you for feedback regarding us, our advertisers or business partners.
Should you respond to a particular offer sent on behalf of our business partners or advertisers, we may also use your personal information to provide a report to our advertisers or business partners that tells them who responded to a particular offer. Similarly, if you accept an offer contained in an email, we may provide the advertiser or business partner with the personal information necessary to fulfill that offer.
Should any of our business partners or advertisers request your personal information for their direct use in advertising or marketing (i.e., when the contact with you would come from them and not from us on their behalf), you will always be given the opportunity to remove yourself from the list.
Your personal information may also be shared with those persons or entities that administer our Site. Your personal information will only be shared with administrators, business partners or advertisers for a particular purpose, and they will not be permitted to use it for any unauthorized purpose.
We may also collect personal information to protect your security or ours, to protect us against liability, or to comply with applicable law. personal information collected for such reasons will not be used for any other purpose.
Principle No. 3 - Obtaining Consent
With your consent, we may use your personal information to send you promotional offers or coupons. You may opt-out of these communications at any time.
We will always obtain your consent to the collection, use or disclosure of your personal information except in limited and specific circumstances, and as permitted by law. For example, we reserve the right to collect, use or disclose any information (i) in connection with enforcement of laws or contractual rights or when required by court order; (ii) in connection with an emergency involving a person's life, health or security, or (iii) when use or disclosure is for the benefit of the individual (such as a gift). We will strive to ensure that individuals understand how their personal information will be used or disclosed.
Except in the specific circumstances enumerated above, we will always provide you the opportunity to decline to give consent, or if previously given, to withdraw such consent.
Principle No. 4 - Limitations on Collection
We will only collect information that is reasonably necessary for the purposes identified to you. Personal information will be collected by fair and lawful means, and the type of information we collect may vary based on the purpose. For example, if you enter a contest, we need your name and other contact information so that we may contact you if necessary. We may require additional information to verify a winning entry.
We may also automatically collect information about your use of the web site through cookies, web beacons, and other technologies.
Web Beacons. Web beacons are small pieces of data that are embedded in images on the pages of web sites. We may use these technical methods to analyze the traffic patterns on our web site, such as the frequency with which our users visit various parts of our web site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send to determine whether you have opened those e-mails or clicked on links in the e-mails. The information from use of these technical methods may be collected in a form that is not personally identifying.
Users in Canada may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance of Canada (“DAA Canada”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA Canada companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.
Opting out from one or more companies listed on the DAA Canada Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our web site or on other web sites. You may continue to receive advertisements, for example, based on the particular web site that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA Canada or NAI web sites, your opt out may not be effective. Additional information is available on the DAA Canada’s web site at http://youradchoices.ca/ or the NAI’s web site at www.networkadvertising.org.
Principle No. 5 - Limitations on Use, Disclosure and Retention
We will only use or disclose personal information for the purposes for which it was collected, except with your consent or as permitted or required by law. Your personal information will only be retained for so long as is required or appropriate for such purposes. We will retain your personal information so long as it is necessary or relevant for the identified purpose or as required by law. We will destroy or make anonymous personal information that is no longer required for the identified purpose.
We may share personal information with our subsidiaries and affiliates and our franchisees. Any use of this information will comply with these guidelines. We do not sell, transfer or disclose personal information or knowingly permit our third party providers to do so. In the course of our business, we may contract with third party providers to perform a variety of functions, such as fulfilling orders, assisting with promotions or programs, providing technical, billing or other services, or enforcing or investigating transactions or business operations. These companies may have access to personal information as necessary to perform their duties. These companies are instructed to use such personal information for the purpose of performing their duties and for no other purpose.
We reserve the right to use or disclose personal information as necessary to comply with applicable laws, regulations or other legal requirements, to protect our legitimate business interests, to fulfill your requests, or to cooperate in any law enforcement investigation or investigation on a matter of public safety.
Arby’s is a United States-based organization, headquartered in Atlanta, GA. Accordingly, your information collected and used by Arby’s is generally stored in the United States and is thus accessible to law enforcement, government and regulatory authorities according to applicable United States law, which may differ from the law applicable in your jurisdiction.
Principle No. 6 - Keeping Personal information Accurate
We will keep personal information as accurately, completely, and as up-to-date as is reasonably necessary and possible for the purposes for which it is to be used. Since you are providing your personal information directly to us, we will take care to enter your information accurately, but we typically will not make any further effort to verify its accuracy or to update. For example, if you provide your telephone number to us, we will assume it is correct. We will update or correct any errors in personal information if you provide the particulars of any required updating or correction in a manner satisfactory to us.
Principle No. 7 - Security of Personal information
We use appropriate security measures to protect against loss, theft, unauthorized access, disclosure, use or modification of personal information. We require that our employees keep all personal information confidential and comply with our information security standards. We also require that third parties to whom personal information may be disclosed provide a level of security for such information that meets our standards. We will use reasonable efforts to assure that the confidentiality of information is maintained when we dispose of or destroy business records.
Principle No. 8 - Information About Our Policies And Procedures
The information we will provide to you about our policies and procedures will include:
- the name of the person who is responsible for our privacy policies and practices;
- the name of the person to whom complaints or inquiries may be sent;
- the means of gaining access to personal information held by us;
- a description of the type of personal information held by us and a general account of its use;
- a reference to our web site(s) where further information regarding our policies and procedures may be obtained.
Principle No. 9 - Your Access to Information
We will advise you of the existence, use, and disclosure of your personal information on file with us and give you access to that information. In that regard, you must make a request in writing and deliver it to the Chief Privacy Officer for Canada at the following address:Arby's of Canada Inc.
Chief Privacy Officer
7045 Edwards Blvd. Suite 304
Mississauga, ON L5S 1X2
We may need specific information about you to enable us to search for, and provide you, with the personal information we have about you. We will advise you whether or not we hold personal information about you and will disclose that information along with particulars with respect to its source, unless such disclosure is prohibited by law. We may charge you a nominal fee depending on the nature of your request. We will advise you of any cost prior to the retrieval of such records.
We will amend our records and, where appropriate, shall make reasonable commercial efforts to advise third parties respecting any amendments to reflect the accuracy and completeness of personal information held by us or disclosed to such third parties. If appropriate, we will advise a third party to whom information has been disclosed of any unresolved dispute regarding the accuracy or completeness of your personal information.
In certain circumstances, we may be unable to provide access to some or all of your information. Such circumstances include those in which the information cannot be separated from the records of others, cannot be disclosed for reasons of personal security or commercial confidentiality, or is protected by solicitor-client privilege. If we are unable to provide some of the personal information we hold about you and in that case we will let you know the reasons why.
We reserve the right not to respond to requests for access to information we reasonably deem to be frivolous or vexatious.
Principle No. 10 - Questions or Concerns
If you have any question, concern or complaint regarding our compliance with these Principles, you may contact Arby's Restaurants of Canada's Chief Privacy Officer at the following address:Arby's of Canada Inc.
Chief Privacy Officer
7045 Edwards Blvd. Suite 304
Mississauga, ON L5S 1X2
We will investigate all complaints as expeditiously as possible and, if a complaint is found justified, we will use reasonable efforts to resolve the matter.