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COLONEL'S CLUB PRIVACY POLICY

Colonel’s Club and any brand within in the Colonel’s Club Loyalty Program (collectively “Colonel’s Club ”) is committed to respecting your privacy. We want to make your online and mobile experiences satisfying and safe. This Privacy Policy describes how we collect, use, disclose, store and otherwise process information through this website (“Site”) and our mobile application (“mobile application” or “app”) in Trinidad and Tobago. We will not use or share your information except as described in this Privacy Policy.

We urge you to read this Privacy Policy so that you understand our commitment to you and your privacy, and how you can participate in that commitment. By using this program, or signing up for the Colonel’s Club ™ Rewards Program (“Colonel’s Club ”), you acknowledge that you understand and agree to the terms of this Privacy Policy.

Colonel’s Club complies with the General Data Protection Regulation (GDPR) as set forth by the European Parliament in April 2015. The regulation mandates that Colonel’s Club protects the personal data and privacy of EU data subjects. If there is any conflict between the policies in this Privacy Policy and the GDPR, the GDPR principles shall govern with respect to EU residents.

CONSENT

Colonel’s Club collects information about you in connection with many of our services. When working with us or using our Site or app program, you may be prompted to make an account which may hold Personal Information, such as your name, birthdate, mailing address, email address, or credit card information. Prior to collecting information, Colonel’s Club will obtain your consent. At any point in time, you can revoke consent and we will cease using and processing your data immediately.

Colonel’s Club gives you choices about the ways we collect, use, and share your personal information. You can choose what contact and financial information will be stored in your account and preferences. However, if you choose not to provide certain details, some of your experiences with us may be affected.

In some jurisdictions, in addition to you agreeing to this Privacy Policy, data privacy laws may require us to obtain a separate consent before we send you information that you have not specifically requested. In certain circumstances, your consent may be implied (e.g. where communications are required in order to fulfill your requests and/or where you have volunteered information for use by us). In other cases, we may seek your consent expressly in accordance with applicable laws (e.g. where the information collected is regarded to be Sensitive Personal Information under local regulations).

ACCESS TO UPDATE/DELETE PERSONAL INFORMATION

You have the right to access and limit the use and disclosure of your personal data. Colonel’s Club provides you many opportunities to access and update your Personal Information. You can ensure that any account, contact, or financial information is up-to-date and you can correct, update, or delete inaccuracies to the information by logging into your account or contacting Colonel’s Club at our Contact Us. Colonel’s Club will attempt to answer all requests that we correct the data if it is inaccurate or delete it, provided Colonel’s Club is not required to retain it by law or for legitimate business purposes.

In addition, to protect your privacy, we will require you to prove your identity before granting access to, or agreeing to update, correct or delete your Personal Information and we will only implement requests with respect to Personal Information about you (not anyone else).

A NOTE SPECIFIC TO EU DATA SUBJECTS

Any personal information collected about EU data subjects via our Site or mobile app program is processed in the Trinidad and Tobago by Colonel’s Club or by a third party acting on our behalf. When you provide personal information to Colonel’s Club, you consent to the processing of your information in the Trinidad and Tobago. Our websites are hosted in the Trinidad and Tobago. If, at any point in time, you wish to know what data we process about you, you can request to access the information by completing the GDPR Contact Us online form.

You have the right to access and limit the use and disclosure of your personal data. Colonel’s Club provides you many opportunities to access and update your Personal Information. You can ensure that any account, contact, or financial information is up-to-date and you can correct, update, or delete inaccuracies to the information by logging into your account or completing the GDPR Contact Us online form. Colonel’s Club will attempt to answer all requests that we correct the data if it is inaccurate or delete it, provided Colonel’s Club is not required to retain it by law or for legitimate business purposes.

You have the right to request that Colonel’s Club erase your personal data on a number of grounds, including if the data is no longer necessary for its original purpose or if you withdraw consent. If Colonel’s Club receives a request, we will inform all third parties who have the data of this request. You also have the right to object to your personal data being processed for profiling, direct marketing, scientific research, and statistics. If you wish to object, please complete the GDPR Contact Us online form. You have the right to transfer your personal data from one electronic processing system to another without being prevented from doing so by Prestige Points’ data processor.

WHAT INFORMATION DO WE COLLECT?

Personal Information

We only collect Personal Information from you when you voluntarily submit such information on our Site or when using our app. We use this information for the specific purpose for which it was provided, such as registering for Colonel’s Club Rewards, entering a contest, participating in a survey, finding a Prestige Holdings location, making a reservation, ordering online (where applicable) and other purposes described in this Privacy Policy. “Personal Information” refers to any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, such as an identification number, physical, physiological, mental, economic, cultural, or social identifiers. Personal Information by collected may include the following: name, address, date of birth, gender, and contact data (including email address, telephone number, and physical address), and online identifiers like social media handles, if provided.

Non-personal Information

We may also collect information that is related to you but that does not personally identify you (“Non-personal Information”). Non-personal Information includes information that could personally identify you in its original form, but that we have modified (for instance, by aggregating, anonymizing, or de-identifying such information) in order to remove or hide any Personal Information.

Technical Information

We may also collect Technical Information about visitors to our Site and users of our app, which is internet or other electronic network activity information such as the domain type, browser version, service provider, and device type (for mobile) used to access our Site or app program. This “Technical Information” is information that does not, by itself, identify a specific individual but which could be used to indirectly identify you. Like many other commercial websites, our Site may employ a standard technology called a “cookie” to collect information about how our Site is used and to remember visitors. This information also provides us information about the technical stability of our Site, app and Colonel’s Club Rewards™ program, as well as support our customer analytics efforts. When you visit our Site, our Servers send a cookie to your computer or mobile device to help personalize your experience and advertisements. Cookies recognize your web browser but information collected from cookies is not personally identifiable. Some web browsers provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer, tablet or mobile device. Although you are not required to accept cookies, if you block or reject them, certain features of our Site will be disabled and you will limit the functionality we can provide when you visit our Site.

For those guests that access our in-store Wi-Fi, we will have access to such guests’ device ID and name, if available.

When you log in to our mobile application, you will be asked whether you want the mobile application to remember you. If you choose yes, the mobile application will remain logged in to your information. At any time you can choose to log out by choosing the logout button on the application.

Information Collected about Friends/Family

Colonel’s Club may also collect information about your friends and family through your interactions on our services. Referring friends to our services requires you to send their personal information to Prestige Points. Other instances, such as sharing content, may also require you to send their personal information to us.

Information Collected from Social Media Applications/Networking Websites

Our Site includes social media features, such as the Facebook Like button and other widgets that run on our Site. These features may collect your IP address and which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the organization providing it.

Information Collected from Other Sources

Colonel’s Club may also collect information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our service to you, and prevent or detect fraud. We work closely with third parties (for example, business partners, service providers, subcontractors, advertising networks, analytics providers, search information providers, fraud protection services) and may receive information about you from them. The following are some examples:

Third-Party Vendors:In order to provide services and improve KFC websites, we may engage the services of third-party vendors. In the process of supplying services to Colonel’s Club , these third-party vendors may need to collect Personal Information about you.
Co-branding:Some company websites or services may be co-branded and offered in conjunction with another company. If you use such websites or services, both Colonel’s Club and the other company may receive the Personal Information that Colonel’s Club collected via that co-branded website or service.
Public Forums, Blogs and the Customer Reference Program:KFC or Colonel’s Club websites may feature bulletin boards, blogs or forums. Any Personal Information that you choose to submit via such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages.
Flash LSOs: We use Local Storage Objects (LSOs) such as HTML5 and Flash to store content information and preferences. We partner with third parties to provide certain features on our site or to display advertising based upon your browsing activity. Various browsers may offer their own management tools for removing HTML5 LSOs.
Log Files:Log files record website activity on our services and enable us to gather statistics about our users' browsing habits. These entries help Colonel’s Club determine (among other things) how many and how often users have accessed or used our services, which pages they've visited, and other similar data.
Clear GIFs:Clear GIFs, sometimes called "web bugs" or "web beacons," are small electronic images that are placed on a web page or in an email message. We use clear GIFs to monitor user behavior, deliver cookies, collect information, count visits, understand usage and campaign effectiveness, and to tell if a recipient has opened and acted upon an email.

INFORMATION COLLECTED THROUGH COLONEL’S CLUB REWARDS®

Guests that join Colonel’s Club Rewards will be asked to provide their email address and phone number. We require your email address to communicate with you about earned rewards, program benefits, program changes, and all promotions and offers available to members.

You have the ability to access and edit the personal information that you have provided to Colonel’s Club Rewards. To update your information or to cancel your account, please visit www. kfc.tt

If you join Colonel’s Club via the mobile application or log in to your Colonel’s Club Rewards account on the mobile application, you will be asked whether you want the mobile application to remember you. If you choose yes, the mobile application will remain logged in to your account. You may be prompted to log in again to access certain functions on the mobile application, such as requesting rewards or paying for online placed orders. At any time you can choose to log out of your account by choosing the logout button on the application. Guests that use our app to order and pay online will, for security purposes, be automatically logged out after a certain period of non-use.

HOW WE USE COLLECTED PERSONAL INFORMATION

We use the information we collect from you for the following purposes:

to perform the task or transaction that you request;
to understand your preferences and history using our Site, mobile application, Colonel’s Club Rewards and related services;
to design initiatives to meet those preferences;
to make it easier and more rewarding for you to use our Site, mobile application and related services by eliminating online hassles; and
to generally make your guest experience at our restaurants more satisfying (in the case of voluntary surveys, push notifications, and customized messages)

If you provide contact information to us, such as a postal or email address, we may use this information to contact you with information about us and our special offers. You can opt-out of receiving these communications from us at any time by following instructions in the communication or contacting us using the information below. If you have downloaded our app, we may contact you about information about us and our special offers. You can opt-out on your personal device by following your device instructions on removing app push notifications.

SECURITY MEASURES TO PROTECT YOUR PERSONAL INFORMATION

Security of all information is of the utmost importance for Colonel’s Club . Colonel’s Club uses technical and physical safeguards to protect the security of your personal information from unauthorized disclosure. We operate secure data networks protected by industry standard firewall and password protection systems to keep all information secure. We also make all attempts to ensure that only necessary people and third parties have access to personal information. Any particularly sensitive information, such as a customer’s credit card number, is encrypted prior to transmission. Nevertheless, such security measures cannot prevent all loss, misuse, or alteration of personal information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. In the case of a data breach, we will notify you without delay of any loss, misuse or alteration of personal information that may affect you. We will notify relevant regulatory bodies within 72 hours of a breach.

Colonel’s Club retains your information for business purposes, for as long as your account is active, and/or for as long as is reasonably necessary to provide you with our products and services. Colonel’s Club will also retain your information as reasonably necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may also retain cached or archived copies of your information for a reasonable period of time. At any point in time, you can withdraw consent and we will immediately stop processing your data.

INFORMATION WE DISTRIBUTE OR MAKE ACCESSIBLE TO THIRD PARTIES

We will not provide access to your information other than as described in this Privacy Policy. We will not rent, sell or share information about you other than as described in this Privacy Policy. The information that you provide is collected by KFC?. In the case of links to our gift card site or other sites, the information you voluntarily provide at those sites will only be shared with those service providers who help Colonel’s Club administer those websites or mobile application and the services they provide. In any case, these service providers may use the information only for the purpose of administering the digital or mobile application and its services for Colonel’s Club , and are contractually required to protect the information and to comply with the obligations of the GDPR and CCPA.

We may share your personal and non-personal information or preferences with trusted third parties for business purposes, to operate and improve, or provide any service requested by you, on our digital or mobile applications. We share information including name, address, date of birth, gender, and contact data (including email address, telephone number, and physical address), and online identifiers like social media handles, if provided. These third parties only have access to personal information necessary for them to complete their service. We require that our third-party service providers and channel partners agree to keep confidential all information we share with them and to use the information only to perform their obligations in the agreements we have in place with them. These third-party service providers and channel partners are expected to maintain privacy and security protections that are consistent with Prestige Points’ privacy and information security policies. We may develop and share summary reports for our advertising partners and agencies that contain non-personal aggregate raw numbers or statistics (which means such information will not tell them who it was that stated a preference or clicked an option).

We may be required to disclose personal information to governmental authorities, law enforcement agencies, government agencies or legal entities. If requested as part of a legal proceeding, we will provide this information upon receipt of and in accordance with appropriate documentation. Except for websites directly related to Colonel’s Club programs and services, Colonel’s Club cannot control the links or their websites and we are not responsible for the contents of any linked website or any link contained in a linked website. The inclusion of any link does not imply endorsement of the website. The use and/or privacy provided by a linked website as to any information you provide in accessing that website is in no way subject to our privacy policy. Any linked website may have its own policy that could differ considerably from our policy, or the linked website may not display any privacy policy at all. In any case, even though a linked website is accessed through our website, we cannot be responsible for any use that a linked website may make of your information.

From time to time, we may conduct promotions and giveaways on or through the Site and app program. As part of registering for those giveaways, you may be asked whether you’d like to receive notifications via email and/or text message to your mobile device. If you agree to those communications, you may receive emails and/or text messages regarding that promotion or giveaway, and text messages may be subject to text message and data rates.

A NOTE REGARDING INTERNATIONAL USERS

This Site and app are operated in Trinidad and Tobago. If you access the Site or use the app outside of the Trinidad and Tobago, you understand and agree that all information that you provide and that we collect will be collected, processed, stored and maintained in Trinidad and Tobago and protected as noted in this Privacy Policy.

A NOTE REGARDING BUSINESS TRANSFERS

In the unlikely event that Colonel’s Club is bought, sold, files for bankruptcy or otherwise dissolves, all personal and non-personal information collected from and about users shall be considered assets of KFC Trinidad & Tobago /Colonel’s Club, and as such, may be transferred or sold, in whole or part to one or more other companies as part of that transaction. Prior to this transaction, we will obtain your consent for the disclosure of your Personal Information.

A NOTE REGARDING CHILDREN

Like you, we have children of our own and are concerned about their safety when they use the Internet. We want you and your family to be safe while visiting our website. Our Site and app are not designed for nor directed to children. We do not offer any program participation to children under the age of 13. We do not knowingly request or collect information about children under the age of 13 on the Site or app. If we learn that someone under 13 has provided Personal Information through our Site or app, we will use reasonable efforts to remove that information from our database.

CHANGES TO THIS POLICY

We will occasionally update this Privacy Policy to reflect changes in our policies and practices from time to time. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Changes will be posted here, and we will also post an appropriate notice on our website. Please review this policy periodically, and especially before you provide any Personal Information to us through the Site.

INQUIRY AND COMPLAINT PROCESS

Colonel’s Club commits to resolve complaints about your privacy and our collection or use of your Personal Information. Customers may contact Colonel’s Club with any questions, concerns, or inquiries about this Privacy Policy or data. If you would like to make a formal complaint, please complete the Contact Us Online Form.