NOODLES & COMPANY PRIVACY NOTICE FOR CONNECTICUT RESIDENTS
Last Updated on August 1, 2023
This Privacy Notice for Connecticut Residents (the “CT Privacy Notice”) supplements the information contained in the Noodles & Company (“Noodles,” “we,” or “us”) Privacy Notice and applies solely to all visitors, users, and others who reside in the State of Connecticut (“consumers” or “you”). We adopt this CT Privacy Notice to comply with applicable Connecticut law, including the Data Privacy Act, as amended from time to time (“CTDPA”) and any terms defined in the CTDPA have the same meaning when used in this CT Privacy Notice. Any other capitalized but undefined terms shall have the meanings set forth in the general Privacy Notice.
Please also note that some of our restaurants are owned and operated by franchisees, who are independent from us. This notice does not apply to franchisees or to websites or mobile apps that they operate. Please refer to out applicable franchisees’ privacy notices for information on how they collect and use your information.
As used in this CT Privacy Notice “Personal Data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. Personal Data does not include de-identified data, publicly available information, or data outside the scope of the CTDPA.
HOW WE COLLECT, USE, AND DISCLOSE YOUR PERSONAL DATA
We collect, use, and disclose your Personal Data as set forth in the Privacy Notice.
Please note that the collection of precise geolocation is considered sensitive Personal Data under the CTDPA. We will obtain your explicit consent and provide your ability to opt into such collection prior to any collection of this information.
If we use de-identified data, we also will maintain and use such de-identified data without attempting to re-identify such data.
RIGHTS AND CHOICES OF CONNECTICUT RESIDENTS
The CTDPA also provides Connecticut residents with specific rights regarding their Personal Data. This section describes the rights of Connecticut residents under the CTDPA, and explains how to exercise those rights.
• Targeted Advertising
Our use of tracking technology, including cookies and related technology, may be targeted advertising under the CTDPA. If you would like to opt out of this advertising you may click “Do Not Sell Or Share My Personal Information” (also found at the bottom of the page), or you may broadcast the Global Privacy Control signal through your web browser or device. More information on Global Privacy Controls can be found here.
• Sale of Your Information
Our use of tracking technology, including cookies and related technology, may be a sale under the CTDPA. If you would like to opt out of this advertising you may click “Do Not Sell Or Share My Personal Information” (also found at the bottom of the page), or you may broadcast the Global Privacy Control signal through your web browser or device. More information on Global Privacy Controls can be found here.
• Conflict of Consent
If you opt out through a preference signal and such signal conflicts with your existing consent/preference given to us or is in conflict with your voluntary participation in our rewards program or similar, we will comply with the opt out preference signal. Notwithstanding the foregoing, we may contact you to notify you of the conflict and give you the choice to confirm your preference as it relates to the existing consent.
Connecticut residents have the right to request that we disclose certain information to them about our collection and use of their Personal Data. You may request (see Exercising Rights) the following:
• confirmation of whether or not we are processing your Personal Data.
• access to your Personal Data that we process.
Once we receive and confirm a Connecticut resident’s consumer request (see Exercising Rights), we will provide confirmation/access to the applicable Personal Data. Please also see Data Portability Rights for how we may provide information.
Data Correction Rights
Connecticut residents have the right to request that we correct inaccuracies in their Personal Data, considering the nature of the Personal Data and the purposes of the processing of the Personal Data. Once we receive and confirm your consumer request (see Exercising Rights), we will use commercially reasonable efforts to correct the inaccurate Personal Data.
Connecticut residents have the right to request that we delete any of their Personal Data that we collected from or obtained about Connecticut residents, subject to certain exceptions. Once we receive and confirm a Connecticut resident’s consumer request (see Exercising Rights), we will delete (and direct our processor to delete) their Personal Data from our records.
Data Portability Right
Connecticut residents have a right to request that we provide a portable copy of the Personal Data that the Connecticut consumer previously provided to us. Once we receive and confirm the consumer request (see Exercising Rights), we will provide a copy of your Personal Data, to the extent reasonably and technically feasible, in a readily useable format to transmit the data to another business.
Only Connecticut residents may make a “verifiable consumer request” (subsequently referred to as a “consumer request”) related to their Personal Data rights except in the case of opt out rights, as described below. A Connecticut resident may also make a verifiable consumer request on behalf of their minor child or in the case of a guardianship or similar person. The guardian may exercise such rights on a Connecticut resident’s behalf. To be verifiable, a consumer request must include:
• provide sufficient information that allows us to reasonably verify that the Connecticut resident is the person about whom we collected Personal Data or an authorized representative; and
• describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Please note that as applied to your opt-out rights (as disclosed above), a Connecticut resident may designate an authorized agent to exercise their right to opt-out of processing their Personal Data for targeted advertising.
We cannot respond to your request or provide a Connecticut resident with Personal Data if we cannot verify his/her identity or authority to make the request and confirm the Personal Data as it relates to that Connecticut resident.
Making a consumer request does not require a Connecticut resident to create an account with us, but we may require authentication of the consumer that is reasonable in light of the nature of the Personal Data requested, such as using an existing account to contact us.
To exercise the rights described above, we’ve provided secure and reliable means to submit a consumer request to us by:
• Calling us at 720-214-1900; or
• Emailing us at [email protected].
INITIAL REQUEST RESPONSE TIMING AND FORMAT
We endeavor to respond to a consumer request within 45 days of its receipt. If we require more time (for a maximum total of 90 days), we will notify the Connecticut resident within 45 days of receiving the request and indicate the reason for the extension. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to a Connecticut resident’s consumer request unless the request is excessive or manifestly unfounded, or a request was made more than once in a 12-month period. If we determine that the request warrants a fee, we will tell the Connecticut resident why we made that decision and provide them with a cost estimate before completing the request. Alternatively, we may decline to respond to the request and notify the Connecticut resident of our reason for doing so.
APPEALS RESPONSE TIMING AND FORMAT
If we decide that we cannot comply with a Connecticut resident’s initial request, that Connecticut resident has a right to appeal our decision. Any appeal should be sent to the place where the initial request was sent (see Exercising Rights). The appeal should clearly indicate that it is an appeal of an initial request and should include the initial request along with our response explaining why we cannot comply with the request. We will review all appeals and provide a response within 60 days of receiving the appeal, including the reasons we can or cannot comply with the request, as applicable. If we cannot comply with a request after an appeal is made, Connecticut residents may submit a complaint to the Connecticut Attorney General, which can be found here: https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page.
We will not process Connecticut residents’ Personal Data in violation of state and federal laws that prohibit unlawful discrimination against Connecticut residents. We will also not discriminate against a Connecticut resident for exercising any of his/her CTDPA rights. Unless permitted by the CTDPA, we will not:
• Deny a Connecticut resident goods or services.
• Charge a Connecticut resident different prices or rates for goods or services.
• Provide a Connecticut resident a different level or quality of goods or services, including denial of goods or services.
If you would like to revoke our right to process your data after you consented, you may call us at 720-214-1900; or email us at [email protected] to revoke your consent. We will comply with your request as soon as practical, but in all cases within 15 days of receipt of your request.
CHANGES TO OUR PRIVACY NOTICE
From time to time, we may update this CT Privacy Notice. If our information practices materially change at some time in the future, we will post the updated notice to our Site or Mobile App to notify you of these changes, and we will only use data collected from the time of the notice change forward for these new or different purposes. In the event we make a material change to how we use your Personal Data, we will provide you with an opportunity to opt out of such new or different use. The date this CT Privacy Notice was last revised is at the top of this page. You are responsible for periodically reviewing the Site and this CT Privacy Notice to check for any updates or changes.
If you have any questions or comments about this CT Privacy Notice, the ways in which Noodles collects and uses your data described above and in the Privacy Notice, your choices and rights regarding such use, or wish to exercise your rights under Connecticut law, please do not hesitate to contact us at:
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