Groucho’s Franchise System, LLC (“Groucho’s”) respects the privacy concerns of the users of this website (www.grouchos.com), the Groucho’s Reward Program (“GRP”), Groucho’s Gift Card Program (GCP), Groucho’s Mobile Applications (each, an “App”), or Online Digital Services (“ODS”) (collectively, the “Digital Services”). This policy describes how we may collect and use your personal information.

The ODS include but are not limited to the following:
• Groucho’s Deli Social Media (including both Groucho’s Corporate and Franchised Locations)
• GRP
• GCP
• E- Club
• Franchise Inquiry Submissions
• Ordering online or through an App
• Grouchos.com
Groucho’s Rewards Program (GRP)
The GRP administered by Groucho’s. Use of the GRP is also subject to this Privacy Policy.

Groucho’s Gift Card Program (GCP)
The GCP is administered by Factor 4 (“F4”). Use of the GCP is also subject to the F4 Privacy Policy available at https://factor4gift.com/privacy-policy/

Online and Mobile Ordering (App)

Online ordering via the ODS is administered by ToGoTechnologies, LLC. Your use of online ordering with ODS is also subject to ToGoTechnologies, LLC’s Terms of Use and Privacy Policy. They are available at: https://www.togoorder.com/Docs/Legal.aspx.

Information We Collect & Use:
We and our trusted service providers collect information from various sources that we use to provide our services to you, to analyze and improve our services, and to communicate with you (e.g., to send you updates or notices about our organization, or emails about products, specials, promotions, or services that we believe may be of interest to you). The information that we collect and the purpose for our collecting such information is as follows:

Information that you provide to us: We collect information that you provide to us when you (i) sign up for the GRP with us, (ii) register a Groucho’s gift/ loyalty card, (iii) sign up for an account using our App, (iv) use our ODS, or (v) communicate with us or join our E-Club. For example, if you register for the GLC or an App account with us, then we may request your personal information (e.g., name, postal address, email address, DOB, telephone number, credit/debit card number, security code) or, as applicable, your business information, to complete the registration process, to process transactions, to send you information about our products, to send you promotional offers that we think may be of interest to you, or to otherwise provide our services to you. Similarly, if you request information from us through an online contact form (or if you email us), we collect the information you provide (e.g., name, telephone number, email address) so that we can respond to you.

Information collected from third parties: We may collect information about you or your business from third parties during providing our services to you.

Information collected through technology: When you visit our website or App, or when you otherwise use any of our ODS, we may collect certain information about your location, computer or device through technology such as cookies, web beacons, GPS or other tracking/recording tools. The information collected may include, but is not limited to, IP addresses, referring URLs, access times, location, browser types, device types, mobile device identifiers, or information about your interactions with our websites, applications or services. (Note that a “cookie” is a text file placed on a computer’s hard drive or stored on a mobile device; a “web beacon,” also known as an Internet tag, pixel tag or clear GIF, is used to transmit information back to a web server.) We may use the information described in this paragraph to, among other things, (i) operate our services, including by remembering information so that you will not have to re-enter it during your visit or the next time you sign in to your account, (ii) identify and protect our customers, (iii) control unauthorized use or abuse of our services, (iv) provide custom, personalized content and information, which could include advertising, (v) monitor aggregate traffic patterns on our websites and services, and (vi) analyze and improve our ODS.

How We Use Your Personal Information
The personal information that you provide will be accessible to us, our affiliates, agents, representatives, franchisees and trusted service providers, as appropriate, to be used for the purposes indicated at the time you voluntarily provide such personal information.
Unless we state otherwise when the information is collected, we and our affiliates, agents, representatives, franchisees and trusted services providers may use personal information about you that you provide to us or them for the following purposes:
• To assist us in better understanding users and visitor’s navigation of any of our ODS.
• To respond to specific requests from users and visitors of this site, including prospective franchisees and registered GRP or E-Club members.
• To obtain parental consent from users or visitors under 13 years of age when necessary.
• To provide any necessary notices to our users or visitors when necessary.
• To guard the security or integrity of our Digital Services when necessary.
• To communicate with registered GRP or E-Club members notices of promotions and/or special offers.

We may share or disclose your information if we determine, in our sole discretion, that we are required to do so under applicable law or regulatory requirements, or if we reasonably believe disclosure is necessary to prevent harm or financial loss, or in connection with preventing fraud or illegal activity, and/or to enforce our Terms of Use.
Children’s Privacy
Groucho’s ODS are intended for use strictly by adults. Groucho’s does not knowingly solicit or collect personal information from children under the age of 13. If Groucho’s obtains knowledge that it has collected personal information from a child under 13 in retrievable form in its files, Groucho’s will delete that information.
Your Choices
From time to time, we may send you emails regarding updates to our ODS or our products/services, notices about our organization, information about products/services we offer, or promotional offers that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “unsubscribe” link provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).

Cookie and Location Controls
You may be able to set your Internet browser or mobile device to block cookies or other tracking/recording tools, including cookies associated with our websites or Services, or to indicate when a cookie is being set by us. However, it is important to remember that many of our websites or Services may not function properly if your cookies or location are disabled. We support the Do Not Track browser setting. Do Not Track (or DNT) is a preference you can set in your browser to let the websites that you visit know that you do not want them collecting certain information about you. For information and instructions about how to manage your cookies, refer to your Internet browser’s or mobile device’s technical information. Further information on how to adjust your cookie preferences through your browser is available at the external, third-party informational website www.allaboutcookies.org.
Third-Party Websites and Services
Our Digital Services may provide links to (or links from) third-party websites or services, none of which are governed by this Privacy Policy. To the extent that any linked third-party websites or services you visit are not owned or controlled by Groucho’s, we are not responsible for those websites’ or services’ content or information practices. We strongly encourage you to review the privacy policies of any site or service before providing any personal information. We assume no responsibility or liability for any information, intellectual property or material that may be obtained on other websites accessed through this website. We do not make any representations or warranties regarding the quality of any product or service contained at any such website or the ownership of intellectual property related to it. Access them at your own risk.
Data Protection and Storage
Groucho’s and our service providers maintain reasonable administrative, technical and physical safeguards to protect the confidentiality of information transmitted online, including but not limited to encryption, firewalls and SSL (Secure Sockets Layer). Groucho’s has implemented policies and practices pursuant to various security rules and regulations relating to the security and safeguarding of payment cardholder data, including the Payment Card Industry Data Security Standards (PCI-DSS). Groucho’s is not liable for loss of passwords due to user negligence. If you believe your password has been lost or compromised, we recommend that you immediately change your password.
Changes to Privacy Policy
We reserve the right to change this Privacy Policy from time to time in our sole discretion. We will post changes on this page and indicate the “last modified” date at the bottom of this page. Please check back often for any updates. Your continued use of the Digital Services after any change in this Privacy Policy will constitute your acceptance of such change.
Contact Us
If you have any questions or concerns about this policy, please contact us using the information provided at http://www.grouchos.com/contactus.html.

This policy was last updated and posted on December 13, 2019.