Culver’s Privacy Policy

Culver Franchising System, LLC (“Culver’s”, “we”, “us”, or “our”) respects your privacy. This Privacy Policy describes the types of personal information we collect about you, how we process that information, and your rights and choices regarding your personal information when you use our websites (including www.culvers.com), our mobile application (the “App”), our Delicious Rewards program, Wi-Fi services at some locations, when you contact us by phone or through our online services, and otherwise interact with us (collectively, the “Services”). Please read this Privacy Policy carefully before you start to use our Services, whether online or offline. When referenced in this Privacy Policy, the term “personal information” (i.e., Personal Data or other similar terms as defined by applicable law) includes any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, including any information that is subject to applicable data protection laws.

Categories of Information We Collect

We collect various types of information about you, including:

Personal Information You Provide Directly:
- Account Information: When you register for MyCulver’s or Delicious Rewards, we collect your name, phone number, email address, and zip code. You may also choose to provide your birth date/month, phone number, and other optional information. For Delicious Rewards, this may also include preferences and other information to personalize your experience.
- Order Information: When you place a mobile order or catering order, we collect your name, phone number, email address, payment information, and delivery address (if applicable).
- Communications: If you contact us, we may collect your name, email address, phone number, and the content of your communication.
- Promotions and Surveys: If you participate in sweepstakes, contests, games, promotions, surveys, or polls, we may collect your name, email address, phone number, address, and other information required for participation.
- Wi-Fi Information: When you access Wi-Fi at some of our restaurant locations, we may collect your name, email address, phone number, and/or social media username.
Information Collected Automatically:
- Website and App Usage: We may collect information about your interactions with our websites and App, such as your IP address, device type, operating system, browser type, pages visited, and actions taken.
- Location Information: If you enable location services in the App, we may collect the real-time geo-location of your device to provide location-based services, such as finding the nearest restaurant and alerting the restaurant team of your estimated and actual times of arrival.
- Purchase History: We collect information about your purchases, including products you like and your order history, especially in connection with the Delicious Rewards program.
- Cookies and Other Tracking Technologies: We use “cookie” technology and participate in interest-based advertising. Cookies may collect information about you, such as your IP address and preferences. More information is available below in the “Cookies and Other Tracking Technologies” section.
Information from Other Sources:
- We may receive information about you from third-party service providers, business partners (including the rewards platform provider), social media platforms, and other sources, where permitted by applicable law. This may include information to support the Delicious Rewards program, such as during the account merger process.

Sources of Personal Information

We collect your personal information in the following ways, pursuant to applicable law:

Directly From You, such as when you use our Services, create an account and profile with us; sign up with us to receive marketing communications; or otherwise reach out to us.
Other Sources, including vendors, affiliates, and through tracking technologies. To learn more about our use of cookies and similar tracking technologies, please review the “Cookies and Other Tracking Technologies” section below.

How We Use Your Personal Information

We may use your personal information for various purposes, including to:

Operate the Delicious Rewards program, including to manage your membership and account, track your Points, facilitate point earning and redemption, and provide rewards and offers.
To manage our business operations, perform our obligations and exercise our rights under any agreement that you or your organization has with us.
Provide and improve our Services, personalize your experience, and understand your preferences.
Process your orders and payments.
Communicate with you, respond to your inquiries, and provide customer support, including for issues related to your Delicious Rewards account.
Send you marketing communications about Culver’s products, promotions, and other offerings, including personalized offers through the Delicious Rewards program, if you have opted in to receive them. You can opt out of marketing communications at any time.
Administer promotions, surveys, and polls, including for the Delicious Rewards program.
Analyze and improve our business and operations.
Detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity, including fraudulent transactions, attempts to manipulate or violate our policies, procedures, and terms and conditions, security incidents, and harm to the rights, property, or safety of Culver’s and our users, customers, employees, or others.
Comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.
For other purposes with your consent, or as otherwise permitted or required by applicable law.
Aggregate or deidentify personal information for internal business purposes. Deidentified information is generally not considered to be personal information under applicable laws.

To the extent that we use deidentified information, we commit to maintaining and using the information in deidentified form and we will not attempt to reidentify the information, except as permitted under the applicable law.

How We Share Your Personal Information

We may share your personal information with:

Within Culver’s: With our affiliates, subsidiaries, and related entities, including for the operation of the Delicious Rewards program and for marketing purposes.
Franchised Operators: With the independently owned and operated Culver’s restaurant locations, particularly to facilitate the Delicious Rewards program, process orders, and provide services.
Service Providers: With third-party service providers who perform services on our behalf, such as the rewards platform provider for the Delicious Rewards program, payment processors, marketing and advertising vendors, data analytics providers, and other vendors who support our business operations. We require these service providers to protect and process your personal information.
Business Partners: With business partners in connection with specific programs or promotions, including the Delicious Rewards program.
Legal Authorities: When required by law, legal process, or government request, or to protect our rights, property, or safety, or the rights, property, or safety of others.
Corporate Transaction: We may disclose your personal information in connection with a proposed or actual corporate merger, acquisition, consolidation, sale of assets, bankruptcy, insolvency or other corporate change. Such recipient will be bound by terms and conditions reasonably similar to those set out in this Privacy Policy.
Deidentified Personal Information: We may disclose or use aggregated or deidentified data for any lawful purpose.
Additional Disclosures: From time to time, we disclose your information to our attorneys, banks, auditors, securities brokers and other professional service providers and advisors in connection with the purposes described above.
Other Parties: With your consent or at your direction.

Your Rights and Choices

You may have certain rights regarding your personal information. The rights available to you depend on our reason for processing your personal information and the requirements under applicable law (i.e., your rights will vary depending on whether you are located in, for example, California or Colorado). Specifically, you may have the following rights:

Right to access: You may have the right to obtain from us confirmation as to whether personal information concerning you is being processed, and, where that is the case, to request access to the personal information.
Right to correct: You may have the right to request that we correct any personal information about you that is inaccurate. Depending on the purpose of the processing, you also have the right to request that we complete the personal information we hold about you where you believe it is incomplete, including by means of providing a supplementary statement.
Right to delete: You may have the right to request that we erase your personal information, under certain conditions. Please note that deleting your personal information may also result in the termination of your Delicious Rewards membership and loss of any accrued Points and Rewards. To submit a data privacy deletion request, please submit the Data Privacy Deletion Form.
Right to data portability: You may have the right to request that we transfer the personal information we have collected about you to another organization, or directly to you, in a structured, commonly used, and machine-readable format, under certain conditions.
Right to withdraw consent: Where we rely on your consent to process your personal information, you have the right to withdraw that consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.
Right to know what personal information is sold or shared and to whom, and right to prohibit the sale or sharing of personal information: We do not and have not in the preceding 12 months, sold your personal information. However, we have shared (in this context, share means use of your personal information for cross-contextual behavioral advertising) your personal information. You may opt-out of the sharing of your personal information by updating your cookie preferences, as described below or by clicking the Your Privacy Choices button at the footer of our website or by engaging with the cookies banners when you first visit our website.
Right to limit the use and disclosure of sensitive personal information: We will only use sensitive or special personal information as needed for the purposes for which it was collected. If this changes, we will notify you, and you may have the right to restrict such additional uses. We do not currently collect sensitive personal information.
Right of non-discrimination/retaliation: We do not discriminate against individuals who exercise any of their rights described in this Privacy Policy, nor do we retaliate against individuals who exercise these rights.
Right to opt out of marketing communications: You may opt out by clicking “unsubscribe” on our marketing communications to you.
Appeal a decision regarding your privacy rights request.

Please note that many of the above rights are subject to exceptions and limitations. Your rights and our responses will vary based on the circumstances of the request. If you choose to assert any of these rights under applicable law, we will respond within the time period prescribed by such law.

If you are located in the State of California in the United States, a person authorized to act on your behalf may make a verifiable request related to your personal information. If you designate an authorized person to submit requests to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf.

In any circumstances, your request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of that person; and (ii) describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

To exercise these rights, please contact us as described in the “Contact Information” section below or use our online webform to request your rights. We will handle your request in accordance with applicable law.

Financial Incentive Program

Culver’s offers the Delicious Rewards program, to customers, which provides certain perks, such as rewards, discounts, and exclusive offers. When you sign up for the Delicious Rewards program, we will ask you to provide your name, email address, and in some cases your telephone number (if you opt-in to receive text messages). To provide the Delicious Rewards program, we may disclose this and other personal information as described in the section entitled “How we Share Your Personal Information.” Because our Delicious Rewards program involves the collection of personal information, it might be interpreted as a “financial incentive” program or a “bona fide loyalty program” under applicable law.
We generally do not assign monetary value to personal information or promotional activities in which we engage. To the extent we create overall value from the Delicious Rewards program to our business that could be directly or reasonably related to the value of personal information, the method for calculating the value would include: (1) costs related to maintaining the Delicious Rewards program, including but not limited to IT infrastructure, delivery of offers, and skilled marketing teams with the appropriate knowledge to enhance personal information; (2) whether the sales generated by the Delicious Rewards program exceed the cost to us of offering the Delicious Rewards program, including the value of discounts to customer; (3) the value of the insights we are able to create based upon aggregate data; and (4) such other data and/or metrics we may consider relevant to any such calculation. These factors may change over time.
Finally, to the extent that you request the deletion of your personal information, you may not be able to continue to participate in the Delicious Rewards program because we require your personal information to manage your Delicious Rewards program account. You may opt-out of the Delicious Rewards program by contacting us at the address described at the end of this Policy or the Delicious Rewards Program Terms. You may learn more about the Delicious Rewards program by reviewing our Delicious Rewards program Terms above.

Data Security

We take reasonable measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. These measures include physical, technical, and administrative safeguards. However, no data security measures are completely foolproof, and we cannot guarantee the security of your information.

Data Retention

We will retain your personal information for as long as necessary to fulfill the purposes for which it was collected, as described in this Privacy Policy, or as required by law. This may include retaining your information for the duration of your Delicious Rewards membership and for a period thereafter as necessary to administer the program, resolve disputes, and comply with legal obligations.

Cookies and Other Tracking Technologies

Every time you come to the website, our website’s web server automatically collects information, including, in some instances, personal information, through cookies, web beacons, and other similar tracking technologies (collectively “cookies”). Cookies are small text files that are placed on your computer or mobile device when you visit a website. Cookies help the website remember information about your visit, which can make it easier to visit the website again and make the website more useful to you. Some cookies are deleted once you close your browser (session cookies), while other cookies are retained even after you close your browser so that you can be recognized when you return to a website (persistent cookies). More information about cookies and how they work is available at www.allaboutcookies.org. Generally, your email address and all other personal information is collected only when you voluntarily provide that data.

Cookies on our website are generally divided into the following categories:

Cookie Type	Description
Strictly Necessary Cookies	These are cookies that our website needs in order to function and that enable you to move around and use the website and features. Without these essential cookies, the website will not perform as smoothly for you as we would like it to, and we may not be able to provide the website or certain services or features you request. Examples of where these cookies are used include: to determine when you are signed in, to determine when your account has been inactive, and for other troubleshooting and security purposes.
Performance and Functional Cookies	Performance and functional cookies provide us with information regarding how visitors navigate and interact with our website. Such cookies allow us to understand, for example, more about how many visitors we have to our website, how many times they visit us and how many times a user viewed specific pages within our Site. Among other performance and functional cookies, we use Google Analytics cookies for these purposes. For more information about Google Analytics, please refer to “How Google Uses Information From Sites or Apps that Use Our Services,” which can be found at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time.
Targeting Cookies	Targeting cookies may be placed by us or third parties to enable third party ad networks to recognize a unique cookie on your computer or mobile device. The information that is collected and shared by these types of cookies may also be linked to the device identifier of the device you are using to allow us to keep track of all the websites you have visited that are associated with the ad network. This information may be used for the purpose of targeting advertisements on our website and third-party sites based on those interests.

We may use the information collected through cookies and related tracking technologies for the following purposes:

To make our website easier to use and generally improve its performance.
To gather metrics about how you interact with our website.
For security reasons.

To provide personalized content. For example, we may store user preferences, your default language, device and browser information, and your profile information, which includes the level of your usage of the website so we can identify you across devices and personalize the content you see.

To advertise to you via behavioral-based/targeted advertising and allow others to do the same.

Most web browsers automatically accept cookies, but you can usually change your browser settings to prevent this. If you disable cookies, your ability to use some features of the website may be limited. For mobile devices, you may be able to manage certain cookies using your built-in mobile device settings and controls. Any choices concerning cookies are browser and/or device specific. If you clear your cookies from your browser on any of your devices, your choices will need to be reset. You should check how to do this on your device(s) and operating systems.

Some cookie providers may also offer opportunities to control your preferences. To learn how to opt-out of Google Analytics, an Analytics cookie, please visit https://tools.google.com/dlpage/gaoptout.

Some of these cookies may be placed by third party service providers to help determine the effectiveness of our advertising campaigns or email communications. The use of cookies by third-party service providers is within their control and not ours. We do not control their websites or their policies and practices regarding your Personal Information, and you should be aware that different rules might apply to the collection, use or disclosure of your personal information by third parties in connection with their advertisements or promotions and other sites you encounter on the Internet. This Privacy Policy does not cover any use of Personal Information that a third-party service provider may directly collect from you, and we do not undertake to confirm, investigate, or police their practices.

Links to Other Websites and Services

Our Services may contain links to third-party websites and services that are not operated by Culver’s. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party websites or services you visit.

Children's Privacy

Our Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13.

Opt-out Preference Signal (Do Not Track)

Culver’s does not currently recognize Do Not Track signals. However, we recognize commercially reasonable universal preference signals (e.g., Global Privacy Control).

Updates to this Privacy Policy

We may update this Privacy Policy from time to time. The updated Privacy Policy will be effective as of the date posted. We encourage you to review this Privacy Policy periodically for any changes.

Contact Information

If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us at:

Culver Franchising System, LLC
Attn: Marketing Dept.
1240 Water Street
Prairie du Sac, WI 53578

Or by calling Guest Relations at 888-427-6952

Or by submitting your comments here: https://www.contactculvers.com/