|
Privacy Policy
Last update: June 3, 2024
The National Restaurant Association and its affiliates, National Restaurant Association
Solutions LLC, The National Restaurant Association Educational Foundation, Environmental
Health Testing LLC (dba National Registry of Food Safety Professionals), Multicultural
Foodservice and Hospitality Alliance, Restaurant Law Center, NRAS Restaurant Owner, LLC, and
National Restaurant Association Political Action Committee (collectively, the "Association,"
"we" or "us") understand that you care about how we collect, use, and share information when
you interact with us through our websites, mobile applications, social media sites and
handles, email, events, surveys, and research (our "Services") and we value the trust you
place in us. This Privacy Policy explains:
We also include specific disclosures for residents of the
European Economic Area, the United Kingdom and Switzerland
as well as Colorado, Oregon,
California, and Nevada.
This Policy applies to the Association and our Services. It also applies anywhere it is
linked. It does not apply to non-Association websites and mobile applications that may link
to the Services or be linked to from the Services. Please review the privacy policies on
those websites and applications directly to understand their privacy practices.
How to Contact Us
We have appointed a data privacy officer who is responsible for overseeing questions
concerning this Policy. If you have any questions, please contact our data protection
officer in the following ways:
- By email: Privacy@restaurant.org
- By phone: 1-800-765-2122
- By post: Director of Security, National Restaurant Association, 233 South Wacker Drive,
Chicago, IL 60606
Information We Collect
Below is a summary of the kinds of personal information we collect. We may collect this name
directly from you, as you use our Services, automatically through technology you use when
using our Services, or from third parties who obtain information about you from publicly
available sources, or from third parties that share your information with us on your behalf.
-
Personal Identifiers:
- We may collect your name, phone number, and email address and address when you create
an account, register for events, or complete a transaction. If you choose to create an
account, you may also be asked to create a username, and we may assign one or more
unique identifiers to your profile.
- You may provide us with payment information, which may be your credit card number or a
bank account, when you complete a transaction or set up a recurring payment.
- We may collect your Social Security number to verify your identity and as required by
law for certain Services.
- We may collect your IP address and/or Device ID automatically when you use our
Services, and may use it for marketing and sales purposes, as described in this
Privacy Policy.
- We may collect information or data you provide by interacting in our online forums and
chatrooms, or by commenting on content posted on our Services. Please note that these
comments are also visible to other users of our Services.
- We collect information you provide when you complete a survey administered by us or a
service provider acting on our behalf.
- We collect information you provide when you purchase or take a course or an exam in
order to provide you with those Services, and for marketing and analysis purposes.
-
Protected Classifications:We may collect your age in order to comply with
laws that restrict collection and disclosure of personal information belonging to minors.
We may collect information about your gender identity or status as a transgender or
nonbinary person, sexuality, disability status, and/or ethnic origin that you voluntarily
disclose to us when using the Services (a) as required by applicable law, federal
contracts or grants, or accreditation agencies, (b) to ensure that we are not
discriminating against anyone on the basis of their protected classifications, (c) to
provide accommodations on the basis of disability, (d) to ensure that we appropriately
refer to your gender identity, or (e) to evaluate our recruitment and other strategies so
that our Services reflect the diversity of the restaurant, foodservice and hospitality
industry.
-
Commercial Information: When you engage in transactions with us, we may
create records of goods or services purchased or considered, as well as purchasing or
consuming histories or tendencies for financial recordkeeping purposes and marketing
purposes. In order to provide you with the Services, we will also collect information
regarding appointment bookings you carry out through our site.
-
Biometric Information: We may collect information about your
physiological, biological, and behavioral characteristics, such as height, weight, hair
color and eye color, for identity verification purposes when registering for an exam, and
as required by applicable law.
-
Internet or Other Electronic Network Activity Information: We may collect
information details regarding the device you use to access our Services, including, but
not limited to, traffic data, cookies, location data, weblogs and other communication
data, the resources that you access, and how you reached our site, your IP address,
operating system and browser type, information about how you interact with our ads and
newsletters, including whether you open or click links in any correspondence, information
that you make available to us on a social media platform (such as by clicking on a social
media icon linked from our Services), including your account ID or username and other
information included in your posts automatically when you utilize our Services. We use
these for analysis and marketing purposes. Details of your visits to our site and
information generated in the course of the use of our site (including the timing,
frequency and pattern of service use) including, but not limited to, traffic data,
cookies, location data, weblogs and other communication data, the resources that you
access, and how you reached our site.
-
Geolocation Data: We may collect your IP address automatically when you
use our Services. We may be able to determine your general location based on the IP
address.
-
Audio, electronic, visual, thermal, olfactory, or similar information: If
you contact us via phone, we may record the call for customer service and quality control
purposes. We will notify you if a call is being recorded at the beginning of the call. If
you take an examination, the service provider administering the exam may video record and
collect your image, thermal, olfactory, and similar information for exam security
purposes.
-
Professional or employment-related information: We may collect
information about your current employer and your employment history for recordkeeping,
marketing and analysis purposes. In the case of Hire Military! or other job board related
Services, we collect information you may submit for possible employment with our members
or other information you may submit to inquire about or apply for a job with us in order
to review your employment application. We also may collect information submitted by or for
our members, including employers or franchisors–which may include employees’ business and
personal contact details, job titles, and membership details, in order to provide you with
Services and for marketing and analysis purposes.
-
Education information: We may collect information about the institutions
you have attended and the level of education you have attained for marketing and analysis
purposes.
-
Inferences drawn to create a profile about a consumer reflecting the consumer’s
preferences or characteristics:
We may analyze your actual or likely preferences through a series of computer processes
for marketing purposes. On some occasions, we may add our observations to your internal
profile. We do not use any of these inferences in furtherance of decisions that result in
providing or denying education enrollment or opportunity or employment opportunities.
How We Use Your Information
We use your personal data for the purposes noted above and otherwise set out in this Policy
and where we have a valid legal ground for doing so under applicable data protection law.
The legal ground will depend on the purpose for which we process your personal data. We use
your personal data in the following ways as necessary in our legitimate business interests,
including to meet our membership obligations and to provide Services.
We may use the information we collect from you for the following purposes:
- To provide membership services, and to keep our membership contact information up to date.
- To provide you with our products and services, including to take steps to enter into a
contract for sale or for services, process payments, fulfill orders, and send service
communications.
- To communicate exam results, pending expiration dates or other information regarding your
certificate, certification or similar status.
- To demonstrate that you have received certain certificates or certifications.
- To provide information or other materials relating to an event you are currently or
previously registered for, including information regarding speakers, exhibitors, sponsors,
or other attendees.
- To enable additional features on our Services and to provide you with a personalized
service.
- To allow members or potential employers to access and download information posted on Hire
Military! or other job board related sites.
- To ensure compliance with standards set forth by accreditation bodies relevant to
certifications.
We may use your personal data in the following ways as necessary for certain legitimate
interests, or where you have given your consent to such processing to the extent required by
applicable law (in which case, such consent can be withdrawn at any time):
- To provide you with information for our products and services, or products or services of
our commercial partners, that we believe may be of interest to you.
- To create custom audiences on social media sites.
- To provide you with the best service and improve and grow our business, including
understanding our customer base, how customers use and interact with our Services,
purchasing trends and understanding the effectiveness of our marketing.
- To detect, investigate, and prevent activities that may violate our policies or be
fraudulent or illegal, and to comply with legal requirements regarding the provision of
products and services.
We retain your information in accordance with record retention policies, based on levels of
business importance and internal guidance for compliance with auditing and legal
requirements, and in accordance with retention requirements set forth by accreditation
bodies.
How We Secure the Information We Collect from or About You
We use a combination of physical, technical, and administrative safeguards to protect the
information we collect through the Services. Once we have deidentified your data, we will
not attempt to reidentify it. While we use these precautions to safeguard your information,
we cannot guarantee the security of the networks, systems, servers, devices, and databases
we operate or that are operated on our behalf.
Our Sharing of Your Information
-
Public:
We may publicly post which certificates and/or certifications you have received from us.
Maintaining a public registry of certificates and certifications granted to individuals
allows current and future employers to determine if someone holds a certificate or
certification and is an essential part of the Services we provide with respect to issuing
such certificates and certifications.
-
Service Providers:
We engage vendors to perform functions on our behalf such as website hosting, software
development, data storage, content management, database management, technical integration,
marketing automation, analytics, site optimization, conducting customer surveys, shipping
and payment processing and providing other business services. There are limited
circumstances in which the service provider collects data directly from you when their
privacy policies may also apply.
-
Media Platforms:
Where you choose to interact with us through social media, your interaction with these
programs typically allows the social media company to collect some information about you
through digital cookies they place on your device and other tracking mechanisms. In some
cases, the social media company may recognize you through its digital cookies even when
you do not interact with their application. Please visit the social media companies’
respective privacy policies to better understand their data collection practices and
controls they make available to you.
-
Third Parties Involved in Advertising:
We partner with third parties who assist us in serving advertising regarding the Services
to others who may be interested in the Services. We also partner with third parties who
use cookies to display interest-based advertising to you on the Services. These third
parties may use tracking technologies on our website or elsewhere to collect or receive
information from the Services and elsewhere on the internet and use that information to
provide measurement services and target ads. While the Association will not share
information that identifies you by name with unaffiliated third parties for their own
uses, such third parties may, with sufficient data from other sources, be able to
personally identify you.
-
Corporate Affiliates:
We share data with other members of our group of companies, as well as with our State
Restaurant Association partners.
-
Business Partners:
We share data with affiliates or companies with whom we have affinity programs or other
commercial relationships in order to market and provide products, goods or services that
may be of interest to you.
-
Potential Employers:
We may share data posted to Hire Military! or other job boards with interested potential
employers and will have no liability for such third-party use.
-
Event Attendees, Sponsors, and Exhibitors:
We may share attendees’ information with sponsors and exhibitors for that event or similar
events or may be used to provide invitations for other events conducted by us. Exhibitors’
information may be shared with Sponsors of such events or for invitation to exhibit at
other events we conduct. We may also share attendee information with public safety
authorities and law enforcement in response to any safety or other incidents at events.
-
Sponsors:
We may share information that you provide when purchasing or accessing resources,
including events, webinars, reports, and other materials, with sponsors or other parties
involved in the production of such resources.
-
Grant Funders:
We may share your information due to requirements we have under certain private grants
awarded to the Association or the Foundation.
-
Employers, Instructors, and Proctors:
If you access our Services through your employer or through a third-party instructor or
proctor, you are using the Services to intentionally interact with your employer or third
party instructor or proctor (as applicable), and an essential part of those Services
includes sharing your name, email address, course information, and other information
regarding your use of the Services with your employer, instructor or proctor. We may
charge those employers, instructors or proctors an administrative fee to cover the costs
of providing such information.
-
Purchasers:
If you access our Services through someone else who has purchased those Services on your
behalf (including by giving you a coupon code to use at checkout), we may share your name,
email and physical addresses, course and exam information, and other information regarding
your use of the Services with the purchaser.
Additional Information About our Data Collection and Sharing Practices
-
Sharing of Aggregated Data:
We may analyze aggregated, de-identified data and share these analyses at our discretion,
including with marketing agencies, media agencies, and analytics providers. These third
parties will not be able to relate this data to identifiable individuals.
-
Combination of Information:
We may combine information from the Services together and with other information we obtain
from our business records. Additionally, information collected about you from a particular
browser or device may be linked to information collected from another computer or device
that we believe relates to you.
-
Personal Data Collected from You About Others:
If you decide to invite others to the site, we will collect your and the other person’s
names, e-mail addresses, and/or phone numbers in order to send an e-mail or text message
and follow up with the other person. You hereby agree that you will obtain the other
person’s consent to this before giving us their personal data. You hereby agree not to
send us the contact details of any legal minor.
-
Change of Ownership or Corporate Organization:
We may transfer to another entity or its affiliates or service providers some or all
information about you in connection with, or during negotiations of, any merger,
acquisition, sale of assets or any line of business, change in ownership control, or
financing transaction. We cannot promise that an acquiring party or the merged entity will
have the same privacy practices or treat your information the same as described in this
policy.
-
Cross-border Transfer of Data:
If you use our Services outside of the United States, you understand that we may collect,
process, and store your personal information in the United States and other countries.
Personal data that we collect from you is generally stored on our computers, servers and
other devices in the United States. However, third-party vendors, consultants and other
service providers that we use may store and process your data where they are based, which
may be in the United States or around the world. The laws in the U.S. regarding personal
information may be different from the laws of your state or country. Any such transfers
will comply with safeguards as required by relevant law. By using the Services, you
consent to the collection, international transfer, storage, and processing of your data.
-
Sales of Personal Information:
On certain occasions, we may sell personal information to third parties (entities we are
not affiliated with, who are not processing personal information). In this context,
"selling" personal information means disclosing it to third parties for monetary purposes,
and not when directed by you (as discussed in this policy). We may sell the following
types of personal information to third parties in order to provide you with targeted
advertising, informational content, and marketing that may interest you. To our actual
knowledge, we do not sell the personal information of minors under the age of 13 or use
the personal information of minors under the age of 13 for targeted advertising.
- We may provide your contact information such as name, phone number, email address and
contact address.
- We may provide commercial information, such as a business’s name and address.
- We may provide your contact information to directory services.
- We may provide your IP address and Device ID to our advertising partners and business
partners.
Your Options and Rights
Please visit the login page on any of our websites to update your contact information and
payment method.
If at any time you would like to unsubscribe from receiving future emails from an
Association entity, you can click the unsubscribe link at the bottom of any email bulletin,
or email us at Privacy@restaurant.org and we
will promptly remove you from correspondence from that entity.
Please note that we may be required to contact you with important information relating to
your use of our Services.
Your Colorado Privacy Rights
The Colorado Privacy Act ("CPA") provides Colorado residents with rights to receive certain
disclosures regarding the collection, use, and sharing of "Personal Data," as well as rights
to access and control Personal Data. The CPA defines "Personal Data" to mean "information
that is linked or reasonably linkable to an identified or identifiable individual." Certain
information we collect may be exempt from the CPA because it is de-identified, considered
public information (i.e., it is made available by a government entity), covered by a federal
privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and
Accountability Act, the Fair Credit Reporting Act, or otherwise excluded from the definition
of Personal Data under the CPA.
From time to time in this section of the Privacy Policy, we may refer to the "processing" or
Personal Data. "Process" or "Processing" means collecting, using, selling, storing,
analyzing, deleting, or modifying Personal Data.
If you are a Colorado resident and would like to see the categories of Personal Data that we
collect or sell, please see the Sections above entitled
Information We Collect,
How We Use Your Information,
Our Sharing of Your Information, and
Additional Information About our Data Collection and Sharing Practices. If you are a Colorado resident and would like to make a request to access your Personal
Data, correct your Personal Data, delete your Personal Data, or request that we do not sell
your Personal Data or use it for targeted advertising or certain kinds of profiling (as
described in more detail below), please visit our
Privacy Request
webpage, or contact us as described above.
If you would like to appeal any decision we make not to comply with your request (in whole
or in part), please respond to the email you received from
Privacy@restaurant.org notifying you of our
decision, or write to us or call us at the above address within forty-five (45) days of your
receipt of our response.
To the extent that we collect Personal Data that is subject to the CPA, that information,
our practices, and your rights are described below.
-
Right to Information Regarding the Categories of Personal Data Collected, Sold, and
Disclosed.
You have a right to obtain information about the categories of Personal Data we collect,
sell, and disclose. Please see the Sections above entitled
Information We Collect,
How We Use Your Information,
Our Sharing of Your Information, and
Additional Information About our Data Collection and Sharing Practices.
-
Right to Access Information and Right to Data Portability. You have the
right to confirm whether we are processing Personal Data collected about you and to access
that Personal Data. When exercising your right to access your Personal Data, you have the
right to obtain your Personal Data in a portable format, and (to the extent feasible) a
format that is readily usable and allows you to transmit the data to another entity. You
may exercise this right up to two times per calendar year. To protect our customers’
Personal Data, we are required to verify your identity before we can act on your request,
and we may redact any highly sensitive information (such as driver’s license numbers,
social security numbers, or financial account numbers). If we redact any information, we
will clearly describe what information we are redacting.
-
Right to Correction. You have the right to correct inaccuracies in your
Personal Data. To protect our customers’ Personal Data, we are required to verify your
identity before we can act on your request. We may not have to comply with this request
based on the nature of the Personal Data you are asking us to correct or the purposes of
processing that Personal Data. If that is the case, we will explain that to you in our
response.
-
Right to Request Deletion of Personal Data. You have the right to request
in certain circumstances that we delete any Personal Data that we have collected directly
from you. To protect our customers’ Personal Data, we are required to verify your identity
before we can act on your request. We may have a reason under the law why we do not have
to comply with your request, or why we may comply with it in a more limited way than you
anticipated. If we do, we will explain that to you in our response.
-
Right to Information Regarding Participation in Data Sharing for Financial
Incentives.
We may run promotions from time to time whereby we incentivize a consumer to share certain
pieces of information with us; for example, we may offer a one-time discount if consumers
sign up for our email marketing list. Participation in these incentives is voluntary, and
you may opt out of the data sharing at any time. If we do so, we will disclose the
categories of Personal Data that we collect through the program, the categories of third
parties to whom we will share the Personal Data received, the value of the program
benefits available to you whether or not you opt out of the sale of Personal Data or the
processing of Personal Data for targeted advertising, and a list of any benefits that
require the sale of Personal Data or processing of Personal Data for targeted advertising
at the time such Personal Data is collected.
-
Right to Opt Out of Targeted Advertising, Sale of Personal Data to Third Parties, and
Certain Profiling.
You have the right to opt out of any targeted advertising or sale of your Personal Data by
us to third parties. You also have the right to opt out of profiling (described below)
that is used in furtherance of decisions that result in providing or denying education
enrollment or opportunity or employment opportunities. Profiling is the automated
processing of your Personal Data to evaluate, analyze or predict things about your
economic situation, health, personal preferences, interests, reliability, behavior,
location, or movements. We do not engage in any of the profiling described above in
furtherance of decisions that result in providing or denying education enrollment or
opportunity or employment opportunities. To exercise your right to opt out of targeted
advertising or the sale of your Personal Data, please visit our
Privacy Request
webpage. Please note that your right to opt out does not apply to our sharing of Personal
Data with service providers, who are parties we engage to perform a function on our behalf
and are contractually obligated to use the Personal Data only for that function.
Sensitive Data
Some of the Personal Information we collect falls under the definition of "Sensitive Data"
under the CPA. The following is a description of our data collection practices with respect
to Sensitive Data, including the Sensitive Data we collect, the sources of that Sensitive
Data, the purposes for which we collect Sensitive Data, and whether we disclose that
Sensitive Data to external parties.
- Protected Characteristics. We may collect your age in order to comply with laws that
restrict collection and disclosure of personal information belonging to minors. We may
collect information about your gender identity, sexuality, disability status, and/or
ethnic origin that you voluntarily disclose to us when using the Services (a) as required
by applicable law, federal contracts or grants, or accreditation agencies, (b) to ensure
that we are not discriminating against anyone on the basis of their protected
classifications, (c) to provide accommodations on the basis of disability, (d) to ensure
that we appropriately refer to your gender identity, or (e) to evaluate our recruitment
and other strategies so that our Services reflect the diversity of the restaurant,
foodservice and hospitality industry. We disclose that information only to third parties
performing services on our behalf, to governmental entities as required by applicable law,
federal contracts or grants, and to accreditation bodies as required in order to offer
certifications accredited by such bodies.
Your Oregon Privacy Rights
The Oregon Consumer Data Privacy Act ("OCDPA") provides Oregon residents with rights to
receive certain disclosures regarding the collection, use, and sharing of "Personal Data,"
as well as rights to access and control Personal Data. The OCDPA defines "Personal Data" to
mean "means data, derived data or any unique identifier that is linked to or is reasonably
linkable to a consumer or to a device that identifies, is linked to or is reasonably
linkable to one or more consumers in a household." Certain information we collect may be
exempt from the OCDPA because it is de-identified, considered public information (i.e., it
is made available by a government entity or widely distributed media), covered by a federal
privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and
Accountability Act, the Fair Credit Reporting Act, or otherwise excluded from the definition
of Personal Data under the OCDPA.
From time to time in this section of the Privacy Policy, we may refer to the "processing" or
Personal Data. "Process" or "Processing" means performing an action or operation, or a
series of actions or operations (including automatically) on Personal Data, such as
collecting, using, selling, storing, analyzing, deleting, or modifying Personal Data.
If you are an Oregon resident and would like to see the categories of Personal Data that we
collect or sell, please see the Sections above entitled
Information We Collect,
How We Use Your Information,
Our Sharing of Your Information, and
Additional Information About our Data Collection and Sharing Practices. If you are an Oregon resident and would like to make a request to access your Personal
Data, correct your Personal Data, delete your Personal Data, or request that we do not sell
your Personal Data or use it for targeted advertising or certain kinds of profiling (as
described in more detail below), please visit our
Privacy Request
webpage, or contact us as described above.
If you would like to appeal any decision we make not to comply with your request (in whole
or in part), please respond to the email you received from
Privacy@restaurant.org notifying you of our
decision, or write to us or call us at the above address within forty-five (45) days of your
receipt of our response. We will approve or deny your appeal, in writing with an explanation
of our decision, within forty-five (45) days of our receipt of your appeal.
To the extent that we collect Personal Data that is subject to the OCDPA, that information,
our practices, and your rights are described below.
-
Right to Information Regarding the Categories of Personal Data Collected, Sold, and
Disclosed.
You have a right to obtain information about the categories of Personal Data we collect,
sell, and disclose. Please see the Sections above entitled
Information We Collect,
How We Use Your Information,
Our Sharing of Your Information, and
Additional Information About our Data Collection and Sharing Practices.
-
Right to Access Information and Right to Data Portability. You have the
right to confirm whether we are processing Personal Data collected about you and to access
that Personal Data. When exercising your right to access your Personal Data, you have the
right to obtain your Personal Data in a portable format, and (to the extent feasible) a
format that is readily usable and allows you to transmit the data to another entity. You
may also request that we provide you with a list of third parties we have shared either
your Personal Data specifically, or anyone’s personal data generally. Please note that
this list would not include any of our affiliates or any service providers or other
entities that process your Personal Data on our behalf. To protect our customers’ Personal
Data, we are required to verify your identity before we can act on your request, and we
may redact any highly sensitive information (such as driver’s license numbers, social
security numbers, or financial account numbers). If we redact any information, we will
clearly describe what information we are redacting.
-
Right to Correction. You have the right to correct inaccuracies in your
Personal Data. To protect our customers’ Personal Data, we are required to verify your
identity before we can act on your request. We may not have to comply with this request
based on the nature of the Personal Data you are asking us to correct or the purposes of
processing that Personal Data. If that is the case, we will explain that to you in our
response.
-
Right to Request Deletion of Personal Data. You have the right to request
in certain circumstances that we delete any Personal Data that we have collected directly
from you or Personal Data that we have collected from another source. To protect our
customers’ Personal Data, we are required to verify your identity before we can act on
your request. We may have a reason under the law why we do not have to comply with your
request, or why we may comply with it in a more limited way than you anticipated. If we
do, we will explain that to you in our response.
-
Right to Opt Out of Targeted Advertising, Sale of Personal Data to Third Parties, and
Certain Profiling.
You have the right to opt out of any targeted advertising or sale of your Personal Data by
us to third parties. You also have the right to opt out of profiling (described below)
that is used in furtherance of decisions that result in providing or denying education
enrollment or opportunity or employment opportunities. Profiling is the automated
processing of your Personal Data to evaluate, analyze or predict things about your
economic situation, health, personal preferences, interests, reliability, behavior,
location, or movements. We do not engage in any of the profiling described above in
furtherance of decisions that result in providing or denying education enrollment or
opportunity or employment opportunities. To exercise your right to opt out of targeted
advertising or the sale of your Personal Data, please visit our
Privacy Request
webpage. Please note that your right to opt out does not apply to our sharing of Personal
Data with affiliates or service providers, who are parties we engage to perform a function
on our behalf and are contractually obligated to use the Personal Data only for that
function.
-
Revoking Consent. If you wish to revoke your consent to our processing of
your Personal Data as specified in this Privacy Policy, you may do by visiting our
Privacy Request
webpage. Please note that we may continue using your Personal Data as required to provide
the Services, as described in this Privacy Policy.
We will provide information that you request pursuant to this section once during any twelve
(12)-month period without charge. For any subsequent requests in a twelve (12)-month period
(other than subsequent requests intended for you to verify our compliance with your prior
request), we may charge a reasonable fee to cover the administrative costs of complying with
your subsequent requests.
Sensitive Data
Some of the Personal Information we collect falls under the definition of "Sensitive Data"
under the OCDPA. The following is a description of our data collection practices with
respect to Sensitive Data, including the Sensitive Data we collect, the sources of that
Sensitive Data, the purposes for which we collect Sensitive Data, and whether we disclose
that Sensitive Data to external parties.
- Protected Characteristics. We may collect your age in order to comply with laws that
restrict collection and disclosure of personal information belonging to minors. We may
collect information about your gender identity or status as a transgender or nonbinary
person, sexuality, disability status, and/or ethnic origin that you voluntarily disclose
to us when using the Services (a) as required by applicable law, federal contracts or
grants, or accreditation agencies, (b) to ensure that we are not discriminating against
anyone on the basis of their protected classifications, (c) to provide accommodations on
the basis of disability, (d) to ensure that we appropriately refer to your gender
identity, or (e) to evaluate our recruitment and other strategies so that our Services
reflect the diversity of the restaurant, foodservice and hospitality industry. We disclose
that information only to third parties performing services on our behalf, to governmental
entities as required by applicable law, federal contracts or grants, and to accreditation
bodies as required in order to offer certifications accredited by such bodies.
Your California Privacy Rights
The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020
("CPRA") provides California residents with rights to receive certain disclosures regarding
the collection, use, and sharing of "Personal Information," as well as rights to access and
control Personal Information with respect to certain business entities. The CPRA defines
"Personal Information" to mean "information that identifies, relates to, describes, is
reasonably capable of being associated with, or could reasonably be linked, directly or
indirectly, with a particular consumer or household." Certain information we collect may be
exempt from the CPRA because it is considered public information (i.e., it is made available
by a government entity) or covered by a federal privacy law, such as the Gramm–Leach–Bliley
Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting
Act, or otherwise excluded from the definition of Personal Data under the CPRA.
Due to the Association and its subsidiaries’ and affiliates’ status as tax-exempt,
not-for-profit trade associations, public charities, and political action committees, it is
our position that we are not subject to either the CCPA or the CPRA.
Because we respect your privacy, we have voluntarily agreed to make certain disclosures
available to California residents. If you are a California resident and would like to see
the categories of personal information that we collect or sell, please see the Sections
above entitled Information We Collect,
How We Use Your Information,
Our Sharing of Your Information, and
Additional Information About our Data Collection and Sharing Practices. If you are a California resident and would like to make such a request to access your
personal information, delete your personal information, request that we do not sell or share
your information, or request that we limit the use of your sensitive personal information to
those purposes authorized by the CPRA, please visit our
Privacy Request
webpage, or contact us as described above.
To the extent that we collect Personal Information that is subject to the CPRA, that
information, our practices, and any rights you may have under the CPRA are described below.
-
Right to Information Regarding the Categories of Personal Information Collected, Sold,
and Disclosed.
To the extent that we collect Personal Information that is subject to the CPRA, you may
have a right to obtain information about the categories of Personal Information we
collect, sell, and disclose. Please see the Sections above entitled
Information We Collect,
How We Use Your Information,
Our Sharing of Your Information, and
Additional Information About our Data Collection and Sharing Practices.
-
Right to Access Information. To the extent that we collect Personal
Information that is subject to the CPRA, you may have the right to request access to
Personal Information collected about you and information regarding the source of that
information, the purposes for which we collect it, and the third parties and service
providers with whom we share it. To protect our customers’ Personal Information, we are
required to verify your identity before we can act on your request.
-
Right to Request Deletion of Information. To the extent that we collect
Personal Information that is subject to the CPRA, you may have the right to request in
certain circumstances that we delete any Personal Information that we have collected
directly from you. To protect our customers’ Personal Information, we are required to
verify your identity before we can act on your request. We may have a reason under the law
why we do not have to comply with your request, or why we may comply with it in a more
limited way than you anticipated. If we do, we will explain that to you in our response.
-
Right to Correction. To the extent that we collect Personal Information
that is subject to the CPRA, you may have the right to correct inaccuracies in your
Personal Information. To protect our customers’ Personal Information, we are required to
verify your identity before we can act on your request. We may not have to comply with
this request if we determine that the contested information is more likely to be accurate
than not, if such a request would conflict with federal or state law, or if compliance
would be impossible or involve disproportionate effort, or for other reasons permitted
under the CPRA. If that is the case, we will explain that to you in our response.
-
Right to Information Regarding Participation in Data Sharing for Financial
Incentives.
We may run promotions from time to time whereby we incentivize a consumer to share certain
pieces of information with us; for example, we may offer a one-time discount if consumers
sign up for our email marketing list. Participation in these incentives is voluntary, and
you may opt out of the data sharing at any time.
-
Right to Opt Out of Sale of Personal Information to Third Parties and Targeted
Advertising.
To the extent that we collect Personal Information that is subject to the CPRA, you may
have the right to opt out of any sale of your Personal Information or sharing of your
Personal Information for cross-context behavioral (targeted) advertising purposes by the
Association to third parties. To exercise this right, please visit our
Privacy Request
webpage. Please note that your right to opt out does not apply to our sharing of Personal
Information with service providers, who are parties we engage to perform a function on our
behalf and are contractually obligated to use the Personal Information only for that
function.
Sensitive Personal Information
Some of the Personal Information we collect falls under the definition of "Sensitive
Personal Information" under the CPRA. The following is a description of our data collection
practices with respect to Sensitive Personal Information, including the Sensitive Personal
Information we collect, the sources of that Sensitive Personal Information, the purposes for
which we collect Sensitive Personal Information, and whether we disclose that Sensitive
Personal Information to external parties. We may use any and all of the Sensitive Personal
Information for any of the purposes described in this Privacy Policy, unless limitations are
listed. The categories we use to describe the information are those enumerated in the CPRA.
- Government Identifiers. If you take an examination, we may collect images of your driver’s
license, state identification card, or passport to verify your identity. We may collect
your Social Security number to verify your identity or to comply with applicable law.
- Complete account access credentials. We may collect information, such as usernames,
account numbers, or card numbers combined with required access/security code or password,
for security purposes.
- Racial or ethnic origin. We may collect information about your gender identity, sexuality,
disability status, and/or ethnic origin that you voluntarily disclose to us when using the
Services (a) as required by applicable law, federal contracts or grants, or accreditation
agencies, (b) to ensure that we are not discriminating against anyone on the basis of
their protected classifications, (c) to provide accommodations on the basis of disability,
(d) to ensure that we appropriately refer to your gender identity, or (e) to evaluate our
recruitment and other strategies so that our Services reflect the diversity of the
restaurant, foodservice and hospitality industry.
Right to Limit Use or Disclosure of Sensitive Personal Information
To the extent that we collect Personal Information that is subject to the CPRA, you may have
the right to limit the use or disclosure of your Sensitive Personal Information to just
actions to those that:
- help to ensure security and integrity, if the use of your Sensitive Personal Information
is reasonably necessary and proportionate to the purpose of ensuring security and
integrity;
- are for short-term, transient use, so long as your Sensitive Personal Information is not
disclosed to another third party and is not used to build a profile about you or otherwise
alter your experience;
- are involved in the performance of services on behalf our business, such as maintaining or
servicing accounts, verifying customer information, processing payments, providing
financing, providing analytic services, and/or providing storage; and
- are used to undertake activities to verify or maintain the quality or safety of the
Services.
Your Nevada Privacy Rights
Residents of the State of Nevada have the right to opt out of the sale of certain pieces of
their information to third parties who will sell or license their information to others. If
you are a Nevada resident and would like to make such a request, please visit our
Privacy Request
webpage, or contact us as described above.
Special Information for Students of Academic Institutions (FERPA)
Students using our Services through an educational agency or institution ("School") may be
entitled to certain rights under federal and/or state student privacy laws, such as the
Family Educational Rights and Privacy Act ("FERPA"). Under FERPA, these rights include the
right to:
- Access and inspect the student’s education records;
- Provide written consent to the disclosure of education records or personally identifiable
information; and
- Request the amendment of the student’s education records that the parent or eligible
student believes are inaccurate, misleading or in violation of the student’s privacy
rights.
As part of our Services to students, you must authorize us to:
- Receive from Schools or collect education records and personally identifiable information
as reasonably required to provide the Services;
- Share with Schools, prospective employers or current employers of a student the exam
results, certification status and professional training of such student;
- Post accreditation, certification or training results to our public website for access by
Schools, employers, educators or others;
- Share or publicly disclose such other education records or personally identifiable
information as reasonably required to attest to a student’s certification status or for
other purposes relevant to users of the Services; and
- Provide students information regarding additional Services that may advance or enhance the
workforce development or career opportunities of students.
Schools that we work with are required to provide students, parents or guardians required
notices and obtain required consents for use of the Services as provided above.
If you are a User who is an academic student at an American educational institution (a
"Student User"), how you give consent depends on what website you are using.
For Student Users of Restaurant.org (including Trendmapper.Restaurant.org), ServSuccess.com,
ServSafeInternational.com, and Benefits.ServSafeBrands.com, complete this
Online Consent Form
and send it to Privacy@restaurant.org before
commencing any Services or providing any educational records or personal information.
For users of the websites listed below, please follow the instructions below based upon when
your account was created.
Website |
New Users |
Accounts Created After March 12, 2022 |
Accounts Created Before March 12, 2022 |
ServSafe.com
ChooseRestaurants.org
nrfsp.com
AHLEI.ServSafeBrands.com
ManageFirst.restaurant.org
Textbooks.restaurant.org
MyProStart.chooserestaurants.org
|
Select ‘Academic Student’ as job role and answer the subsequent questions regarding
consent.
|
Update your profile to give consent by changing your job role to ‘Academic Student’ and
answering the subsequent questions.
|
Complete this
Online Consent Form
and send it to Privacy@restaurant.org
before commencing any Services or providing any
educational records or personal information.
|
Information for Individuals Located in the United Kingdom, European Economic Area and
Switzerland
The categories of personal data that we collect, and the recipients of that data are
described above. We process personal data on the following legal bases (which are described
in more detail above): (1) with your consent; (2) as necessary to perform our agreement to
provide Services; and (3) as necessary for our legitimate interests in providing the
Services where those interests do not override your fundamental rights and freedom related
to data privacy, as described above. Personal information we collect may be transferred to,
and stored and processed in, the United States or any other country in which we or our
affiliates or subcontractors maintain facilities, as described above.
Users that reside in the United Kingdom, EEA or Switzerland have the right to lodge a
complaint about our data collection and processing actions with the supervisory authority
concerned. Contact details for data protection authorities are available
here.
If you are a resident of the United Kingdom, EEA or Switzerland, you are entitled to certain
rights. Please note: In order to verify your identity, we may require you to provide us with
personal information prior to accessing any records containing information about you. These
rights include the following:
-
Right to Access Information and Right to Data Portability. You have the
right to confirm whether we are processing personal data collected about you (including
the purposes, the categories, the categories of recipients, the retention period, the
source of the data) and to access that personal data. When exercising your right to access
your Personal Data, you have the right to obtain your Personal Data in a portable format,
and to the extent feasible a format that is readily usable and allows you to transmit the
data to another entity. To protect our customers’ Personal Data, we are required to verify
your identity before we can act on your request, and we may redact any highly sensitive
information (such as driver’s license numbers, social security numbers, or financial
account numbers). If we redact any information, we will clearly describe what information
we are redacting.
-
Right to Rectification. You have the right to correct inaccuracies in
your Personal Information or, taking into account the purpose of the processing, to have
incomplete personal data completed.
-
Right to Request Deletion of Personal Data. You have the right to request
in certain circumstances (such as if the data is no longer necessary to fulfill the
purpose for which it was collected, where you withdraw consent and no other legal ground
exists for processing, where you object to the processing and there are no overriding
legitimate grounds for processing, where the data was unlawfully processed, where the data
is required to be deleted to be in compliance with applicable law) that we delete any
personal data about you. To protect our customers’ personal data, we are required to
verify your identity before we can act on your request. We may have a reason under the law
why we do not have to comply with your request, or why we may comply with it in a more
limited way than you anticipated. If we do, we will explain that to you in our response.
-
Right to Request Restriction of Processing: You have the right to request
that we restrict our processing if we are processing your data based on legitimate
interests or the performance of a task in the public interest as an exercise of official
authority (including profiling); using your data for direct marketing (including
profiling); or processing your data for purposes of scientific or historical research and
statistics.
To submit a request to exercise your rights, please contact us at
Privacy@restaurant.org. We may have a reason
under the law why we do not have to respond to your request, or respond to it in a more
limited way than you anticipated. If we do, we will explain that to you in our response.
Changes to This Policy
We may make changes to this Policy from time to time. We will post any changes, and such
changes will become effective when they are posted unless otherwise required by law. Your
continued use of our Services following the posting of any changes will mean you accept
those changes. For questions about our privacy practices, contact us at:
Director of Security
National Restaurant Association
233 South Wacker Drive
Chicago, IL 60606
1-800-765-2122
Email:
Privacy@restaurant.org
Additional Information About Our Use of Tracking Technologies and Interest-Based Advertising
The Association relies on partners to provide many features of our sites and services using
data about your use of the Association and other sites. We use cookies for the following
purposes:
-
Site Operations: Enabling features that are necessary for
providing you the services on our site, such as identifying you as being signed in,
tracking content views remembering your preferences and the number of times you have been
shown an advertisement.
-
Analytics: Allowing us to understand how our services are being
used, track site performance and make improvements
-
Personalized Advertising: Delivering tailored advertising based
on your preferences or interests across services and devices and measuring the
effectiveness of ads
-
Social Media: Enabling the sharing of content from our services
through social networking and other sites
Below is a list of these partners with links to more information about the use of your data
by our service providers and third parties that use tracking devices or cookies. We have
provided links to information about the choices these services may make available to you.
In addition to the foregoing, The National Restaurant Association Educational Foundation
("NRAEF") partners with Microsoft Clarity and Microsoft Advertising to capture how you use
and interact with NRAEF’s website through behavioral metrics, heatmaps, and session replay
to improve and market NRAEF’s programs and any products/services made available through
NRAEF’s website. Website usage data is captured using first and third-party cookies and
other tracking technologies to determine the popularity of products/services and online
activity. Additionally, we use this information for site optimization, fraud/security
purposes, and advertising. For more information about how Microsoft collects and uses your
data, visit the
Microsoft Privacy Statement.
Most web browsers automatically accept cookies but, if you prefer, you can usually modify
your browser setting to disable or reject cookies. If you delete your cookies or if you set
your browser to decline cookies, some features of the Services may not be available, work,
or work as designed. You may also be able to opt out of or block tracking by interacting
directly with the third parties who conduct tracking through our Services.
You can learn more about ad serving companies and the options available to limit their
collection and use of your information by visiting the websites for the
Network Advertising Initiative, the
Digital Advertising Alliance,
and the
European Interactive Digital Advertising Initiative. Similarly, you can learn about your options to opt out of mobile app tracking by certain
advertising networks through your device settings and by resetting the advertiser ID on your
Apple or Android device.
Please note that opting-out of advertising networks services does not mean that you will not
receive advertising while using our Services or on other websites, nor will it prevent the
receipt of interest-based advertising from third parties that do not participate in these
programs. It will, however, exclude you from interest-based advertising conducted through
participating networks, as provided by their policies and choice mechanisms. If you delete
your cookies, you may also delete your opt-out preferences.
|