Last Revised on: May 25, 2021
This Privacy Policy for California Residents (“California Privacy Policy”) applies to websites and mobile applications of , Einstein Noah Restaurant Group, Inc., Bruegger’s Enterprises, Inc., Noah’s New York Bagels Company, Inc., and Manhattan Bagel Company, Inc. (together “Operator,” “We,” “Us,” and “Our”). This California Privacy Policy is parallel in scope to and supplements the information contained in Our general privacy policy (“Website and Mobile App Privacy Policy”). We adopted this California Privacy Policy in accordance with the notice requirements under the California Consumer Privacy Act of 2018, as amended (“CCPA”), and any terms defined in the CCPA have the same meaning when used in this California Privacy Policy.
Definitions Specific to this Policy
The CCPA includes definitions for terms specific to this California Privacy Policy that do not apply to Our Website and Mobile App Privacy Policy, including the following terms:
“Personal Information” means 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. Personal Information does not include publicly available information obtained from government records; deidentified or aggregated consumer information that cannot be reconstructed to identify you; any information covered under the Gramm-Leach-Bliley Act or the California Financial Information Privacy Act, activities covered by the Fair Credit Reporting Act, or protected health information as defined under the Health Insurance Portability and Accountability Act.
“Sale” or “sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.
“Service Provider” means a sole proprietorship, partnership, limited liability company, corporation, association, or other legal entity that is organized or operated for the profit or financial benefit of its shareholders or other owners, that processes information on behalf of a business and to which the business discloses a consumer’s Personal Information for a business purpose pursuant to a written contract.
“Third Party” means a person or entity who is not a business that collects Personal Information from consumers, as defined in the CCPA, and to whom the business discloses a consumer’s Personal Information for a business purpose pursuant to a written contract.
The Personal Information We Collect and Disclose
The chart below shows the categories of Personal Information We may collect; examples of the type of Personal Information in each category; all types of sources from which each category of Personal Information is collected; the business purposes for which that category of Personal Information is collected; and all types of third parties with whom that category of Personal Information is shared. As this chart shows, We disclose certain Personal Information to third parties for a business purpose. We also share/sell certain Personal Information to third parties. This information covers the past 12 months.
| Categories of Personal Information | Examples: | Types of Sources from which this Category of Personal Information Is Collected | Business Purpose(s) for Collection | Types of Third Parties with Whom this Category of Personal Information Is Shared/Sold or Disclosed |
|---|---|---|---|---|
| Unique identifiers | Name, signature, address, telephone email, account name, online identifier, IP address | -Directly from you by telephone, Our websites, Our mobile apps -Social media -Other individuals -Rewards programs -Analytics providers -Vendors -Franchisees -Business partners | -Provide information, products and services -Security, credit or fraud prevention -Provide customer service and assess satisfaction -Personalize customer experience -Improve products and services -Improve marketing and customer communications -Comply with legal requirements | Disclose: -Stored value account administrator -Franchisees Share/Sell: -Online advertising partners -Analytics providers -Vendors -Business partners |
| Financial information | Partial credit card number, tokenized credit card number, partial debit card number, tokenized debit card number or any other financial information | -Directly from you by telephone, Our websites, Our mobile apps, in-person -Franchisees -Gift card provider | -Complete transactions -Track purchase history -Process claims | Disclose: -Vendors -Business partners -Franchisees -Gift card provider |
| Purchase history | Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies | -Directly from you by telephone, Our websites, Our mobile apps, in-person -Other individuals -Rewards programs -Analytics providers -Vendors -Franchisees -Business partners | -Complete transactions -Customer communication related to goods and services -Dispute resolution -Process claims -Marketing communications -Operate Our systems | Disclose: -Stored value account administrator -Franchisees -Gift card provider Share/Sell: -Online advertising partners -Analytics providers -Vendors -Business partners |
| Internet activity | Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and other web activity | -Directly from you by cellular telephone, Our websites, Our mobile apps, in-person -Social media | -Provide information, products and services -Provide customer service and assess satisfaction -Personalize customer experience -To monitor Our click through rate -Improve products and services -Improve marketing and customer communications -Comply with legal requirements | Disclose: -Franchisees Share/Sell: -Online advertising partners -Analytics providers -Vendors -Business partners |
| Geolocation data | Geolocation data | -Directly from you by cellular telephone, Our websites, Our mobile apps | -Provide mobile applications -Provide customer support -Offer relevant services | Disclose: -Franchisees Share/Sell: -Online advertising partners -Analytics providers -Vendors -Business partners |
| Inferences | Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, predispositions, behavior, and attitudes | -Directly from you by telephone, Our websites, Our mobile apps, in-person -Social media -Rewards programs -Analytics providers -Vendors -Franchisees -Business partners | -Provide mobile applications -Provide customer support -Offer relevant services -Security, credit or fraud prevention -Personalize customer experience -Provide information and notices related to use of Our products and services -Improve products and services -Improve marketing and customer communications | Disclose: -Franchisees Share/Sell: -Online advertising partners -Analytics providers -Vendors -Business partners |
We will not collect a category of Personal Information not listed above, or use any Personal Information collected in any of the above categories for a business purpose not listed above, without first providing you with notice.
You have the right to request certain information regarding the Personal Information We have collected about you in the preceding 12 months. You may make such a request up to twice in a 12-month span. Please note that there are circumstances in which We may not be able to comply with your request pursuant to the CCPA, including when We cannot verify your request and/or when there is a conflict with Our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request if this is the case.
- If you would like to request (1) specific pieces and the categories of Personal Information collected about you; (2) the categories of sources providing that Personal Information; (3) the categories of third parties with whom We have shared that Personal Information; and (4) the business purposes for collecting, using and sharing that Personal Information, click here email help@bagelbrands.com. The link will take you to an interactive webform that you can complete and submit to make a request for information that We will then verify; if you use a telephone number, you will be guided through a process that will allow you to submit a verifiable request.
Verification Process
In order to protect your information, We will confirm a requestor’s identity before responding to any request. You must log into your account or We will ask a few questions in order to confirm your identity. To complete the verification process you must log into your account and independently verify account access or correctly answer one or more questions to confirm your identity. If We still cannot verify your identity as required by the CCPA, We will let you know and may ask additional questions. Otherwise, We will acknowledge your request and contact you later with Our full response.
We will only send CCPA verification questions from one of the brand-specific email addresses listed below this paragraph. Before sending a verification response, please double-check the email address. If you receive an email that appears to be from Us but is not from one of Our CCPA verification email addresses listed below, do not respond.
Bruegger’s Bagels: dataprivacy@brueggers.com
Einstein Bros. Bagels: dataprivacy@einsteinbros.com
Manhattan Bagel: dataprivacy@manhattanbagel.com
Noah’s New York Bagels: dataprivacy@noahs.com
Any information We gather through this process will only be used for consumer verification, security procedures, or fraud-prevention. We will delete any verification information as soon as practical after processing your request.
Financial Incentives and Non-Discrimination
We will not discriminate against you if you exercise any of the rights provided by the CCPA set forth in this California Privacy Policy. Please note that a legitimate denial of a request for information, deletion, or to opt-out is not discriminatory, nor is charging a fee for excessive or repetitive consumer requests as permitted by the CCPA.
Certain of Our companies (but not all) offer a loyalty/rewards program (each, a “Rewards Program”) as a financial incentive to consumers who allow Us to retain and share their Personal Information. These incentives generally include complimentary or discounted products, and other special offers. For more information on Our Rewards Programs, visit https://bagelbrands.com/loyalty-program-terms-and-conditions/. When exercising your rights under this California Privacy Policy, if you select either the option to delete your data or opt out of its sale, such elections will effectively prevent access to your Rewards Program account and/or your participation in our Rewards Programs and, correspondingly, We unfortunately must treat such elections as a withdrawal from all of Our companies’ Rewards Programs, and your account for the Rewards Programs will be terminated. Upon termination of your Rewards Program account, (1) all points, rewards and other offers associated with your account will be deemed forfeited, for which no consideration will be given, and (2) if your account has a U.S. dollar funds balance loaded on the account, your funds balance will be transferred by us from your account to a substitute funds access code which will be sent separately by us to you by email.
We estimate the average value of a Rewards Program is $10 per year (which may be higher or lower as to a specific Rewards Program). We arrived at such value by estimating the approximate retail value of complimentary or discounted products provided through a Rewards Program.
Deletion of Your Personal Information
You have the right to request that We delete certain Personal Information that We have collected. Please note that there are circumstances in which We may not be able to comply with your request pursuant to the CCPA, including when We cannot verify your request and/or when there is a conflict with Our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request if this is the case.
- If you would like to request that We delete your Personal Information pursuant to the requirements of the CCPA, click here or email help@bagelbrands.com. The link will take you to an interactive webform that you can complete and submit to make a request for deletion that We will then verify; if you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request.
Authorized Agents
You may designate an authorized agent to exercise your rights under the CCPA on your behalf.
Pursuant to the CCPA:
- Only a business entity or natural person registered with the California Secretary of State may act as an authorized agent.
- You must provide the authorized agent written permission to exercise your rights under the CCPA on your behalf.
- We may deny a request from an authorized agent on your behalf if the authorized agent does not submit proof that he, she, or it has been authorized by you to act on your behalf if We request such proof, as permitted by the CCPA.
- Even if you use an authorized agent to exercise your rights under the CCPA on your behalf, pursuant to the CCPA We may still require that you verify your own identity directly to Us. This provision does not apply if you have provided a power of attorney under California Probate Code sections 4000 to 4465.
Personal Information of Minors
We are proud of Our online information, and We strive to offend no one. However, Our websites and mobile applications are not intended for children or minors under the age of sixteen years. Accordingly, We do not store information from minors under the age of sixteen years. If you believe that a child has submitted personal information to Us, please contact Us at the appropriate email address listed below and We will delete the information.
Bruegger’s Bagels: dataprivacy@brueggers.com
Einstein Bros. Bagels: dataprivacy@einsteinbros.com
Manhattan Bagel: dataprivacy@manhattanbagel.com
Noah’s New York Bagels: dataprivacy@noahs.com
Right to Opt-Out
You have the right to request that We do not sell Personal Information that We have collected. If you exercise that right, please note that pursuant to the CCPA We may have to subsequently inform you that you need to opt-in if the sale of your Personal Information is required to complete a transaction you have initiated. If opting-in is required, We will provide you with the necessary instructions.
- If you would like to request that We do not sell your Personal Information pursuant to the requirements of the CCPA, click here or email help@bagelbrands.com. The link will take you to an interactive webform that you can complete and submit to make a request for deletion; if you use the telephone number, you will be guided through a process that will allow you to submit a request.
- If you use an authorized agent to submit your request to opt-out, We will request that the agent provide Us with proof that he, she, or it has been authorized by you to act on your behalf. The CCPA requires you to provide the authorized agent written permission to exercise your rights under the CCPA.
Additional Information
If you would like additional information regarding Our California Privacy Policy, please email Us at one of the email addresses below.
Bruegger’s Bagels: dataprivacy@brueggers.com
Einstein Bros. Bagels: dataprivacy@einsteinbros.com
Manhattan Bagel: dataprivacy@manhattanbagel.com
Noah’s New York Bagels: dataprivacy@noahs.com
Additional California Privacy Rights
California Civil Code Section § 1798.83 permits users of Our web site that are California residents to request certain information regarding Our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please send an email to the appropriate email address below with the subject “Shine the Light Request.”
You may view Our Website and Mobile App Privacy Policy or contact Us at one of the email addresses or toll-free phone numbers listed below with any questions.
Bruegger’s Bagels:
Einstein Bros. Bagels:
Manhattan Bagel:
dataprivacy@manhattanbagel.com
Noah’s New York Bagels:
Changes to Our California Privacy Policy
We reserve the right to amend this California Privacy Policy at Our discretion and at any time. When We make changes to this California Privacy Policy, We will post an updated notice on Our website with the effective date.