Privacy Policy

RESPONSABLE
  • ConverseNow Technologies Inc.

USERS
  • End customers ("they", "them", "their") who want to place their food order with the Parent Restaurant Organization (and their franchisees) using the voice ordering platform ("Phone" or "Drive-Thru")

PURPOSES
  • Compliance with contractual obligations.

  • Sending of advertising communications, in those cases in which it has expressly consented.

LEGAL BASIS OF DATA PROCESSING
  • Execution of contractual obligations.

  • Consent of the interested party in the case of sending advertising communications.

RECIPIENTS
  • Other companies of the ConverseNow group and its' approved business partners

  • The user data can be transferred to the respective Parent Restaurant Organization (and its franchisees) where they will be placing their food order

RIGHTS
  • Access, rectify and delete data, as well as other rights, as explained in the additional information

ADDITIONAL INFORMATION
  • They can consult additional and detailed information on how we treat their personal data in our Privacy Policy

Please take a few minutes to read the following policy so that they understand how we treat the user information. As we continuously improve and expand our services, this policy might change, so please check it periodically.

This Privacy Policy describes how ConverseNow Technologies Inc. ("ConverseNow, "Service Provider", "we," "our," "us") collects, uses, and shares information they provide while placing their order via our voice ordering platform ("Phone" or "Drive-Thru") subject to their consent. It also describes their rights and choices regarding our use and sharing of their information, including how they can access and update such information.

Their engagement & interaction with our voice ordering platform - constitutes their agreement and acceptance of this Privacy Policy and their consent to the practices it describes. If they have questions or comments about our Privacy Policy, please contact us as set forth in the section entitled "Contact Us" below.

Data Controller Information

The data controller with respect to the data processing described in this Privacy Policy is ConverseNow Technologies Inc., located at the address in the section entitled "Contact Us" below.

Information Collection

Information they provide

We collect information they provide directly via the voice ordering platform ("Phone" or "Drive-thru"). The information we collect includes personally identifiable information, which is any information that concerns they individually and would permit someone to identify them. Some examples of information we collect include the following:

  • Contact Data. We collect their first and last name, postal address, email address, telephone number, and other contact data

  • Demographic Data. We collect demographic information including their gender, and country.

  • Payment Data. We collect data necessary to process their payment if they make a purchase, including their payment instrument number (such as a credit card number), the security code associated with their payment instrument.

  • Order Information. We collect information about their orders and food choices.

  • Profile Data. We collect their interests, favorites, and other profile data.

  • Content. We collect the content of messages they send to us, such as feedback and product reviews they give, or questions and information they provide to customer support.

We collect information they provide at various points during their ordering process, such as the following:

  • Account Registration – To submit their order to the restaurant, they will be required to provide information as requested. This requires them to provide their first name and last name, email address, postal address, telephone number, and loyalty membership details. They may also provide payment data and profile data to help speed up and facilitate their future orders.

  • Online Orders – They can place an online order for carryout or delivery through their registered account or as a guest. If they place a carryout order, they will need to provide their first name and last name, email address, telephone number, and order information. If They pay online, they will also need to provide their payment data. If they place an order for delivery, they will also need to provide their postal address.

  • Rewards Programs – We may offer rewards programs, sweepstakes, contests, surveys, or other promotions ("Promotions") through our ordering platform. In order to participate in a Promotion, they may be required to provide contact data, profile data, and other information.

  • Other Transactions – We may offer them other opportunities to transact with us through our ordering platform. If they conduct transactions through our online ordering platform, we will collect information they provide directly about the transactions they engage in while interacting with our online ordering platform. This information may include payment and billing information as well as the nature, quantity and price of the goods or services they exchange and the individuals or entities with whom they communicate or transact business.

  • Email and other voluntary communications - They may also choose to communicate with us through email, via the Web site or through other means. Such communications may be in connection with our customer service efforts, their questions, or for other purposes. We collect the information in these communications, and such information may include information that personally identifies them.

They may choose to voluntarily disclose other information when using the voice ordering platform that we do not request, and, in such instances, they are solely responsible for such information.

Information Collected Automatically

When they visit the parent restaurant organization (or their franchisee) by phone or on Drive-Thru, we automatically collect information about their interactions. Some examples of information we collect include the following:

  • Service Use Data. We collect data about the features they use, the emails and advertisements they view/listen, the products they purchase, the date and time of their interaction, the queries they ask during their interaction, and the personal information associated with their phone number, if any, from which they linked directly to the restaurant, and other similar information.

  • Log Files A log file is a file that records events that occur in connection with their interaction, such as Phone number, caller name associated with their telephone service provider, call duration, language and utterances they use, date/time stamps, and related data. This information allows us to recognize them and help customize their ordering experience and make it more convenient for them. The log files are also useful in allowing more efficient tracking of their transaction history and preserving information between sessions. The information collected from log files may also be used to improve the functionality of the platform.

Types of logging on our platform include:

    • Functionality: Used to remember their preferences and for facilitating transactions such as purchases.

    • Performance or Analytics: Used to measure ordering activity to improve user experience.

    • Targeting: Used to offer information and offers that specifically interest them.

 

For further information on tracking technologies and their rights and choices regarding them, please see the sections entitled "Analytics, Advertising, and Retargeting" and "Their Rights and Choices" below.

Information Collected Other Third Parties

We also obtain information about them from other third-party sources and combine such information with information we have collected about them. To the extent we combine such third-party sourced information with information we have collected about them on our online ordering platform, we will treat the combined information in accordance with this Privacy Policy, plus any additional restrictions imposed by the source of the data. These third-party sources vary over time, but may include:

  • Social networks when they reference our Service or grant permission to parent restaurant organization (or their franchisee) to access their data on one or more of these services.

  • Partners with which we offer co-branded services, sell or distribute our products, or engage in joint marketing activities.

  • Publicly available sources such as open government databases or other data in the public domain.

We are not responsible for the accuracy of any information provided by third parties or third-party policies or practices.

Information Use

We use the information about them for our legitimate interests, including for purposes such as:

  • servicing users' accounts or memberships;

  • providing services and support to users;

  • processing, servicing or enforcing transactions and sending related communications;

  • responding to their questions, inquiries, comments and instructions;

  • protecting our systems from fraud and unlawful access;

  • maintaining the security and integrity of its systems;

  • helping to establish and verify the identity of users;

  • improving our ordering platform, advertisements, products, and services;

  • providing users with product or service updates, promotional notices and offers; and

  • advertisements, and other information about Parent Restaurant Organization, Franchisee and its affiliates.

We also use information about with their consent, including for purposes such as:

  • providing them with Promotions;

  • sending them promotional newsletters and marketing communications;

  • serving digital advertisements to them tailored to their interests on third party ad properties; and

  • fulfilling any other purposes disclosed to them and with their consent.

We may use information that does not identify them (including information that has been de-identified) without obligation to them except as prohibited by applicable law. For information on their rights and choices regarding how we use their information, please see the section entitled "Their Rights and Choices" below.

Purposes and legal basis of data processing

The Users' personal data will be processed by us under the following legal basis and for the following processing purposes:

  1. contractual obligations i.e. in order to give execution to the general conditions of the voice ordering platform and to the sale conditions, being accepted by the User during the call; fulfill specific requests of the User. Subject to the User giving a specific and optional consent to its data processing for marketing purposes, any contact data (name, surname, electronic mail address, phone number) will be used by us (and/or the parent restaurant organization and their franchisees) for the sole purpose of ascertaining the identity of the relevant User (also by means of validation of the electronic e-mail address), avoiding frauds or infringements, and contact the User only for services reasons;

  2. legal obligations, or in order to fulfill obligations provided by the law or the European laws and regulations.

Providing the personal data for the processing purposes specified above is optional but necessary, since failing to provide the same imply the impossibility to process their request.

Further purposes of processing: marketing (sending advertising material, direct sales and commercial communication)

With the free and optional User's consent, some User's personal data (name, surname, electronic mail address, phone number) may be processed by the parent restaurant organization and their franchisees also for marketing purposes (direct sale, dispatch of marketing material and commercial communication) or in order for the parent restaurant organization and their Franchisee to contact the relevant User by means of electronic mail for proposing to the same to purchase products and/or services offered by Franchisee and/or third parties companies, present offers, promotions and commercial opportunities.

Giving consent to personal data processing for such purpose is free and optional and, in the event such consent is missing, the possibility to carry on a purchase is not prevented in any manner whatsoever. In the event that such consent has been granted, the relevant User may revoke the same without retroactive effects at any time whatsoever.

The relevant User may also easily oppose to the sending of further marketing communications (by e-mail) also clicking on the specific revocation link for revoking the consent, which is included in each marketing e-mail. Once revoked the consent the parent restaurant organization and their Franchisee will send to the User an electronic mail message in order to confirm that the consent has been actually revoked.

Such requests will have to be made to the Parent Restaurant Organization (or their franchisee) and it will be the responsibility of the Parent Restaurant Organization (or their franchisee) to send this request to us though our website (https://www.conversenow.ai) following the methods specified under the section entitled "Contact Us" or by writing to us at customer.support@conversenow.ai

Responsibility of identifying the end user will lie with the arent Restaurant Organization (or their franchisee) before sending the request to ConverseNow.

We hereby inform that, following the exercise of the right to object to the sending of marketing communications, it could be possible due to technical issues (i.e. sending list already completed a little before the receipt by the parent restaurant organization and their franchisee of the objection request) the relevant User continues receiving further marketing messages. In the event that the relevant User continues receiving marketing messages once elapsed 24 hours from the exercise of the objection right, please flag such issue to us, using the contacts specified under the section entitled "Contact Us" or by writing to us at customer.support@conversenow.ai

Disclosure of Information

We disclose information about them as follows:

  • ConverseNow employees. ConverseNow employees and/or workers appointed to manage personal data may become aware of any Users' personal data. Such subjects, who are formally appointed by ConverseNow as "persons in charge for the processing", will process the relevant User's data exclusively for the purposes specified under this policy and in compliance with the provisions of the GDPR & CCPA, and other relevant privacy regulations.

  • Service Providers. ConverseNow uses agents, vendors, consultants and other service providers to help it maintain and operate its online ordering platform, input orders manually into ConverseNow platform, payment processing, and for other reasons related to the operation of its business, and those companies may receive their information for that purpose. These companies may only use such information for the purpose of performing those functions and may not use it for any other purpose, although we may permit them to use aggregate information which does not identify them or de-identified data for other purposes.

  • Parent Restaurant organization and their Franchisee. We share their information with Parent Restaurant organization and their Franchisee in connection with it performing services on our behalf. For example, we share their information with them in order to facilitate their orders, maintain and administer their online accounts, respond to their questions and comments, comply with their requests, market and advertise to them, and otherwise comply with applicable law.

  • Affiliates. We share their information with our affiliates for internal business purposes. For example, we share their information with our affiliates for customer support, marketing, and technical operations

  • Business Partners. We share their information with our business partners in connection with offering them co-branded services, selling or distributing our products, or engaging in joint marketing activities.

  • Promotions. Our Promotions may be jointly sponsored or offered by third parties. If they voluntarily choose to enter a Promotion, we share their information with third parties a set forth in the official rules that govern the Promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a Promotion, they agree to the official rules that govern that Promotion, and, except where prohibited by applicable law, allow the sponsor and/or other parties to use their name, voice and/or likeness in advertising or marketing materials.

  • Merger or Acquisition. We may share their information if ConverseNow is involved in a merger, acquisition, or sale of all or a portion of its assets. In such event, they may be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of their information, as well as any choices they may have regarding their information.

  • Security and Compelled Disclosure. ConverseNow must disclose information about them in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may share information about them in connection with legal requirements, such as in response to an authorized subpoena or when we believe in good faith that disclosure is necessary to protect our rights, protect their safety or the safety of others, or investigate fraud. We may also share information about them to defend the Terms of Use or other policies applicable to the Web site or if we believe their actions are inconsistent with our user agreements or policies. To the maximum extent permitted by applicable law, we may use IP addresses, mobile device identifiers or any other information we collect to identify users, and may do so in cooperation with copyright owners, internet service providers, wireless service providers or law enforcement agencies in our discretion. Such disclosures may be carried out without notice to them.

  • Consent. We may share their information for any other purpose disclosed to them and with their consent. Parent Restaurant Organization (or their Franchisee) may also disclose aggregated de-identified information to potential business partners and other unaffiliated entities for any purpose except as prohibited by applicable law. For information on their rights and choices regarding how we share their information, please see the section entitled "Their Rights and Choices" below.

 

Retention period

ConverseNow will retain User's personal data for the period necessary for the execution of the services or to attend their requests or claims up to 2 years. After this time, ConverseNow will keep retaining the data only to the extent necessary to fulfill its obligations provided by the law or the European laws and regulations.

When Users have given their consent for their personal data to be processed for the marketing purposes, their personal data will be retained until their consent is revoked.

Their Rights and Choices

Review and Update of Account Information

They have the right to access certain account information that they have voluntarily submitted to us while placing their order on online ordering platform. They may correct, update, amend, delete, or remove that information.

Such requests will have to be made to the Parent Restaurant Organization (or their franchisee) and it will be the responsibility of the Parent Restaurant Organization (or their franchisee) to send this request to us though our website (https://www.conversenow.ai) following the methods specified under the section entitled "Contact Us" or by writing to us at customer.support@conversenow.ai

Responsibility of identifying the end user will lie with the arent Restaurant Organization (or their franchisee) before sending the request to ConverseNow.

We will respond to their request for access within 30 days. We may require additional information from them to allow us to confirm their identity. Please note that we will retain and use their information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. European data subjects have additional rights as set forth in the section entitled "Their European Privacy Rights" below.

Analytics and Advertising

They may also exercise choice regarding the receipt of interest-based advertising. Some of the advertisers that perform advertising-related services for us, and our partners/customers may be members of the Network Advertising Initiative ("NAI"). Some of these companies may also participate in the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. To learn more about the DAA and their opt out options for their members, please visit (i) for website opt out, http://www.aboutads.info/choices; and (ii) for mobile app opt out, http://www.aboutads.info/appchoices.

Please be aware that, even if they are able to opt out of certain kinds of interest-based advertising, they may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain interest-based advertising to them but does not mean they will no longer receive any targeted content and/or ads (e.g., from other ad networks).

In addition, our European users may learn more information about their online choices at www.theironlinechoices.com and to view their opt out choices for this type of advertising.

ConverseNow is not responsible for effectiveness of, or compliance with, any third parties opt out options or programs or the accuracy of their statements regarding their programs.

Communications

In order to provide service to them, we may send them communications related to their transactions, security or the administration of the platform. From time to time, ConverseNow may also send them other messages or updates on behalf of the parent restaurant organization (or their Franchisee), or their promotions and other activities. If they do not wish to receive such promotional communications, they can opt out at any time by following the instructions provided in those communications.

Such requests will have to be made to the Parent Restaurant Organization (or their franchisee) and it will be the responsibility of the Parent Restaurant Organization (or their franchisee) to send this request to us though our website (https://www.conversenow.ai) following the methods specified under the section entitled "Contact Us" or by writing to us at customer.support@conversenow.ai

Responsibility of identifying the end user will lie with the arent Restaurant Organization (or their franchisee) before sending the request to ConverseNow.

Please note that even if they opt out of receiving promotional communications, we may continue to send them non-promotional emails, such as those about their account, servicing, or our ongoing business relations.

Their Privacy Rights

If they are a data subject in the European Economic Area ("EEA"), they have the right to request from ConverseNow information about the processing of their data, and specifically:

  1. The right to access their personal data in order to know which data are being processed, as well as to request the rectification of inaccurate data, or, where appropriate, to request erasure of their personal data when, among other reasons, they are no longer necessary in relation to the purposes for which they were collected.

  2. Under certain circumstances, the right to request the limitation of the processing of their data, in which case we will only keep them for the exercise or defense of claims.

  3. Under certain circumstances, the right to request the restriction of the processing of their personal data, in which case ConverseNow shall only keep them for the exercise or defense of legal claims.

  4. Under certain circumstances, and for reasons related to their particular situation, the right to object to the processing of their personal data. ConverseNow will stop treating their data, except for compelling legitimate reasons, or for the exercise or defense of legal claims.

  5. The right to receive the personal data provided in a structured, commonly used and machine-readable format when technically possible and to transmit them to another data controller.

To exercise any of these rights, such requests will have to be made to the Parent Restaurant Organization (or their franchisee) and it will be the responsibility of the Parent Restaurant Organization (or their franchisee) to send this request to us though our website (https://www.conversenow.ai) following the methods specified under the section entitled "Contact Us" or by writing to us at customer.support@conversenow.ai

Responsibility of identifying the end user will lie with the arent Restaurant Organization (or their franchisee) before sending the request to ConverseNow.

We will respond to their request within 30 days. We may require additional information from them to allow us to confirm their identity. Please note that we store information as necessary to fulfil the purposes for which it was collected and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

In any case, Users are entitled to file a complaint with the competent supervisory authority, in particular in the Member State of the User's habitual residence, place of work or place of the alleged infringement if the User believes that Franchisee processing of his or her Personal Data is in violation of the applicable law.

International Transfer

We are based in United States and the information we collect is governed by Data protection laws in the U.S. and other jurisdictions. However, please be aware that information collected through the voice ordering platform may be transferred to, processed, stored, and used outside of United States as well. Data protection laws in these countries may be different from those of the United States. Their use of the voice ordering platform or provision of any information therefore constitutes their consent to the transfer to and from, processing, usage, sharing, and storage of their information in the U.S. and other jurisdictions as set forth in this Privacy Policy. If their data is collected in the European Union ("EU"), we will transfer their personal data subject to appropriate or suitable safeguards, such as standard contractual clauses.

Children's Privacy

The voice ordering platform is directed toward and designed for use by persons aged 16 or older. ConverseNow will not approve applications of or establish or maintain registrations for any child whom ConverseNow knows to be under the age of 16. ConverseNow does not solicit or knowingly collect personal data from children under the age of 16. If ConverseNow nevertheless discovers that it has received personal data from an individual who indicates that he or she is, or whom ConverseNow otherwise has reason to believe is, under the age of 16, ConverseNow will delete such information from its systems. Additionally, a child's parent or legal guardian may request that the child's information be corrected or deleted from our files.

Such requests will have to be made to the Parent Restaurant Organization (or their franchisee) and it will be the responsibility of the Parent Restaurant Organization (or their franchisee) to send this request to us though our website (https://www.conversenow.ai) following the methods specified under the section entitled "Contact Us" or by writing to us at customer.support@conversenow.ai

Responsibility of identifying the end user will lie with the arent Restaurant Organization (or their franchisee) before sending the request to ConverseNow.

Data Security

ConverseNow maintains reasonable physical, electronic, and procedural safeguards to help guard their information from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Please be aware, however, that any email or other transmission they send through the internet cannot be completely protected, and we cannot guarantee the security of their information collected through our online ordering platform.

Changes to this Privacy Policy

ConverseNow reserves the right to modify or supplement this policy at any time. If a material change to the terms of this policy is made, ConverseNow will post a notice prior to the change becoming effective on its homepage and a link to the new policy.

Contact Us

If they have questions or comments about this Privacy Policy, the information practices of Franchisee, or their dealings with our Web site, please contact us:

By email: privacy@conversenow.ai

By mail: PO Box 170459, Austin TX 78717

Revision Date

This policy was last updated January 4, 2021.