Privacy Policy

 

Effective Date: January 1, 2023

 

Inspire Brands, Inc. (the “Company”) provides this Privacy Notice (“Notice”) to explain our practices regarding the collection and use of Personal Information about employees, contractors, and others who work for us (collectively, “Team Members”) and Job Applicants within the context of your employment or job application at Inspire Brands, Inc. and our following brands: Arby’s, Baskin-Robbins, Buffalo Wild Wings, Dunkin’, Jimmy Johns, and Sonic under their respective legal entities. This Notice explains what Personal Information we collect about Team Members and Job Applicants, why we collect it, how we use and share it, and the rights you have relating to your Personal Information under the California Consumer Privacy Act, as modified by the California Privacy Rights Act of 2020 (the “CCPA”) and any other applicable privacy regulation.

 

As used in this Notice, the term “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated.

 

To jump to our Job Applicant Section, please click here.

 

  1. Cookie and Tracking Controls

To learn how to manage how we and our vendors use cookies and other tracking tools, and to read our Do Not Track Policy, click here.

 

  1. How and Why We Collect Your Personal Information

Within the past 12 months, we collected Personal Information about our Team Members as follows:

Category of Personal Information Categories of Sources from which Collected Purposes for Collection / Use
Identifiers including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers •   Directly from you

•   Automatically when you use our electronic systems

•   Created by us (e.g., your username and Company email address)

•   From service providers that help us to run our business

 

•  To communicate with you

•  To assess your eligibility for employment

•  To onboard and enroll you as a Team Member

•  To manage job duties and operate our business

•  To provide compensation and benefits

•  To process reimbursements

•  To comply with applicable laws and regulations

•  To manage the security of our premises and systems

•  To detect and prevent fraud against you and/or us

Personal Information described in Cal. Civ. Code § 1798.80(e), including your name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or other financial information, medical information, or health insurance information •   Directly from you

•   From service providers that help us to run our business

•   From third parties

•  To communicate with you

•  To assess your eligibility for employment

•  To onboard and enroll you as a Team Member

•  To manage job duties and operate our business

•  To provide compensation and benefits

•  To process reimbursements

•  To comply with applicable laws and regulations

•  To manage the security of our premises and systems

•  To detect and prevent fraud against you and/or us

Characteristics of protected classifications under California or federal law, including age and date of birth, race, ancestry, ethnic origin, sex, gender, sexual orientation, gender identity, religion or creed, military or veteran status, medical condition, disability, marital status •   Directly from you

•   From service providers that help us to run our business

•   From third parties

•  To comply with applicable laws and regulations

•  To manage our corporate diversity and inclusion programming

Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies •   Directly from you •  To manage corporate information technology

•  To manage the security of our premises and systems

•  To administer corporate discounts

•  To detect and prevent fraud against you and/or us

•  To process reimbursements

Biometric information, including fingerprints and facial scans, in limited circumstances where you are aware of the collection WE DO NOT COLLECT BIOMETRIC INFORMATION NOT APPLICABLE
Internet or other electronic network activity information, including browsing history, search history, and information regarding your interactions with our websites, applications, or advertisements •   Automatically when you use our electronic systems

•   From service providers that help us to run our business

•   From third parties

•  To manage corporate information technology

•  To manage the security of our premises and systems

•  To manage job duties and operate our business

•  To detect and prevent fraud against you and/or us

Geolocation data, including access-control data based on Team Member badge swipes and location data inferred from your device IP address •   Directly from you

•   Automatically when you use our electronic systems

•   From service providers that help us to run our business

•   Automatically when you use our electronic systems

•   Via access-control systems

•   Through GPS tracking of company vehicles

•  To manage corporate information technology

•  To manage the security of our premises and systems

•  To manage company vehicles

•  To detect and prevent fraud against you and/or us

Audio, electronic, visual, thermal, olfactory, or similar information, including closed-circuit images, photographs and video of you (for ID badges, marketing materials, etc.), and audio recordings as may relate to your job functions •   Directly from you

•   Automatically while you are on Company property or using certain Company devices (e.g., if you answer or place phone calls on a recorded line or use our videoconferencing software)

•  To manage the security of our premises and systems

•  To manage job duties, evaluate performance, and operate our business

Professional or employment-related information, including:

Recruitment information (such as skills, qualifications, references, recommendations, and other information included in a resume, application form, or cover letter)

Background information commonly used for onboarding and security screenings

Team Member profile information (Team Member status, organization information, performance and talent information, employment background, functional experience, leadership experience, honors or awards, timesheets, education, training, professional certifications, evaluations, developmental planning, career interests and development information, and other talent management and team-based assessments)

Compensation, payroll, and benefits information

Medical, parental, family, vacation, and other leave and associated records, including details of the types of and reasons for leave being taken, duration of leave, and leave-related correspondence

Any termination of employment documentation, including resignation letters, dismissal letters, minutes of meetings, settlement agreements and related correspondence

•   Directly from you

•   From service providers that help us to run our business

•   From third parties

•  To assess your eligibility for employment

•  To onboard and enroll you as a Team Member

•  To manage job duties, evaluate performance, and operate our business

•  To provide compensation and benefits

•  To comply with applicable laws and regulations

•  To manage the security of our premises and systems

•  To detect and prevent fraud against you and/or us

Non-public education information, including school(s) attended, grades, transcripts, records of attendance, disciplinary records, and other information relating to your secondary and post-secondary education •   Directly from you

•   From service providers that help us to run our business

•   From third parties

•  To assess your eligibility for employment

•  To onboard and enroll you as a Team Member

Inferences used to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes •   Drawn from the other categories of Personal Information we collect •  To manage job duties, evaluate performance, and operate our business

•  To manage corporate information technology

•  To detect and prevent fraud against you and/or us

 

In addition to the above, we may collect the following information about you, which does not directly fall within the categories listed in the CCPA:

  • Citizenship, immigration, visa status, and work authorization information (including information from related documents, such as your passport, driver’s license, or other identification, proof of residence, and proof of authorization to work in the United States, and documents you provide with your US Citizenship and Immigration Services Form I-9)
  • Emergency contacts/next of kin information, details about your spouse/partner, dependents and beneficiaries (such as their names, ages, titles, relationship to you, addresses, telephone numbers, and email addresses)
  • Languages spoken
  • Criminal records information including results of background checks obtained through government agencies such as the US Federal Bureau of Investigation
  • Withholdings, and tax information (such as information collected on IRS Form W-4 and California Tax Form DE 4)
  • Information about births, adoptions, deaths, child medical support orders, loss of eligibility for medical coverage, and other life events that may trigger an opportunity to modify your benefits elections
  • Information about your health, sickness, and absences (including information regarding your physical and/or mental health, any participation in health and wellness programs, drug and alcohol screening information, medical provider information—for example, if you apply for workers’ compensation—and information about any conditions that may require accommodations within the workplace)
  • Vehicle information (ex. year, make, model, color, and license plate)

Unless otherwise specified, the sources of this Personal Information, the purposes for which we use it, and the categories of persons to which we disclose it are the same as those listed for Professional or Employment-Related Information.

 

  • Our Collection of Sensitive Personal Information

Within the past 12 months, we collected the following categories of Sensitive Personal Information about our Team Members:

Category of Sensitive Personal Information Categories of Sources from which Collected Purposes for Collection / Use
Social security, driver’s license, state identification card, or passport number •   Directly from you

•   From service providers that help us to run our business

•   From third parties

•  To assess your eligibility for employment

•  To onboard and enroll you as a Team Member

•  To provide compensation and benefits

•  To comply with applicable laws and regulations

•  To manage the security of our premises and systems

Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account •   Directly from you

•   Automatically when you use our electronic systems

•  To manage corporate information technology

•  To manage the security of our premises and systems

Precise geolocation (location within a radius of 1,850 feet) •   Directly from you

•   Automatically when you use certain types of electronic systems

•   From service providers that help us to run our business

•   Through GPS tracking of company vehicles

•  To manage corporate information technology

•  To manage the security of our premises and systems

•  To manage company vehicles

Personal Information that reveals a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership •   Directly from you

•   From service providers that help us to run our business

•   From third parties

•   To comply with applicable laws and regulations

•   To manage corporate diversity and inclusion programming

Personal Information collected and analyzed concerning a Team Member’s health •   Directly from you

•   From service providers that help us to run our business

•   From benefits providers

•  To provide benefits

•  To comply with applicable laws and regulations

Personal Information collected and analyzed concerning a Team Member’s sex life or sexual orientation • Directly from you

• From benefits providers

•    To comply with applicable laws and regulations

•    To provide certain benefits

•    To manage our corporate diversity and inclusion programming

 

In addition to the purposes described above, we may use and disclose any category of Personal Information or Sensitive Personal Information we collect to respond to law enforcement requests, or as otherwise required or authorized by applicable law, court order, or governmental regulations; to protect our rights and interests and those of others (including our franchisees); to resolve any disputes; to enforce our terms and policies; and to evaluate or conduct a merger, sale, or other acquisition of some or all of our assets. We also reserve the right to use Personal Information we collect for any other purpose identified in an applicable privacy notice, click-through agreement, or other agreement between you and us, or otherwise with your consent.

We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.

 

  1. How Long We Keep Your Personal Information

We keep the categories of Personal Information described above for as long as is necessary or permitted for the purposes described in this Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:

  • Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
  • Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected;
  • The Personal Information is reasonably necessary to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
  • We are otherwise required or permitted to keep your information by applicable laws or regulations.

Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.

  1. Disclosures of Team Member Personal Information

Within the preceding 12 months, we have not sold or shared for cross-context behavioral advertising the personal information of Team Members that we collect in relation to your employment at Inspire Brands, Inc or related entities. If you also interact with us as a consumer, please review our Brand’s Consumer Privacy Notice for more information about our practices in that context.

The chart below shows the categories of Personal Information we have disclosed to our service providers and contractors for a business or commercial purpose during the last 12 months.

Disclosures for a Business or Commercial Purpose
Category of Personal Information Categories of Recipients to Which the Information Was Disclosed Purposes for Disclosure
Personal Information
Identifiers •   Service providers that help us to run our business

•   Benefits providers

•   To communicate with you

•   To assess your eligibility for employment

•   To onboard and enroll you as a Team Member

•   To manage job duties and operate our business

•   To provide compensation and benefits

•   To process reimbursements

•   To manage corporate information technology

•   To comply with applicable laws and regulations

•   To manage the security of our premises and systems

•   To detect and prevent fraud against you and/or us

Personal Information described in Cal. Civ. Code § 1798.80(e) •   Service providers that help us to run our business

•   Benefits providers

•   To communicate with you

•   To assess your eligibility for employment

•   To onboard and enroll you as a Team Member

•   To manage job duties and operate our business

•   To provide compensation and benefits

•   To process reimbursements

•   To manage corporate information technology

•   To comply with applicable laws and regulations

•   To manage the security of our premises and systems

•   To detect and prevent fraud against you and/or us

Characteristics of protected classifications •   Service providers that help us to run our business •   To comply with applicable laws and regulations

•   For diversity and inclusion programs

 

Commercial information •   Service providers that help us to run our business

•   Benefits providers

•   To manage corporate information technology

•   To manage the security of our premises and systems

•   To administer corporate discounts

•   To detect and prevent fraud against you and/or us

•   To process reimbursements

Internet or other electronic network activity information •   Service providers that help us to run our business •   To manage corporate information technology

•   To manage the security of our premises and systems

•   To manage job duties and operate our business

•   To detect and prevent fraud against you and/or us

Geolocation data •   Service providers that help us to run our business •   To manage corporate information technology

•   To manage the security of our premises and systems

•   To manage company vehicles using GPS tracking

•   To detect and prevent fraud against you and/or us

Professional or employment-related information •   Service providers that help us to run our business

•   Benefits providers

•   To assess your eligibility for employment

•   To onboard and enroll you as a Team Member

•   To manage job duties, evaluate performance, and operate our business

•   To provide compensation and benefits

•   To comply with applicable laws and regulations

•   To manage the security of our premises and system

•   To detect and prevent fraud against you and/or us

Non-public education information •   Service providers that help us to run our business •   To assess your eligibility for employment

•   To onboard and enroll you as a Team Member

Inferences •   Service providers that help us to run our business •   To manage corporate information technology

•   To manage job duties and operate our business

•   To detect and prevent fraud against you and/or us

Sensitive Personal Information
Social security, driver’s license, state identification card, or passport number •   Service providers that help us to run our business

•   Benefits providers

•   To assess your eligibility for employment

•   To onboard and enroll you as a Team Member

•   To provide compensation and benefits

•   To comply with applicable laws and regulations

•   To manage the security of our premises and systems

•   To detect and prevent fraud against you and/or us

 

Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account •   Service providers that help us to run our business •   To manage corporate information technology

•   To manage the security of our premises and systems

Precise geolocation •   Service providers that help us to run our business •   To manage corporate information technology

•   To manage the security of our premises and systems

•   To manage job duties and operate our business

•   To manage company vehicles using GPS tracking

•   To detect and prevent fraud against you and/or us

Personal Information that reveals a Team Member’s racial or ethnic origin, religious or philosophical beliefs, or union membership •   Service providers that help us to run our business

•   Benefits providers

•   To comply with applicable laws and regulations

•   For diversity and inclusion programs

Contents of mail, email, and text messages except those for which we are the intended recipient •   Service providers that help us to run our business •   To manage corporate information technology

•   To manage the security of our premises and systems

•   To detect and prevent fraud against you and/or us

Personal Information collected and analyzed concerning a Team Member’s health •   Service providers that help us to run our business

•   Benefits providers

•   To manage job duties

•   To provide benefits

•   To comply with applicable laws and regulations

 

Personal Information collected and analyzed concerning a Team Member’s sex life or sexual orientation •   Service providers that help us to run our business

•   Benefits providers

•   To comply with applicable laws and regulations

•   To provide certain benefits

•   For diversity and inclusion programs

 

  1. Job Applicant Notice

This section explains our practices regarding the collection of Personal Information through our job application process, including our careers websites. This Notice explains what Personal Information we collect about applicants, why we collect it, how we use and share it, and the rights you have relating to your Personal Information under the California Consumer Privacy Act, as modified by the California Privacy Rights Act of 2020 (the “CCPA”) and other relevant privacy regulations.

 

How and Why We Collect Your Personal Information

 

Category of Personal Information Categories of Sources from which Collected Purposes for Collection / Use
Identifiers including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, driver’s license number, or other similar identifiers Directly from you

Automatically when you use our website

From service providers that help us to run our business

 

To open and maintain your application records

To assess your eligibility for employment

To communicate with you regarding your application

To show you relevant advertisements relating to employment with us

To comply with applicable laws and regulations

To detect and prevent fraud against you and/or us

Personal Information described in Cal. Civ. Code § 1798.80(e), including your name, signature, social security number, address, telephone number, driver’s license or state identification card number, education, employment, and employment history Directly from you

From service providers that help us to run our business

 

To open and maintain your application records

To assess your eligibility for employment

To communicate with you regarding your application

To show you relevant advertisements relating to employment with us

To comply with applicable laws and regulations

To manage the security of our premises and systems

To detect and prevent fraud against you and/or us

Characteristics of protected classifications under California or federal law, including age and date of birth, race, ancestry, ethnic origin, sex, gender, gender identity, military or veteran status, Directly from you

 

To comply with applicable laws and regulations
Internet or other electronic network activity information, including browsing history, search history, and information regarding your interactions with our websites, applications, or advertisements Automatically when you use our website

From service providers that help us to run our business

From third parties

To facilitate your use of our website

To provide you with tailored recommendations, and updates

To show you relevant advertisements relating to employment with us.

To improve our website, set default options, and provide you with a better application experience

To protect the security of our website

To detect and prevent fraud against you and/or us

Geolocation data, including location data inferred from your device IP address Automatically when you use our website

From service providers that help us to run our business

From third parties

To provide you with tailored recommendations, and updates

To show you relevant advertisements relating to employment with us

To improve our website, set default options, and provide you with a better application experience

To protect the security of our website

To detect and prevent fraud against you and/or us

Professional or employment-related information, including:

Skills, qualifications, work experience, references, recommendations, and other information included in a resume, CV, application form, or cover letter;

Answers to behavioral or other screening questions in an application or interview;

Information contained in any personal webpages or documents you choose to share with us;

Information relating to professional licenses, training, disciplinary actions, and membership in professional organizations;

Information relating to membership in civic organizations

Directly from you

From service providers that help us to run our business

From third parties

To open and maintain your application records

To assess your eligibility for employment

To show you relevant advertisements relating to employment with us

To comply with applicable laws and regulations

To detect and prevent fraud against you and/or us

Non-public education information, including school(s) attended, grades, transcripts, records of attendance, disciplinary records, and other information relating to your secondary and post-secondary education Directly from you

From service providers that help us to run our business

From third parties

To open and maintain your application records

To assess your eligibility for employment

To comply with applicable laws and regulations

 

We may collect the following information about you, which does not directly fall within the categories listed above:

  • Citizenship, immigration, visa status, and work authorization information (including information from related documents, such as your passport, driver’s license, or other identification, proof of residence, and proof of authorization to work in the United States, and documents you provide with your US Citizenship and Immigration Services Form I-9)
  • Languages spoken
  • Criminal records information including results of background checks obtained through government agencies such as the US Federal Bureau of Investigation
  • Drug screening information

Unless otherwise specified, the sources of this Personal Information, the purposes for which we use it, and the categories of persons to which we disclose it are the same as those listed for Professional or Employment-Related Information.

Our Collection of Sensitive Personal Information of Job Applicants

 

Category of Sensitive Personal Information Categories of Sources from which Collected Purposes for Collection / Use
Social security, driver’s license, state or identification card Directly from you

From service providers that help us to run our business

From third parties

To assess your eligibility for employment

To comply with applicable laws and regulations

To manage the security of our premises and systems

Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account Directly from you

 

To open and maintain your application records

To manage the security of our premises and systems

To detect and prevent fraud against you and/or us

Personal Information that reveals a job applicant’s racial or ethnic origin, religious or philosophical beliefs, or union membership Directly from you To comply with applicable laws and regulations
Personal Information collected and analyzed concerning a job applicant’s health (i.e., drug-screening information) Directly from you

From service providers that help us to run our business

To assess your eligibility for employment
Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation Directly from you To comply with applicable laws and regulations

 

 

In addition to the purposes described above, we may use and disclose any category of Personal Information or Sensitive Personal Information we collect to respond to law enforcement requests, or as otherwise required or authorized by applicable law, court order, or governmental regulations; to protect our rights and interests and those of others (including our franchisees); to resolve any disputes; to enforce our terms and policies; and to evaluate or conduct a merger, sale, or other acquisition of some or all of our assets. We also reserve the right to use Personal Information we collect for any other purpose identified in an applicable privacy notice, click-through agreement, or other agreement between you and us, or otherwise with your consent.

We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.

 

  • Submitting Requests Relating to Your Personal Information

If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To exercise any of these rights, please submit a request through emailing HRSolutionscenter@inspirebrands.com or call us at 1-866-657-6642 Please note that, if you submit a request to know, request to delete or request to correct, you will be asked to log into your account or to provide 2-3 pieces of Personal Information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. An authorized agent may submit a request on your behalf using the webform or toll-free number listed above.

Right to Know. You have the right to know what Personal Information we have collected about you, which includes:

  • The categories of Personal Information we have collected about you, including
    1. The categories of sources from which the Personal Information was collected
    2. Our business or commercial purposes for collecting or disclosing Personal Information
    3. The categories of recipients to which we disclose Personal Information
    4. The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information
  • The specific pieces of Personal Information we have collected about you

Right to Delete Your Personal Information. You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions. Where we use deidentification to satisfy a deletion request, we commit to maintaining and using the information in deidentified form and will not to attempt to reidentify the information.

Right to Correct Inaccurate Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.

Rights Related to Automated Decision-Making. You have the right to opt out of automated decision-making, including profiling, that we use to evaluate certain personal aspects relating to your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.  

Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us, including retaliation against you as a Team Member, job applicant, or independent contractor.

  • Reasonable Security Measures

The Internet is not 100% secure. We cannot promise that your use of our sites or apps will be completely safe. We encourage you to use caution when using the Internet. This includes not sharing your passwords.

 

  1. We Store Information in the United States

If you live outside of the United States, you understand and agree that we may transfer your information to the United States. This site is subject to U.S. laws, which may not afford the same level of protection as those in your country.

 

  1. Third Party Sites and Links

If you click on a link to a third party site, you will be taken to websites we do not control. This includes our pages on social media sites. This policy does not apply to the privacy practices of these websites. Read the privacy policy of other websites carefully. We are not responsible for these third party practices.

  1. Information Collection from Children

 

Our sites and apps are meant for adults. We do not knowingly collect personally identifiable information from children under 13 without permission from a parent or guardian. If you are a parent or legal guardian and think your child under 13 has given us information, you can email us. You can also write to us at the address listed at the end of this policy. Please mark your inquiries “COPPA Information Request.” Parents, you can learn more about how to protect children’s privacy on-line here.

  • Policy Updates

We may make changes or updates to this Policy. We will notify you of any material changes to this Policy as required by law. All changes will also be posted on our website. Please check our site periodically for updates.

 

  • How to Contact Us

If you have any questions about how Inspire Brands handles your Personal Information or if you need to access this notice in an alternative format or language, please contact our Human Resources Department at:

Phone: 1-866-657-6642

Email: HRSolutionscenter@inspirebrands.com

Last Updated: January 1, 2023