Updated as of January 1, 2021
Cinnabon Franchisor SPV LLC, Cinnabon LLC and their affiliates and subsidiaries (collectively, “Cinnabon” “we” or
otherwise process information and personal information that we obtain about users (“Users”) of our websites (each a
“Site” and collectively the “Sites”), our mobile applications (each an “App” and collectively the “Apps”), our social
media networking pages, and the services available through our Sites and Apps (each a Service and collectively the
“Services”). This Policy will apply to each Cinnabon Site or App that displays it This Policy does not apply to any
websites, webpages, or mobile apps that are run or owned by any Cinnabon franchisees, or any other third party.
This Policy and our
describe our collection, use and disclosure of personal information and other information collected from Users.
In this Policy, “personal information” means any information that Cinnabon has collected and that
identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with
a particular person or device.
If you are a California resident, please click here to learn more
your consumer data privacy rights.
Information We Collect About You
We collect personal information directly from Users, such as when they sign up to receive special offers or
information from us, sign up for our rewards programs, download franchise kits, or register for an account with us. We
also collect certain information (including personal information) automatically through Users’ use of our Sites,
Apps and Services. If you would like to use our Sites, Apps, and Services, but decide not to provide this personal
information, certain Services may not be available to you.
Information We Collect Directly From You
You can browse our Sites without registering or submitting your personal information to us, but we will automatically
collect certain information about your use of our Sites and Apps through cookies and other web tracking technologies
Other Information We Collect Automatically
To use our Apps and certain Services (e.g., to sign up for rewards programs, enter contests, make a purchase, or
request a franchise kit from us), you must register with us or otherwise provide us with your name and other personal
information. We may also collect personal information that you enter on our Sites or Apps or provide to us in any
other ways, such as through email or forms on our Sites or Apps. The type of personal information that we collect from
you depends on your interaction with us and your use of our Sites, Apps, and Services, but may include:
- personal details, such as full name, mailing address, email address, phone number, and other contact
- transaction information (if you make a purchase), such as information about the products you buy, billing
address, method of payment, and payment details; and
- location data, and any other personal information that you choose to provide.
Other Information about Your Activities and Interactions
We collect information from you when you submit a review, comment or other content to our Sites or Apps or on our
social networking pages, and when you contact us. In addition, we track when you like us or share our content through
Facebook, Twitter or other social networking platforms. Blogs on many of our Sites are hosted by WordPress (to review
other third parties.
Information from Third Parties
We may collect personal information about potential customers and franchisees from third parties, including name,
contact and other information. We also may collect information about any comments or reviews you post about us on
third party websites.
Our Sites and Apps may access and collect your geolocation information in order to facilitate our Services, such as
enabling the functionality of our Sites and Apps that provide you with information about stores near you. We may also
use information about the location of the device you are using to help us understand how our Sites, Apps, and other
Services and functionality are being used and to deliver more relevant advertising. For most mobile devices and
computer systems, you are able to withdraw your permission for us to collect this information by using the device or
Other Information We Collect Automatically
We may automatically collect certain information – including personal
information – about your use of our Sites, Apps and social networking pages through cookies and other web
tracking technologies, including, but not limited to: log files; domain name; browser type and operating system; page
views and related activities; IP address; the length of time you use our Sites, Apps, and Services; access date and
time; browser type; device ID or other mobile or App identifier; and referring URL. We may combine this information
with other information that we have collected about you. Please
for more information.
How We Use Your Information
We process and use your personal information if there is a legal justification for doing so. Below is an overview of
the legal justifications for processing personal information, and why we use your personal information. Additional
details on how we process your personal information may be provided to you in a separate notice or contract.
Performance of a Contract / Entering into a
your personal information is necessary in some cases to perform a contract with you or take steps to enter into a
contract at your request:
- Providing Support and Services - to provide our support and Services to you, to communicate with you, to
respond to your inquiries, to provide you with documentation or communications which you have requested from us,
provide after-sales support, and for other customer service purposes.
- General Business Operations - to process your orders or purchases.
Our Legitimate Interest. Processing
your personal information is in our legitimate interests, which are not overridden by your interests and
fundamental rights. When the justification for processing your personal information is our legitimate interests,
those interests are to use User personal information to conduct and develop our business activities with Users and
with others in order to support our reputation and increase our revenues, while limiting the use of personal
information to those purposes that strictly support the conduct and development of our business within the
reasonable expectation of the individuals concerned:
- Personalize Content – to make recommendations to you about our Services; to tailor the information
send or display to you; to offer customization, based on your location; and to otherwise personalize your
based on your purchase history and your interactions with the Sites, Apps, and social networking pages.
- Advertising – to send you targeted advertising on our Sites, in our Apps, or on third-party
- Marketing and Promotions – to send you news and newsletters, special offers and promotions, or to
contact you about information we think may interest you.
- Analytics and Improvement – to better understand how Users access and use our Sites, Apps and
order to improve them, respond to User desires and preferences, and for other research, marketing and analytical
purposes; to conduct research and analytics; to evaluate transactions involving the Sites, Apps, and social
pages; to operate, evaluate, maintain, improve and develop the Site, Apps, and social networking pages (including
monitoring and analyzing trends, access to, and use); and to evaluate, improve, and develop our Services generally
tracking User interaction and review of our Services.
- Protect Our Legal Rights and Prevent Misuse – to respond to claims asserted against us, comply with legal
process (e.g. subpoenas or warrants), or enforce or administer our agreements and terms; to conduct fraud
risk assessment, or investigations; to protect our rights, property, or safety and those of Users, or others; and
protect our confidential and proprietary information.
- Comply with Legal Obligations – to comply with the law, a judicial
proceeding, court order, subpoena, or other legal process.
- Corporate Reorganization – to share your personal information with third parties in connection with
potential or actual sale of our company or any affiliate, or of any of our assets or those of any affiliated
in which case personal information held by us about our Users may be one of the transferred assets.
Compliance with European Union (“EU”)
your personal information is necessary in some cases for us to comply with a relevant legal obligation:
- EU Records - to keep accounting records and evidence of Services.
- Protect Our Legal Rights and Prevent Misuse in the EU - to respond to claims asserted against us, comply
legal process (e.g., subpoenas or warrants), or enforce or administer our agreements and terms; to conduct fraud
prevention, risk assessment, or investigations; to protect our rights, property, or safety and those of Users, or
others; and to protect our confidential and proprietary information.
- Comply with EU Legal Proceedings - to comply with the law, a judicial proceeding, court order, subpoena, or
other legal process.
process your personal information in some cases because you have consented to that processing:
• Testimonials – to publish on your User experience with our Services our Sites, Apps, or social
How We Share Your Information
We do not sell or rent your personal information for monetary compensation. We may share your information, including
personal information, as follows:
Any information, including personal information, that you post on public areas of our Sites and Apps, such as reviews,
comments, and photos, may be available to, and searchable by, all Users of the Sites and Apps. Reviews may also be
viewable by non-registered visitors to our Sites and Apps.
Affiliates and Subsidiaries
We may disclose the personal information we collect from you to our affiliates or subsidiaries for their own
marketing, research, and other purposes. For example, if you request information about one of our franchises, we may
share your information with other affiliated franchise companies in which we think you may be interested. In addition,
if you sign up to receive information or updates from one of our affiliates, we may send you information from other
affiliates. If you would like to opt-out of receiving marketing communications, please submit your request here.
We may disclose the personal information we collect from you to third party vendors, service providers, contractors or
agents who perform functions on our behalf, such as payment processors, website and mobile application developers,
hosting providers, auditors, advisors, consultants, customer service, marketing analytics and advertising companies,
and support providers.
In the event that we are involved in a potential or actual bankruptcy, merger, acquisition, reorganization, sale of
assets, or similar event, your personal information may be sold or transferred as part of that transaction, in
connection with that transaction, or in anticipation of a possible transaction. This Policy will apply to your
personal information as transferred to the new entity.
In Response to Legal Process
We may disclose the personal information we collect from you to a court, legal authority, adverse litigation party,
legal counsel, and other advisors in connection with a judicial proceeding, court order, subpoena, or other legal
To Protect Us and Others
We may disclose the personal information we collect from you to a court, legal authority, government agency, adverse
litigation party, legal counsel and other advisors, where we believe it is necessary to investigate, prevent, or take
action regarding illegal activities, suspected fraud, situations involving potential threats to the rights, property,
and safety of Cinnabon or any other person; to enforce or administer our Terms
Conditions, this Policy, or another Cinnabon policy; or as evidence in litigation in which we are involved.
We or our third party providers may share information that does not identify you. For example, we may share anonymous,
aggregated statistics about Users with third parties for marketing, advertising, research, or similar purposes.
With Your Consent or at Your Direction
In addition to the sharing described in this Policy, we may share information about you with third parties whenever
you consent to or direct such sharing, for example, to provide information about franchise opportunities with Cinnabon
about your use of our Sites, Apps, and Services. We may combine this information with other personal information we
collect from you. For example, we may use these technologies to:
- uniquely identify you or your device;
- allow you to access and use our Services, where without them, our Services may not work properly;
- help us monitor the performance of our Services;
- help us customize your experience;
- market to you through targeted advertising; and
- for other purposes described under the section entitled “How We Use Your
Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for
record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Sites, Apps, and Services,
while others are used to enable a faster log-in process or to allow us to track your activities. For more information
on the specific types of first and third party cookies served through our Sites and Apps, please see our
Clear GIFs, pixel tags and other technologies
Clear GIFs are tiny graphics with unique identifiers, similar in function to cookies. In contrast to cookies, which
are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs
(a.k.a. web beacons, web bugs or pixel tags), in connection with our Sites and Apps to, among other things, help us
manage content, and compile statistics about usage. We and our third party service providers use clear GIFs in HTML
e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track
whether our e-mails are forwarded.
We may use local storage technologies, such as HTML5 or Flash Local Storage
Objects (“Flash LSOs”) to store your Site preferences and to personalize your visit. Typically, you cannot
control, delete, or disable the acceptance of HTML5 or Flash LSOs through your web browser. For more information on
HTML5 and Flash LSOs, or to learn how to manage your settings for HTML5 and Flash LSOs, go to the Adobe Flash Player
Help Page, choose “Global Storage Settings Panel” and follow the instructions.
Advertising and Analytics
We use third-party analytics tools, including, but not limited to, Google Analytics, FullStory, and ClickDimensions,
to collect, monitor, and analyze information we collect from you in order to improve functionality and
user-friendliness of our Sites and Apps, and to better tailor the Services to our visitors’ needs.
In addition, we may send Users targeted ads, based on their location and activities on our Sites and in the Apps. We
may also participate in third-party ad networks (including but not limited to Google Ads, Flashtalking, Quantcast,
Mediamath, Dstillery, RhythmOne, and Facebook Ads) and allow third parties, including network advertisers, to use
cookies, pixel tags, and other tracking technologies on the Sites and Apps to collect usage information and display
targeted ads. These third parties may be able to associate the information they collect with other information they
have about you from other sources. These third-party cookies and other technologies are governed by each third’s
not this one.
For more information on third-party analytics and advertising practices,
please visit our
Our Sites do not honor browser do-not-track requests. However, you can find information on how to opt out of many
participating website ad networks at the following websites:
Network Advertising Initiative
Digital Advertising Alliance
. Please note that opting out does not prevent all targeted ads from being displayed to you. Also, if you delete
cookies or change devices, your opt-out may no longer be effective.
Mobile App Users
If you download or use any of our Apps, and you agree to share your location information with us and receive push
notifications from us, we will use your location information to send you customized notices, offers, and coupons. You
can opt-out of push notifications or of sharing your location information by adjusting the settings in your mobile
device after downloading the App. If you use an Apple iOS device, you can disable push notifications by turning them
off for the App you are using within the
“Notifications Center” under the “Settings” menu; you may disable location
information for an App by going to “Settings,” “Privacy,” and then
“Location Services,” and turning off sharing for the particular App. For
Android users, you can turn off these notifications through the Menu
settings within our App.
User Generated Content
Any content you post to our Sites, Apps, or social networking pages (“User
Generated Content”), may be available to all Users, and we cannot prevent such content from being used in a
manner that violates this Policy, the law, or your personal privacy. We may review such User Generated Content, remove
it, or combine such User Generated Content with other information we have collected about you and use it as described
in this Policy. All User Generated Content is subject to our Terms and
Conditions and the
User Generated Content Terms and Conditions.
Plug-ins and Social Media Widgets
Our Sites may include social networking features and widgets, such as the
Facebook “Like” button and the “Share this” button, as well as other interactive mini-programs
that run on our Sites. These features may collect your IP address, which page you are visiting on our Sites, and may
set a cookie to enable the feature to function properly. These features are displayed on our Sites, but are hosted by
providing them, not this Policy. You should consult their respective privacy policies for information about their
We display personal testimonials of satisfied customers on our Sites, in addition to other endorsements. We may post
your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at email@example.com.
Our Sites, Apps, and Services may contain links to third-party websites. Any access to and use of such linked websites
is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are
not responsible for the information practices of such third-party websites. Please read their respective privacy
policies for information about how these third parties handle the processing of personal information and other
information. If you delete your account, to the extent permitted by applicable law, we will retain and use your
personal information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate
business records, and enforce our agreements.
Duration of Personal Information Retention
As a general rule, your personal information may be stored as long as the information is required to fulfill our
legitimate business needs or the purposes for which the information was collected, or for as long as is required by
You can contact us by email at: firstname.lastname@example.org with
questions or concerns regarding the retention period of your personal
How I Can Correct My Information
You may modify certain personal information that you have submitted to us. If you wish to correct any of the
personal information you have provided to us, you may contact us by email at: email@example.com. Please note that copies of information that you have
updated, modified or deleted may remain viewable in cached and archived pages of the Sites or App for a period of
time, and we may maintain records in our systems of this information as well. If you are a user in the European
(“EEA”), you may have additional rights, as set forth in the “
Your European Privacy Rights
” section below.
Personal Information Marketing Choices
We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the e-mail or submitting your request here. Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt-out of
receiving emails about recommendations or other information we think may interest you, we may still send you
administrative e-mails about your account or any Services you have requested or received from us.
Our Services are not targeted at children under 13 years of age.
No one under the age of 13 may provide any information to us through our Sites or Apps. We do not knowingly collect
personal information from children under 13. If you are under 13, do not access, use, or provide any information on
our Sites or Apps, or on or through any of their features.
Note to EEA Users
: If you are under 16, you should not access, or provide any information on our Sites or Apps, or on or through any of
If we discover that a child under 13, or equivalent minimum age depending on the jurisdiction, has provided us with
personal information, we will delete such information from our systems. If you are a parent or legal guardian of a
child under 13, or equivalent minimum age in the relevant jurisdiction, whom you believe has submitted personal
information to us, please contact us at firstname.lastname@example.org.
Notice to Nevada Residents
Nevada law allows consumers to direct certain businesses not to sell their personally identifiable information to
third parties to license or sell that information to additional third parties. If you are a Nevada resident, you may
submit such opt-out requests to email@example.com. To be effective, your
request must include your full name, address, phone number, and email address. We will endeavor to respond to your
verified request within 60 days of receiving the request. However, due to unforeseen circumstances, we may need to
extend this period by up to 30 days. If an extension is reasonably necessary, we will notify you of this during the
initial 60-day period.
The Services are headquartered in the United States. Please be aware that information you provide to us or that we
obtain as a result of the Services may be collected in your country and subsequently transferred to, maintained,
accessed and otherwise processed in the United States or another country by us or our service providers for the
purposes mentioned above in accordance with applicable law. The privacy laws of these countries may not always offer
the same level of protection as in your country.
Your European Privacy Rights
If you are a data subject in the EEA, subject to certain conditions and restrictions set out in the General Data
Protection Regulation (“GDPR”) and
other applicable laws, you have the following rights with regard to our
processing of your Personal Data (as defined in the GDPR):
● Right of access, erasure and
the right to
request access to and obtain a copy of any of your Personal Data that we
may hold, and to request the deletion of your Personal Data under certain
circumstances. If the Personal Data we hold about you is inaccurate or
incomplete, you are entitled to request to have it corrected. If you are
entitled to have information corrected and if we have shared your Personal
Data with others, we will let them know about the rectification where
possible. If you ask us, we will also tell you, where possible and lawful
to do so, with whom we have shared your Personal Data so that you can
contact them directly.
● Your Right to Restriction of Processing.
You can ask us to restrict the processing of your Personal Data in certain circumstances, such as where you contest
the accuracy of that Personal Data or you object to our use or stated legal basis Where your Personal Data is
subject to restriction, we will only process it with your consent or for the establishment, exercise or defense of
legal claims. If you ask us, we will also tell you, where possible and lawful for us to do so, with whom we have
shared your Personal Data so that you can contact them directly.
● Right to Data Portability.
are relying (as the justification for processing) upon your consent, or the fact that the processing is necessary to
perform a contract to which you are party or to take steps at your request prior to entering a contract, and the
Personal Datais processed by automated means, you have the right to receive a copy of the Personal Data we have
obtained from you in a structured, commonly used and machine readable format, and to reuse it elsewhere or to ask us
to transfer this to a third party of your choice.
Right to object to processing (including profiling)
based on legitimate interest grounds
– Where we are relying upon legitimate interests to process Personal Data, you have the right to object to
processing. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds
for the processing that override your interests, rights and freedoms, or we need to process the Personal Data for
the establishment, exercise or defense of legal claims. Where we rely upon legitimate interest as a basis for
processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case
on an individual basis.
Right to object to direct marketing (including
You have the right to object to our use of your Personal Data (including profiling) for direct marketing purposes,
such as when we use your Personal Data to invite you to our promotional events.
● Your right to withdraw your consent. In
event your Personal Data is processed on the basis of your consent, you have the right to withdraw consent at any
time, without affecting the lawfulness of processing based on consent before its withdrawal.
● Your right to lodge a complaint.
the right to lodge a complaint with the supervisory authority of your habitual residence, place of work, or place of
alleged infringement, if you consider that the processing of your Personal Data infringes applicable law.
Please note that some of these rights may be limited, such as where we have an overriding interest or legal obligation
to continue to process your Personal Data. If you wish to exercise any of these rights or for any other inquiries or
complaints regarding the processing of your Personal Data by us, please contact us as at firstname.lastname@example.org.
Please also note that Cinnabon Franchisor SPV LLC is a data controller with respect to the data of franchisees,
prospective franchisees and franchisee applicants it collects or otherwise processes.
We are committed to taking appropriate measures designed to keep your personal information secure. We have taken
reasonable steps to help protect the information we collect about you from loss, misuse, unauthorized access,
disclosure, alteration, and destruction. While we make considerable efforts to protect our information systems, no
data security measures can guarantee 100% security. We encourage you to safeguard your passwords, ID numbers, or other
special access features on our Sites and Apps.
If you have questions about the privacy aspects of our Sites, Apps or Services or would like to make a complaint,
please contact us at email@example.com.
Changes to this Policy
This Policy is current as of the “Updated as of” date set forth above. We may change this Policy from time
to time, so please be sure to check back periodically. The modified Policy will be effective immediately upon posting.
If we make any changes to this Policy that materially affect our practices with regard to the personal information we
have previously collected from you, we will endeavor to provide you with notice in advance of such change through
commercially reasonable efforts available to us.