1. About this policy

Kentucky Fried Chicken Pty Ltd (ABN 79 000 587 780) and KFC Saipan/J&G and each of its independently owned franchisees (“KFC Franchisees”) (collectively referred to as “KFC”, “we”, “us” or “our”) are committed to protecting the privacy of personal information in accordance with the CNMI's privacy laws. (“Privacy Laws”). This Privacy Policy sets out our approach to handling personal information and includes information about how we collect, use, disclose and hold your personal information.

The scope of this Privacy Policy covers the personal information handling practices of restaurants owned by KFC in Saipan and KFC Franchisees. Kentucky Fried Chicken Pty Ltd and J&G do not control the use or disclosure of personal information and may not have access to the personal information held by KFC Franchisees. KFC Franchisees are responsible for ensuring that your personal information collected by them is handled in accordance with this Privacy Policy and the CNMI's privacy laws.

This Privacy Policy applies to all personal information collected in any way through our company owned and independently owned restaurants, restaurant support centre, customer service centres, using a computer or mobile device, through our website (www.kfcmarianas.com) (“Website”). You should read this Privacy Policy carefully because anytime you provide your personal information to us or obtain our goods or services, you consent to the terms of this Privacy Policy.

We may, from time to time, review and update this Privacy Policy. A current version of this Privacy Policy will be published on our Website, or may be obtained free of charge upon request to the contact details below. All personal information collected and held by us will be governed by the most recently updated Privacy Policy.

2. Collection of personal information by KFC

We will only collect personal information from you that we reasonably require for one or more of our business functions or activities, and will do so by lawful and fair means.

The kinds of personal information we may collect from you will depend on what type of interaction you have with us. However, it may include:

• information such as your name, postal address, date of birth, gender, occupation, telephone number, email address, age, IP address and credit or debit account details;
• personal information you provide to us when you participate in a promotion, competition, promotional activity, loyalty program, survey, market research or customer behavioural activity, or subscribe to our mailing list,
• personal information obtained through use of our Website, or interacting with or by following our social media pages like Facebook, Twitter and Instagram;
• personal information you provide to us via a KFC branded restaurant, customer service centre, or support centre, or when you place an order in-store, by telephone, or via KFC’s mobile or electronic ordering system. This information may include your name and contact details, menu preferences and previous order information, IP address and financial information including credit card details and payment details;
• your records of communication with us when you submit an enquiry or make a complaint;
• if you are applying for a position with us, your personal information as outlined in the section below entitled “Employment Applications”;
• if you are applying to become a KFC Franchisee, your personal information as outlined in the section below entitled “Franchise Applications”.

If you interact with us through our Website or a mobile application we may also collect personal information about you including:

• usage and preference information, including by the use of cookies which is detailed further below in the section entitled “Cookies and passive information collection”;
• information about the device you are using;
• other information including your IP address, access dates and times, browser type and pages visited.

In some circumstances, we may collect personal information from third parties such as credit reporting agencies or our marketing agencies. Where we do, we will ensure that we act in accordance with relevant CNMI laws.

You have the option of not identifying yourself, or to use a pseudonym when dealing with us. However, in some cases it will not be practicable to deal with you anonymously or using a pseudonym, including when you have elected to receive direct marketing materials or requested delivery of products or services from us, in which case we may be unable to provide you with materials, products or services if you do not identify yourself.

We will not collect sensitive information about you (such as information about your racial or ethnic origins or political or religious beliefs) unless the collection is required by law or you have consented to such collection including if you are applying for a position with KFC or to become a KFC Franchisee.

3. The purpose of collecting your personal information

We will generally only collect and use your personal information for the primary purposes of:

carrying out general business operations;

providing you with goods and services;

communicating with you;

responding to your enquires or complaints;

meeting legal and regulatory obligations;

conducting, improving and developing a relationship with you; and

marketing (such as providing you with information about KFC products and promotional notices and offers).

4. How your personal information is held

Where we store your personal information depends on the interaction you have had with us. However, some areas may include:

• databases for processing customer enquiries or feedback;
• or email or SMS databases for marketing communications.

We take reasonable steps to protect your personal information from loss or unauthorised access. Unfortunately no data transmission over the Internet can be guaranteed as totally secure. Although we strive to protect such information, we do not warrant the security of any information you transmit to us or from our online services and you use these services at your own risk.

We only keep your personal information for as long as it is required for the purpose for which it was collected or as otherwise required by law. We will take appropriate measures to destroy or permanently de-identity your personal information if there is no longer need to retain it. These measures may vary depending on the type of information concerned, the way it was collected and how it was stored.

5. How your personal information will be used

We use your personal information for our business functions and activities, and to provide products and services to you, which may include:

• processing meal orders you place with us in our branded restaurants or via our electronic or mobile ordering system, providing you with email or SMS confirmation of your meal orders, providing you with our products and services and processing meal refunds where applicable;
• locating the nearest restaurant to you and providing you with location based notifications;
• administering and responding to your enquiry or feedback about our products and/or services;
• conducting, and allowing you to participate in, a KFC promotion, competition, promotional activity, loyalty program, survey, market research or customer behavioural activity;
• providing marketing and advertising materials for current and future products and services, invitations to events and special offers, competitions and promotions in person and through other means including our Website, telephone, mail, electronic messages (e.g. SMS, MMS, instant messaging and email) or any other form of electronic, emerging, digital or conventional communication;
• analysing our products and services so as to improve and develop new products and services;
• assisting you with remembering and re-ordering from our menu in future;
• administering and conducting traineeships;
• facilitating our internal business operations, including fulfilment of any legal and regulatory requirements;
• maintaining and improving the operation or navigation of our Website;
• processing and considering your employment application and conducting reference checks (refer to Employment Application section below);
• providing information that you request about our franchises and processing and considering your franchise application and conducting record checks (refer to Franchise Application section below).

We operate CCTV cameras at our premises and restaurants.  Images captured by our CCTV cameras are collected, used and stored for security and operational purposes, and to assist with any investigations relating to incidents or accidents at our premises and restaurants.

We may also use your personal information for other purposes not listed above which will be made clear to you at the time we collect your personal information, or for such purposes as may be required or permitted by law.

6. Disclosure of personal information to third parties

We may disclose personal information we collect from you:

• to related companies, KFC Franchisees (or to KFC and its related companies if a KFC Franchisee collects the personal information), suppliers, consultants, contractors, and agents for the purposes set out in the section above entitled “How your personal information will be used” or for other purposes related to the purpose for which the personal information is collected and which you would reasonably expect us to do so.  For example, your name and telephone number may be disclosed to our supplier to enable that supplier to respond to your request for information about a particular product it produces;
• to relevant Federal, State, Territory food safety authorities and health authorities for the purpose of investigating a food safety or health issue;
• if you are an employee or trainee, to Federal and State educational training institutions for the purpose of conducting retail training and receiving funding for such training;
• to KFC Franchisees, including those located in Saipan, if you have made a enquiry or complaint relating to a store that is owned and operated by one of our KFC Franchisees;
• to third parties to help us analyse our business practices and improve our products and services, and obtain feedback;
• to third party service providers that we use to help us conduct our business (including but not limited to technology service providers, archival service providers and marketing and communications agencies and service providers);
• to our professional advisors and insurers in the course of obtaining professional advice;
• in the event there is a change of ownership of any KFC business, to the new owners of the business (but only on the basis that the personal information is kept within the business);
• where the law requires or authorises us to do so;
• to others that you have been informed of at the time any personal information is collected from you; and
• with your consent (express or implied) to others.

If we engage third party contractors to perform services for us which involves handling personal information, we will require our contractors to comply with Privacy Laws.

7. Cross border disclosure

Your personal information may also be processed by, or disclosed to employees, representatives, or other third parties operating outside of Saipan who work for, or are engaged by KFC or its affiliated companies in other countries, including in the USA and in other countries where KFC operates, and to our services providers who may be located outside of Saipan, including in Singapore.

Disclosure may also include the transfer of your personal information to our KFC Franchisees any where else outside of Saipan.

By interacting with KFC and its Website or mobile applications, you consent to the disclosure of your personal information outside of Saipan. Before your personal information is disclosed to an overseas recipient, we will take steps that are reasonable in the circumstances to ensure that the overseas recipient does not breach CNMI's privacy laws in relation to your personal information.

8. Direct marketing and opting in or out

We may use your personal information to:

• promote and market current and future products and services to you; and
• inform you of upcoming events and special promotions and offers.

We may disclose your personal information to marketing agencies so they can assist us in the marketing of KFC products and services to you.

We will only offer you products or services where we reasonably believe that they could be of interest or benefit to you.

At the point we collect personal information from you, you may be asked to “opt in” to consent to us using or disclosing your personal information.  You may “opt out” of receiving marketing communications by clicking on an unsubscribe link at the end of an email or by contacting us with this request (refer to Privacy Queries and Complaints section). 

9. Mobile device permissions

If you use a mobile device to access our Website or a KFC mobile application, we may collect device information from you. Mobile platforms such as iOS and Android generally define certain types of information or data that applications cannot access without your consent. Each platform has its own permissions system for obtaining consent to the collection of this information. You can generally manage your platform level permissions through the ‘Settings’ section on your device.

10. Social media and third party content, advertising and functionality 

You are able to interact with us though social media sites including Facebook, Twitter, YouTube, Google+ and Instagram. 

We may collect your personal information when you provide personal information on social media sites.  This information may be collected over time and combined with information collected across different websites and online services. We may use your information as set out in this Privacy Policy and to assess your social media profile and assign you an internal engagement score, hashtag score or reach score.

In addition to us collecting information from these sites, you should be aware that third parties may collect or receive certain information about your interactions with KFC social media sites, including through the use of cookies, beacons and similar technologies. 

By engaging with any of these sites, you are subject to the terms and conditions (including privacy policies) of those sites. The content you post to these social media sites will be viewable by the general public and may be re-posted. We are not responsible for any content that has been reposted. We may at any time remove content you post on our social media sites which we determine is inappropriate or offensive, but we are not obliged to monitor your use. 

11. Cookies and passive information collection

We use technologies such as cookies to personalise your experience on our Website. For example, we use cookies to recognise your browser on each visit to our Website, to track pages visited on our site and to display KFC advertisements. Cookies are small files that our web server may send to your computer or device when you visit our Website.  Cookies can facilitate your ongoing access to and use of the Website.  They allow us to store your preferences, collect information about how you visit and access our Website, track usage patterns and to compile data that can assist us improve our content, products, services and target advertising.  Most often, they are used to recognise repeat users of our Website and to remember user preferences.

We may use cookies to help us improve our products and services.

Most browsers are automatically set up to accept cookies. The storage of cookies can be de-activated or the browser can be configured in a way that sends a notification when cookies are sent. You are always free to decline our cookies. However, certain features of the Website may not work without cookies and this may limit the services provided by our Website.

For more information about cookies and how you can opt out, ask us.

Third party data and advertising companies may use cookies to collect information about your online activities, including visits to our Website. They use this information to try to match advertising you see on other, non-KFC websites you visit, with your interests.

We also may use technologies called beacons that communicate information from your device to a server. Beacons can be embedded in online content, videos, and emails, and can allow a server to read certain types of information from your device, know when you have viewed particular content or a particular email message, determine the time and date on which you viewed the beacon, and the IP address of your device. We and other third parties use beacons for a variety of purposes, including to analyse the use of our Website and (in conjunction with cookies) to provide content and ads that are more relevant to you.

To the extent that you are using any of our location-based services or functionality, then your location data including the location of your device upon using such location-based services will be handled in accordance with the terms of this Privacy Policy.

We also collect and use your IP address to help diagnose any problems with our server and administer our Website.  Your IP address is used to help identify you and to gather broad demographic information about you.

12. Employment Applications

Generally, the type of personal information we collect about applicants is the information included in your application for employment, for example, your name, postal address, telephone number, email address, education details, employment history and other information relating to your work experience.

In considering your application, we may also obtain personal information about you from third parties, for example, from your previous employers or nominated referees.  

Subject to your consent, we may also collect sensitive information about you such as information about your health (including any disability) or any criminal record you may have. 

We collect personal information for any one or more of the following purposes:

• assessing you for a position with us or one of our related entities;
• assessing whether you are suitable to progress to each stage of the recruitment process for a vacant position;
• storing your information for future employment opportunities.

If you do not provide us with the information we request, we will be unable to do one or more of the above.

We may disclose your information to:

13. Franchise Applications 

Generally, the type of information Kentucky Fried Chicken Pty Ltd collects about franchise applicants is the information included on the Franchise Application Form, for example, your name, postal address, telephone number, email address, education details, residency status, employment history, financial capacity and other information relating to your qualifications and experience.

In considering your application, Kentucky Fried Chicken Pty Ltd may also obtain personal information about you from third parties, for example, from your previous employers or nominated referees.  Subject to your consent, Kentucky Fried Chicken Pty Ltd may also collect sensitive information about you such as information about any criminal record you may have or your membership of any professional or trade association.

Kentucky Fried Chicken Pty Ltd collects personal information for any one or more of the following purposes:

• assessing your application to become a KFC Franchisee;
• assessing whether you are suitable to progress to each stage of the KFC franchise recruitment process;
• storing your information for future KFC franchise opportunities.

If you do not provide Kentucky Fried Chicken Pty Ltd with the information Kentucky Fried Chicken Pty Ltd requests, Kentucky Fried Chicken Pty Ltd will be unable to do one or more of the above.

Kentucky Fried Chicken Pty Ltd may disclose your information to:

• referees or previous employers;
• our related entities;
• law enforcement agencies to verify whether you have a criminal record;
• educational organisations to the extent necessary to verify your qualifications;
• specific third parties such as:
  • banks;
  • insurers and advisors;
  • credit agencies to conduct credit checks;
  • third parties as required to enforce our franchise agreement(s) and comply with the Franchising Code of Conduct;
  • as required to perform KFC’s role as franchisor.

14. Third party websites

KFC may offer links to websites that are operated by third parties.  If you visit one of these linked websites, you should review their privacy and other policies.  We are not responsible for the policies and practices of third parties.

15. Access and Correction of your Personal Information

You may, at any time, request access to and correction of any personal information we hold about you by contacting us (refer to the Privacy Queries and Complaints section below).   

If you make an access request, we may ask you to verify your identity and put your request in writing for security reasons.  We may charge a reasonable administration fee to cover the costs of meeting your request.

We take reasonable steps to ensure your personal information is accurate, up-to-date and not misleading by updating our records whenever changes to the data come to our attention.

16. Privacy Queries and Complaints 

If you have any questions or complaints about how we handle your personal information or a breach of the CNMI's privacy laws or wish to access or correct personal information we hold about you, please contact us at:

Management, KFC Saipan/J&G
Town House Shopping Center, Beach Road, Chalan Kanoa, Saipan 96950

Telephone: 234-6523 or 989-0110 

Website: www.kfcmarianas.com 

Our Management will consider your question or complaint and respond to you in a reasonable timeframe.

This Policy was last updated on April 23, 2020.