PRIVACY POLICY

Last Updated: February 2021

THIS PRIVACY POLICY APPLIES TO YOUR ACCESS AND USE OF ANY DUNKIN’ ONLINE SERVICES. BY DOWNLOADING OR USING ANY OF THE DUNKIN’ ONLINE SERVICES, YOU ARE AGREEING THAT YOU HAVE READ AND AGREE TO BE BOUND BY THIS PRIVACY POLICY, OUR TERMS AND CONDITIONS, AND CONSENT TO OUR COLLECTION, USE AND DISCLOSURE PRACTICES, AND OTHER ACTIVITIES DESCRIBED IN THIS PRIVACY POLICY.  IF YOU DISAGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF CONDITIONS, THEN PLEASE DO NOT USE ANY OF THE DUNKIN’ ONLINE SERVICES.

This Privacy Policy describes the types of information that Dunkin’ Brands, Inc. and its affiliates (“Dunkin’ Brands” or “we” or “us”) collects from you when you visit Dunkin.co.uk, or DunkinBrands.com (“Websites”) and other parts of the DUNKIN’ online services, and how we use, share and protect that information. Please note, this Privacy Policy does not apply to information collected outside of the DUNKIN’ online services, offline by DUNKIN’ Brands, by our franchisees, or through any other entity sites that link to or are accessible from the DUNKIN’ online services. Please read on for more details about our Privacy Policy.

  1. What Kind of Information We Collect
  2. Information You Provide

    Whether accessing the DUNKIN’ online services from your home computer, mobile phone, or other device, DUNKIN’ Brands and its agents collect information you directly provide. For example, we collect information when you register an account, enroll in our mailing lists, locate a restaurant, apply for a job, interact with Customer Service, or otherwise communicate or transact with us through the DUNKIN’ online services. We also collect information when you access the DUNKIN’ online services using voice functionality services available through the microphone on a device.

    The information we collect includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you (“personal information”). The categories of information we collect, which includes the kinds of information we have collected in the last 12 months, include the following:

    • Name and Contact Data:  We collect your first and last name; mailing address; telephone number; e-mail address, and other similar contact data.
    • Credentials:  We collect username and password, and similar security information (for account authentication and administration)
    • Demographic Data:  We collect information about your interests and activities, your gender, month and date of birth, and other demographic information.
    • Payment Data:  We collect data necessary to process your payments if you make purchases through the DUNKIN’ online services, such as your financial account information and other payment information, or other forms of payment.
    • Content:  We collect the content of messages you send to us, such as feedback and information you provide to customer service.  We also collect the content of your communications as necessary to provide you with the DUNKIN’ online services you use;
    • CV Data:  We collect data as necessary to consider you for a job opening if you submit an application to us, such as your employment & education history and references.

    You may choose to voluntarily submit other information to us through the DUNKIN’ online services that we do not request, and, in such instances, you are solely responsible for such information. Please note that if you access the DUNKIN’ online services using voice functionality services available through the microphone on a device, it may collect background noise or communications that you do not voluntarily provide. Therefore, you should take steps to prevent the communication of unnecessary information when accessing the DUNKIN’ online services using voice functionality services.

    Information once “de-identified” is not subject to this Privacy Policy and we may treat it as non-personal information and use it without obligation to you except as prohibited by applicable law.

    Information Collected Automatically

    In addition, we automatically collect information about your device and how your device interacts with the DUNKIN’ online services.  We use Service Providers to collect this information.  The categories of information we automatically collect, including what we collected in the last 12 months, include the following:

    • Service Use Data: We collect data about the features you use, the pages you visit, the e-mails and advertisements you view, the products and services you view and purchase, the time of day you browse, your referring and exiting pages, and other similar information.
    • Device Connectivity and Configuring Data:  We collect data about the type of device or browser you use, your device’s operating software, 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 various tracking technologies to automatically collect information (“Tracking Technologies”), when you use the DUNKIN’ online services, including the following:

    • Log Files: A log file is a file that records events that occur in connection with your use of the DUNKIN’ online services, such as your service use data.
    • Cookies: Cookies are small data files stored on your device browser directories to store your information about your use of the DUNKIN’ online services and your activities online (collectively, “Cookies”).  A Cookie will typically contain the name of the domain (internet location) from which the Cookie has come, the “lifetime” of the Cookie (i.e. when does it expire), and a value, usually a randomly generated unique number. We use Cookies so that we can improve your online experience – for example, by remembering you when you come back to visit us and making the content you see more relevant to you. Cookies also enable us to track online purchases made through the DUNKIN’ online services.
    • Pixel Tags (“Web Beacons” or “clear gifs”): Pixel Tags are small graphic images, also known as “web beacons” or “clear gifs,” embedded in web pages, e-mail messages, video, or advertisements that send information about your use to a server. There are various types of pixel tags (which contain JavaScript code). When you access or view a website, video, email, or advertisement that contains a pixel tag, the pixel tag permits us or a separate entity to drop or read cookies on your browser. Pixel tags are used in combination with cookies to track activity by a particular browser on a particular device. We incorporate pixel tags from separate entities that allow us to count the number of visitors to the DUNKIN’ online services, to monitor how users navigate the DUNKIN’ online services, to count content views, bring you advertising both on and off the DUNKIN’ online services, including geographically relevant advertising based on your IP address, and provide you with additional functionality, such as the ability to connect the DUNKIN’ online services with your social media account.
    • Embedded Scripts: An embedded script is programming code designed to collect information about your interactions with the DUNKIN’ online services. It is temporarily downloaded onto your device from our web server or a separate entity with whom we work, is active only while you are connected to the DUNKIN’ online services and deleted or deactivated thereafter.
    • Location-identifying Technologies: GPS (global positioning systems) software, geo-filtering, Bluetooth, beacons, and other location-aware technologies locate you (sometimes precisely) for purposes such as verifying your location and delivering or restricting relevant content based on your location. An example of how we may use location-aware technologies is, if you have enabled location services on your device with respect to the DUNKIN’ online services, we may use such location data to determine if you are near a DUNKIN’ Brands physical location (or another retailer), to predict your arrival time at our drive-through or pick-up counter after you have placed an order, allowing our restaurants’ crew members to better sequence your order, or to send you advertising or promotions via push notifications. We may also associate your location captured via location-aware technologies with your device identifier and combine that data with transactional information to improve the services offered to you.
    • Voice Processing Technologies: Voice processing technologies collect audio through the microphone on your device, for purposes such as responding to your instructions or requests and providing you with relevant content based on your requests. We only maintain the audio long enough to complete your instruction or request and then immediately delete it. We 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 browser, device and applications.
    • In-App Tracking Methods: There are a variety of tracking technologies that may be included in mobile apps, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifiers or other identifiers such as mobile Ad IDs to associate app user activity to a particular app and to track user activity across apps. Our apps may also include SDKs, code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising both on and off the DUNKIIN’ online services with your social media account.
    • Connected Devices: We use technology in connected devices, including your vehicle, home assistant, or smartwatch, to determine your location, serve advertising, or provide promotional offers. Information we collect through your connected devices will depend on the device and your settings, but may include voice, location, payment information, or biometric data. We also associate the information from connected devices to your device identifier and combine that with transactional information to improve the services offered to you. For more information, please refer to the sections on “Location-identifying Technologies” and “Voice Processing Technologies” above. Some information about your use of the DUNKIN’ online services and other sites and apps may be collected using Tracking Technologies across time and services and used by us and others for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the DUNKIN’ online services and certain other

    For further information on how we use Tracking Technologies for analytics and advertising and your rights and choices regarding them, please see the “Analytics and Advertising” and “Your Rights and Choices” sections below.

  3. How We Use the Information We Collect
  4. We collect and use information about you for our legitimate interests, business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for using information, including but not limited to in the last 12 months, include the following:

    • process and manage the DUNKIN’ online services, including your use of our products and services
    • perform services requested by you, such as to respond to your inquiries or requests
    • communicate with you in connection with our and separate entity products, services, offers, promotions, rewards, and marketing efforts, such as when we send you offers and promotions that you can take advantage of through the DUNKIN’ online services or at your local DUNKIN’ shop (for information about how to manage these communications and marketing efforts, please see “Your Rights and Choices” below);
    • further our business purposes, such as to perform data analysis, audits, fraud monitoring and prevention, preventing and addressing breach of policies or terms and threats or harm, to enhance, improve or modify the DUNKIN’ online services, to identify usage trends, conduct research, including focus groups and surveys, determine the effectiveness of our promotional campaigns and to operate, improve and expand our business activities;
    • communicate with you about DUNKIN’ Brands, including about your orders or purchases, your services, accounts, reminders about events, contests you entered into, your requests for information, sending you technical notices, security alerts, support and administrative messages, and to update you about changes to the DUNKIN’ online services, policies or terms;
  5. How We Disclose Information We Collect
  6. We share information about you with other entities for any purposes consistent with our statements and practices described in this Privacy Policy or as permitted by applicable law. The categories of entities to whom we disclose information, including in the last 12 months, include the following:

    Service Providers

    We disclose information to entities that process the information on our behalf. These service providers provide us with services such as website hosting, professional services, including information technology services and related infrastructure, customer service, marketing, e-mail delivery, auditing and other similar services. We endeavor to contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the service for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.

    Vendors

    We share information with vendors, including analytics and advertising technology companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Advertising and Analytics” section below.

    Corporate Transactions or Events

    We reserve the right to disclose information in connection with, or during negotiations of, any proposed or actual corporate reorganization, merger, sale, joint venture, assignment, purchase, transfer or any other disposition or acquisition or business combination of all or any portion of our business, assets or stock, including in connection with any bankruptcy or similar proceedings.

    Other Legal Reasons

    In addition, we use or disclose information as we deem necessary or appropriate: (1) under applicable law, including laws outside your country of residence; (2) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (3) to comply with subpoenas and other legal processes; (4) to pursue available remedies or limit damages we may sustain; (5) to protect our operations or those of any of our Affiliates; (6) to protect the rights, property, life, health, privacy, safety or property of DUNKIN’ Brands, our Affiliates, you and others; and (7) to enforce our terms and conditions.

    Facilitating Requests

    We share information at your request or direction, such as when you choose to share information with a social network about your activities on the DUNKIN’ online services.

    Consent

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

    Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you except as prohibited by applicable law. For information on your rights and choices regarding how we share information, please see the “Your Rights and Choices” section below.

  7. Social Media and Technology Integrations
  8. We offer parts of our DUNKIN’ online services through websites, platforms, and services operated, controlled, or owned by separate entities. In addition, we integrate technologies operated or controlled by separate entities into parts of our DUNKIN’ online services. Some examples include: links to order.dunkin.co.uk, ordering our products, finding a route to the closest store location, applying for a job, “liking” or “sharing” our content over social media, registering or logging-in to the DUNKIN’ online services through your social media or email account, chatting with a bot, or using voice-activated platforms.  If you use a separate entity’s website, platform, or service, both DUNKIN’ Brands and the applicable entity may have access to certain information about you and your use of the DUNKIN’ online services and the other entity’s service. Similarly, if you publicly reference the DUNKIN’ online services on another entity’s website, platform, or service (e.g., by using a hashtag associated with DUNKIN’ Brands in a tweet or post), we may use your reference on or in connection with the DUNKIN’ online services. To the extent we combine information from these separate entities with information we collect directly from you on the DUNKIN’ online services, we will treat the combined information in accordance with this Privacy Policy. However, these other entities are not under our control, and may use Tracking Technologies to independently collect information about you and may solicit information from you. Further, to the extent that you access the DUNKIN’ online services using voice functionality services available through the microphone on a device, that device may collect information about you. When you use a separate entity’s website, platform, or service, you are bound by the privacy policy of that entity and DUNKIN’ Brands does not control and is not responsible for the privacy practices or the content of any such entity or device. You should consult the privacy policy of the separate entity to or from which you access content or link to determine the information practices of that separate entity.

    Analytics and Online Advertising

    We use Google Analytics and other companies for analytics services (i.e., to help us understand how users access and use the DUNKIN’ online services). These services use Tracking Technologies to track the actions of users of the DUNKIN’ online services, to measure statistics of user activity on the DUNKIN’ online services, and provide other services relating to DUNKIN’ online services activity and internet usage.  We also engage and work with agencies, advertisers, ad networks, and other technology services to serve advertisements about our products and services on the DUNKIN’ online services and/or on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.

    As part of this process, we incorporate Tracking Technologies into our DUNKIN’ online services (including our website and emails) as well as our ads displayed on other websites and services. Some of these Tracking Technologies track marketing efforts and deliver “interest-based advertisements” that may be more relevant to individual consumers by tracking your activities across time and services for purposes of associating the different devices you use and delivering relevant ads and/or other content to you. For example, if your information indicates that you live in an area where a particular in-store promotion is going on (such as a new snack offering), you may receive an advertisement on the DUNKIN’ online services and/or on another entity’s website that is specific to that promotion. As above, the information collected and stored by any such entity remains subject to their own policies and practices.

    We serve ads on and through other entities, such as Apple, Facebook and Google, that are targeted to reach people (or people similar to people) who have visited our DUNKIN’ online services or are identified in one or more of our databases (“Matched Ads”). This is generally done by us uploading a customer list to a technology service or incorporating a pixel from a technology service on our DUNKIN’ online services, and the technology service matching common factors between our data and their data. For instance, we incorporate the Facebook pixel on our DUNKIN’ online services and may share your email address with Facebook as part of our use of Facebook Custom Audiences. Some technology services, such as LiveRamp, may provide us with their own data, which is then uploaded into another technology service for matching common factors between those datasets. To opt-out of receiving Matched Ads, please contact the applicable technology service. If we serve Matched Ads in Apple services, you should be able to click into the box in the lower right corner of such ads to find out how to opt-out or limit those ads. If we use Facebook Custom Audiences to serve Matched Ads on Facebook services, you should be able to hover over the box in the right corner of such Facebook ads and find out how to opt-out.  We are not responsible for such technology service’s failure to comply with your opt-out instructions.

    For further information on Tracking Technologies and your rights and choices regarding analytics, please see “Information Collected Automatically” above and “Your Rights and Choices” below.

  9. Your Rights and Choices
  10. Review and Update of Account Information

    You can visit the account section of the DUNKIN’ online services to access, remove, or update certain account information we have on file about you and that you have submitted through the DUNKIN’ online services.

    We may retain your information for as long as your account is active or as reasonably useful for commercial purposes. We will retain and use your information as necessary to comply with our legal obligations or data retention policies, resolve disputes, and enforce our agreements.

    Tracking Technologies Generally and “Do Not Track”

    If you do not wish to receive Cookies or wish to manage when you accept Cookies in general, you may set your browser to reject or delete Cookies or to alert you when a Cookie is placed on your device.  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 setting and limitations. Although you are not required to accept our Cookies, if you set your browser to reject Cookies, you may not be able to use all of the features and functionality of the DUNKIN’ online services. For example, you may not be able to add items to your Shopping Cart, proceed to Checkout, or use any products and services that require you to sign in. To find out more about Cookies, including how to see what Cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

    With respect to our mobile apps, you can stop all collection of information via the app by uninstalling the app.  You may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device. You can also reset your device Ad ID at any time through your device settings, which is designed to allow you to limit the use of information collected about you. Please be aware that if you disable or remove these technologies some parts of the DUNKIN’ online services may not work.

    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, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms.  For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

    Analytics and Interest-Based Advertising

    You may exercise choices to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout, by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/, or downloading the Google Analytics Opt-out Browser Add-on.

    Most of the companies with whom we work to provide you with targeted ads support the Self-Regulatory Principles for Online Behavioral Advertising of the Digital Advertising Alliance (“DAA”) (“Principles”). This means that they allow you to exercise choice regarding the collection of information about your online activities over time and across websites for online interest based advertising purposes. More information about these Principles can be found at www.aboutads.info/. If you want to “opt out” of receiving online interest-based advertisements on your internet browser from advertisers and other companies that participate in the DAA Self-Regulatory Program for Online Behavioral Advertising and perform advertising-related services for us and our partners, please follow the instructions at www.aboutads.info/choices, or http://www.networkadvertising.org/choices/.  An “opt-out” Cookie will be placed on your device indicating that you do not want to receive interest-based advertisements.  Opt-out Cookies only work on the internet browser and device they are downloaded onto. If you want to opt-out of interest-based advertisements across all of your browsers and devices, you will need to opt-out on each browser on each device you actively use. If you delete Cookies on your device generally, you will need to opt-out again. If you want to “opt out” of receiving online interest-based advertisements on your mobile apps, please follow the instructions at http://www.aboutads.info/appchoices.

    To opt out of us using your data for Matched Ads, please contact us as set forth in the “Contact Us” section below and specify that you wish to opt out of matched ads. We will request that the applicable technology service not serve you matched ads based on information we provide to it. Alternatively, you may directly contact the applicable technology service to opt out.

    Please note that when you “opt-out” of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on the DUNKIN’ online services. It means that the online ads that you do see from participants should not be based on your particular interests. Dunkin’ Brands is not responsible for effectiveness of, or compliance with, any other entities opt out options or programs or the accuracy of their statements regarding their programs. In addition, other entities may still use Tracking Technologies to collect information about your use of the DUNKIN’ online services, including for analytics and fraud prevention as well as any other purpose permitted under the Principles.

  11. Data Security
  12. We implement and maintain reasonable administrative, physical, and technical security measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information collected through the DUNKIN’ online services.

  13. Updates to this Policy
  14. We may change this Privacy Policy from time to time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of the DUNKIN’ online services indicates your consent to the Privacy Policy then posted. If we make any material changes to this Privacy Policy, we will post those changes through a prominent notice on the DUNKIN’ online services or notify you directly. Regardless of our efforts, we encourage you to review this Privacy Policy each time you visit the DUNKIN’ online services.

  15. Contact Us
  16. If you have any questions regarding this Privacy Policy, our privacy practices, our data practices, or our compliance with applicable law, you can email us at [email protected]

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