Privacy Policy

REVISION DATE: This policy was last updated july 1, 2018.


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


This Privacy Policy applies to the No Pão online and mobile web sites ( www.mynopao.com) (collectively, the "Web Sites") and the No Pão platforms and applications owned and operated by No Pão LLC ("No Pão", "we," "our," "us"), including but not limited to the No Pão Anyware platform ( https://anyware.dominos.com) available through third party devices (collectively, the "Applications"). This Privacy Policy describes how No Pão collects, uses, and shares information you provide through the Web Sites and Applications. It also describes your rights and choices regarding our use and sharing of your information, including how you can access and update such information.


Your use of the Web Sites or Applications constitutes your agreement to our Terms of Use, and acceptance of this Privacy Policy and your consent to the practices it describes. If you have questions or comments about our Privacy Policy, please contact us as set forth in the section entitled "Contact Us" below.


INFORMATION COLLECTION

Information you provide

No Pão collects information you provide directly via the Web Site and Applications. The information we collect includes personally identifiable information, which is any information that concerns you individually and would permit someone to identify you. Some examples of information we collect include the following:

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

Credentials. We collect passwords, password hints, and other information for authentication and account access.

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

Order Information. We collect information about your orders and food choices.

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

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

Resume Data. We collect data as necessary to consider you for a job opening if you submit an application to us, including your employment history, transcript, writing samples, and references.


We collect information you provide at various points of the Web Sites and Applications, such as the following:

Account Registration - To register an account with No Pão, you will be required to fill out a registration form on the Web Sites or Applications. This form requires you to provide your first name and last name, email address, postal address, telephone number, and credentials. You may also provide payment data and profile data to help speed up and facilitate your future orders.

Online Orders - You can place an online order for carryout or delivery through your registered account or as a guest. If you place a carryout order, you will need to provide your first name and last name, email address, telephone number, and order information. If you pay online, you will also need to provide your payment data. If you place an order for delivery, you will also need to provide your postal address in addition to the information above.

Rewards Programs - We may offer rewards programs, sweepstakes, contests, surveys, or other promotions ("Promotions") through our Websites or Applications. In order to participate in a Promotion, you may be required to register an account and/or provide contact data, profile data, and other information.

Other Transactions - We may offer you other opportunities to transact with us through the Web Sites or Applications. If you conduct transactions through the Web Sites or Applications, we will collect information you provide directly about the transactions you engage in while on the Web Sites or Applications (including any data gathered through the Application while located in a No Pão store and when you speak to and use voice ordering services through the No Pão Anyware platform, including through third party devices). This information may include payment and billing information as well as the nature, quantity and price of the goods or services you exchange, transcripts of any words that you speak while using voice ordering services through the No Pão Anyware platform, including through third party devices, and the individuals or entities with whom you communicate or transact business.

Email and other voluntary communications - You may also choose to communicate with us through email, via the Web Sites, via the Applications (including through voice ordering services through the No Pão Anyware platform available on third party devices), or through other means. Such communications may be in connection with our customer service efforts, your questions, or for other purposes. We collect the information in these communications, and such information may include information that personally identifies you.


You may choose to voluntarily disclose other information when using the Web Sites or Applications that we do not request, and, in such instances, you are solely responsible for such information. Further, certain Applications, such as those using the No Pão Anyware platforms available on third party devices, may capture information that you do not voluntary provide, such as background noise or secondary communications. Therefore, you should take steps to prevent the communication of unnecessary information when using such Applications.


Information Collected Automatically

When you visit the Web Sites or Applications (including when you use the Applications in a No Pão store), we automatically collect information about your device and how your device interacts with our Web Sites or Applications. Some examples of information we collect include the following:

Service Use Data. We collect data about the features you use, the emails and advertisements you view, the products you purchase, the date and time you access the Web Sites or Applications, the pages you access while at the Web Sites or Applications, and the internet address of the web sites, if any, from which you linked directly to the Web Sites or Applications, and other similar information.

Device Connectivity and Configuration Data. We collect data about the type of device you use, the operating system and browser you use, your internet service provider, your device's regional and language settings, and other similar information. This data also includes IP address, MAC address, device advertising Id (e.g., IDFA or AAID), and other device identifiers.

Location Data. We collect data about your device's location, which can be precise (e.g., latitude/longitude data) or imprecise (e.g., location derived from an IP address or data that indicates a city or postal code level).


We use cookies and other tracking technologies now and hereafter developed to collect this information, including the following:

Log Files 

A log file is a file that records events that occur in connection with your use of the Web Sites and Applications, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data.

Cookies 

The Web Sites' and Applications' servers, or the servers of third parties that are used to operate the Web Sites and Applications, may place a "cookie" on your device, store data in your device's browser or access pre-existing removable tracking features on your device in order to allow you to use the Web Sites and Applications and to personalize your experience. A "cookie" is a small piece of data that can be sent by a web server to your device, which then may be stored by your browser on your device's hard drive. Cookies and browser storage allow us to recognize your device while you are on our Web Sites and Applications and help customize your online experience and make it more convenient for you. Cookies and browser storage are also useful in allowing more efficient log-in for users, tracking transaction histories and preserving information between sessions. The information collected from cookies and browser storage may also be used to improve the functionality of the Web Sites and Applications. To learn more about how we use cookies, please visit the "Your Rights and Choices" section below.


Types of cookies and tags on our Web Sites and Applications include:

- Functionality: Used to remember your preferences and for facilitating transactions such as purchases.

- Performance or Analytics: Used to measure site activity to improve user experience.

- Targeting: Used to display information and offers that specifically interest you.


Local Storage 

We use Local Storage, such as HTML5 storage, to store information related to whether the user has chosen to "Remain Logged In" as well as tokens if third party services are used. Third parties with whom we partner to provide certain features on our Web Sites and Applications or to display advertising based upon your web browsing activity use Local Storage such as HTML 5 storage to collect and store information. Various browsers may offer their own management tools for removing HTML5 Local Storage.


Web Beacons ("Tracking Pixels") 

Web beacons are small graphic images, also known as "internet tags" or "clear gifs," embedded in web pages and email messages. Web beacons may be used to count the number of visitors to the Web Sites and Applications, to monitor how users navigate the Web Sites and Applications, and to count content views. We may incorporate web beacons from third parties that allow us track our conversions, bring you advertising both on and off the Web Sites and Applications, and provide you with additional functionality, such as the ability to connect our Web Sites and Applications with your social media account.


Embedded Scripts 

An embedded script is programming code designed to collect information about your interactions with the Web Sites and Applications. It is temporarily downloaded onto your device from our web server or a third party with whom we work, is active only while you are connected to the Web Sites and Applications, and deleted or deactivated thereafter.


Location-identifying Technologies 

GPS (global positioning systems) software, geo-filtering, and other location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your location.


Voice Processing Technologies 

Voice processing technologies collect data through the microphone on your device to effectuate an instruction or request by you. We only maintain the audio long enough to complete your instruction or request and then immediately delete it. We may use non-audio data associated with the collection for additional purposes such as data analytics and in accordance with this Privacy Policy


Device Fingerprinting 

Device fingerprinting is the process of analyzing and combining sets of information elements from your device's browser, such as JavaScript objects and installed fonts, in order to create a "fingerprint" of your device and uniquely identify your device and applications.


In-App Tracking Methods 

There are a variety of tracking technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device advertising Id or other device identifiers to associate app user activity to a particular app and to track user activity across apps.


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


Information Collected from Franchisees and Other Third Parties

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

Our independent franchisees on whose behalf we provide services.

Social networks when you reference our service or grant permission to No Pão to access your data on one or more of these services.

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

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

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


INFORMATION USE

No Pão uses the information about you for our legitimate interests, including for purposes such as:

- opening, maintaining, administering and servicing users' accounts or memberships;

- providing services and support to users;

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

- responding to your questions inquiries, comments and instructions;

- protecting our systems from fraud and unlawful access;

- maintaining the security and integrity of its systems;

- helping to establish and verify the identity of users;

- improving our Web Sites, Applications, stores, advertisements, products, and services; and providing users with product or service updates, promotional notices and offers, advertisements, and other information about No Pão and its affiliates.


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

- providing your with our Promotions;

- sending you promotional newsletters and marketing communications;

- serving digital advertisements to you tailored to your interests on third party ad properties; and fulfilling any other purposes disclosed to you and with your consent.


Some of our lawful bases for processing your information stem from our independent franchisees on whose behalf we provide services. We may use information that does not identify you (including information that has been de-identified) without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the section entitled "Your Rights and Choices" below.


DISCLOSURE OF INFORMATION

We disclose information about you as follows:

Service Providers. No Pão uses agents, vendors, consultants and other service providers to help it maintain and operate its Web Sites, Applications, payment processing, and for other reasons related to the operation of its business, and those companies may receive your information for that purpose. These companies may only use such information for the purpose of performing those functions and may not use it for any other purpose, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.

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

Franchisees. We share your information with our independent franchisees in connection with us processing your information on their behalf. For example, we share your information with our independent franchisees in order to facilitate your orders, maintain and administer your online accounts, respond to your questions and comments, comply with your requests, market and advertise to you, and otherwise comply with applicable law.

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

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

Third Parties. We share your information with other third parties for purposes of facilitating your requests (such as when you choose to share information with a social network about your activities on the Web Sites or Applications) and in connection with tailoring advertisements, measuring and improving our Web Sites or Applications and advertising effectiveness, and enabling other enhancements.

Merger or Acquisition. We may share your information if No Pão is involved in a merger, acquisition, or sale of all or a portion of its assets. In such event, you may be notified via email and/or a prominent notice on our Web Sites or Applications of any change in ownership or uses of your information, as well as any choices you may have regarding your information.


Security and Compelled Disclosure. No Pão must disclose information about you in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may share information about you in connection with legal requirements, such as in response to an authorized subpoena or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud. We may also share information about you to defend the Terms of Use or other policies applicable to the Web Sites and Applications or if we believe your actions are inconsistent with our user agreements or policies. To the maximum extent permitted by applicable law, we may use IP addresses, mobile device identifiers or any other information we collect to identify users, and may do so in cooperation with copyright owners, internet service providers, wireless service providers or law enforcement agencies in our discretion. Such disclosures may be carried out without notice to you.

Consent. We may share your information for any other purpose disclosed to you and with your consent.

No Pão may also disclose aggregated de-identified information to potential business partners and other unaffiliated entities for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled "Your Rights and Choices" below.


EXTERNAL LINKS, APPLICATIONS AND DEVICES

The Web Sites and Applications may contain links to other web sites, or may be available through third party devices, not maintained or related to No Pão. These links and devices are not sponsored by or affiliated with the Web Sites, Applications, or No Pão. No Pão has not reviewed any or all of the sites hyper-linked to or from the Web Sites or Applications, and has not reviewed any or all of the devices through which certain No Pão Applications like No Pão Anyware are available, and is not responsible for the content or privacy practices of other web sites, applications or devices. The links and devices are accessed and used at the user's own risk, and No Pão makes no representations or warranties about the content, completeness or accuracy of these links or devices, the sites hyper-linked to the Web Sites or Applications or the devices through which the Applications like No Pão Anyware may be available. Third party web sites that are accessible by hyperlinks from the Web Sites or Applications may use cookies and other tracking technologies. No Pão encourages you to read the privacy policies provided by other web sites and devices manufacturers before you provide any information to them. No Pão does not implicitly endorse third party sites hyper-linked to the Web Sites or Applications or devices through which Applications such as No Pão Anyware may be available.


SOCIAL MEDIA FEATURES

Our Web Sites and Applications may include social media features, such as the Facebook Like button. These social media features may use tracking technologies to collect information about you, such as your IP address, which page you are visiting on the Web Sites or Applications, and may set a cookie to enable the social media feature to function properly. If you use social media features, information you post or provide access to may be publicly displayed on our Web Sites and Applications or by the third party service that you use. Similarly, if you post information on a third party service that references our Web Sites and Applications (e.g., by using a hashtag associated with No Pão in a tweet or status update), your post may be used on or in connection with our Web Site and Applications. Also, both No Pão and the third party may have access to certain information about you and your use of our Web Site and Applications and the social media features. Social media features are operated by a third party and governed by the privacy policy of the third party providing it. We are not responsible for and make no representations regarding the policies or business practices of any third parties and encourage you to familiarize yourself with and consult their privacy policies and terms of use.


ANALYTICS, ADVERTISING, AND RETARGETING

No Pão has engaged third parties, including Snap, for analytics services. These third parties may use cookies and other tracking technologies to analyze your usage of our Web Sites and Applications, including data collected when you speak to and use voice ordering services through the No Pão Anyware platform. Information generated by these services may be transmitted to and stored by these third parties on servers in the U.S. (or elsewhere) and these third parties may use this information for purposes such as evaluating your use of the Web Sites and Applications, compiling statistic reports on the Web Sites and Applications' activity, and providing other services relating to Web Sites and Applications activity and other internet usage.


We may also engage third parties, including Snap, to serve advertisements on the Web Sites and Applications and/or on other sites. These third parties collect and share information with us during your visits to this and other sites in order to provide advertisements about goods and services likely to be of greater interest to you, measure and research the effectiveness of our advertisements, track page usage and paths followed during visits through our Web Sites and Applications, help us serve relevant internet banner advertisements on our Web Sites and Applications and on other sites, and track use of our internet banner advertisements and other links from our marketing partners' sites to our Web Sites and Applications. No Pão may use the information collected on its Web Sites and Applications for online behavioral advertising purposes including retargeting and to customize ads to you when you visit third party sites.


For further information on tracking and your rights and choices regarding them, please see the sections entitled "Information Collected Automatically" above and "Your Rights and Choices" below.


YOUR RIGHTS AND CHOICES

Review and Update of Account Information

You have the right to access certain account information that you have voluntarily submitted to us through the Web Sites and Applications. You may correct, update, amend, delete, or remove that information by making the change within your No Pão online account or contacting us as set forth in the section entitled "Contact Us" below. We will respond to your request for access within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. European data subjects have additional rights as set forth in the section entitled "Your European Privacy Rights" below.


Tracking Technologies Generally

Most web browser applications (such as Microsoft Internet Explorer, Google Chrome, Firefox and Apple Safari) have features that can notify you when you receive a cookie or prevent cookies from being sent. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.


You can reset your device advertising Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. For information on how to do this on Apple devices, visit Apple.com or https://support.apple.com/en-us/HT202074. For information on how to do this on Android devices, visit Google.com. You can stop all collection of information via an app by uninstalling the app.


The location data collected through an app depends on your device settings and app permissions. You can exercise choice over the location data collected through our apps by (i) for GPS data, disabling location in your device settings or disabling location permissions to that app; (ii) for Bluetooth data, disabling Bluetooth and any Bluetooth scanning option in your device settings; or (iii) for WiFi data, disabling WiFi and any WiFi scanning option in your device settings. You can stop collection of all location data via an app by uninstalling the app.


Your browser settings may allow you to automatically transmit a "Do Not Track" signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, No Pão does not respond to "Do Not Track" signals or other mechanisms. For more information on "Do Not Track," visit http://www.allaboutdnt.com.

If you disable cookies or other device tracking features, however, you may not be able to use certain functions of the Web Sites or Applications.

Analytics and Advertising

You may exercise choices regarding the use of cookies for analytics services as follows:

- Click here to view the Google analytics opt out choice.

- Click here to view the Adobe analytics opt out choice.


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


In addition, some of the advertisers that perform advertising-related services for us and our partners may offer their own opt out choice:

- Click here to view the Google Doubleclick opt out choices.

- Click here to view the Facebook opt out choices.

- Click here to view the Twitter opt out choices.

- Click here to view the Pandora opt out choices.


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


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


No Pão is not responsible for effectiveness of, or compliance with, any third parties' opt out options or programs or the accuracy of their statements regarding their programs.


Communications

In order to provide service to you, we may send you communications related to your transactions, security or the administration of the Web Sites or Applications. From time to time, No Pão may also send you other messages or updates about our Web Sites, Applications, No Pão, or our promotions and other activities. If you do not wish to receive promotional communications from No Pão, you can opt out at any time by following the instructions provided in those communications or by contacting us as set forth in the section entitled "Contact Us" below. Please note that even if you opt out of receiving promotional communications, we may continue to send you non-promotional emails, such as those about your account, servicing, or our ongoing business relations.


PRIVACY SHIELD AND INTERNATIONAL TRANSFER

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Web Sites or Applications from outside of the U.S., please be aware that information collected through the Web Sites or Applications may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Web Sites and Applications or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information in the U.S. and other jurisdictions as set forth in this Privacy Policy. If your data is collected in the European Union ("EU"), we will transfer your personal data subject to appropriate or suitable safeguards, such as the Privacy Shield Framework discussed below.


No Pão participates in the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from the EU and Switzerland to the U.S., respectively. No Pão has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability. For purposes of this section, No Pão refers to the following U.S. legal entities: No Pão LLC, No Pão Distribution LLC, No Pão International Franchising Inc, and No Pão International Payroll Services, Inc.


In accordance with our obligations under the Privacy Shield, and subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission, we hereby affirm our commitment to subject all personal data transferred from the EU and Switzerland to the Privacy Shield Principles. This means that, in addition to our other obligations under the Privacy Shield Principles, we shall be liable to you for any third-party agent to which we transfer your personal data and that processes such personal data in a manner that violates the Privacy Shield Principles, unless we can demonstrate that we are not responsible for the resulting damages.


For inquiries or complaints regarding our compliance with Privacy Shield, please contact us as set forth in the section entitled "Contact Us" below. If we are unable to resolve your complaint directly, you may submit your complaint at no cost to you to the American Arbitrator Association (AAA) at http://info.adr.org/safeharbor/. In the event there are residual complaints that have not been resolved by AAA, or any other means, you may seek a non-monetary remedy through binding arbitration to be provided to you in accordance with the Privacy Shield Principles.


To learn more about the Privacy Shield Framework, and to view No Pão's certification, please visit http://www.privacyshield.gov. A list of companies certified under the Privacy Shield Framework is available at the following link: https://www.privacyshield.gov/list.


CHILDREN'S PRIVACY

The Web Sites and Applications are directed toward and designed for use by persons aged 13 or older. No Pão will not approve applications of, or establish or maintain registrations for any child whom No Pão knows to be under the age of 13. No Pão does not solicit or knowingly collect personal information as defined by the U.S. Children's Privacy Protection Act ("COPPA") from children under the age of 13. If No Pão nevertheless discovers that it has received personal information from an individual who indicates that he or she is, or whom No Pão otherwise has reason to believe is, under the age of 13, No Pão will delete such information from its systems. Additionally, a child's parent or legal guardian may request that the child's information be corrected or deleted from our files by contacting us as set forth in the section entitled "Contact Us" below.


DATA SECURITY

No Pão maintains reasonable physical, electronic, and procedural safeguards to help guard your information from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Please be aware, however, that any email or other transmission you send through the internet cannot be completely protected, and we cannot guarantee the security of your information collected through our Web Sites or Applications.


CHANGES TO THIS PRIVACY POLICY

No Pão reserves the right to modify or supplement this policy at any time. If a material change to the terms of this policy is made, No Pão will post a notice prior to the change becoming effective on its homepage and a link to the new policy.


DATA CONTROLLER INFORMATION

The data controller with respect to the data processing described in this Privacy Policy depends on the processing at issue. When you provide your information through a website or application operated by No Pão LLC that posts a link to this Privacy Policy, the data controller is No Pão LLC, located at the address in the section entitled "Contact Us" below. Sometimes No Pão LLC operates as a processor on behalf of an independent franchisee, a separate legal entity, which is the controller. If that is the case, the Privacy Policy of the website or application in question will identify the name of the applicable franchisee who is the controller.


CONTACT US

If you have questions or comments about this Privacy Policy, the information practices of No Pão, or your dealings with our Web Sites or Applications, please contact us:

By email: contact@mynopao.com