Privacy

This Privacy Policy ("Privacy Policy") describes the information practices of MTY FRANCHISING USA, INC., and its Affiliates, dba Ginger Sushi ("Ginger Sushi") and, as applicable, its affiliates, subsidiaries and related entities including, without limitation, Kahala Management, L.L.C. ("Affiliates"), (Ginger Sushi and its Affiliates are referred to herein, as the context may require, as "we", "us", or "our"). It covers the information that we collect about you, how we use and share this information, and your choices regarding our collection and use. It applies to your access to, and use of, any of our websites, mobile applications, and online services or programs where this Privacy Policy is posted or linked (collectively, "Online Services").

If you do not agree with any term in this Privacy Policy, please do not provide any personal information. However, if you choose not to provide your personal information, you may not be able to, among other things, access particular areas of our website, access and use rewards programs, email clubs, order certificates, obtain franchise information, enter contests, request samples, or send us e-mail. If you have any questions or concerns regarding this Privacy Policy, please contact us via the Contact Information provided at the end of this Privacy Policy.

Please note that residents of certain jurisdictions have additional rights as set forth below in the section titled Additional Information for Certain Jurisdictions.

If you are a California resident, please refer to the Additional Information for California Residents section below for important information about the categories of personal information we collect and disclose, as well as your rights under California privacy laws, including your right to submit a request to opt-out of the sales and sharing of your personal information by us.

The Ginger Sushi Franchise System

The Ginger Sushi franchise system is a restaurant network made up of company-operated, franchised, and licensed Ginger Sushi restaurant businesses. Ginger Sushi franchisees ("Franchised Operators" or "Operators") own and operate their own individual franchised businesses. Ginger Sushi licensees ("Licensees") are granted a license to use Ginger Sushi's trade name and marks in the sale of Ginger Sushi products at Ginger Sushi licensed locations. Franchised Operators and Licensees are independent third parties, and this Privacy Policy does not apply to the privacy practices of any Franchised Operator or Licensee, or to any Ginger Sushi operations outside of the United States. Please see the Franchised Operator and Licensee Online Services section below for more information regarding a Franchised Operator's or Licensee's applicable policies.

Information Covered by This Privacy Policy

This Privacy Policy applies to information, including Personal Information, collected about you by Ginger Sushi and its third-party service providers. As used in this Privacy Policy, "Personal Information" means information that personally identifies you.

Information Collected

Ginger Sushi and its third-party service providers collect information about you from a variety of sources, including information you provide directly to us, and information we collect about you when you interact with us. For example, we and our third-party service providers collect information both directly and indirectly from you when you:

• access or use our Online Service;
• order and/or purchase any of our brand’s products or services;
• contact or communicate with us;
• create an account with us;
• request information from us;
• register for any event or program, and/or participate in any event, program, contest, surveys, or other promotion that we may offer directly or with another third party from time to time (collectively, "Promotions");
• begin or complete the application process for a franchise opportunity, or for employment with us;
• access or use Ginger Sushi pages or accounts on any third-party social media platforms such as Facebook, Twitter, or Foursquare ("Social Media Pages");
• sign-up for communications (e.g. social media notifications) from us;
• provide or submit comments, stories, suggestions, or other content or input to us;
• interact with our Online Services via mobile, tablet or laptop device; and/or 
• otherwise interact with us and Ginger Sushi Online Services.

We may collect, compile, store, publish, promote, report, sell, or otherwise disclose or use any and all of the aggregate information; provided that such information does not personally identify you or, if it does, as set forth in this Privacy Policy.

Personal Information

We and our third-party service providers collect Personal Information provided by you or on your behalf, which information may include your:

• name;
• address;
• telephone numbers (including mobile numbers);
• email addresses;
• birthday details and/or age;
• demographic information; and/or
• financial information (e.g., credit and debit card numbers).

We do not require you to provide any information related to your racial origin, religious beliefs, or sexual orientation.

When you use the fingerprint login features on your Apple or Android devices, we do not receive your fingerprint data. Your mobile phone's authentication mechanism helps us verify that it is you.

Transaction Data

We and our third-party service providers may also collect information, including Personal Information, relating to your purchases from Ginger Sushi locations and our Franchised Operators and Licensees, such as the authorization code of the transaction, payment method, the date and time of the transaction, items purchased, and the purchase price ("Transaction Data").

Information Collected Automatically

We and our third-party service providers use tracking technologies such as Traffic Data, Cookies, Web Beacons, and others to automatically collect certain information from you when you use Ginger Sushi Online Services. The following are examples of information we may collect with these technologies:

• your IP address, browser type, and operating system;
• your device attributes including but not limited to device ID;
• pages you view within our Online Services (including videos viewed);
• if you buy goods from us, what you buy, where you buy, how frequently you buy and rewards you earn;
• search information (e.g. terms or keywords you search for when using the Ginger Sushi Online Services);
• websites you visited before coming to Ginger Sushi Online Services;
• emails from us that you open and/or forward; and/or
• offers or links from us to which you connect.

We use this information to personalize your online experience and for marketing purposes.

Our Online Services tracks and collects your IP address, domain server, type of computer, and type of web browser (collectively, "Traffic Data") for our marketing purposes and to manage and improve Ginger Sushi Online Services.

We also use cookies, which are small text files that are stored on a user's computer and allow websites to remember information about users ("Cookies"). We use Cookies to monitor how our Online Services are used, for marketing purposes, and to help personalize and improve Ginger Sushi Online Services. Most browsers automatically accept Cookies. You have the choice to set your browser to accept or reject Cookies. Each browser is different, so check the "Help" menu of your browser to learn how to change your Cookie preferences. You can also learn more about Cookies at the following websites:

If you choose to decline Cookies, you may not be able to fully experience the interactive features of our our Online Services or programs, features, and services made available through any of Ginger Sushi Online Services.

Certain pages on our Online Services and Social Media Pages may contain web beacons (also known as Internet tags, pixel tags, and clear GIFs), which are small bits of code embedded in pages or images on our Online Services and Social Media Pages ("Web Beacons"). We may also include Web Beacons in e-mails we send to you to learn if messages have been opened, acted on, or forwarded. You can disable the ability of Web Beacons to capture such information. Please refer to the "Help" menu of your browser to learn more about Web Beacons and your ability to disable them. You can also adjust your cookies settings through the cookies preference manager widget located at the bottom left of the gingersushi.com website. However, your settings are browser and device specific – so, if you come back to our website from a different device or browser, or you delete cookies on your current browser, you will need to apply these settings again.

We and our third-party service providers may also utilize other tracking technologies. For example, if permitted by applicable law, we may collect "referrers" and various environmental variables. A "referrer" is information the web browser passes along to our or our third-party service provider web servers, which refers to the URL from which you accessed Ginger Sushi Online Services. Environmental variables may include, among other things, the domain from which you access the Internet, the time you accessed our Online Services or Social Media Pages, the type of web browsers and operating system or platform used, the Internet address of the website you left to visit our Online Services or Social Media Pages, the names of the web pages you visit, and the Internet address of the website you visit next. These environmental variables are collected by many websites. We use these technologies for marketing purposes and to optimize user's experience with Ginger Sushi Online Services.

We treat information automatically collected as non-personally identifying information. Such information may be combined with your Personal Information so that we can improve and customize our Online Services and our communications and Promotions. To the extent that information automatically collected is combined with Personal Information, we treat the combined information as Personal Information for the purposes of this Privacy Policy.

You may encounter tracking technologies/cookies from our third party service providers that we have allowed on our Ginger Sushi Online Services. We do not control the tracking technologies used by third party providers as detailed herein.

We may target and track the videos you view on Ginger Sushi Online Services. You consent to our tracking of your video viewing through the our Online Services or third party social media for up to two years or as permitted by applicable law or until you withdraw consent.

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. ("Google"), on certain Ginger Sushi Online Services. Google Analytics collects information such as how often you visit Ginger Sushi Online Services, what pages you visit within Ginger Sushi Online Services, and what other sites you visited prior to coming to the applicable Ginger Sushi Online Service. We use the information provided by Google Analytics to improve Ginger Sushi Online Services. For more information regarding how Google collects, uses and shares your information please visit http://www.google.com/policies/privacy/partners/. Google provides users more choice on how their data is collected by Google Analytics by developing an Opt-out Browser Add-on which can be located at: http://tools.google.com/dlpage/gaoptout?hl=en. By installing this Add-on, no information is being sent to Google Analytics.

California's Do Not Track Notice

At this time, there is no worldwide uniform or consistent industry standard or definition for responding to, processing, or communicating Do Not Track signals. Thus, our Online Services are unable to respond to Do Not Track Signals. We do not, however, currently track your Personal Information over time and across third-party websites.

Ginger Sushi does not allow third parties to collect Personal Information about your online activities when you use our Online Services for such third party use. We do use third party web analytics services on Ginger Sushi Online Services, such as Google Analytics, to help us obtain and analyze information about your browsing or usage habits but this information does not include Personal Information other than your IP address.

Mobile Applications

In addition to the information described above, we and our third-party service providers may collect additional information when you utilize any of our mobile applications, including for example, the type of mobile device you use, the temporary or persistent unique device identifiers (sometimes called UDID), the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use our mobile applications.

If you utilize any of the location-based services in our mobile applications, such as the fine a location function, we and our third-party service providers may collect, use, and share location data, including the real-time geographic location of your device. We use such information to provide and improve location-based products and services. You may opt-out from further allowing us to have access to your location data by adjusting the permissions in your mobile device.

Information Use

We use your information that we collect, including Personal Information, for a variety of business purposes, including for example:

• providing our brand’s products and services to you;
• processing payments;
• communicating with you regarding our locations, products, services, events, Promotions, and other offers;
• tailoring our brand’s products, services, Promotions, communications, and Ginger Sushi Online Services, and advertisements to your interests;
• creating and managing your accounts with us (e.g., email clubs, text distribution lists, rewards programs, online registration for events, online ordering, mobile payments, etc.);
• administering our Promotions and other offers;
• responding to your inquiries, comments, stories, or postings;
• improving and customizing our brand’s products, services, Promotions, and Ginger Sushi Online Services;
• for internal operations such as enhancing our product and service offerings, marketing efforts, and to conduct research and analysis;
• developing new products, services, and Promotions;
• for marketing purposes;
• to prevent, detect, and investigate fraud, security breaches, and potentially prohibited or illegal activities;
• to enforce our Terms and Conditions of Use; and/or
• to protect the security and integrity of our business and Ginger Sushi Online Services.

Information Sharing and Disclosure

We may share and disclose your Personal Information under the following circumstances:

• with third parties that provide a variety of services on our behalf, including the development, maintenance, and support of our Online Services and Social Media Pages, payment processing, online and mobile application ordering, the distribution of email and mobile messages, Promotions, ad serving, marketing, and marketing research and analysis;
• within Ginger Sushi and with its Affiliates (as such terms are defined above in this Privacy Policy);
• with our Franchised Operators and Licensees in order to provide our brand’s products, services, and Promotions to you, and for marketing purposes;
• to comply with law, a court order, or other legal process, or in connection with a legal investigation;
• as may be necessary to protect the safety, property, or other rights of Ginger Sushi, its Affiliates, Franchised Operators and Licensees, and our and their respective employees, customers, visitors, users, or any other person or entity;
• to enforce any applicable terms and conditions and other agreements;
• in the event of a corporate transaction (for example, the sale of our company, our assets or a portion of our assets to a third party, or financing);
• in aggregated or other non-personally identifiable form; and/or
• in accordance with your consent.

User Generated Content

our Online Services and Social Media Pages may allow users to post messages and submit their own content (e.g., stories, comments, blogs, postings, etc.), which may include Personal Information. You are responsible for all actions resulting from any information, including Personal Information, which you post on our Online Services or Social Media Pages. Please remember that any information you post becomes public information, is not subject to this Privacy Policy, and Ginger Sushi is not responsible for the results of such postings.

Collection and Use of Personal Information of Prospective Ginger Sushi Franchised Operators

If you complete an application for a franchise opportunity with Ginger Sushi, or express interest or otherwise request information about franchise opportunities, we collect Personal Information that you provide in connection with your request for information and/or to evaluate your application for a franchise restaurant business opportunity. We may also collect Personal Information about you from third parties to supplement, update, or verify your information, and/or to process your application for consideration as a Franchised Operator. Applicable law may require that you authorize a third party to share your Personal Information with us before we can acquire it. Failure to provide any requested information may negatively impact consideration of your application to become a Franchised Operator. By expressing interest in becoming and/or applying to become a Franchised Operator, you consent to our collection, use, and disclosure of your Personal Information in this manner.

Collection and Use of Personal Information of Our Employment Applicants

If you complete an application for employment with us, or request information regarding such opportunities, we collect Personal Information that you provide in connection with your request for information and/or to evaluate your application for employment with us. We may also collect Personal Information about you from third parties to supplement, update, or verify your information, and/or to process your application for consideration as our employee. Applicable law may require that you authorize a third party to share your Personal Information with us before we can acquire it. Failure to provide any requested information may negatively impact consideration of your employment application. By applying to become an employee of ours you consent to our collection, use, and disclosure of your Personal Information in this manner.

Your Choices

We provide you with the opportunity to update and/or delete certain information and to opt-out of having your Personal Information used or disclosed for certain purposes. For example, you may

• correct, update, and delete your online accounts;
• change your choices for subscriptions and certain communications (e.g., email clubs, text distribution lists, rewards programs, and other notifications);
• choose whether to receive Promotions and offers from us;
• request that we do not share your Personal Information with third parties for their marketing purposes; and/or
• request access to your Personal Information.

You may exercise your choices by contacting us via the Contact Information provided at the end of this Privacy Policy, or following instructions provided in communications sent to you.

Because we plan our communications in advance, it may take several weeks for your request to become effective. If you continue to receive our communications after expressing an opt-out preference, please let us know so that we can investigate the situation.

Children's Privacy

We do not knowingly collect Personal Information online from children under the age of 13 without parental or guardian consent. Please contact us via the Contact Information provided below if you believe we may have collected such information without parental or guardian consent or other than in a manner authorized by law, and we will work to delete it. We or our Affiliates may need to access and use your child's personal information in order to respond to a service request, prevent fraud, or assist us in the management and improvement of our Ginger Sushi Online Services. We encourage parents of children under 13 to regularly check and monitor their children's use of e-mail and other activities online.

Information Security

We seek to keep your Personal Information secure and implement reasonable technical, administrative, and physical safeguards to help us protect such information from unauthorized access, use, and disclosure. If we collect or transmit sensitive information such as a credit card number, we use industry standard methods to protect that information. We also request that our third-party service providers use commercially reasonable security measures to protect your information from unauthorized access or use. However, no method of electronically transmitting or storing data is ever completely secure, and therefore, we cannot guarantee that your information will never be accessed, used, or disclosed in a manner that is inconsistent with this Privacy Policy.

Links, Third-Party Websites, and Social Media Platforms

Our Online Services and our communications (including e-mails) may contain links to other third-party websites, including, without limitation, the websites of Franchised Operators and Licensees, and social media platforms such as Facebook, Twitter, or Foursquare (such third-party websites and social media platforms are collectively referred to herein as "Linked Sites"). We are not responsible for the privacy practices, policies, or content of any Linked Sites, even if you link to them from our Online Services or our communications. This Privacy Policy does not apply to any Linked Sites. We have no control over the collection or use of information, including Personal Information, on any Linked Site. We encourage you to read and understand the privacy policies of any Linked Sites that you visit.

Franchised Operator and Licensee Online Services

Ginger Sushi Franchised Operators and Licensees are independent third parties and may own, operate, and maintain a website, mobile application, social media page, or other online service for his, her, or its franchised or licensed restaurant business ("Franchised Operator or Licensee Online Services"). This Privacy Policy does not apply to the privacy practices of any Franchised Operator or Licensee. Therefore, you should carefully review the privacy policy of each Franchised Operator or Licensee Online Services that you visit. Questions or concerns regarding any Franchised Operator or Licensee Online Services should be directed to the applicable Franchised Operator or Licensee.

We may, subject to certain terms and conditions, allow a Franchised Operator or Licensee to link to Ginger Sushi Online Services. Ginger Sushi, however, is not responsible or liable for any Franchised Operator or Licensee Online Services, even if it is linked to this Site, or for any Franchised Operator's or Licensee's online conduct and privacy practices.

E-mail Security

"Phishing" is a scam designed to steal your Personal Information. If you receive an e-mail that looks like it is from us asking you for your Personal Information which you suspect may be a scam, please notify us as provided in the Contact Information section included at the end of this Privacy Policy.

Data Transfers

We may transfer the personal information we collect about you to countries other than the country in which the information originally was collected. The data protection and other laws of such other countries might not be as comprehensive as those in your country. By providing your information, you understand that it may be transferred to our facilities and to those third parties with whom we share it as described in this Privacy Policy.

Changes To This Privacy Policy

We may revise this Privacy Policy from time to time effective upon posting the revised Privacy Policy, along with the date on which it was most recently updated, on Ginger Sushi Online Services. Please check our Privacy Policy periodically to see if it has been updated. If a change to this Privacy Policy materially affects the use or disclosure of your Personal Information, a notice will be posted at www.Ginger Sushi.com along with a link to the updated Privacy Policy. Your continued use of our Online Services and/or provision of your information thereafter constitute your acceptance of such changes. Please contact us as described below if you would like information regarding any changes.

Additional Information For Certain Jurisdictions

Residents of Virginia, Colorado, Connecticut, and Utah have additional rights under applicable privacy laws, subject to certain limitations:

• Correction. The right to correct inaccuracies in their personal information, taking into account the nature and purposes of the processing of the personal information.
• Deletion. The right to delete their personal information provided to or obtained by us.
• Access. The right to confirm whether we are processing their personal information and to obtain a copy of their personal information in a portable and, to the extent technically feasible, readily usable format.
• Opt-out. The right to opt-out of certain types of processing, including:
  • To-opt out of the “sale” of their personal information.
  • To opt-out of targeted advertising by us.
  • To opt-out of any processing of personal information for purposes of making decisions that produce legal or similarly significant effects.

You may submit a request to exercise most of your privacy rights under U.S. state privacy laws online using our webform. To opt-out of targeted advertising by us, you can adjust your cookies settings through our cookies preference manager (see the Section titled, Information Collected Automatically above for further information). We will respond to your request as required under the applicable privacy law(s). If we deny your request, you may appeal our decision by submitting another webform request.

Additional Information for California Residents

This section supplements the information contained in our Privacy Policy above and provides, in general, our policies and practices under the California Consumer Privacy Act (“CCPA”). This section applies solely to individuals who reside in California (“consumers” or “you”). If you do not reside in California, this section does not apply to you. All terms defined by the CCPA have the same meaning when used here. This section does not address or apply to our handling of publicly available information made lawfully available by state or federal governments or other personal information that is subject to an exemption under the CCPA.

This section was last updated: July 1, 2023

Categories of Personal Information Collected and Disclosed

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with particular California consumers, households, or devices (“Personal Information”). Our collection and handling of Personal Information varies with our relationship and interactions with You. For example, we may collect different categories of Personal Information from customers, potential customers, employees, employee applicants, other workforce members, and potential franchisees.

Sales and Sharing of Personal Information

The CCPA defines a "sale" as disclosing or making available Personal Information to a third party in exchange for monetary or other valuable consideration, and “sharing” broadly as disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. While we do not disclose Personal Information to third parties in exchange for monetary compensation from such third parties, we may “sell” or “share” the following categories of Personal Information in order to receive certain services, information, or benefits from third parties: identifiers; customer records; commercial information; internet or other electronic network activity information; and inferences. We share these categories with third-party advertising networks, social networks, data analytics providers, and franchise owners (such as when we allow third-party tags to collect browsing history and other information on our websites to improve and measure our ad campaigns).

We do not sell or share sensitive Personal Information as that term is defined by the CCPA (“Sensitive Personal Information”), nor do we sell or share any Personal Information about individuals who we know are under sixteen (16) years old.

Sources of Personal Information

We may collect the Personal Information identified in the categories above from the following sources:

• Directly from you. For example, from information you provide in the course of obtaining products or services from us, from information provided in employment applications, or in from information on franchise applications or forms.
• Indirectly from you. For example, through our use of cookies and pixels on our websites.
• Our business vendors.
• Advertising networks.
• Data analytics providers.
• Social networks.
• Internet service providers.
• Operating systems and platform.
• Data brokers.
• Our franchisees.

Use of Personal Information

We may use the Personal Information that we collect for the following business or commercial purposes and as otherwise directed or consented to by you:

• To provide or fulfill the reason for which you provided the Personal Information. For example, we may use such information to add you to our rewards program, to create and secure your account with us, or to process and complete online purchases and transactions.
• To correspond with you. For example, if you request information or wish to share an experience that you had at one of our stores, we may ask for your name, address, and email address, so that we can best respond to your comments.
• To improve or customize our services and products.
• For marketing and advertising purposes.
• To evaluate and process inquiries from interested potential franchisees.
• To detect fraud and prevent loss.
• To provide you with information about our products and services through periodic emails or text messages.
• To respond to requests from law enforcement or court order as required by applicable or governmental regulations.
• To evaluate your application and eligibility for employment.
• To manage your compensation and benefits.
• To manage your development, performance, and conduct.
• To protect us against illegal activity and other misconduct.
• To comply with our legal obligations.
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our website users/consumers is among the assets transferred.
• Other business purposes allowed by the CCPA.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes from those listed above without providing you notice.

Our use of your Personal Information may vary depending on whether you are a customer, potential customer, employee, employee applicant, or potential franchisee.

Sensitive Personal Information

We only use and disclose Sensitive Personal Information as reasonably necessary: (i) to perform our services requested by you, (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents, (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct, (iv) to verify or maintain the quality and safety of our services, (v) for compliance with our legal obligations, (vi) to our service providers who perform services on our behalf, and (vii) for purposes other than inferring characteristics about you. We do not use or disclose your Sensitive Personal Information other than as authorized pursuant to section 7027 of the CCPA regulations (Cal. Code. Regs., tit. 11, § 7027(m)).

Retention of Personal Information

We retain the Personal Information we collect only as reasonably necessary for the purposes described above or otherwise disclosed to you at the time of collection.

Your Rights Under the CCPA

In general, if you are a California resident you have the following rights under the CCPA:

• Right to Know/Access: With respect to personal information we have collected about you in the prior 12 months, subject to certain exceptions and up to twice per twelve (12)-month period, you have the right to require us to tell you:
  • Categories of Personal Information we collected about you.
  • Categories of sources of Personal Information we collected about you.
  • Whether we sold or shared Personal Information about you.
  • Business or commercial purposes for which we collected, sold, or shared Personal Information about you.
  • Categories of third parties with whom we share Personal Information about you.
  • Specific pieces of Personal Information collected about you.
• Right to Delete: You have the right to request that we delete any of your Personal Information that we collected and retained, subject to certain exceptions. We may deny your deletion request if retaining the Personal Information is necessary for us or our service providers and/or contractors to:
  • 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • 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.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

  We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers and contractors to take similar action.

• Right to Opt-Out of Sale/Sharing: You have the right to opt-out of the sale or sharing of your Personal Information.
• Right to Correct: You have the right to correct the Personal Information we may have collected about you if that information is inaccurate. We reserve the right to request identifying documentation from you in certain circumstances, as permitted by law.
• Right to Limit: You have the right to limit our use or disclosure of your Sensitive Personal Information to certain purposes permitted by law. As further explained above in the section titled Sensitive Personal Information, we only use and disclose Sensitive Personal Information as permitted by the CCPA, thus this right is not available.
• Right to Non-Discrimination: You have to right to not be discriminated against for exercising your rights under the CCPA. Unless permitted by the CCPA, we will not, as a result of you exercising your rights under the CCPA:
  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Financial Incentives

The CCPA allows us to offer certain financial incentives for providing us with your Personal Information that can result in different prices or rates for our goods or services. Any financial incentive we offer will reasonably relate to your Personal Information’s value. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. If we provide a financial incentive, we will provide you with the details here, including how the incentive is related to your data before you participate so that you may make an informed decision about whether and how to participate. However, if you choose to opt-out, do not provide certain necessary Personal Information, or request that we delete this Personal Information, we will not be able to administer the program and provide you with the financial incentive.

Exercising Your Rights to Know/Access, Correct, or Delete

You may submit requests on your own behalf or have your legally authorized agent do so for you by:

• Calling us Toll-Free at 866-452-4252; or
• Completing the request form available here.

When you submit your request, you must provide us with enough detail so that we can verify you are the person about whom we collected Personal Information (or that you are a legally authorized representative), and also understand, evaluate, and respond to your request. At a minimum, we need the following information:

• What you are requesting: You must describe your request with sufficient detail that allows us to understand, evaluate, and respond to it. For example, if you are submitting a request to know, you must let us know whether you are requesting to know categories or specific pieces of Personal Information.
• Who you are: You must let us know who you are, and whether you are a California resident submitting the request on your own behalf or whether you are an authorized agent submitting the request for a California resident. Specific requirements for authorized agents are detailed under the section titled How We Verify Requests below. We will only use Personal Information provided in the request to verify your identity or your authority to make the request on behalf of a California resident.
• Information regarding the California resident for whom the request is made: You must provide us enough identifying information so that we can begin processing the request. We may need further information to verify the request, as detailed under the section titled How We Verify Requests below.

Exercising Your Right to Opt-Out of Sale and Sharing

You may opt out of most third-party tags and cookies on our website using our cookie preference manager, by adjusting the settings in your browser (i.e., disabling cookies), or by clicking the “Do Not Sell or Share My Personal Information” link located at the bottom of the gingersushi.com website. Your settings are browser and device specific—so, if you come back to our website from a different device or browser, or you delete cookies on your current browser, you will need to apply these settings again. In addition, our website responds to global privacy control—or “GPC”—signals, which means that if we detect that your browser is communicating a GPC signal, we will process that as a request to opt that particular browser and device out of sales and sharing (i.e., via cookies and tracking tools) on our website. Note that if you come back to our website from a different device or use a different browser on the same device, you will need to opt out (or set GPC for) that browser and device as well. More information about GPC is available at: https://globalprivacycontrol.org/.

How We Verify Requests

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation of your request with the 10-day timeframe, please contact us at the toll-free number provided above or by using our webform.

When you submit a request to know/access, delete, or correct, we will take steps to verify your identity and the request by matching the information you provide with the information we have in our records. We may send an email to the email address that we have in our records asking you to verify that you made the request. We may also require additional information from you that is necessary to verify and respond to your request and you must provide us with all information that we request. You can provide us this information either through our toll-free telephone number or the webform provided above. We work to respond to a verifiable consumer request within forty-five (45) days of receiving it. If we require more time (up to ninety (90) days in total), we will inform you of the reason and the extension period in writing.

If we verify your request to know/access, we will provide you a report responding to your specific request, subject to the exceptions provided for in the CCPA. This report will include any Personal Information that our service providers or contractors have collected about your pursuant to their contractual obligations to us.

If we verify your request to delete, we will delete, and instruct our service providers, contractors, and all third parties with whom we have shared your Personal Information to delete, any Personal Information we have collected about you, subject to the exceptions provided for in the CCPA.

If we verify your request to correct, we will correct, and instruct our service providers and contractors to correct, the incorrect Personal Information at issue, subject to the exceptions provided for in the CCPA.

We will inform you if we cannot verify your request. If we cannot verify your request, the CCPA prohibits us from deleting, correcting, or providing you any information regarding what Personal Information we may have collected.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded and as permitted under the CCPA. If we determine that the request warrants a fee that is permitted under the CCPA, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We accept requests from authorized agents of California residents. If you are an authorized agent, we may require additional information and documentation, such as a valid power of attorney or written and signed authorization from the consumer. We may also require a valid email address for the consumer so that we can directly confirm the request and your authorization.

California Privacy Rights under California’s Shine-the-Light Law

Under California’s "Shine the Light" law, California residents who provide us their personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we may from time-to-time share with third parties for their own direct marketing use; such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year. If you are a California resident and would like to make such a request, please submit your request in writing at customerservice@kahalamgmt.com, using the subject line "California Privacy Information." In your request, please attest to the fact that you are a California resident and provide a current California address. We will reply to valid requests by sending a response to the email address from which you submitted your request. Our response to you will be limited to information on covered sharing and the relevant details required by the Shine the Light law.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated policy on our website or mobile application and update the policy’s effective date. Your continued use of our website or mobile application following the posting of changes constitutes your acceptance of such changes.

How to Contact Us for More Information

We welcome your questions and comments about privacy. If you would like to contact us, or if you need to access this policy in and alternative format due to having a disability, please send us an e-mail at customerservice@kahalamgmt.com, or contact us at:

Contact Information

If you have any questions about this Privacy Policy or our use of your Personal Information, please contact us in any of the ways set forth below.

Address:

Ginger Sushi
9311 E. Via de Ventura
Scottsdale, AZ 85258
Attn: Marketing Manager
customerservice@kahalamgmt.com

Via the web:
https://www.gingersushi.com

Phone:
866-452-4252

Effective: January 2018

© 2018 MTY FRANCHISING USA, INC. All rights reserved.