Effective: July 1, 2022
Acknowledgement of Terms
By accessing or using our Site, making a transaction with us, or otherwise providing information to us, you agree to the terms of the most recent version of this Policy then in effect and posted on our Site. We reserve the right, at our sole discretion, to change, modify, add or remove portions of this Policy at any time. If this Policy changes in the future, we will let you know by posting the updated policy on our Site with the most recent modification date. Please check this page periodically for changes. Your continued use of our Site, our mobile app, our any rewards programs, or contacting our guest services center, means you acknowledge and understand our current and updated Policy.
What Information We Collect and How We Use It
Visitors to our Site are not required to register or provide information to us in registering, making a purchase or otherwise providing personal information through our Site. We do not knowingly collect personal information on individuals under the age of 16 without parental consent. If you believe personal information was provided to us by someone under 16, please contact us immediately at email@example.com.
If you choose to establish a Naughty Gull account, you will be required to provide some information, such as your name, address, phone number, email address, username and password, and you will have the option to provide additional information and set preferences. We use the information you supply for the purpose of providing the services you have requested, and as described in this Policy. In addition, we may from time to time contact you via email or regular mail about new products, services, content, or information that we think may be of interest to you. You can opt-out of certain communications by following the instructions in the "Opting Out" section of this Policy.
If you shop with us, you will need to provide your name, address, phone number(s), email address, billing information (including credit/debit card number and expiration date), and, if applicable, the names, addresses, and phone numbers of gift recipients. We use this information to process and fulfill your order or as otherwise described in this Policy. We may contact gift recipients, using the information you provide regarding new products and services that we think may be of interest to them. Gift recipients may opt out of certain communications as described in the "Opting Out" section below.
You will have the option to provide other information to us, such as your date of birth, your favorite store, ordering preferences or favorites, allergen or other dietary information, or other information that you choose to provide. We may use this information, including information that personally identifies or reasonably could identify you ("personal information"), collected by or provided through the Site to improve our services, products, and operations; customize content and experiences on our Site; perform statistical, demographic and marketing analysis, fulfill orders and other requests for products or services; contact you about our products, services and events; provide you with information that you have requested or that we think may be of interest to you; or for other business operations and support.
In certain instances, we may use or disclose your personal information to identify, contact or bring legal action against persons or entities who may be causing injury to you, Naughty Gull, or others; detect, investigate, and prevent fraud and other unlawful activities; protect and defend ourselves, our property, our employees, our customers, and our users; conform to applicable law or comply with our legal requirements or legal process served on us or the Site; or act under emergency circumstances to protect the personal safety of us, our affiliates, agents, or the users of the Site or the public. In the event of a merger, consolidation, sale, or transfer of all or substantially all of our company or its assets, information collected by our Site may be transferred to the purchaser or the new company. Under such circumstances we would, to the extent possible, require the acquiring party to follow the practices described in this Policy, as it may be amended from time to time. Nevertheless, we cannot promise that an acquiring company or the merged company will have the same privacy practices or treat your information the same as described in this Policy.
We may use or disclose information that does not directly identify you including, but not limited to, aggregate data about your use of the Site or our services in any manner we deem appropriate or necessary.
When you interact with any of our social media accounts or pages, we may collect personal information that you provide or make available through that page or site. The social media site's privacy policies will apply to the collection, storage, and sharing of information on through the social media site. If you choose to link or login to your Naughty Gull account with or through a social networking service, Naughty Gull and that service may share certain information about you and your activities. With your consent, we also may share information about your activities, including what you view on the Site, with that social network's users.
When you download or access certain features of the Site, such as our mobile application, we may collect information about your location. You can change when we collect location information about you in your device's settings. We may use your location information to provide you with information on products and services that you request, including processing your orders and sending you information about your orders, and personalize content and experiences on our Site, including providing you with recommendations, information, and offers about our products and services. We also may use your location information to optimize or improve our products, services, and operations, perform statistical, demographic, and marketing analyses, and detect, investigate, and prevent activities that may violate our policies or be illegal.
We may use third-party analytical tools, including Google Analytics, a web analytics service provided by Google, Inc. ("Google"), to help us better understand how you use our Site. These analytical tools will place cookies or other tracking technology on your computer or device to collect information about your activity related to, and usage of, the Site. The information collected by these analytical tools will tell us things like which search engine referred you to our Site, how you navigated around our Site, what you purchased, and other information related to the Site activity and usage. This information will help us to better serve you with more personalized information and product offerings. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor and any referring website. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google's privacy policies.
In the event a third-party provider of analytical tools will have access to personal information, such as your name, address, phone number or precise location, we contractually require such third-party provider to limit its use of information to perform services for us and to maintain all of the information it collects and analyzes for us securely and in confidence. Such third parties may not share your information with anyone else, or use it for any other purpose, except on an aggregated basis.
We also may partner with third-party advertising companies who may utilize cookies or other tracking technologies, to collect information about you when you use the Site. These cookies and other technologies are used to provide advertisements about goods and services that may be of interest to you. These third parties may collect information about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based advertising or other targeted content. These partners do not have access to or use your name, address, email address, telephone number or other personally identifiable information from us, without your consent. They may, however, use persistent identifiers to anonymously track your Internet usage across other websites in their networks beyond our Site. Such third parties may, with sufficient data from other sources, be able to personally identify you. If you have any questions about an advertisement or other targeted content, you should contact the responsible advertiser directly.
Accessing Your Account Information
After setting up an account with Naughty Gull, you can access, review, correct and/or delete the personal information saved in your account. You may also ask us to assist by emailing us at firstname.lastname@example.org.
Sharing Your Information
We do not sell your personal information to other companies.
Our Site is not intended for children under the age of 16. We will not request information from anyone that we know is under the age of 16 without verifiable parental consent. By using our site or mobile app you are warranting you are at least 16 years of age. If we become aware that a guest is under the age of 16 and has registered without parental contest, then we will remove their information. Additionally, you must be 18 years old to register or create an account with us without parental consent. By personally creating an account with us, you represent you are at least 18 years old.
Links to Other Sites
California and Other State Law Privacy Rights
Persons with disabilities may obtain this notice in alternative format upon request by contacting us at email@example.com.
California Shine the Light
Residents of the State of California and certain other states have the right to request information from Naughty Gull regarding other companies to whom the company has disclosed certain categories of information during the preceding year for those companies' direct marketing purposes. If you are a resident of such states and would like to make such a request, please email firstname.lastname@example.org or write to us at Naughty Gull, 420 Hudson St, New York, NY 10014.
California Consumer Privacy Act
The California Consumer Privacy Act ("CCPA") and certain other states provide their residents with rights to receive certain disclosures regarding the collection, use, and sharing of personal information. Certain information we collect may be exempt from these state laws because it is considered public information (i.e., it is made available by a government entity) or covered by a specific federal privacy law. To the extent that we collect personal information that is subject to the CCPA or other state laws, such information, our practices and your rights are described below.
Right to Notice Regarding the Categories of Personal Information Collected
You have the right to receive notice of the categories of personal information we collect, and the purposes for which those categories of personal information will be used. The categories we use to describe the information are as follows:
- We may collect your name, phone number, and email address and contact address when you create an account or complete a transaction. If you choose to create an account, you will also be asked to create a username, and we will assign one or more unique identifiers to your profile. We use this information to provide the Site, respond to your requests, and send information and advertisements to you.
- We may collect your social media handle and basic account information when you interact with our Site through social media.
- We may collect a unique numerical identifier, assigned to you by a first party cookie, automatically when you use our Site in order to identify you, provide the Site, keep you logged in to the Site, prevent fraud, and provide you with targeted information and offers.
- We may collect your IP address automatically when you use our Site. We use this information to identify you, gauge online activity on our website, measure the effectiveness of online Site, applications, and tools, and serve targeted advertisements based on your online activities.
- We may collect your Device ID automatically when you use our Site. We use this information to monitor your use and the effectiveness of our Site, to identify you, and to provide you with targeted information and offers.
- We may collect the names, addresses, and phone numbers of gift recipient when you provide it to us upon purchase of a gift card or other similar gift.
Protected Classifications: We may collect your age in order to comply with laws that restrict collection and disclosure of personal information belonging to minors.
We may collect payment information when you provide it to us, which may include your credit card number or a bank account number, when you complete a transaction. You have the option to store this information to your account or set up a recurring transaction. We use this information to streamline and facilitate payments and transactions. When you engage in transactions with us, we may create records of goods or services purchased or considered, as well as purchasing or consuming histories or tendencies. We use this information to measure the effectiveness of our Site and to provide you with targeted information, advertisements and offers.
Internet or Other Electronic Network Activity Information: We may collect information about your browsing history, search history, information regarding your interaction with websites, and applications or advertisements automatically when you utilize our Site. We use this information to gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and to serve targeted advertisements based on your online activities
Geolocation Data: As described above, we may collect your IP address or device identifier automatically when you use our Site or apps. We may be able to determine your location based on the IP address. When you use our app, we may collect your precise location (e.g., your GPS coordinates). With your permission, we use and analyze your location information we collect from you and your device to (1) respond to your requests to find nearby restaurants; (2) confirm the restaurant location for your mobile orders; (3) offer promotions; and/or (4) manage online delivery and pickup.
Audio, electronic, visual, thermal, olfactory, or similar information: If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of the call. We may collect your photographic or video image when you visit one of our locations. We use this information to monitor our customer service, maintain the security of our systems and physical locations, and train employees.
Professional or employment-related information: We may collect information about your current employer, your employment history and other background information if you apply for a job with us. We may use this information to conduct background and other screening activities.
Education information: We may collect information about the institutions you have attended and the level of education you have attained if you apply for a job with us. We may use this information to conduct background and other screening activities.
Inferences drawn to create a profile about a consumer reflecting the consumer's preferences or characteristics: We may collect your date of birth and other information about your preferences when you provide it to us, such as your favorite store, ordering preferences or favorites, allergen or other dietary information, or other information that you may choose to provide. We use this information to respond to your requests, improve the Site, and send information and advertisements to you. We may analyze your actual or likely preferences through a series of computer processes. On some occasions, we may add our observations to your internal profile. We use this information to gauge and develop our marketing activities, measure the appeal and effectiveness of our Site, applications, and tools, and to provide you with targeted information, advertisements, and offers. We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the personal information was collected.
We may share any of the above-listed information with service providers, which are companies that we engage for business purposes to conduct activities on our behalf. Service providers are restricted from using personal information for any purpose that is not related to our engagement. The categories of service providers with whom we share information include agencies that administer consumer promotions, analyze data, process and fulfill orders you place, and provide customer services.
Right to Know/Access Information
You have the right to request access to personal information collected about you and information regarding the source of that information, the purpose for which we collect it, and the third parties, any service providers with whom we share it. You may submit such a request as described below. To protect our customers' personal information, we are required to verify your identity before we can act on your request.
Right to Request Deletion of Information
You have the right to request in certain circumstances that we delete any personal information that we have collected directly from you. You may submit such a request as described below. To protect our customers' personal information, we are required to verify your identity before we can act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
How to Submit a Request
You may submit a request to exercise your rights to know/access or delete your personal information by emailing us at email@example.com.
In order to process your request to know/access or delete personal information we collect, disclose, or sell, we must verify your request. We do this by:
Asking you to:
- Provide personal identifiers we can match against information we may have collected from you previously; and / or,
- Confirm your request using the email or telephone account stated in the request.
You may authorize another individual or a business registered with applicable state laws such as the CCPA, called an authorized agent, to complete a notarized affidavit in order to verify the identity of the authorized agent and confirm that you have authorized them to act on your behalf. Parents of minor children may submit a birth certificate in lieu of an affidavit, in order to make requests on the child's behalf.
Right to Information Regarding Financial Incentives
You have the right to be free from discrimination based on your exercise of your CCPA or other state privacy law rights. We may run promotions from time to time whereby we incentivize a consumer to share certain pieces of personal information with us. For example, we may offer a one-time discount if consumers sign up for our email marketing list. Participation in these incentives is voluntary, and in order for us to use your personal information, you shall be required to opt in and consent at the time of sign-up to permit the sale, transfer for value or retention of such information.
You may ask questions, submit comments and opt out of receiving updates and other mailings from us by contacting us via email at firstname.lastname@example.org or regular mail at Naughty Gull, 420 Hudson St, New York, NY 10014
Last Updated July 1, 2022