Privacy Policy

Effective Date: 11/18/2020

This Privacy Policy describes how JINYA Holdings, Inc., along with our subsidiaries and affiliates (collectively referred to as “JINYA Ramen Bar”, “we”, “us” or “our”), processes Personal Information when you use our websites, mobile applications, newsletters, restaurants or otherwise communicate with us (collectively, the “Services”). We are committed to ensuring the privacy and integrity of the Personal Information you share with us or we otherwise collect as we provide these Services. Throughout this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual.

1. Information We Collect

In most cases, we collect Personal Information directly from you. However, we may also obtain Personal Information about you from third parties or automatically when you interact with our business.
Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from the Services if that information is necessary to provide such Services or if we are legally required to collect it. Below is a description of the different types of Personal Information we process and the sources from which we obtain them:

  • Customer. The type of information we collect from our customers varies and may include information about:
    • Contact information, such as your name, postal address, e-mail address, and telephone number;
    • Names, postal addresses, e-mail addresses and telephone numbers of others to whom you ask us to send information;
    • Username and password to access our products and services online;
    • Payment information (such as payment card details, financial account information and billing address);
    • Online order history;
    • Information about your education, work and military history, legal work eligibility status, and other information relevant to specific jobs for which you may apply; and
    • Other personal information you may provide to us.
  • Business partners and vendors. We may receive contact details and payment information from business partners’ and vendors’ employees in furtherance of the relevant partner or vendor relationship.
  • Events. We collect Personal Information about you if you choose to register for an event sponsored by us. This Personal Information may include your name, address, title, company, phone number, and email address, as well as specific information relevant to the event for which you are registering.
  • Communications. If you choose to contact us for any purpose, we will collect your contact details, your name, and the content, date and time of your message, as well as our reply and any follow up action we take in relation to your inquiry.
  • Job applicants. If you apply for a job with us via our website, you will be asked to enter or upload personal information including, but not limited to, your first and last name, resume, phone, and email address. You may also provide additional personal information if you submit a job application at one of our restaurants including, but not limited to, employment history, references and educational background.
  • Other sources. We may receive Personal Information about you from other sources, including third parties that help us update, expand, and analyze our records, identify new customers, or prevent or detect fraud. We may also receive information about you from social media platforms, for example when you interact with us on those platforms or access our social media content. The information we may receive is governed by the privacy settings, policies, and/or procedures of the relevant social media platform, and we encourage you to review them.

2. Cookies and Similar Technologies

Through the use of cookies and similar technologies, we may collect your device IP address, unique device ID, hardware and software type, Internet service provider, serving domain, geographical area, location data, browser type and settings data (such as screen resolution, color depth, time zone settings, browser extension and plugins) operating system, referring URLs, search history, information on actions taken or interaction with our digital assets (e.g., page views) and dates and times of actions. The types of cookies we use include:

  • Google Analytics to collect information about how you use our Services. We use this information to create reports and improve our Services. The cookies help us understand the number of visitors to our website and where visitors come from. To learn more about how Google uses data when you use our Services, visit https://policies.google.com/technologies/partner-sites. To opt-out from these cookies across all websites, visit http://tools.google.com/dlpage/gaoptout. Most web browsers allow you to manage cookies through the browser settings. Be aware that, if you opt out from and do not agree to certain cookies, your experience on our Services may be diminished and some features may not work as intended depending on the cookie. To find out more about cookies, you can visit www.aboutcookies.org or www.allaboutcookies.org.

3. Use of Personal Information

We may use your Personal Information for the follow purposes:

  • To provide services to our customers, including.
  • For marketing purposes, including to send alerts, newsletters and other communications to our customers and business contacts.
  • To manage our business relationships with customers, vendors and suppliers, business partners and other contractors, including processing invoices and sending service-related communications.
  • For recruitment purposes, including to evaluate job applications and invite you for a job interview.
  • To communicate with you, and respond to your inquiries.
  • For other business purposes, such as to provide, operate and improve our products and services, perform data analyses, detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement, defend our legal rights, and comply with our legal obligations and internal policies.

4. Legal grounds for using Personal Information

If you are located in the European Economic Area, we only process your Personal Information when we can rely on a valid legal ground such as:

  • Execution of a Contract. We need your Personal Information to provide you with our Services, to operate our website, to evaluate your job application or to otherwise respond to your queries.
  • Compliance with a Legal obligation. We are required or allowed to collect and use your Personal Information, for example to detect fraud or to comply with our tax, accounting and anti-money laundering obligations.
  • Legitimate interest. We or a third party, have a legitimate interest in processing your Personal Information. For example, we have a legitimate interest in using your Personal Information to conduct business analytics or to improve the safety, security and performance of our products and services. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.
  • Consent. You have consented to the use of your Personal Information, for example to send you newsletters or for the use of certain cookies.

5. Disclosure of Personal Information

We may disclose Personal Information about you as described below:

  • With affiliates, subsidiaries, offices and representatives around the world as needed to provide legal services. With third party contractors engaged by us in the course of business (e.g., accountants, insurance companies, banks, auditors, legal counsel and other professional experts, advisors and/or consultants engaged by us).
  • With government agencies, regulators or courts, as required by applicable law and/or in the context of legal proceedings.
  • As necessary to provide services to our clients.
  • With event partners or co-sponsors.
  • With vendors and service providers who perform services on our behalf, including dealers, distributors, marketing and research agencies, with whom we have a direct contractual relationship.
  • If you post other information to our website or mobile application, such as comments, that information may be displayed and viewable by other users.
  • If you gave us your permission, or if we believe doing so is required or appropriate to (i) comply with laws, law enforcement requests, and legal process, such as a court order or subpoena; (ii) respond to your requests; or (iii) protect your, our or others’ rights, property, or safety.
  • In case of merger, sale, or other asset transfers.

6. Your Rights and Choices

Depending on applicable law, you may have some rights and choices with respect to your Personal Information. Those rights may be limited by local law requirements. You may exercise these rights by contacting us as specified below.

  • Events. To update or correct the information you provide to us via our website for an event sponsored by us, you may contact the event coordinator via email or telephone. You may also re-submit your Personal Information through the website by re-registering for the event.
  • Marketing. We allow you to opt out of future communications at any time by following the opt-out instructions contained in such communications.
  • European privacy rights. If you are located in the European Economic Area, you may have the following rights to the extent provided by law:
    • Request access to and receive information about the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have the information deleted, or exercise your right to data portability to easily transfer your Personal Information to another company.
    • Lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
    • Withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.
  • California Privacy Rights. If you reside in California and have provided your Personal Information to us, you may request information once per calendar year about our disclosures of certain categories of Personal Information to third parties for their direct marketing purposes, if any. Please see the “Rights For California Residents” section below for more information on your rights and how to submit a request.

7. International Data Transfers

We are a business with a corporate office in Burbank, CA. Your Personal Information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information. If you are located in the European Economic Area, we rely on contracts approved by the European Commission to transfer your Personal Information to our offices around the globe. In addition, we may transfer your Personal Information:

  • To countries that have been deemed to provide an adequate level of protection of Personal Information by the European Commission;
  • To partners and vendors by relying on contracts approved by the European Commission;
  • To U.S. based partners and vendors certified under the EU-U.S. Privacy Shield framework. You may contact us to obtain a copy of the safeguards we use to transfer Personal Information outside the European Economic Area.

8. Links to Other Websites

This website may link to websites maintained by outside organizations, including third-party social networks (such as Google+, Facebook, Twitter, LinkedIn) and our clients. Please be aware that these third-party websites are governed by their own privacy policies. Our firm is not responsible for the content or policies maintained by these websites. Please familiarize yourself with the privacy policy of any third-party website you visit, as it will govern any information you submit through that website.

9. Security

We maintain administrative, technical and physical safeguards that are intended to appropriately protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. However, because no information system can be 100% secure, we cannot guarantee the absolute security of your information.

10. Data Retention

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period.

11. Rights for California Residents

This section supplements our privacy policy with additional information for California residents only.  The California Consumer Privacy Act (“CCPA”) provides specific protections and rules with respect to California’s own definition of “Personal Information,” which includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.  Personal Information includes any health data that we collect from our guests and our employees in response to public health guidance or mandates from government authorities.  As noted above, we collect information that you provide directly when you register for or use the Services, user credentials that you supply directly when you register for or update your login information to use the Services, demographic data, payment data, device data, usage data, location data, information about your interests and preferences, third party integrations, and other third party data.

The Company’s Collection, Use and Disclosure of Personal Information

This section of the CA Privacy Policy describes, for the 12 months preceding the date last updated, above, (a) the categories of Personal Information we have collected about you, (b) the sources of that Personal Information, (c) the business and commercial purposes for use, and (d) the categories of third party recipients of your Personal Information. Unless we inform you otherwise, this section also serves as our “Notice at Collection” by informing you of your Personal Information to be collected in the future and the purposes for its use.

Categories of Personal Information Collected

In the last 12 months, Company collected the following categories of Personal Information about California Consumers:

  • Identifiers, including: real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, telephone number, signature, age, company
  • Commercial information, including: products and services purchased or considered, date and location of purchase, purchase price, purchase history, and purchase tendencies, and record of personal preferences
  • Internet or other electronic network activity information, including: browsing history, search history, web site interaction information, application interaction data, advertisement interaction data, internet service provider, name and version of operating system, name and version of browser, date and time of visit, pages visited, and geolocation
  • Sensory information, including: photos, and video surveillance
  • Professional and Employment information, including: professional information and employment information
  • Financial Information, including: credit, debit and gift card data, and related payment information.
  • Profile information, including: Customer feedback on surveys, attitudes collected from open-ended comments left by users on Company website, purchasing patterns, store location preferences (including how often you visit and when you visit), and other consumer preferences

Sources of Personal Information and Purposes for Using Personal Information

In the last 12 months, Company collected the categories of Personal Information listed above from the following sources: (1) Customers; (2) Website Users and used those categories of Personal Information for the following purposes:

Categories of Personal Information Collected in the Last 12 Months Sources of that Personal Information Business Purposes and Commercial Purposes for Collecting that Personal Information

Identifiers
Real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, telephone number, signature, age, company

Directly from Customers;(2) Website Users
  • to provide customer service,
  • to fulfill and process orders
  • to provide products, information and services requested by customers
  • display personalized advertisement when on our site or a third-party website
  • to facilitate communication, including communicate with you about special offers, promotions, marketing, to participate in surveys, contests, and other information that may be of interest to you
  • to communicate with you about information and notices to your use of our site
  • to detect and prevent security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and assist in prosecuting those responsible for that activity.
  • undertake activities to maintain the quality of our products and services
  • to improve our products and services
  • to invite you to participate in surveys and provide feedback to us
  • to understand your needs and interests better
  • to improve content, functionality, and usability of our sites
  • improve our marketing and promotional efforts
Commercial information
Products and services purchased or considered, date and location of purchase, purchase price, purchase history, and purchase tendencies
Directly from Customers;(2) Website Users
  • to provide customer service,
  • to fulfill and process orders
  • to provide products, information and services requested by customers
  • undertake activities to maintain the quality of our products and services
  • to improve our products and services
  • to understand your needs and interests better
  • improve our marketing and promotional efforts
Internet or other electronic network activity information
Browsing history, search history, web site interaction information, application interaction data, advertisement interaction data, internet service provider, name and version of operating system, name and version of browser, date and time of visit, pages visited, and geolocation
From: (1) Automated technologies deployed from website;(2) Website Users
  • display personalized advertisement when on our sites or a third-party website
  • to detect and prevent security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and assist in prosecuting those responsible for that activity
  • to understand your needs and interests better
  • to improve content, functionality, and usability of our sites
  • improve our marketing and promotional efforts
Sensory information
Photos, and video surveillance
From: (1) Surveillance cameras at store locations;(2) Social Media
  • Undertaking internal research for technological development and demonstration.
  • Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting impressions to unique visitors, verifying positioning and quality of impressions, and auditing compliance with the law.
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  • Pictures and or comments that are either taken by us, our vendors or retrieved on social media to use for public relations and or goodwill
Professional & Emplyoment Information
Photos, and video surveillance
Directly from: (1) Customers; (2) Website Users
  • Employment and recruiting including for interview purposes, selecting candidates, payroll administration and employee timekeeping, benefit administration, creation of tax forms, office administration, business expense processing, industry benchmarking, and internal communications
  • to detect and prevent security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and assist in prosecuting those responsible for that activity
  • improve our marketing and promotional efforts
Financial Information
Credit, debit and gift card numbers, and related payment information
Directly from: (1) Customers; (2) Website Users
  • to fulfill and process orders
  • to verify information
  • to provide products, information and services requested by customers
  • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, and providing analytic services.
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
Profile Information
Customer feedback on surveys, attitudes collected from open-ended comments left by users on Company website, purchasing patterns, store location preferences (including how often you visit and when you visit), and other consumer preferences
Directly from: (1) Customers; (2) Website Users
  • to provide products, information and services requested by customers
  • undertake activities to maintain the quality of our products and services
  • to improve our products and services
  • to invite you to participate in surveys and provide feedback to us
  • to understand your needs and interests better
  • to improve content, functionality, and usability of our sites
  • improve our marketing and promotional efforts

Disclosure Of Personal Information To Third Parties

In the last 12 months, Company disclosed the following categories of Personal Information about California Consumers to the following categories of third parties for a business or commercial purpose:

Category of Personal Information Categories of Third Parties to Whom We Disclose Categories of Personal Information for a Business Purpose in the Last 12 Months
Identifiers
Real name, alias, postal address, email address, telephone number, age
  • website support service providers
  • marketing and advertising service providers
  • online ordering and delivery service providers
  • reservation service provider
  • payment processing service provider
  • Government agencies, law enforcement, and other parties as required by law, including in litigation
Commercial Information
Products and services purchased or considered, date and location of purchase, purchase price, purchase history, and purchase tendencies
  • website support service providers
  • marketing and advertising service providers
  • online ordering and delivery service providers
  • reservation service provider
  • payment processing service provider
  • Government agencies, law enforcement, and other parties as required by law, including in litigation
Internet or Other Electronic Network Activity Information
Browsing history, search history, web site interaction information, application interaction data, advertisement interaction data, internet service provider, name and version of operating system, name and version of browser, date and time of visit, and pages visited
  • website support service providers
  • marketing and advertising service providers
  • Government agencies, law enforcement, and other parties as required by law, including in litigation
Sensory information
Photos, and video surveillance
  • Government agencies, law enforcement, and other parties as required by law, including in litigation
Professional or Employment information
Professional information, employment-related information
  • Government agencies, law enforcement, and other parties as required by law, including in litigation
Financial Information
Credit, debit and gift card numbers, and related payment information
  • marketing and advertising service providers
  • online ordering and delivery service providers
  • payment processing service providers
  • Government agencies, law enforcement, and other parties as required by law, including in litigation
Preference Information
Purchasing patterns, store location preferences (including how often you visit and when you visit), and other consumer preferences
  • website support service providers
  • marketing and advertising service providers
  • online ordering and delivery service providers
  • reservation service provider
  • Government agencies, law enforcement, and other parties as required by law, including in litigation

California law requires that we describe the personal information we collect about California consumers, including by identifying specific categories of information.

Sale Of Personal Information To Third Parties

While we do not sell (as “sell” is traditionally defined) your personal information to data brokers in exchange for money. We disclose limited identifiers in order to provide you with relevant and personalized advertisements through our advertising partners.

Financial Incentives

We provide financial incentives through our E-Club to consumers who allow us to retain and disclose their Personal Information, including the following categories: unique identifier, purchase history, geolocation data, and protected class information. These incentives may include payments to consumers (e.g., free food), and a lower price for goods or services (e.g., discounts).

YOUR CALIFORNIA PRIVACY RIGHTS

a) Right to Know

California Consumers have the right to submit a verifiable request to know:

  • The categories and specific pieces of Personal Information that Company has collected about them;
  • The categories of sources from which Company collected the Personal Information;
  • The categories of Personal Information that Company sold or disclosed to a third party (other than a service provider) for a business purpose and the categories of recipients of that information.
  • The business or commercial purposes for Company’s collection, disclosure, or sale of the Personal Information.

b) Right To Delete

  • California Consumers have the right to submit a verifiable request for deletion of their Personal Information that Company has collected from the Consumer.

c) Right to Opt Out of Sale of Personal Information

  • California Consumers have a right to opt-out of the sale of the Personal Information.

HOW TO EXERCISE YOUR RIGHTS

a) Making Right to Know or Right to Deletion Requests

Company will respond to requests in accordance with applicable law if it can verify the identity of the individual submitting the request. California Consumers can exercise their rights in the following ways:

b) Making Right to Opt Out of Personal Information Sales Requests

To opt out of the sale of your personal information, you may submit a request to us by visiting https://www.jinyaramenbar.com/your-privacy-choices/. Alternatively, you can click here: YOUR PRIVACY CHOICES.

12. Changes to This Policy

We may make changes to this Privacy Policy. The “Last updated” date at the top of this page indicates when this Privacy Policy was last revised. If we make material changes, we may notify you via a notice posted on our website or other method. We encourage you to read this Privacy Policy periodically to stay up-to-date about our privacy practices.

13. Contact Us

If you have any questions about this Privacy Policy, you may contact us here

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