1. Information We Collect

Boston Market collects both Personal Information and Other Information regarding users of the online services, either directly or through the activities of third-party vendors and service providers ("Vendors"). For purposes of this Notice, "Personal Information" is an identifier that allows a specific person to be contacted, such as first and last names, physical addresses, email addresses and phone numbers. "Other Information" is any information that is not Personal Information. We may combine Other Information with Personal Information, and in those circumstances we will treat the combined information as Personal Information. The Personal Information that Boston Market collects may include, for example and without limitation: Personal details, such as your first and last name, birthday information, postal address, email address, phone number, Transaction information, including information about the menu items you buy, prices, methods of payment and payment details Account information, geolocation (which may include specific longitude and latitude) Financial payment details for purchases Financial and business information related to a catering applicant/customer We may use automated technology to collect information from your computer system or mobile device when you visit our restaurants, use our online services, or in-restaurant technology. Automated technology may include cookies, local shared objects, and web beacons. There is more information below about cookies and other technologies in Section 4. We may collect information about your: -internet protocol (IP) address; -date and time of access of our online services or technology; -name and URL of the file retrieved when you use our online services; -computer or mobile-device operating system and browser type; -type of mobile device and its settings; -unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device; -device and component serial numbers; advertising identifiers (for example, IDFAs and IFAs) or similar identifiers; -referring website (a site that has led you to ours) or application; and -activity related to how you use our online services, such as the pages you visit on our sites or in our mobile apps. Information you provide directly when you use or otherwise interact with the online services, complete a survey, contact us through our Guest Service Center at [email protected], provide feedback and/or submissions, make a press inquiry, or submit information through the Online services or in connection with a Program. Information recorded as a result of your interaction with us, our Vendors or franchisees and/or use of the Online services (including information we receive when you use your Program member card(s), historical sales information, your geolocation information (which may include specific longitude and latitude) and information about the device you are using (for example, device type, characteristics and status, browser type, operating system and application version and information about how our application is used) or through our marketing activities (see the "Usage Information" and "Third Party Analytics and Targeted Marketing" sections below). Our online services and in-restaurant technology may collect information about the exact location of your mobile device or computer using geolocation and technology such as GPS, Wi-Fi, Bluetooth, or cell tower proximity. For most mobile devices and computer systems, you will be requested to give your permission for Boston Market to process this information. You are able to withdraw your permission for us to collect this information by using the device or web-browser settings. If you have any questions about how to prevent us from collecting exact information about your location, we recommend you contact your mobile-device service provider, the device manufacturer, or your web-browser provider. Some online services and in-restaurant technology may not work properly without information about your location. By law, we may need to keep certain information. Information we collect from other sources. We may collect information about you from other companies and organizations, including public databases, social media platforms, or third party partners such as analytics or marketing providers. We may also collect information that is publicly available. For example, we may collect public profile information about you when you interact with us through social media. We may also collect communications to us or regarding us on social media. Other information we may collect includes, for example, your occupation, general geographic location, media and brand preferences, inferred interests, demographic information, purchase behavior, public online activities, and other information about you or your household. -Information that you provide as part of entering a contest or sweepstakes online through the online services or through a third-party website. This information will be used as described in the applicable Official Contest/Sweepstakes Rules. -Information that is publicly available, for example information you submit to a blog, chat room or social media network like Facebook or Twitter. -Information that your social media network provides to us if you connect your social media account with Boston Market. For example, this may include your social media ID or username, name, email address, general location, friends list, and demographic information such as gender or birthday/age. Note that certain of the information we receive will become part of your account(s) with Boston Market and will be subject to this Privacy Notice. -Information as described elsewhere in this Notice, the Terms, and/or applicable Program terms, or at the time such information is collected. We may combine the information you provide us, with information that is collected through automated methods, and with information we receive from other sources, for example, our advertisements that you see. We may also associate information we collect about you with information we collect about other users accounts if you/your employer has set up an account for multiple authorized users (for example, a corporate catering account).

2. How We Use the Information We Collect

We may use the information we collect in the following ways. To provide our services and contract with you:

• To contact you by email, phone, text, push notice (after consent)or other method regarding our products and services, including matters related to your account, your order, or your future catering needs.
• To provide you with, or otherwise respond to your submissions or requests for, information and/or services, including but not limited to providing webcasts, text messages, push notices, marketing, and other programs; responding to Guest Service issues, catering and other inquiries; and letting you know if you qualify for one of our programs (for example, Rotisserie Rewards or VIP).
• To provide services, programs and services functionality and to administer the online services, Programs and services, including to let you sign up for an account, provide you with program benefits, verify your participation in a program or service, process orders placed and applicable payments, track submissions, and make your historical ordering information that we have available to you. We do not have your historical ordering information for orders you place through third parties like GrubHub, DoorDash, Postmates or otherwise not placed through bostonmarket.com or our mobile app. Note that third-party information you provide may be maintained in connection with your submission. Please note that we may suspend, cancel, or combine multiple Rotisserie Rewards, or VIP, or other accounts through the services if they appear to be duplicative.
• To contact you by email, phone, text, push notice (after consent)or other method regarding our products and services, including matters related to your account, your order, or your future catering needs.
• To send you promotional messages regarding new menu items, products or services, events in our restaurants, events that Boston Market sponsors, including but not limited to contests, sweepstakes and surveys, and special offers and marketing programs, which may include information about our affiliated company(ies), and/or other programs with which any of us or them are involved, and/or information about third party products, services, offers or programs.
• To invite you to participate in surveys. Survey responses received by Boston Market may not be in an anonymous format and may be associated with your Program account or other Personal Information.
• To provide location-based services to you (such as notifying you of nearby Boston Market restaurant locations or sending push notifications to you) or to engage in analysis, research, product development, and targeted marketing by email, push notification, online or in-app advertising, or otherwise based on your device’s geolocation (which may include specific longitude and latitude), your use of our services (including the Boston Market mobile application), and Personal Information that we collect from you on the Services. See "Location" below for more information. If you do not want to share your specific longitude and latitude with Boston Market, you may adjust your location preferences on your computer, browser, or mobile device. To enhance our customers' and Service users' experiences in our restaurants, on the services or in a program, and enhance the sales efforts of Boston Market and/or our franchisees.
• To conduct research and analysis and to otherwise measure the effectiveness of the services, programs and our online and offline marketing efforts, and to develop and implement menu items, products, services, and marketing programs. This may include combining Personal Information with other information and other personal information drawn from online and offline sources.
• To work with third parties to append data to our records or enable other parties to append other information to their records.
• To coordinate program activities and communications with other communications and marketing programs conducted by us and/or franchisees. For purposes of targeted or customized advertising or messaging to you, including as described in the Third Party Analytics and Targeted Marketing section below. As otherwise described in this Privacy Notice, the Terms, and/or Program terms, or at the time such information is collected.

To comply with applicable law: protect against, identify and prevent fraud and other crime, claims and other liabilities; comply with legal obligations and our policies; establish, exercise or defend a legal claim; and/or to monitor and report compliance issues. We may use the information we collect about you in other ways, which we will tell you about at the time we collect it or for which we will seek your consent. To unsubscribe from marketing emails, click the “unsubscribe” link found in our marketing email messages. You can also unsubscribe through bostonmarket.com or our mobile app.

3. How We Share the Information We Collect

We do not sell your personal information and only share your information as described in this Privacy Notice. We may share your Personal and/or Other Information with third parties as described in this Notice and for our business purposes including, for example and without limitation: We may share your information with our vendors, including without limitation companies that host our services or information systems, deliver communications on our behalf, make gift card and e-gift card services available to you, or otherwise assist us with providing the services to you. To our affiliates, business units, Vendors, consultants and agents, and to other third parties, and to administer programs and services. To third parties when you use their services together with our services, or when you share information directly through our services. For example, the services may contain links to third-party websites that incorporate comments and social media features. Our services may also contain a Facebook "like" button and/or a Twitter "follow" button. If you choose to use these features or other comment or sharing features provided through the services, such action may disclose your Personal Information not just to third-party websites and services, but also to their users and the public more generally. The services may also allow you to share portions of your account information with third parties (for example, in connection with your use of an electronic wallet) and will automatically share information about your use of our services with third parties if you use third party services to interact with the services. See the "Third-Party Sites" section below. To third parties that operate plug-ins on the services (such as the Facebook "like" button and the Twitter "follow" button). Even if you do not click on these plug-ins, they may collect information about you, such as your IP address and the pages that you view. They also may set and/or access a cookie. These plugins are governed by the privacy policy of the company providing them. To third parties in the event of a proposed or actual merger, acquisition, bankruptcy, financing, sale, or other transfer of some or all of our business or assets. To Vendors and other third parties to engage in analysis, research, improvements to our menu, menu items, products and services, and product development. These parties may use insights gathered from such information to improve their own products or services. To Vendors and other third parties in aggregated form and/or in a format that does not, by itself, identify you individually, such as sharing statistics about users of the Online services for Boston Market's, Vendor's, and third party(ies)' business purposes or otherwise. To third parties so they can tell you about their products, services, offers and programs which work with or are otherwise related to Boston Market's, and/or its affiliates menu items, products, services and offers. For example, we may share your information with a payment processor in order for them to tell you about how their services work with Boston Market's services. Pursuant to judicial or governmental subpoenas, warrants, or other like orders, to cooperate with other requests from government or law enforcement, and in other ways necessary to comply with applicable law, as well as to investigate, prevent, or take action regarding illegal activities, suspected fraud, violation of third-party rights, situations involving potential threats to the physical safety of any person, or any other similar situation, or violations of the Terms or program terms. We may also use and share Personal and Other Information to establish, protect, or exercise our legal rights or defend against legal claims. As otherwise described in this Privacy Notice, the Terms, and/or Terms of Use, or at the time such information is collected. To learn about opting out of the sharing of your Personal Information, see the "Your Choices and Changing Your Information" section. There may be times where we may share information when it does not directly identify you. For example, we may share anonymous, aggregated statistics about your use of our online services. Or we may combine information about you with other customers and share the information in a way that does not link to a specific customer.

4. Usage Information

Like most websites, apps and other like services, the online services gather traffic patterns, usage information, and similar data. This usage data may identify you individually and we may associate it with Personal Information that we collect from you on the online services and related to any Program(s) you participate in and as otherwise described in this Notice. (See the "Information We Collect" and "How We Use the Information We Collect" sections of this Notice and any applicable individual Program terms for more details.) We may use this data in aggregated form or share aggregated statistics about visitors to the online services with others outside of Boston Market, and we may allow third parties to collect and aggregate Other Information through the online services and/or Vendor sites accessible from or through the online services. Boston Market and/or our third-party Vendors may use cookies, pixels and web beacons (described below), device identifiers such as IDFA for iOS or Advertising ID for Android, device location features or beacons, or other similar technology ("Tracking Technologies"), to enhance the browsing and usage experience on the Services and enable certain functionality related to our Services. The information captured about your activities on the Services will also make it possible for us, among other things: (i) to speed navigation and provide you with custom tailored content; (ii) to remember information you gave to us so you do not have to re-enter it each time you visit the Services; (iii) to target advertising as described in the "Third Party Analytics and Targeted Marketing" section below and monitor the effectiveness of certain of our marketing campaigns; (iv) to monitor total number of visitors, pages viewed, the web address you came from, and type of browser you are using; and (v) to enforce limitations on downloads described for online coupons and other similar offers. For example, the Services may use Google Analytics and/or other third party services to help collect and analyze certain information for the purposes described in this Notice. Cookies and other technologies "Cookies" are small text files or records that are stored on your web browser or device when you visit a website. To block cookies used on the online services, you can clear your browser(s) of all existing cookies and set your browser(s) to refuse cookies. The "help" functionality of your browser(s) will explain how to do this. If you refuse cookies, your experience on the online services, some Programs, and some of our online advertising may be affected. For example you may not be able to utilize all of the features on the online services. "Pixels" or "web beacons" are small objects or images used by a website or third-party ad server to cause a cookie to track a user's activity on particular sites and/or using particular advertising/links, for example, to record that a user has visited a particular webpage or viewed a particular email, and to collect other information about that user on that site, including the IP address of the computer (and therefore infer information, such as geolocation (which may include specific longitude and latitude)), web pages being viewed, date/time viewed, and user activity on a particular page. We, and our vendors who provide services to us, may use cookies, web beacons and other similar technologies on our online services and in other areas related to our business, such as online advertising, to collect information and provide you with the services or products that you have requested. Use the options in your web browser if you do not wish to receive a cookie or if you wish to set your browser to notify you when you receive a cookie. Click on the “Help” section of your browser to learn how to change your cookie preferences. If you disable all cookies, you may not be able to take advantage of all the features available on a website. Some newer web browsers may have a "Do Not Track" preference that transmits a "Do Not Track" header to the websites you visit with information indicating that you do not want your activity to be tracked. Boston Market does not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created. Some of our third-party Vendors may permit you to opt out using Do Not Track functionality. Where video is available on our online services, we may target and track the videos you view. You consent to our tracking of your video viewing through online services or third-party social media for up to two years, or as otherwise permitted by applicable law, or until you withdraw your consent. Please note the following:  You might be assigned a cookie when using our online services.  We offer certain features that are available only through the use of cookies and other similar technologies.  We may use both session (for the duration of your visit) and persistent (for the duration of a fixed period of time) cookies and other tracking technologies.  Our online services and other areas related to our business may have web beacons. We use cookies, web beacons and other similar technology, to collect information for the purposes described in this Privacy Notice. We may also combine the information collected by these technologies with information we have collected about you by other means that are described in this Notice. We may use these technologies: -to uniquely identify you or your device; -to allow you to access and use our online services, where without them, our online services may not work properly; -to further system security where appropriate; -for statistical purposes, in order to measure use of our websites and mobile apps; improve our menu, menu items, products and services; -to help us monitor the performance (e.g., traffic, errors, page load time, popular sections, etc.) of our online services; -to remember you, for your convenience, when you visit our online services -to help customize your experience; -to market to you through targeted advertising; and -for other purposes described in the section of this Privacy Notice titled, “How we use the information we collect.” For example, we may use certain technologies to determine whether you have opened an e-mail or clicked on a link contained in an e-mail, how you use the pages and content in our mobile apps, or whether you have clicked on a Boston Market online advertisement. Both we and others (such as our advertising networks) may use these technologies to collect information about your online activities, over time and across third-party websites and devices, and when using our online services to further personalize your experience with us. Targeted advertising When you use our online services, we (and our vendors who provide services to us) may collect information about your activities so that we can provide you with advertising tailored to your interests. Because we take part in advertising (“ad”) networks, you may see certain ads on other websites. Ad networks allow us to target the information we send you based on your interests, other information related to you, and contextual means. These ad networks track your online activities over time by collecting information through use of cookies, web beacons, and web-server logs. The ad networks use this information to show you advertisements that may be of particular interest to you. The ad networks we take part in may collect information about your visits to websites that also take part in the relevant ad network, such as the pages or advertisements you view and how you use the websites. We use this information, both on our online services and on third-party websites that take part in the ad networks, to provide you with advertising tailored to you, and to help us assess how effective our marketing is. This may include to engage in targeted and personalized online advertising on the online services, on third-party websites, mobile apps, TV, or other online or offline services operated by third parties. This marketing may be targeted to you based on Personal or Other Information collected over time, such as through your participation in the Programs, your activity on the online services, your device’s geolocation (which may include specific longitude and latitude), your activity on unaffiliated third-party sites, mobile apps, or other online services, other marketing activities and Programs, and/or from third parties with whom we work. We and our Vendors, including without limitation Facebook, may use Tracking Technologies (as described under "Usage Information" above) to collect information for such marketing and evaluation purposes. For example, our Vendors may use the fact that you visited the Boston Market website to deliver ads to you on non-Boston Market websites, or they may use the fact that you used the Boston Market mobile app to deliver ads to you on non-Boston Market mobile apps. We and our Vendors may also identify whether our marketing activities and programs resulted in you engaging in other activities on our online services, our advertising and/or marketing, making purchases from us and/or our franchisees, visiting restaurants, or otherwise engaging with us. In addition, we and our Vendors may target Boston Market ads to you on your TV or other online services if we or our Vendor have identified you as a Boston Market customer using information we share with them, such as your name, email address, or mailing address. You can opt out of targeted advertising by visiting www.networkadvertising.org/managing/opt_out.asp. If you choose to opt out, you will continue to receive advertisements but they will not be tailored to your interests. We and our Vendors may implement and evaluate our marketing activities and programs.

5. Third-Party Analytics and Targeted Advertising

Analytics We partner with third-party Vendors to engage in analytics, analysis, auditing, measurement, research, and reporting, including without limitation based on Personal or Other Information collected over time, such as through your participation in the Programs, your activity on the online services, your device’s geolocation (which may include specific longitude and latitude), and your activity on unaffiliated third-party sites, mobile apps, or other online services. Our Vendors may use web logs or pixel tags, and/or they may set and access cookies or other Tracking Technologies on your computer or other device. For example, we may use Facebook, Google Analytics, Google Analytics Advertising Features and/or other third party services to help collect and analyze certain information for the purposes described in this Notice, including to evaluate our targeted marketing activities. Also see the "Targeted Marketing" section below. We may use this data in individual form, in a format that that does not, by itself, identify you individually and/or aggregated form, we may share information that does not, by itself, identify you individually and/or aggregated information and/or statistics with others outside of Boston Market, and we may allow third parties to collect and aggregate Other Information in connection with the use of Tracking Technologies. Your Personal information may also be used for analytics related to tracking your activities on the online services, for example, whether you participated in a Program, and which links within our online service you clicked on. You may opt out of the use of cookies by changing you browser settings. Cross-Device Technologies We and our Vendors may use collected information to establish connections among related web browsers and devices (such as smartphones, tablets, computers, and TVs) for targeted advertising, analytics, attribution, and reporting purposes. We and/or our Vendors may match your browsers or devices if you log into the same online service on multiple devices or if your devices share similar attributes that support an inference that they are used by the same person or household. This means that your online behavior (information about your activity on websites or apps on your current browser or device and your device’s geolocation (which may include specific longitude and latitude)) may be combined with information collected from your other browsers or devices. For example, our Vendors may use this information to deliver an ad on your tablet or smartphone, to limit the number of times you see an ad across your devices, and to help measure the effectiveness of advertising campaigns across devices. Location We and/or our Vendors may collect the geolocation (which may include specific longitude and latitude) of your mobile device based upon information identified by your mobile device by, for example, using satellite, cell phone tower, WiFi signals, beacons, Bluetooth and/or near field communication protocols. We may use and share your mobile device’s geolocation (which may include specific longitude and latitude) together with Personal or Other Information to identify your local restaurant, to provide you with personalized messaging or content (for example, that you have a Rotisserie Rewards reward available) and/or for marketing purposes by email, push notification, online or in-app advertising, or by other means, as described in "Targeted Marketing" above and/or as otherwise described in this Privacy Notice. See "Opt-Out Choices" below to opt-out of location collection. If you choose to opt-out of location collection, certain functionality of our online services may not be available. Opt-Out Choices You may opt out of certain of our or our Vendors' targeted marketing practices in web browsers and mobile applications by following the instructions above in this Privacy Notice, or below. Please note that you will need to opt out separately on all of your browsers and devices, as each opt-out will apply only to the specific browser or device from which you opt out. If you delete or reset your cookies or mobile identifiers, change browsers, or use a different device, any opt-out cookie or tool may no longer work and you will have to opt out again. If you participate in any programs with, or receive services from, our franchisees or licensees, you will need to opt out of their systems separately. Note that some Vendors, franchisees or licensees may also make their own opt-out process available. Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising about Boston Market. -Web Browser Opt-Out. To opt out in web browsers, please visit the Network Advertising Initiative Consumer Opt-Out Page at www.networkadvertising.org/choices, the Digital Advertising Alliance Consumer Choice page at www.aboutads.info/consumers. -Mobile Application Opt-Out. To opt out in mobile apps, please download the Digital Advertising Alliance's AppChoices tool at www.aboutads.info/appchoices and adjust the advertising preferences on your mobile device. For example, to adjust your advertising preferences in iOS, visit the limit ad tracking settings within the Settings functionality of your mobile device; to adjust your advertising preferences in Android, visit the opt-out of interest-based ads settings within the Settings functionality of your mobile device. You can also use the settings within your device to opt out of or turn off push notifications. -Location Opt-Out. If you do not want Boston Market to use your specific longitude and latitude information for targeted marketing purposes, you may adjust your location preferences on your computer, browser, or mobile device. You can also stop our collection of location information by uninstalling our mobile application from your device. If you would like to request that Boston Market limit the use or sharing of your Personal Information for other targeted marketing purposes, such as to deliver targeted ads to you on your TV (where available), or other online service based on your Personal Information, please contact us by emailing our Guest Service Center at [email protected]. If your Personal information has previously been shared with our Vendors or other third parties, any request to limit such sharing may not be effective with respect to such previously shared Personal Information. Some of the Vendors that display our ads on their services may provide you with additional choices to opt out of targeted advertising. For example, social media and TV providers may allow you to control your advertising preferences directly through their services. Please review the privacy policies of the third-party services you use for more information.

6. Children’s Privacy

The online services are not directed toward children under the age of 13, and we do not knowingly collect any Personal Information from children under the age of 13. If you are between the ages of 13 and 18, please ensure that you use the online services with the permission of a parent or guardian. You must be 18 to use some portions of the online services. If a child under 13 provided this Site with Personal Information, we ask that a parent or guardian contact us by emailing our Guest Service Center at [email protected], call us at 800-877-2870 or write us at Guest Service Center, Boston Market Corporation, 14103 Denver West Pkwy, Golden, CO 80401 so that we may promptly delete the child's information from our records.

7. Information Security

Boston Market maintains reasonable physical, electronic, and procedural safeguards to protect your Personal Information. Unfortunately though, we cannot guarantee that any safeguards or security measures will be sufficient to prevent a security problem. If you believe your account(s) have been compromised, please immediately contact us by emailing our Guest Contact Center at [email protected] take immediate action to remove any credit card, Boston Market gift card, or other payment information associated with your account(s). Email submissions over the Internet may not be secure, so please do not include any sensitive or confidential information in your message to us. Personal and Other Information may be transferred to and stored on computers and servers located in the United States and other countries located outside your country of residence. Personal Information might be disclosed to governments or law enforcement agencies in these countries where required by law. By agreeing to this Notice, using the online services, and/or sharing your Personal Information with Boston Market, you consent to such transfer. We are committed to taking appropriate measures designed to keep your personal information secure. Our technical, organizational and physical procedures are designed to protect personal information from accidental, unlawful or unauthorized loss, access, disclosure, use, alteration, or destruction. While we make efforts to protect our information systems, no website, mobile application, computer system, or transmission of information over the internet or any other public network can be guaranteed to be 100% secure.

8. Your Choices and Changing Your Information

We provide you with the ability to review or change certain of your Personal Information and make certain choices about how we use or share Personal or Other Information. You may review, change, or exercise choice regarding certain of your Personal or Other Information as follows: To update, verify, or delete certain of your Personal Information, please edit the applicable account. If you need assistance, please contact us by emailing our Guest Service Center at [email protected]. Note that not all fields are able to be changed. To opt out of certain analytics tracking, online advertising and third-party tracking, see the “Usage Information” and the “Analytics” and “Opt-Out Choices” subsections of the “Third Party Analytics and Targeted Marketing”section above. To stop sharing your specific longitude and latitude information with us, you may adjust your location preferences on your computer, browser, or mobile device. To request that Boston Market does not share your Personal Information with third parties for their own marketing purposes on a going-forward basis, please contact us by emailing our Guest Service Center at [email protected]. To unsubscribe from marketing emails, click the “unsubscribe” link found in our marketing email messages. In some cases this information may not be immediately updated, subject to retention for Program administration, dispute resolution, troubleshooting, and other valid legal or business reasons. Your historical usage information may remain in our records. Also see the “Usage Information” and “Analytics” and “Opt-Out Choices” sub section of the “Third Party Analytics and Targeted Marketing” section above for other limitations. Other choices may be available within your account page or presented to you in certain marketing communications.

9. Third-Party Sites/Services

The online services may access or provide links to web sites or online services not operated by Boston Market, including our Vendor(s) related to certain Programs or services offered through the online services (such as gift card purchases or interaction with voice assist services or other third party assisted ordering processes (e.g., Google, Facebook, Instagram)). We may also provide you with access to third party functionality that allows you to post certain content from the online services to your social media account(s). Any information that you provide that interacts with the Third Party service or that you post to a third-party site or service is governed by the applicable third partys terms and privacy Notice. Boston Market assumes no responsibility for third-party services or websites, including but not limited to, the privacy practices of these third-party sites. We encourage you to be aware of this when you leave the Online services and/or share information with third parties or the public, and we recommend that you review the privacy policies of such third-party sites. For More Information If you have any questions regarding our Privacy Notice, please contact us by emailing our Guest Service Center at [email protected].

10. State-Specific Rights

The law in some states may provide you with additional rights regarding our use of Personal Information. To learn more about any additional rights that may be applicable to you as a resident of one of these states, please see below and the privacy addendum for your state that is attached to this Notice. Your California Privacy Rights California Civil Code Section 1798.83 permits customers of Boston Market who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us by emailing our Guest Service Center at [email protected] or write us at: Guest Service Center, Boston Market Corporation, 14103 Denver West Pkwy. Golden, CO 80401. After January 1, 2020, you may also have the additional rights described in the California Privacy Addendum attached to this Notice.

11. Changes To Our Privacy Statement

This Privacy Notice is in effect as of the date noted at the top of the statement. We may change or modify this privacy statement from time to time. If we do, we will post the revised version here and change the “last updated date” (the date it applies from) at the top of the statement. You should check here regularly for the most up-to-date version of the statement. Any changes or modifications will be effective immediately upon posting of the changes or modifications, and to the extent permitted by law you waive any right you may have to receive specific notice of such changes or modifications.

12. How To Contact Us

You can contact us at any time about our privacy practices at our company headquarters, as noted below. Attention: Data Protection Office Boston Market Corporation 14103 Denver West Pkwy Golden, CO 80401 [email protected]

• Boston Market Privacy Addendum for California Residents Effective Date: January 1, 2020

  This Privacy Addendum for California Residents (the “California Addendum”) supplements the information contained in Boston Market’s Privacy Notice (our “Notice”) and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice. Note that this California Addendum does not apply to our California employees. Please contact your local human resources department if you are a California employee and would like additional information about how we process your Personal Information.

• Information We Collect

  Our online services (as defined in our Notice) collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, Boston online services have collected the following categories of personal information from its consumers within the last twelve (12) months:

  Category	Examples	Collected
  A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	YES
  B. Personal information categories listed in the California	A name, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.	YES
  Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Some personal information included in this category may overlap with other categories.
  C. Protected classification characteristics under California or federal law.	Age (40 years or older).	YES (if you provide us your birthdate)
  D. Commercial information.	Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
  E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
  F. Internet or other similar network activity.	Browsing history, search history, information on a your interaction with a website, application, or advertisement.	YES
  G. Geolocation data.	Physical location or movements.	YES
  H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
  I. Professional or employment- related information.	Current or past job history or performance evaluations.	NO
  J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
  K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

  The examples provided above come from the CCPA and other statutes, as noted. They are reproduced here for your convenience to help you understand the types of information that are considered within each category. It is not meant to imply that we collect all such information listed in the examples. We only collect the specific pieces of Personal Data described in our Notice. Personal information does not include: - Publicly available information from government records. - Deidentified or aggregated consumer information. - Information excluded from the CCPA’s scope, like: - health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; - personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994. Boston Market obtains the categories of personal information listed above from the categories of sources described in our Notice.

• Use of Personal Information

  We may use, sell, or disclose the personal information we collect for the purposes described in our Notice. Boston Market will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

• Sharing Personal Information

  Boston Market may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights). When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales. We share your personal information with the categories of third parties described in our Notice. Disclosures of Personal Information for a Business Purpose In the preceding twelve (12) months, Boston Market has disclosed the following categories of personal information for a business purpose:.

  Category A: Identifiers. Category B: California Customer Records personal information categories. Category C: Protected classification characteristics under California or federal law. Category D: Commercial information. Category F: Internet or other similar network activity. Category G: Geolocation data. Category H: Sensory data. Category K: Inferences drawn from other personal information.

  We may disclose your personal information in the future for a business purpose to the categories of third parties described in our Notice. Sales of Personal Information The California State Attorney General may issue guidance on if the use of advertising and analytics cookies on our online services may be considered a “sale” of Personal Information as the term “sale” is broadly defined in the CCPA. Until such guidance has been issued, we continue to consider it a “sale” in order to be as transparent as possible with users of our online services and will comply with the restrictions of the “sale” of this information to the extent technologically feasible. In the preceding twelve (12) months, Boston Market has “sold” the following categories of Personal Information:

  Category A: Identifiers. Category B: California Customer Records personal information categories. Category D: Commercial information. Category F: Internet or other similar network activity. Category G: Geolocation data. Category K: Inferences drawn from other personal information.

  We sell your personal information to the following categories of third parties:

  - Data brokers or aggregators. - Advertisers. - Social media companies. - Internet cookie information recipients, such as analytics and behavioral advertising services.

• Your Rights and Choices

  - The categories of personal information we collected about you. - The categories of sources for the personal information we collected about you. - Our business or commercial purpose for collecting or selling that personal information. - The categories of third parties with whom we share that personal information. - The specific pieces of personal information we collected about you (also called a data portability request). - If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: - sales, identifying the personal information categories that each category of recipient purchased; and - disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

  Deletion Request Rights You have the right to request that Boston Market delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. 2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 3. Debug products to identify and repair errors that impair existing intended functionality. 4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. 5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). 6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent. 7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. 8. Comply with a legal obligation. 9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

• Non-Discrimination

  Deletion Request Rights You have the right to request that Boston Market delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. 2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 3. Debug products to identify and repair errors that impair existing intended functionality. 4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. 5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). 6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent. 7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. 8. Comply with a legal obligation. 9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

• Changes to Our Privacy Notice

  Boston Market reserves the right to amend this California Addendum at our discretion and at any time. When we make changes to this California Addendum, we will post the updated notice on the online services and update this California Addendum’s effective date. Your continued use of our online services following the posting of changes constitutes your acceptance of such changes.

• Contact Information

  If you have any questions or comments about this notice, the ways in which Boston Market collects and uses your information described above and in the Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact as set forth in the Notice. We may be reached at [email protected] and at Attention: Data Protection Office Boston Market Corporation 14103 Denver West Pkwy Golden, CO 80401