International Prospective Franchisee Privacy Notice

Last Updated: 21 October 2022

Little Caesar Enterprises, Inc. values the privacy of your personal data. This privacy notice (“Privacy Notice”) describes how we collect, use, and disclose your personal data collected and applies to personal data you provide on international.littlecaesars.com, at trade shows, through electronic communications and interactions with us, and as part of the process of learning about and/or applying for a Little Caesars® franchise, as well as data about you that we obtain from third parties (“Applicable Activities”). This Privacy Notice also describes the rights you have to your personal data.

Please note that this Privacy Notice only applies to the Applicable Activities stated above, and different privacy notices and practices may apply to personal data processed under a franchise agreement.

Little Caesar Enterprises, Inc. is the controller of personal data that is processed through the Applicable Activities. In this Privacy Notice, “Little Caesars,” “we,” “our,” or “us” means Little Caesar Enterprises, Inc. You can contact our Data Protection Officer with questions about this Privacy Notice the following ways:

Email: [email protected]

Postal Mail:
Little Caesar Enterprises, Inc.
c/o Legal Department, Data Protection Officer 2125 Woodward Ave.
Detroit, Michigan 48201
USA

Information We Collect

The personal data we collect depends on how you interact with us. This section describes the personal data we collect through those interactions.

Little Caesars International Franchisee Website

There are a few ways we collect personal data through the website:

  • Interest Form: We collect your first and last name, telephone number, email address, and country. Per our franchisee assessment process, we also ask you to confirm you have the minimum liquidity to qualify as a franchisee.
  • Email: If you email us via the website, the local email application on your device will open. At a minimum, we collect the email address used to contact us and the contents of your communications with us. We also collect any additional personal data you choose to include in your email.
  • Webinar Registration: We collect your first and last name and email address.

Trade Shows and In-Person Interactions

If you interact with us at trade shows or through in-person interactions, we may collect your contact information, including first and last name, email address, mailing address, telephone number, and country. We also collect any additional personal data you choose to leave with us.

If you provide us with a business card, we collect any additional information you provide on your business card. Additionally, if you have consented to third-party trade show or event organizers to share your personal data with us, we collect the personal data you have agreed to share via these third- party organizers.

Social Media Websites

On social media or social networking websites, we collect your name or username/handle and the contents of your communications with us. We may also process information you make publicly available on your social media sites.

Direct Email and Other Communications

We collect your first and last name, email address, the contents of your communications with us, and any additional personal data you choose to share with us.

If you reach out to us through our customer support channels or via telephone, we collect the necessary personal data to respond to your request (your first and last name, contact details, and the purpose for your outreach). We also collect any additional information you choose to share with us.

Franchisee Application Process

Before completing the full franchisee application, we ask you to provide your identification documentation, which will vary by jurisdiction depending upon applicable law. Examples of identification documentation include drivers’ license, passport, national identification number, social security number or other government issued identification document. We collect this information to comply with United States federal laws regarding doing business with foreign nationals. Additionally, we ask you to provide the incorporation papers of your business bank and/or brokerage statements, and similar documents evidencing your liquidity and net worth.

If you complete the franchisee application, we collect your first and last name, as well as basic contact information, descriptions of business experience, financial qualifications, and countries and locations of interest for operating Little Caesars® stores. We also ask you to provide information about your franchising experience and additional details regarding your business entity, business partners, and proposed business plans. Lastly, we ask you to provide general background check information, including any legal proceedings against you.

You also have the option of providing additional information regarding your business entity, your education experience, your interest in a Little Caesars franchise, and general information about your proposed franchise market. This information is not required as part of the franchisee application.

We ask the person completing the application on behalf of a corporation to provide the names of any partners or officers in the corporation. In such circumstances, we collect your name, and any other personal data shared by the individual completing the franchisee application for the corporation, from someone other than yourself.

Third Parties

We also collect your personal data from third parties we have engaged to provide services to us.

  • Background Check Vendor: After obtaining your consent to complete a background check, our background check provider will review and confirm the information you provided. As part of this process, the background check provider may provide additional information about you available through public sources or records.
  • Lead Generation Services: With your consent, lead generation services provide us with your first and last name, email address, phone number, location and/or country, job title, company, and LinkedIn URL.
  • Brokers: If a broker contacts you on our behalf, the broker will collect some or all of the information described in the Franchise Application Process above, including your first and last name and business and financial information.

How We Use Personal Data

We use your personal data for business and commercial purposes, including to respond to requests made by you, to evaluate your eligibility to become a franchisee, to ensure security and prevent fraud, and for marketing and advertising purposes. This section describes the legal bases we use to process your personal data and the purposes for which we process your personal data.

Consent

In certain circumstances, we ask for your consent prior to processing your personal data. We process your personal data to:

  • contact you regarding franchising opportunities and
  • promote our franchising activities, including sending marketing materials and invitations to
    events.

You can withdraw your consent at any time by contacting us as described in the Contact section below. Withdrawing your consent will not affect the lawfulness of processing your personal data prior to your withdrawal.

Pre-Contractual Steps or Perform a Contract

Where you have asked us to take pre-contractual steps in view of our entering into a contract with you, or we are performing on an existing contract with you, we process certain personal data you share with us. This includes processing your personal data to:

  • communicate with you;
  • provide you with requested services or information;
  • register you for events at your request; and
  • research and assess your eligibility to become a franchisee, including learning more about your
    business and franchising experience, evaluating proposed market conditions, and conducting a background assessment.

If you do not provide us with certain personal data, we will not be able to perform pre-contractual steps or enter into a contract with you. For example, if you do not provide us with the certain fields in the franchisee application, we will be unable to evaluate your eligibility to become a franchisee.

Comply with Applicable EU or UK Law or Obligations

Under certain European Union or United Kingdom laws and regulations, we are required to process certain personal data, including maintaining internal records to comply with those laws, complying with those laws, regulations, and legal obligations as necessary, and responding to lawful governmental requests.

Legitimate Interests

We process certain personal data in our legitimate interests as long as those do not infringe your fundamental rights or interests. For example, we may process your personal data relying on our legitimate interests in order to:

  • communicate with you by interacting with you on social media sites, providing you with information about franchising opportunities, and/or inviting you to events, where those communications do not require your consent; our legitimate interest is to promote our franchise system in order to grow our revenues and retain our reputation in the market;
  • to evaluate or participate in a merger, corporate transaction or other activity that involves the transfer of some or all our business assets; our legitimate interest is to maximize the efficiency of our business in order to continue to grow our revenues;
  • detect, prevent, or investigate suspicious activity or fraud; our legitimate interest is to defend our rights and interests as well as our reputation in the market by limiting fraudulent actors who may target our brand or business;
  • enforce our terms, contracts, or other policies; our legitimate interest is to defend our rights in order to continue to grow our business;
  • engage in, defend, and manage legal claims; our legitimate interest is to comply with applicable laws in operating our business, to respond to legal proceedings or court orders, and to defend our rights, in order to protect our reputation in the market; and
  • comply with applicable laws outside of the United Kingdom or the European Union; our legitimate interest is to comply with applicable laws in operating our business.

We do not currently make decisions based solely on automated processing or automated decision- making that would produce legal effects or similarly significantly affect you.

How We Share Personal Data

We share your personal data to the extent necessary to fulfill the purposes described in this Privacy Notice and as permitted by applicable law. This includes us sharing with our service providers operating under our direction to assist in providing corporate functions, sharing with your consent, sharing as part of a corporate transaction, sharing with our marketing partners, and disclosure to legal and/or government entities as described below.

Service Providers

We share your personal data with our service providers that support our business operations and purposes described in this Privacy Notice. For example, we use service providers to provide website hosting and administration services, background check services, direct marketing and mailing services, and webinar services. These service providers will only process personal data upon our instructions.

Your Consent

If you consent to us sharing your personal data, we will only share your personal data in the context and circumstances to which you consented.

Corporate Transaction

If we are involved in a merger, corporate transaction or other activity that involves the transfer of some or all our business assets, we may share your personal data with companies or individuals involved in the negotiations or involved in the transfer.

Legal and Government Entities

We will disclose your personal data when we believe such disclosure is required by law or as part of a legal process when we believe the disclosure is necessary to enforce our contract or policies or to protect our rights, property, health or safety, customers, or partners. This includes disclosing personal data to our legal and other advisors, courts and other tribunals, law enforcement, government agencies, and our insurers.

We may also share information that cannot be used to identify you and is irrevocably anonymized. For example, we may disclose aggregate statistics that cannot be disaggregated, linked to you or used to identify you.

Privacy Rights

You may, at any time, change your preferences regarding receiving communications from us. To withdraw your consent to receive marketing and promotional communications from us, please email us at [email protected] and clearly indicate your request to withdraw consent for international franchise marketing materials. Please note that if you withdraw your consent to receive marketing materials, we may still send you transactional emails in response to direct inquiries from you.

Where the EU or UK GDPR applies, you have certain rights to your personal data. You have the right to:

  • obtain a copy of the personal data we hold about you and information about how we process it;
  • request that we correct personal data we hold about you;
  • request that we delete your personal data in certain circumstances;
  • request that we restrict processing your personal data;
  • request we send your personal data to a third party or provide you with a portable copy of your personal data, if possible; and
  • withdraw consent to the processing of your personal data for the future.

These rights may be subject to specific conditions as set out in relevant law or other authority. You can exercise these rights by contacting us at [email protected] with your specific privacy right request or by mailing your privacy right request to the mailing address provided under the Contact section of this Privacy Notice. Before fulfilling your request, we may need to verify your identity.

Right to Object to Processing

In addition to the rights listed above, you also have the right to object to processing of your personal data on grounds related to your particular situation where we rely on a legitimate interest, and to processing for direct marketing purposes.

If you have concerns regarding our compliance with applicable privacy laws, you also have the right to lodge a complaint with a supervisory authority in the EEA (link). Before contacting a supervisory authority, we would appreciate the opportunity to first address your concerns, which you may do by contacting us at the email or postal addresses noted above.

Security and Personal Data Retention

We protect your personal data by using technical, physical, and managerial security measures. However, no security system is perfect, and due to the nature of the Internet, we cannot guarantee that any data, including personal data, will be completely secure from intrusion or unauthorized access by third parties. You are responsible for maintaining the security of your systems and devices.

We retain your personal data while we have a business purpose to do so. If you become a franchisee, we retain the information you provided while a prospective franchisee for the duration of your franchisee relationship with us plus the applicable statutory period for resolving business or contract disputes. For non-franchisees, we retain your personal data for the duration of our discussions with you plus the applicable statutory period for resolving business or contract disputes.

International Data Transfers

Your personal data may be transferred to, stored, and processed in a country outside the EEA or the United Kingdom, including the United States and Mexico, which may have privacy laws that differ from the country in which you are located and have not received adequacy decisions from the European Commission. In such cases, we will take measures to ensure the adequate protection of your personal data and compliance with this Privacy Notice.

Children

The Applicable Activities are not intended to be used by or collect personal data from persons under 18. If you are the parent or guardian of a person about whom you believe we have collected personal data, please contact us immediately as described in the Contact section of this Privacy Notice.

Privacy Notice Updates

This Privacy Notice may be updated, and the date of the most recent update of the Privacy Notice is posted at the top of the Privacy Notice. You will be notified of any changes to this Privacy Notice that may materially affect your privacy rights or how we use or collect your personal data. We encourage you to periodically check for updates to this Privacy Notice.

Contact Information

If you have any questions, comments, or concerns about your privacy, you can contact our Data Protection Officer at [email protected] or via postal mail at:

Little Caesar Enterprises, Inc.
c/o Legal Department, Data Protection Officer 2125 Woodward Ave.
Detroit, Michigan 48201
USA