PRIVACY POLICY
SPARROW, LLC IS CONCERNED ABOUT PRIVACY ISSUES AND WANTS YOU TO BE FAMILIAR WITH HOW WE COLLECT, USE AND DISCLOSE YOUR INFORMATION.
This privacy policy describes our practices in connection with information that we collect through websites operated by us from which you may be accessing this privacy policy (the “Websites”), through the software applications made available by us for use on or through computers and mobile devices (the “Apps”), through our social media pages that we control from which you may be accessing this privacy policy (collectively, our “Social Media Pages”), as well as through html-formatted email messages that we send to you that link to this privacy policy (collectively, including the Websites, the Apps and our Social Media Pages, the “Services”).
Please read this privacy policy carefully. By using the Services, you consent to our collection and use of your Personal Information (described below) as described in this privacy policy. Except as set forth in this privacy policy, your Personal Information will not be used for any other purpose without your consent. You may withdraw your consent to our processing of your personal information at any time. However, withdrawing consent may result in your inability to continue using the Services or some of their features.
PERSONAL INFORMATION WE MAY COLLECT
“Personal Information” is information about you that, alone or in combination with other information, can uniquely identify you as an individual. We may collect certain Personal Information from you when you visit the Websites or use the Services, including but not limited to:
• Name
• Postal address (including billing and shipping addresses)
• Telephone number
• Email address
We may use a third-party payment service to process payments made through the Services. If you wish to make a payment through the Services, your Personal Information may be collected by such third party and not by us and will be subject to the third party’s privacy policy, rather than this privacy policy. We have no control over, and are not responsible for, this third party’s collection, use and disclosure of your Personal Information.
If you submit any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this privacy policy.
HOW WE MAY COLLECT PERSONAL INFORMATION
We and our service providers may collect Personal Information in a variety of ways, including:
• Through the Services: We may collect Personal Information through the Services, e.g., when you sign up for a newsletter or make a purchase.
• Offline: We may collect Personal Information from you offline, such as when you visit our restaurants, place an order over the phone or contact us.
• From other sources: We may receive your Personal Information from other sources, such as public databases; joint marketing partners; social media platforms; from people with whom you are friends or otherwise connected on social media platforms; and from other third parties.
HOW WE MAY USE PERSONAL INFORMATION
We may use your Personal Information:
• To respond to your inquiries and fulfill your requests, such as to send you newsletters.
• To send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies.
• To complete and fulfill your purchase or sign you up for events, for example, to process your payments, have your order delivered to you, communicate with you regarding your purchase or reservation and provide you with related customer service.
• To send you marketing communications that we believe may be of interest to you.
• To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read these rules carefully.
• For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
HOW PERSONAL INFORMATION MAY BE DISCLOSED
Your Personal Information may be disclosed:
• To our third-party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services.
• To third-party sponsors of sweepstakes, contests and similar promotions.
• To identify you to any guest you register for an event.
• By you, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials. Please note that any information you post or disclose through these Services will become public information and may be available to users of the Services and to the general public. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Services.
• To your friends associated with your social media account, to other website users and to your social media account provider, in connection with your social sharing activity, such as if you connect your social media account to your Services account or log into your Services account from your social media account. By connecting your Services account and your social media account you authorize us to share information with your social media account provider and you understand that the use of the information we share will be governed by the social media site’s privacy policy. If you do not want your Personal Information shared with other users or with your social media account provider, please do not connect your social media account with your Services account and do not participate in social sharing on the Services.
• To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
OTHER INFORMATION
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:
• Browser and device information, including device ids, advertising ids, and other persistent identifiers, such as your IP address. Your IP address is a number that is automatically assigned to the computer that you are using by your internet service provider (ISP).
• Information collected through cookies, pixel tags and other technologies, such as the actions taken within and outside of the websites and apps and the date and time of your use of the websites and apps
• Demographic information such as your gender or city and other information voluntarily provided by you
• Aggregated information
HOW WE MAY COLLECT OTHER INFORMATION
We and our third-party service providers may collect Other Information in a variety of ways, including:
• Through your browser or device: certain information is collected by most browsers or automatically through your device, such as your media access control (mac) address, computer type (windows or macintosh), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
• Using cookies: cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience while using the Services. We can recognize your computer to assist your use of the Services. We also gather statistical information about the usage of the Services in order to continually improve the design and functionality, understand how the Services are used and to assist us with resolving questions regarding the Services. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies in online advertising to track responses to our advertisement
If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or to be given the choice of declining or accepting the transfer to your computer of a cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. For example, we may not be able to recognize your computer and you may need to log in every time you visit the applicable Services. You also may not receive advertising or other offers from us that are relevant to your interests and needs.
• Using pixel tags and other similar technologies: pixel tags (also known as web beacons and clear gifs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.
• IP address: An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels of the Services, helping diagnose server problems, and administering the Services.
• Physical location: we may collect the physical location of your device by, for example, using satellite, cell phone tower or wifi signals. We may use your device’s physical location to provide you with personalized location-based Services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you choose to deny such uses and/or sharing, we and/or our marketing partners may not be able to provide you with the applicable personalized Services and content.
• From you: information such as your preferred means of communication is collected when you voluntarily provide it. Unless combined with Personal Information, it does not personally identify you.
• By aggregating information: aggregated Personal Information does not personally identify you (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).
HOW WE MAY USE AND DISCLOSE OTHER INFORMATION
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.
If we are required to treat Other Information as Personal Information under applicable law, then we may use it as described in the “How We May Collect Other Information” section above, as well as for all the purposes for which we use and disclose Personal Information.
In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location). If we do, we will treat the combined information as Personal Information for so long as it is combined.
THIRD-PARTY SERVICES
This privacy policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.
Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Twitter, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
SECURITY
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “contacting us” section below.
CHOICES AND ACCESS
Your choices regarding our use of your Personal Information:
If you no longer wish to receive marketing-related emails from us, you may opt-out from such messages by following the instructions contained in each such email. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
If you believe your Personal Information is being improperly used by us or any third party, please immediately notify us via email at info@Sparrow.com and include the word “security” in the subject line.
How you can access, change or suppress your Personal Information:
If you would like to review, correct, update, suppress, or delete the Personal Information that you have provided to us, you may contact us by email at info@Sparrow.com or write to the following address:
Sparrow _, LLC.
8720 W Sunset Blvd
West Hollywood, CA 90069
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have it suppressed from our database, or otherwise let us know what limitations you would like to put on our use of it. For your protection, we may only implement requests with respect to the Personal Information associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.
We do not honor Do Not Track Requests and signals.
EU Users’ Rights
The GDPR provides users located in the EU under its protection certain rights with respect to their Personal Information collected by us on the Websites. Accordingly, Sparrow recognizes and will comply with the GDPR and those rights, except as limited by applicable law. The rights under the GDPR include:
• Right of Access: This includes the right to obtain from us your Personal Data and whether it is being processed, along with the purposes of the processing; categories of Personal Data concerned; recipients to whom your Personal Data has been disclosed; the period for which your Personal Data is being stored; and the right to lodge a complaint
• Right of Rectification: This includes the right to correct inaccurate Personal Data collected and/or stored by us.
• Right of Erasure (“Right to be Forgotten”): This includes the right to have your Personal Data deleted. However, if applicable law requires us to comply with your request to delete information, fulfilment of your request may prevent you from using our services and may result in closing your account.
• Right to Restriction of Processing: This includes the right to request restriction of how and why your Personal Data is used or processed by us.
• Right to Data Portability: This includes the right to receive your Personal Data in a structure, readable format and the right to have your Personal Data transferred.
• Right to Object: This includes the right to object to us processing your Personal Data for reasons such as direct marketing purposes and for scientific or historical research or statistical purposes.
• Right to not be Subject to Automated Decision-Making: This includes the right to not be subject to a decision based solely on automated processing, including profiling, that could have a legal, or similarly significant, effect on you from being made solely based on automated processes.
Under the GDPR, the lawful basis for us processing your Personal Information for the uses described herein will typically be because you have provided your consent; it is necessary for our contractual relationship; the processing is required for us to comply with legal obligations; and/or the processing is in our legitimate interest on providing you with the Services.
California Users’ Rights
Under the CCPA, California users have the following rights:
• Right to Know About Personal Information Collected, Disclosed, or Sold: You have the right to request that Sparrow disclose what Personal Information of yours it collects, uses, discloses, and sells over the past 12 months.
• Right to Request Deletion of Personal Information: You have the right to request that Sparrow delete any of your Personal Information that we collected from you
• Right to Opt-Out of the Sale of Personal Information: Sparrow does not sell Personal Information.
• Right to Non-Discrimination for Exercising CCPA Rights: Sparrow shall not discriminate against California Users for exercising their rights under the CCPA.
To exercise your rights under the CCPA – or have an authorized agent exercise your rights under the CCPA on your behalf – please submit either a “Request to Know Personal Information” or a “Request to Delete Personal Information” to Sparrow by contacting Sparrow at INFO@SPARROW.COM. Sparrow will verify this request by ensuring that such request is from the registered email address and that the requestor can provide additional information as requested by us.
PURSUANT TO CALIFORNIA’S “SHINE THE LIGHT LAW” (CIVIL CODE SECTION 1798.83), A CALIFORNIA RESIDENT WHO HAS PROVIDED PERSONAL DATA TO A BUSINESS WITH WHOM HE/SHE HAS ESTABLISHED A BUSINESS RELATIONSHIP FOR PERSONAL, FAMILY, OR HOUSEHOLD PURPOSES (A “CALIFORNIA CUSTOMER”) MAY REQUEST INFORMATION ABOUT WHETHER THE BUSINESS HAS DISCLOSED PERSONAL INFORMATION TO ANY THIRD PARTIES FOR THE THIRD PARTIES’ DIRECT MARKETING PURPOSES. IN GENERAL, IF THE BUSINESS HAS MADE SUCH A DISCLOSURE OF PERSONAL DATA, UPON RECEIPT OF A REQUEST BY A CALIFORNIA CUSTOMER, THE BUSINESS IS REQUIRED TO PROVIDE A LIST OF ALL THIRD PARTIES TO WHOM PERSONAL DATA WAS DISCLOSED IN THE PRECEDING CALENDAR YEAR, AS WELL AS A LIST OF THE CATEGORIES OF PERSONAL DATA THAT WERE DISCLOSED. CALIFORNIA CUSTOMERS MAY REQUEST FURTHER INFORMATION ABOUT OUR COMPLIANCE WITH THIS LAW BY E-MAILING INFO@SPARROW.COM. PLEASE NOTE THAT WE ARE REQUIRED TO RESPOND TO ONLY ONE REQUEST PER CALIFORNIA CUSTOMER EACH YEAR AND THAT WE ARE NOT REQUIRED TO RESPOND TO REQUESTS MADE BY MEANS OTHER THAN THROUGH THIS E-MAIL ADDRESS.
RETENTION PERIOD
We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law.
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide Personal Information through the Services. If a child under 13 submits Personal Information to us through the Services, 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 are a parent of a child under 13 years of age and you believe your child has provided us with Personal Information, please contact us at info@Sparrow.com and we will delete the information from our system.
CROSS-BORDER TRANSFER
The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.
SENSITIVE INFORMATION
We ask that you not send us, and that you not disclose to us, any sensitive Personal Information (e.g., social security numbers, credit card numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Services or otherwise.
UPDATES TO THIS PRIVACY POLICY
We may change this privacy policy from time to time. The “last updated” legend at the top of this page indicates when this privacy policy was last revised. Any changes to this privacy policy will become effective when we post the revised privacy policy on the Services. Your use of the Services following these changes means that you accept the revised privacy policy.
CONTACTING US
If you have any questions about this privacy policy, please contact us by email at info@Sparrow.com or at the following address:
Sparrow _, LLC
8720 W Sunset Blvd
West Hollywood, CA 90069
Because email communications are not always secure, please do not include sensitive information in your emails to us.