Church's Texas Chicken®

Cajun Operating Company and affiliates[1] (“Church’s^®”) Internet Consumer Privacy Policy for Consumers (the “Consumer Privacy Policy”)

Last Updated: February 28, 2024

At Church’s® (also referred to in this Consumer Privacy Policy as “we,” “our,” or “us”), we strive to do everything we can to respect the trust customers have in our brand and our commitment to your privacy is no exception. We are committed to protecting and safeguarding consumer privacy, especially for children.

Thanks again for visiting our website and for placing your trust in Church’s®.

Church’s® is pleased to provide information to all of its customers about its privacy practices in this Consumer Privacy Policy. Please be assured that Church’s® uses its best efforts to protect the privacy of visitors to this website and the Church’s mobile app.  This Consumer Privacy Policy applies to any website where the Consumer Privacy Policy is displayed. This Consumer Privacy Policy does not pertain to Church’s® franchisees or employees.

1. Notice at Collection of Personal Information

A. Types of Information We Collect; Sales/Sharing of Personal Information

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, we have collected the categories of Personal Information listed in the below chart from consumers within the last twelve (12) months. As indicated in the chart, we may also “sell” or “share” certain categories (as such terms are defined under applicable privacy laws) for marketing purposes to third parties, such as data analytics providers, advertising technology vendors, and social media platforms as described in this Consumer Privacy Policy. We do not knowingly sell or share Personal Information about persons under the age of 16. Please click here to opt out of the sale or sharing of your Personal Information, including targeted advertising. You may also choose to enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”). We will process the GPC signal as a request to opt out.

B. The Business and Commercial Purposes for Which We Collect and Use Your Personal Information:

• To fulfill or meet the reason for which the information is provided, such as carry out your requests, fulfill orders, and process payments for our products and services as well as communicate with you about your orders, purchases or accounts with us, requests, questions, and comments. For example, if you provide us with Personal Information in order for us to provide you with rewards through our Loyalty Program, we will use that information to determine the rewards for which you qualify and provide you those rewards through our mobile app or other methods as disclosed.
• To provide online services to you, which includes our websites or mobile apps.
  To provide customer support, including to process any concerns about our services.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To market to you, improve our services, and the following additional legitimate business interests: (a) use analytics and profiling technology to personalize your experience, deliver content (including advertising) tailored to your interests and how you use our online services or in-store technologies, manage our business, help diagnose technical and service issues, administer our online services and in-store technologies, identify users of our online services, identify a device for fraud prevention purposes, gather demographic information about our customers, and determine usage patterns of our services; (b) maintain, manage, and improve our products, offers, promotions, and online services and other technology; (c) send you e-mails or text messages about our products and services, competitions, offers, promotions or special events that we believe may interest you; (d) to send you e-mails or text messages about the products and services of our business partners; (e) provide location-based services; (f) deploy cookies and similar technologies; and (f) provide online services to you, which includes our websites or mobile apps.
• To conduct surveys on customer satisfaction.
• To carry out our obligations and enforce our rights arising from the Loyalty Program, Ordering Application, Contests, Sweepstakes, Games or any other contract between you and us.
• As necessary or appropriate to protect the rights, property or safety of us, our customers or others and ensure the security of our networks and systems.
• To respond to law enforcement requests and as required by applicable law, court order, legal request, governmental regulations, law enforcement investigation or an investigation on a matter of public safety.
• As described to you when collecting your Personal Information or as otherwise set forth under applicable privacy laws.

We may use the information we collect about you in other ways, which we will tell you about at the time we collect it or for which we will seek your consent.  We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

C. Retention

We will retain your Personal Information for as long as reasonably necessary to provide you with our services that you request, for marketing purposes unless you opt out as described in our Consumer Privacy Policy, or otherwise where permitted or required in accordance with applicable law. We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. What this means in practice will vary between different types of information, and when we consider our approach we take into account ongoing business or legal needs for the information, for example in relation to tax, health and safety, and potential or actual disputes or investigations.

2. How We Collect Your Personal Information

We may collect information about you from you (including when you create an account, engage with customer service, make a purchase, or fill out a survey) and from other companies and organizations.  We may also collect information that is publicly available (i.e. social media).

We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from our agents. For example, from documents that our agents provide in order to provide us with services.
• Indirectly from you or our agents. For example, through information we collect from you or our agents in the course of providing services to you or our agents providing services to us.
• Directly and indirectly from activity on any of the Church’s® websites where this Consumer Privacy Policy is displayed, such as from submissions through our website portal or website usage details collected automatically.
• From third-parties that interact with us in connection with the services we perform. For example, from companies that help us to process orders or administrate our Loyalty Program.
• Through automated means.  We may use automated technology to collect information from your computer system or mobile device when you visit our restaurants, use our website, mobile app, or online services, or in-restaurant technology to collect information about the exact location of your mobile device or computer using geolocation and technology such as GPS, Wi-Fi, Bluetooth, or cell tower proximity. Automated technology may include cookies, local shared objects, geofencing and web beacons. We partner with Microsoft Clarity and Microsoft Advertising to capture, monitor, and record how you use and interact with our website through behavioral metrics, heatmaps, and session replay, including capturing keystrokes, mouse movements, form field entries, and overall engagement with our website, to improve and market our products/services. 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.

Please note that we may combine Personal Information that we receive from various sources. For example, we may combine Personal Information that we collect from you offline with Personal Information we collect from you through our online services. Similarly, we may combine Personal Information that we receive from third parties with Personal Information we already have about you. We use, disclose, and protect combined Personal Information as described in this Consumer Privacy Policy.

3. Who Will Have Access To Your Personal Information or With Whom We Will Share Your Personal Information

We may disclose each category of your Personal Information to the following categories of recipients:

• Our Service Providers. We disclose your Personal Information to our service providers that provide business, professional, marketing, analytics, or technical support services to us, help us operate our business and the services, or administer activities on our behalf. We require our service providers to only use your Personal Information in connection with providing services to Church’s®.
• Our Franchisees or Affiliates. We disclose your Personal Information to our franchisees or affiliates for business purposes.
• Our Research Partners. We disclose your Personal Information to our research partners, including those that administer surveys or conduct research projects in partnership with us or on our behalf.
• Our Analytics Partners. We disclose your Personal Information to our partners that assist us in performing analytics and help us measure the effectiveness of our services’ content and our marketing and advertising efforts.
• Our Marketing and Advertising Partners. We disclose your Personal Information to third parties for marketing and advertising purposes, including social media platforms, third-party advertising networks, and other parties that assist us in serving and optimizing our advertisements.
• Competent Governmental, Regulatory, and Public Authorities. We disclose your Personal Information to government and law enforcement authorities, in each case to comply with legal or regulatory obligations or requests.
• Relevant Third Parties as Part of a Corporate Transaction. In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with a bankruptcy or similar proceeding), we may disclose or transfer your Personal Information to certain third parties, such as the acquiring entity and its advisers.
• Other Third Parties. We will disclose your Personal Information to other third parties at your direction or with your consent. Additionally, we will disclose your Personal Information as we believe necessary or appropriate to: (a) comply with applicable law; (b) enforce our terms and conditions; (c) protect our operations; (d) protect our rights, privacy, safety, or property, and/or those of you or others; and (e) allow us to pursue available remedies or limit damages that we may sustain.

We may disclose your Personal Information for other reasons that we will describe at the time of information collection or prior to disclosing your information.

Certain disclosures may be considered “sales” or “shares” of Personal Information under applicable U.S. state privacy laws. Details on how to exercise your legal rights with respect to such “sales” or “shares” can be found in the “Your Privacy Choices and Rights” section below.

Please note that we may de-identify or aggregate Personal Information so that it will no longer be considered Personal Information and disclose such information to other parties for purposes consistent with those described in this Consumer Privacy Policy.

4. Children’s Privacy

Our website and mobile app are intended for a general audience. We do not direct our website or mobile app to users under eighteen (18), nor do we knowingly solicit or collect any Personal Information from users under the age of eighteen (18). If you are a parent or legal guardian and think that your child has given us data, please contact us at privacy@churchs.com. If we learn that a minor has provided Personal Information through our websites or mobile app, we will use reasonable efforts to remove such information from our files.

5. Links to Other Sites

We may offer links to sites that are not operated by Church’s®. If you visit one of these linked sites, you should review their privacy and other policies. We are not responsible for the policies and practices of other companies, and any information you submit to those companies is subject to their privacy policies.

6. Other Church’s® Web Sites

All web sites operated by Church’s® will adhere to this Consumer Privacy Policy. The policies of some Church’s® sites may vary, however, because of local customs, practices or laws or due to circumstances unique to that site. In all cases, however, sites operated by Church’s® will honor the commitments to our customers set forth in this Consumer Privacy Policy regarding the collection and use of Personal Information.

7. Church’s® Franchisee Web Sites

Many Church’s® restaurants are owned and operated by franchisees who are independent businessmen and women. Some franchisees also operate web sites. In many cases, franchisee sites follow this Consumer Privacy Policy. However, please review the privacy policy of each site to determine the privacy policies of that site.

8. Your Privacy Choices and Rights

Depending on your U.S. state of residence, you may have certain rights in relation to your Personal Information, including:

• Right to Know: You may have the right to know what Personal Information we have collected about you, including the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information we have collected about you. Please note that we may not be required to respond to your requests “to know” or access specific pieces of personal information more than twice in any 12-month period.
• Right to Data Portability: You may have the right to access your information in a portable format.
• Right to Delete: You may have the right to request that we delete Personal Information that we have collected from you, subject to certain exceptions.
• Right to Correct: You may have the right to correct inaccurate Personal Information that we may maintain about you, subject to appropriate verification.
• Right to Opt Out of Certain Types of Personal Information Uses and Disclosures: We use and disclose to third parties’ Personal Information for analytics and advertising purposes. Accordingly, you may have the right to opt out of the “sale” or “sharing” of your Personal Information, or the use and disclosure of your Personal Information for “targeted advertising” (as these terms are defined in applicable law).

Please note that, where permitted under applicable law, we may decline a request if we are unable to verify your identity (or an agent’s authority to make the request) and confirm the Personal Information we maintain relates to you.

Exercising Your Privacy Rights

To exercise your privacy rights, please submit a consumer request to us by:

• Emailing us at privacy@churchs.com
• Visiting churchs.com/privacy-request
• Calling us at (866) 372-5246

We may take steps to verify your identity before responding to your request by asking you a series of questions about your previous interactions with us. Submitting a privacy rights request does not require you to create an account with us.

We will not discriminate against you if you decide to exercise your privacy rights.

Agent Requests

Only you, or someone legally authorized to act on your behalf, may submit a request related to your Personal Information. You may also submit a request on behalf of your minor child.

Depending on your U.S. state of residence, you may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf.  Your agent may contact us as set forth below in “How to Contact Church’s Texas Chicken® USA” to make a request on your behalf.  Even if you choose to use an agent, as permitted by law, we may require verification of the agent’s authorization to act on your behalf, require you to confirm you have authorized the agent to act on your behalf, or require you to verify your own identity.

Opt-Out Requests

You may request to opt out of the sale or sharing of your Personal Information, or of targeted advertising, at any time by clicking the “Do Not Sell or Share My Personal Information” link here or at the bottom of our website homepages, or you can email us at privacy@churchs.com.

Submitting an opt-out request does not require you to create an account with us.

Alternatively, you can use certain preference signals to exercise your sale and sharing opt-out right automatically with all businesses that you interact with online, including Church’s®. If you enable a browser-based opt-out preference signal, such as Global Privacy Control (GPC), upon receipt or detection, we will treat the signal as a valid request to opt out of the sale or sharing of Personal Information linked to that browser and any consumer profile we have associated with that browser. Please note that if you use different browsers or browser profiles, you will have to enable the signal on each browser or profile.

Right to Appeal

Depending on your U.S. state of residence, you may have the right to appeal a decision we have made in connection with your privacy rights request. To appeal a decision, please contact us at privacy@churchs.com.

Marketing Communications Rights and Choices

If you have agreed to receive marketing communications from us, you can later opt out by following the opt-out instructions in the marketing communications we send you.

You can also generally find your communication preferences with instructions on how to opt out in the profile section of the online services that you use.

You may also have the ability to change your communication preferences using your device settings.

If you do opt out of receiving marketing communications from us, we may still send communications to you about your transactions, any accounts you have with us, and any contests, competitions, prize draws or sweepstakes you have entered. Opting out of one form of communication does not mean you have opted out of other forms as well. For example, if you opt out of receiving marketing emails, you may still receive marketing text messages if you have opted in to receiving them. Please note that if you are receiving communications from a Church’s Texas Chicken® franchise, then you will need to opt out from them directly.

Behavioral Advertising Opt-Out

You may be able to opt out of receiving certain targeted or interest-based advertisements using the browser opt-out tools and consumer choice mechanisms provided by advertising industry self-regulatory groups by following the links below:

• Network Advertising Alliance (NAI): https://optout.networkadvertising.org/?c=1
• Digital Advertising Alliance (DAA): https://optout.aboutads.info

You also can control whether you see interest-based advertisements on your mobile device(s) in the following ways:

• Your device operating system may provide mechanisms that allow you to opt in or opt out of the use of information about your use of mobile apps to deliver interest-based advertising to your mobile device. For more information, consult your device settings.
• The DAA offers a tool for opting out of the collection of cross-app data on mobile devices for interest-based advertising. To exercise your choices with respect to participating companies, please download the AppChoices tool at www.aboutads.info/appchoices.

You will need to opt out separately on all of your browsers and devices, as each opt out will apply only to the specific browser or device from which you opt out. If you delete or reset your cookies or mobile identifiers, change browsers, or use a different device, any opt-out cookie or tool may no longer work and you will have to opt out again.

Even if you choose to opt out of receiving interest-based advertising, you may still receive advertising, but the advertisements may be less relevant.

Some of our partners may provide you with additional choices with respect to interest-based advertising. For example, certain social media platforms allow you to control your advertising preferences directly through their services. Please review the privacy policies of the third-party services you use for more information.

9. Disability Access

If you are a user with a disability, or an individual assisting a user with a disability, and have difficulty accessing or navigating our digital channels – including this Consumer Privacy Policy– please contact us at accessibility@churchs.com.  You can also review our Digital Accessibility Statement.

10. How to Contact Church’s Texas Chicken® USA

If you have any questions or concerns about this Consumer Privacy Policy, you may contact us at privacy@churchs.com.

11. Changes to our Consumer Privacy Policy

From time to time, it may be necessary for Church’s® to change this Consumer Privacy Policy. If we change our policy, we will post the revised version here, so we suggest that you check here periodically for the most up-to-date version of our Consumer Privacy Policy. Rest assured, however, that any changes will not be retroactively applied and will not alter how we handle previously.