Effective Date: March 31, 2024
Last Updated: March 31, 2024

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Our Privacy Policy describes how we handle personal information generally. This supplemental Consumer Health Data Privacy Policy (“Consumer Health Data Notice”) applies to Little Caesar Enterprises, Inc., and explains our practices as to personal information that qualifies as “consumer health data” as such term is defined by Washington’s My Health My Data Act, Nevada’s Consumer Health Data Privacy Law, and other U.S. consumer health data privacy laws, as each are amended and as and when they become effective including any regulations thereunder (“U.S. Consumer Health Data Privacy Laws”).

The U.S. Consumer Health Data Privacy Laws have distinct requirements for what data practices must be disclosed and the manner in which the disclosure must be presented. Section I covers the required disclosures in Washington’s law, which also satisfy most of the requirements in the non-Washington laws. For additional information required under non-Washington laws (including Nevada), see Section II.

I.                   Consumer Health Data Practices and Privacy Rights

We may collect consumer health data if you make a customer service or support request, or a complaint to or about us, or if you are involved in an accident or incident at one of our store locations. For example:

• If you are present during an incident or accident that occurs at one of our store locations (such as a safety or security incident), we may collect information about you, including consumer health data, in relation to this. This includes your physical characteristics (your face, tattoos, etc.), that we observe through review of CCTV footage, in order to investigate the incident. Some of the U.S. Consumer Health Data Privacy Laws may classify this type of information as biometric data. We may collect some or all of the other categories of consumer health data listed below in relation to an incident or accident.
• If you file an injury report related to a visit at one of our store locations or one of our franchisees’ store locations, we may collect your consumer health data in relation to the injury report. This could include all of the categories of consumer health data in the list below.
• When you make an order, we provide you the option to submit information regarding whether you are visually impaired or have any reach limitations in order to assist with fulfilling your order. This information falls under the “individual health conditions, treatment, diseases, or diagnosis” category the from the list below.
• For other customer service or support requests or complaints, we will collect all of the categories of consumer health data from the list below that you provide to us, and that are necessary for us to collect in addressing your request or complaint.

We collect, use, and disclose your consumer health data to respond to your requests for customer support or service, to address your complaint, or to establish, exercise, or defend a legal claim. We may also collect, use, and disclose your consumer health data to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or any activity that is illegal under applicable state law or federal law; preserve the integrity or security of systems; or investigate, report, or prosecute those responsible for any such action that is illegal under applicable state law or federal law.

The categories of consumer health data that we collect may include the following categories:

1. Individual health conditions, treatment, diseases, or diagnosis
2. Social, psychological, behavioral, and medical interventions
3. Health-related surgeries or procedures
4. Use or purchase of prescribed medication
5. Diagnoses or diagnostic testing, treatment, or medication
6. Data that identifies a consumer seeking health care services
7. Biometric data
8. Consumer health data that we or our processors infer, derive, or extrapolate based on other consumer health data, or on personal information generally
9. Bodily functions, vital signs, symptoms, or measurements indicating consumer health data

We share consumer health data with third parties in limited circumstances, as follows:

• Vendors that are classified as “processors” under the U.S. Consumer Health Data Privacy Laws which process consumer health data to assist us in providing products and services requested by consumers, and for the other purposes described in this Consumer Health Data Notice.
• Our other agents and contractors who assist us with the processing purposes described in this Consumer Health Data Notice, such as legal representatives who assist us with complaints involving consumer health data.
•  If your request or complaint, or an incident or accident, relates to or implicates one of our or franchisees or their store location(s), we will share your personal information, including any consumer health data that is relevant to your requestor complaint, with the applicable franchisee so that they can respond to your request or complaint, or assist us with doing so.
• If your request or complaint, or an incident or accident, relates to or implicates one of our affiliated or related entities, we may share your consumer health data with such affiliates or related entities, which are listed at https://ilitchnewshub.com/our-companies/.
• Assignees or potential assignees as part of an acquisition, merger, asset sale, or other transaction where another party assumes control over all or part of our business.
• Other parties with your consent.

We may share all of the categories of consumer health data that we collect, which as discussed above depends on the circumstances under which we collect it. We do not sell consumer health data.

We collect consumer health data from the following sources: you, your agents and representatives (for example, legal representatives in relation to a complaint), governmental entities (for example, if you have filed a lawsuit against us, we may obtain information from official filings or that we receive from government bodies), our affiliates and related entities, and franchisees, and other third parties that may have your consumer health data in relation to the processing purposes described herein.

Subject to applicable law, you may have the following rights related to your consumer health data:

• Right to confirm processing of consumer health data and access such data
• Right to delete
• Right to withdraw consent (from processing which requires your consent)
• Right to appeal our refusal to act on a request within a reasonable time after you receive our decision. You may appeal our decision regarding your request by following the instructions in our response to your request. If your appeal is denied, you can raise a concern or lodge a complaint with the Washington State Attorney General at http://www.atg.wa.gov/file-complaint.

You may request to exercise these rights by visiting our Privacy Rights Request Form. Please note, as or required under Washington’s My Health My Data Act, we take commercially reasonable efforts to authenticate your request before we process your request. If we believe we need further information to authenticate your request, we may ask you to provide additional information to us.

Pursuant to the requirements of Washington’s My Health My Data Act, we will respond to your privacy requests free of charge, up to twice annually. If requests are manifestly unfounded, excessive, or repetitive, we may charge a reasonable fee to cover the administrative costs of complying with the request or decline to act on the request.

II.                 Additional Disclosures Required under Non-Washington Laws (including Nevada)

We do not allow third parties to collect or use consumer health data over time and across different Internet websites or online services.

You may appeal our decision regarding a privacy rights request by following the instructions in our response to your request. If your appeal is denied, you can raise a concern or lodge a complaint with the Nevada Attorney General at https://ag.nv.gov/Complaints/File_Complaint/.‍

We will retain and use your consumer health data for the length of time needed to carry out the purposes outlined in this Consumer Health Data Notice and in accordance with our record retention policies.

If we change this Notice, we will post the revised version here and change the last updated date (the date it applies from) and/or contact you directly where we deem appropriate to do so under applicable law. You should check here regularly for the most up-to-date version of the Consumer Health Data Notice.

If you have any questions about this Consumer Health Data Notice or practices described in it, you should contact us in the following ways:

Postal Mail:

Little Caesar Enterprises, Inc.
Attn: Privacy/Legal Department 2125 Woodward Ave.
Detroit, MI 48201

Email: privacy@lcecorp.com