CHIPOTLE’S PRIVACY POLICY

(Last updated July 16, 2018) 
SCOPE

All data subjects whose personal data is collected, in compliance with the requirements of the General Data Protection Regulation (“GDPR”).

RESPONSIBILITIES

The Data Protection Officer is responsible for ensuring that this notice is made available to data subjects prior to Chipotle’s collecting/processing their personal data.

All Employees of Chipotle who interact with data subjects are responsible for ensuring that this notice is brought to the data subject’s attention and the data subject’s consent to the processing of their data is secured, when appropriate. Such consent is not necessary when data is collected for other lawful purposes under the GDPR.

PRIVACY POLICY
Who Are We?

Chipotle Mexican Gill, Inc., a Delaware corporation, and its subsidiaries and affiliated companies (collectively, “Chipotle”, “we”, “us”, or “our”) operates Chipotle Mexican Grill restaurants, which serve a focused menu of burritos, tacos, burrito bowls (a burrito without the tortilla) and salads, made using fresh ingredients. As of December 31, 2017, we operated 2,363 Chipotle restaurants throughout the United States, as well as 37 international Chipotle restaurants, and we also had eight non-Chipotle restaurants. We focus on finding fresh, high-quality raw ingredients to make great tasting food prepared using classic cooking methods; on building strong restaurant teams that are centered on providing an excellent guest experience; on building restaurants that are operationally efficient and aesthetically pleasing; and on doing all of this with the highest regard for the safety of our customers and with a continuing awareness of and respect for the environment.

Our Data Protection Officer (“DPO”) and data protection representatives for the European Union and United States can be contacted by completing the respective online form:

EU-based data protection representative: Talk to Us

US-based data protection representative: Talk to Us

Chipotle may collect information from you because we have a legal reason (allowed by law or under contract) to collect the information, or because you have consented for us to do so for a specific purpose. The personal data we would like to collect from you and process is:
 

Personal Data Type Source
Technical information, IP address, information about what type of device you use to connect to our website, your URL, what parts of our website you click on and how long you look at our website, name, address, phone number, email address, purchase history, or payment information. By filling in a form or sending us an email or SMS
  Applying for a job at Chipotle
  From third party contractors, payment and delivery services, business partners, advertising networks, analytics providers, search information providers, credit reference agencies, background checking agencies, etc.

The personal data we collect will be used for the following purposes, without limitation, include:

  • marketing
  • fulfilling orders
  • fulfilling contractual obligations
  • fulfilling legal obligations
  • the prevention of fraud

Our legal basis for processing the personal data, without limitation:

  • the data subject has given clear consent for us to process their personal data for a specific purpose;
  • the processing is necessary for a contract we have with the data subject, or because they have asked us to take specific steps before entering into a contract;
  • the processing is necessary for us to comply with the law; and/or
  • the processing is necessary for our legitimate interests or the legitimate interests of a third party so long as no good reason to protect the data subject’s personal data overrides those legitimate interests.

Any legitimate interest pursued by us, or third parties we use, include but are not limited to as follows:

  • the use of client or employee data;
  • marketing;
  • fraud prevention;
  • to enforce or apply our Terms of Use, or other agreements;
  • to protect the rights, property, or safety of Chipotle, our customers, employees, or others;
  • intra-group transfers; or
  • information technology security.

The special categories of personal data concerned are:

  • None
COOKIES

For more information read our cookie policy.

CONSENT

By consenting to this Privacy Policy, you are giving us permission to process your personal data specifically for the purposes identified. Consent is required for Chipotle to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by completing the respective online form to contact our Data Protection Officer:

European Union: Talk to Us

United States: Talk to Us

When We Might Share Your Personal Data With Third Parties

We do not, and will not, sell any of your personal data to any third party – including your name, address, email address or payment card information. We want to earn and maintain your trust, and we believe this is essential in order do that.

As an essential part of being able to provide our services to you, Chipotle will pass on your personal data to third parties for processing your data without first obtaining your consent, either because you have consented to allow us to do so or for other legal reasons. The following third parties will receive your personal data for the following purposes as part of the processing activities:
 

  • service providers that help us to get any purchases which you make through our website to you, such as delivery companies, gift voucher printers, payment service providers;
  • service providers that help us to run our business such as marketing agencies, website hosting providers, website developers, providers of wifi access at our venues and newsletter distributors;
  • service providers that help us manage our loyalty scheme, including the provision to make payment using the loyalty App;
  • service providers that give us with the ability to send email, text messages (SMS), mobile app push notifications and messages using other digital means;
  • professional advisers including lawyers, bankers, auditors and insurers who provide advice to us when we require it;
  • law enforcement agencies in connection with any investigation to help prevent unlawful activity;
  • third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them.  If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy;

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. If you would like any more information about the third parties which we work with to provide our services to you, please contact us on the contact details provided later in this Privacy Policy.

WHERE WE STORE YOUR PERSONAL DATA

We primarily store and process your personal data in the EU/European Economic Area (“EEA”). If we do transfer your personal data outside the EEA it will be because you have consented or because we have a legal reason to do so. Some examples of reasons your data may be processed outside of the EEA include:

  • Order fulfilment
  • Payment processing
  • Technical support services
  • Email and digital voucher deployment
  • Other digital targeting.

If your personal data cannot be processed within the EEA, we will:

  • Comply with all other data protection principles
  • Where possible, be to a country that is on the list of the EU Commissions’ countries that provide adequate protections for the rights and freedoms of data subjects
  • If the transfer is to the United States of America, we will use reasonable endeavors to make sure they participate in the Privacy Shield program or relevant contracts contain standard contractual clauses approved by the European Commission
  • Make sure we have assessed the adequacy of protections in all other cases.
RETENTION PERIOD

Chipotle will not retain your personal information for longer than required. We will store the personal data for as long as required by law, until we no longer have a valid reason for keeping it, or until you request us to stop using it. We may keep just enough of your personal information to ensure that we comply with your requests not use your personal information or comply with your right to erasure. For example, we must keep your request to be erased even if it includes your personal data until such time as you are no longer our customer. If you have questions about our data retention policy, please contact complete our online form here.

Your Rights as a Data Subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organization.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that Chipotle refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.

COMPLAINTS

In the event that you wish to make a complaint about how your personal data is being processed by Chipotle (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Chipotle’s data protection representatives including the Data Protection Officer (DPO).

The details of these contacts are:

  Supervisory authority contact details Data Protection Officer (DPO)
Contact name: Information Commissioner’s Office Jim Slater
  •  
Wycliffe House Water Lane 
Wilmslow 
Cheshire 
SK9 5AF 
Chipotle EU, 83 Baker Street, Marylebone, London, W1U 6AG
  •  
  •  
 
ONLINE PRIVACY STATEMENT
Personal Data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: “any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

Why we use your information

This Privacy Policy tells you how we, Chipotle, will collect and use your personal data for digital vouchers, email and other digital means.

Why do these third parties need to collect and store personal data?

In order for us to provide you with the below services we need to collect personal data for correspondence purposes and/or detailed service provision. We are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy. Chipotle will obtain your consent before contacting you for marketing purposes.

  • our till system provider and mobile App developer to process digital vouchers, online/App orders and mobile push notifications;
  • our email service provider to send you digital vouchers and emails;
  • social media providers to contact you with relevant digital messages.

Will Chipotle share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to Chipotle in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfill the services they provide on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Chipotle’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.


How will Chipotle use the personal data it collects about me?

Chipotle will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. Chipotle is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.


Under what circumstances will Chipotle contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimize the risk of unauthorized access or disclosure.


Can I find out the personal data that the organization holds about me?

Chipotle, at your request, can confirm what information we hold about you and how it is processed. If Chipotle does hold personal data about you, you can request the following information:

  • Identity and the contact details of the person or organization that has determined how and why to process your data. In some cases, this will be a representative in the EU.
  • Contact details of the data protection officer, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of Chipotle or a third party, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • If we intend to transfer the personal data to a third country or international organization, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority.
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?

Chipotle accepts the following forms of ID when information on your personal data is requested:

  • Driving license (photo)
  • Passport
  • Named utility bill or bank/credit card statement (from the last 3 months)
 

Contact details of the [Data Protection Officer (DPO)] / [GDPR Owner]:

Address: Chipotle EU, 83 Baker Street, Marylebone, London, W1U 6AG
Contact: Talk to Us

LINKS TO OTHER WEBSITES

From time to time, we may provide links to and from websites or other applications of our partners, advertisers, affiliates, or other business associates. If you follow a link to any of these websites, please note that these websites may have their own privacy policy notices and that we do not accept any responsibility or liability for any such notices. Please check these notices, where available, before you submit any personal data to these websites or applications.

CHILDREN

Chipotle does not believe its website or marketing content is appealing to children, nor is it directed at children as defined under applicable law. Chipotle does not knowingly collect personally identifiable data from children, and strives to comply with the provisions of all applicable laws. If you are a parent of a child, we seek your consent to any data collection or processing regarding your child.

CHANGES TO OUR PRIVACY POLICY

Chipotle may change this notice from time to time in the future. Any such change will be posted here and, when appropriate, Chipotle will notify you in writing. We advise you to check back frequently to see any updates or changes.