Privacy Policy – updated

Sweetgreen, Inc.

PRIVACY POLICY

Effective Date: February 19, 2019

This privacy policy will be effective on February 19, 2019.  Please see here for our privacy policy in effect prior to February 19, 2019.

Sweetgreen, Inc. (“Company,” “ Sweetgreen,” “We,” or “Us”) has prepared this Privacy Policy to describe our practices regarding the personal information we collect through our websites and digital platforms, including electronic kiosks at Sweetgreen restaurant locations (collectively, “Site”), our mobile applications (collectively, “Application”), and the services we provide through the Site and Application (collectively, with the Site and Application, the “ Services”).

If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any suspected security violations to us, please contact us at privacy@sweetgreen.com .

A Note About Children. We do not intentionally gather personal information online from visitors who are under the age of 13. If a child under 13 submits personal information to Company online and we learn that the personal information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any personal information collected online from a child under 13, please contact us at privacy@sweetgreen.com .

Your California Privacy Rights. If you are a user of the Services and a California resident, California’s “Shine the Light” law (California Civil Code § 1798.83) permits you to request and obtain from us once a year, free of charge, information regarding our disclosure of your personal information (if any) to third parties for their direct marketing purposes. If this law applies to you and you would like to make such a request, please submit your request in writing to privacy@sweetgreen.com.

A Note to Users Outside of the United States . If you are a non-U.S. user of the Services, by using our Services and providing us with data, you acknowledge and agree that your personal information may be processed for the purposes identified in the Privacy Policy. In addition, your personal information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of personal information may be less stringent than the laws in your country. By providing your data, you consent to such transfer and processing.

1. Types of Data We Collect .

(a) Personal Information You Provide to Us.

  • We will collect personal information you submit when you create an account on our Services, including your first and last name, e-mail address, phone number, and password (“Account”).
  • When you place an order through the Services for delivery or to pick up in one of our restaurants, we collect information necessary to process your order.
  • We retain information about your transactions with us, such as the details of past orders placed through your Account.
  • If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail.
  • We may also collect personal information at other points in our Services that indicate that personal information is being collected.

(b) Information Collected via Technology.

  • Information Collected by Our Servers . Our servers (which may be hosted by a third-party service provider) may collect information automatically from your computer or device, including but not limited to:
    • The date and time of your visit, the pages and content you view, and links you click on while navigating within our Services;
    • Information about the type of content accessed via our Services;
    • The site you visited before and after visiting our Site;
    • Your Internet Protocol (IP) address (a numerical address assigned to your computer by your Internet service provider so that other computers connected to the Internet can communicate with your browser online) that can sometimes be used to derive your general geographic area;
    • Search terms you enter using our Services or on a referral site;
    • Unique identifiers, including non-global mobile device identification numbers;
    • Information about your device such as your device type, screen size, browser type, language and other settings, memory capacity, plug-ins, Internet domain, TCP configuration parameters, operating system, carrier code, time zone and the names, versions and package IDs of software installed on your device; and
    • Information collected through cookies, pixel tags and other tracking technologies (see additional descriptions of these terms below).
  • Cookies . Like many online services, we use cookies to collect information. “ Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.
  • Pixel Tags . In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages and e-mail messages. We may use Pixel Tags to collect information about your interactions with our email messages, such as the links you click on and whether you open or forward a message, the date and time of these interactions and the device you use to read emails.
  • Analytics . We use third-party analytics services including Google Analytics (“ Analytics Services”), to help analyze how users use our Site. The information generated by the Cookies or other technologies about your use of our Site (the “ Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer the Analytics Information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Service’s ability to use and share Analytics Information is restricted by such Analytics Service’s terms of use and privacy policy. By using our Site, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. For a full list of Analytics Services, please contact us at privacy@sweetgreen.com. To learn more about how Google uses data, visit www.google.com/policies/privacy/partners/.
  • Location Information . If you tell us where you are (e.g., by allowing your mobile device to send us your location), we may store and use that information to provide you with location-based information and advertising.

(c) Information Collected from Third Party Companies. We may receive personal information and/or anonymous data about you from companies that help provide our Services, including LevelUp, the provider of our mobile Application. We may also receive personal information and/or anonymous data from other third parties, including but not limited to companies that have entered into joint marketing relationships or other joint ventures with us. We may combine any information about you that we receive from third parties with information we have already collected from you via our Services and use that combined information pursuant to this Privacy Policy.

(d) Information Collected from Social Networking Sites. If you communicate with us or mention us via Social Network Sites (“SNSs”) (e.g., Facebook or Twitter), we may collect the communications, your name, your user ID and/or user name associated with that SNS, any information or content you have permitted the SNS to share with us, such as your profile picture, email address and any information you have made public in connection with that SNS. You should check your privacy settings on your SNSs to understand and change the information sent to us through these services.

(e) Referral Information Collected from You. If you decide to invite a third party to create an Account, we will collect your and the third party’s name and e-mail address in order to send an e-mail and follow up with the third party. You or the third party may contact us at privacy@sweetgreen.com to request the removal of this information from our database. As part of your use of the Services, we may provide you the opportunity to connect automatically with your friends through the use of contact importer tools. If you elect to use these tools, we will access information regarding your friends to facilitate automatic connection with your friends.

2. Use of Your Personal Information .

(a) General Use. In general, personal information we collect is used to respond to requests that you make, improve our Services, aid us in serving you better, or inform you of offers we believe may be of interest to you. Your personal information is used to:

  • Create and administer your Account;
  • Fulfill your orders, including by communicating them to our local stores, delivery networks and other service providers and by providing you with receipts, order confirmations and pickup instructions;
  • Provide you with offers and promotions from Sweetgreen, our Affiliates, joint venture partners and other companies that offer products or services that may be of interest to you;
  • Provide you with Services and customer support, including administering your participation in our Sweetgreen Rewards Program and any other promotional programs we may provide;
  • Provide improved administration of our Services;
  • Measure and analyze audience traffic and improve the quality of your experience when you interact with our Services;
  • Respond to your requests, resolve disputes and/or troubleshoot problems;
  • Tailor the features and content of the Services to you and customize the offers and advertising you see in our Services and other websites, apps and e-mail programs you may use;
  • Evaluate and improve our Services and develop new products and services;
  • Communicate with you about the Services, including sending you welcome e-mails such as when you create an Account or join our Rewards Program, offers for products and services you may be interested in, and administrative e-mail notifications such as security or support and maintenance advisories;
  • Prevent potentially prohibited or illegal activities, comply with applicable law, and enforce the terms of any agreements we may have with you, including our Terms of Use Agreement; and
  • For any other purposes disclosed to you in this Privacy Policy or at the time we collect your information or pursuant to your consent.

(b) Creation of Anonymous Data. We may create anonymous data records from personal information by excluding information (such as your name) that makes the data personally identifiable to you. We reserve the right to use anonymous data for any purpose and disclose anonymous data to any third parties in our sole discretion.

(c) Advertising. We may work with third parties, including Google Analytics and Facebook Pixel, for the purpose of advertisement delivery, including online behavioral advertising and multi-site advertising. Information about your use of the Services may be used by third parties in order to provide advertisements about goods and services of interest to you. To assist with advertisement delivery services, these third parties may also set cookies or web beacons that collect your information across the Services and other sites and applications over time to deliver advertisements that they believe will be of most interest to you. If you would like to obtain more information about these practices, please visit http://www.networkadvertising.org/choices/ or http://www.aboutads.info/choices/ . To learn more about how Google uses data, visit www.google.com/policies/privacy/partners/ . To learn more about how Facebook uses data, visit https://www.facebook.com/privacy/explanation . If you would like to opt out of targeted advertising from participating advertisers, please see Section 6 below.

(d) Text Messaging. Subject to your opt-out choices described below, if you provide your mobile telephone number to Sweetgreen when creating or updating your account, or if you send us a text message, you agree that we and our representatives may use your number to send you text messages, including via automatic telephone dialing equipment, to communicate with you about your orders or for any customer service, account-related or marketing purpose. If you do not wish to receive marketing calls or texts messages from us, you can opt out by emailing your request and telephone number to privacy@sweetgreen.com. If you choose to provide a mobile telephone number when ordering through an electronic kiosk at a Sweetgreen location, you agree that we may use your number to text you to confirm, process, and notify you about the status and pickup location of your order, provide you with a receipt, or otherwise communicate with you about your order.

3. Disclosure of Your Personal Information. We may disclose your personal information as described below and as described elsewhere in this Privacy Policy.

(a) Users. When you post comments on our Services, you will be identified by your first name, last name, and/or user handle. Please note that any personal information you include on a public area of the Services will be publicly viewable. Once displayed publicly, that information can be collected and used by others. We cannot control who reads your postings or what other users may do with the information that you voluntarily post, so it is very important that you do not put data such as private contact information which you do not want to make available to the public in your posts. Once you have posted information publicly, while you will still be able to edit and delete it on the Services, you will not be able to edit or delete such information cached, collected, and stored elsewhere by others (e.g., search engines).

(b) Third Parties Designated by You. When you use the Services, the personal information you provide will be shared with any third parties that you authorize to receive such information.

(c) Third Party Service Providers. We may share your personal information with vendors, business partners, subcontractors and third party service providers that help us provide the Services.

(d) Affiliates. We may share some or all of your personal information with our parent company, subsidiaries, and other companies under common ownership or control with us (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.

(e) Joint Marketing Partners and Joint Ventures. We may also share any personal information we collect with third party companies that have entered into joint marketing collaborations or other joint ventures with us, which may use and share such information pursuant to its own Privacy Policy. Please contact us at privacy@sweetgreen.com for further information regarding such third party companies and their privacy policies.

(f) Corporate Restructuring. We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Privacy Policy.

(g) Social Networking Sites. Some of our Services may enable you to post content to SNSs (e.g., Facebook or Twitter). If you choose to do this, we will provide information to such SNSs in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policy of the third party provider of such SNSs. We will not be responsible or liable for: (i) the availability or accuracy of such SNSs; (ii) the content, products or services on or availability of such SNSs; or (iii) your use of any such SNSs.

(h) Other Disclosures . Regardless of any choices you make regarding your personal information (as described below), Sweetgreen may disclose personal information if it believes in good faith that such disclosure is appropriate (a) in connection with any legal investigation or proceeding; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Sweetgreen; (c) to protect or defend the rights or property of Sweetgreen, its affiliates, its business partners, or its users; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, our applicable Terms of Use Agreement, or any other contractual arrangement.

4. Third-Party Payment Processing. For online payments and/or Automated Clearing House (ACH) payouts, we use the payment services of SCVNGR, Inc. doing business as LevelUp ( www.thelevelup.com) and Chase Paymentech. To simplify the ordering process for you on your next order, we save the last four digits of your credit card, the expiration date of your credit card, the credit card type, your first and last name, and a token identifier to match your information to your full credit card number, which is stored by our service providers. We do not store your full credit card number or your CVV2 number (the 3 to 4 digit security code on your card). We do not have access to your full credit card number stored by our service providers. For more information on how payments are handled, and to understand the data security and privacy protections afforded to such information, please refer to the LevelUp Privacy Policy ( https://www.thelevelup.com/privacy ) and the Chase Merchant Services Privacy Statement ( https://merchantservices.chase.com/privacy-statement ).

5. Third Party Websites. Our Site may contain links to third-party websites. When you click on a link to any other website, you will leave our Site and go to another site, and another entity may collect personal information or anonymous data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites, or to any collection of your personal information after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third-party websites are for your convenience and do not signify our endorsement of such third parties or their products, content or services.

6. Your Choices Regarding Your Information. You have several choices regarding use of information on our Services:

(a) Email Communications. When you create an Account and provide your email address, we will periodically send you administrative e-mails, free newsletters, and e-mails that directly promote the use of our and our business partners’ products and services. When you receive newsletters or promotional communications from Sweetgreen, you may indicate a preference to stop receiving further communications from Sweetgreen and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly at privacy@sweetgreen.com. Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Use Agreement or Privacy Policy. Any e-mails you receive from our business partners will be subject to such third party’s privacy policy.

(b) Text Messages. To stop receiving text messages from a short code operated by Sweetgreen, reply STOP to any message you receive from such short code. Note that we may send you a message to confirm receipt of your STOP request. You can also opt-out of Sweetgreen marketing texts by emailing us your request and mobile telephone number to privacy@sweetgreen.com.

(c) Google Analytics. You may prevent your data from being collected and used by Google Analytics by opting out through the use of the Google Analytics Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout/.

(d) Facebook Pixel. You may opt-out of data collection and use by Facebook Pixel by visiting http://www.aboutads.info/choices.

(e) Other Targeted Advertising. If you would like to opt out of targeted advertising from participating advertisers, please visit http://www.networkadvertising.org/choices/ or http://www.aboutads.info/choices/ .

(f) Cookies. If you decide at any time that you no longer wish to accept cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser’s technical information. If you do not accept cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify cookies, please let us know at the contact information provided below.

(g) Location Information. You can deactivate location access on your mobile device.

(h) SNS. Please refer to the privacy settings of the SNS to determine how you may adjust our permissions and manage the interactivity between the Services and your SNS account.

(i) Changing or Deleting Your Personal Information. You may review, update, correct or delete the personal information stored in your Account by editing your personal information in your Account settings or by contacting us. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes. Please remember, however, if we have already disclosed some of your personal information to third parties, we cannot access that personal information any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.

7. Do Not Track. We do not currently respond to “do not track” signals from web browsers.

8. Security of Your Personal Information. We use a variety of security technologies and procedures to help protect your personal information from authorized use, access, and disclosure. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee the absolute security of your personal information.

9. Changes to This Privacy Policy. This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy at http://sweetgreen.com/privacy-policy and we will change the “Last Updated” date above. You should consult this Privacy Policy regularly for any changes.