This Incentive/Loyalty Programs notice is a supplement to our U.S. State Privacy Notice and Privacy Policy. In this notice, we have used certain terms that are defined in those documents. We are providing this notice because some of our Incentive/Loyalty Programs may be deemed a “Financial Incentive” and/or “Price or Service Difference” under the California Consumer Privacy Act (“CCPA”) and/or a “Bona Fide Loyalty Program” (e.g., loyalty, rewards, premium feature, discount, or club card program) under the Colorado Privacy Act (“CPA”). The PI we collect and retain for or related to operation of these programs is described in our U.S. State Privacy Notice, and includes identifiers and contact information, personal records, commercial information, Service usage information, location data, and inferences we make based on other PI. We do not collect Sensitive PI as part of our Incentive/Loyalty Programs, and Sensitive PI is not required to take advantage of any of our Incentive/Loyalty Program benefits. Of the categories of PI collected through our Incentive/Loyalty Programs just mentioned, identifiers and contact information may be Sold and/or Shared, and all of them (excluding location data) may be processed for purposes of Targeted Advertising.
The categories of recipients that will receive the PI collected in respect of our incentive/loyalty programs are Business Vendors, Website and App Management Vendors, Third-Party Promotional Partners (if you sign-up to third-party promotions or otherwise opt-in to disclose PI to such partners), Delivery and Ordering Platforms, Payment Processors, Franchisees in their capacity as Service Providers, Affiliates and Related Entities, and Third-Party Digital Businesses (as to the final category, some may be classified as “Data Brokers” as defined under certain U.S. Privacy Laws).
We do not utilize “Bona Fide Loyalty Program Partners” as such term is defined under the CPA to administer Incentive/Loyalty Program benefits.
We currently offer the following Incentive/Loyalty Programs in connection with the collection and retention of PI:
- eClub: We offer rewards to customers participating in our eClub, consistent with our Terms of Service. Participants in eClub receive promotional offers, including free products, discounts, coupons, and opportunities to participate in other promotional opportunities. You can subscribe to eClub here.
- Surveys: You may also be offered the opportunity to participate in a survey. Participation in the survey may result in Little Caesars collecting additional information from you, including your preferences, experiences, beliefs, opinions, and responses to the survey questions. In exchange for your participation in the survey, you may be offered a financial incentive, as described above.
- Limited-Time Promotions: From time to time, we may offer incentives limited to a specific time period, or time limited sweepstakes, contests and other promotions. Participation in a limited time offer or promotion is governed by the applicable terms and conditions for the program (e.g., Sweepstakes Rules and Prize Acceptance Agreements), which will also describe any financial incentives associated with the promotion.
For CCPA purposes, we treat the value of your PI collected through our Incentive/Loyalty Programs as equivalent to our total program expenses (excluding the value of benefits). The value of each program is the value of the program benefits, including free products, discounts, and coupons, the value of which will depend on individual customer participation. By participating in our Incentive/Loyalty Programs, you agree that the benefits are reasonably related to the value of the PI collected and retained.
Participation in our Incentive/Loyalty Programs is always optional, and you can terminate program participation at any time as explained in applicable program terms. You can also contact us at privacy@lcecorp.com to unsubscribe or cancel your participation.
Please note, you will no longer be able to participate in our Incentive/Loyalty Programs if you make a request to delete PI. This is because we need the PI collected in relation to the Incentive/Loyalty Programs, including certain information that falls within identifiers and contact information, personal records, commercial information, service usage information, location data, and inferences categories mentioned above, in order to administer the Incentive/Loyalty Programs. Therefore, if you request that we delete your PI, we will do so, subject to legal exceptions, however without that information it will not be possible to provide you with our Incentive/Loyalty Programs (e.g., to communicate with you regarding your rewards, collect and retain your information which rewards are based on, etc.).