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PRIVACY POLICY
Effective Date: April 7th,
2025
1. INTRODUCTION
This Privacy
Policy, together with the RightBytes Platform Privacy Addendum set forth below,
(collectively "Policy") applies to the National Checking Company
(d/b/a NCCO) mobile, web and kiosk applications collectively known as RightBytes, which include EatSuite,
InsightsAI, CompassAI, InsightsLite, TaskBytes, InstaMenu, StockSmart, Waste
Tracking, and DishPatch (collectively, the “Apps”). The Apps are used by
businesses and their authorized personnel to manage menus, inventory, operational
tasks, compliance activities, reporting, and related functionality, and also
support food ordering by end users through deployed hardware in convenience
stores, restaurants, and similar environments. This Policy describes how
National Checking Company (d/b/a NCCO) ("we," "us," or
"our") collects, uses, stores, and shares your information when you
use our Apps. By downloading, accessing, or using our Apps, you agree to the
collection and use of your information in accordance with this Policy. If you
do not agree with the terms of this Policy, please do not use our Apps.
2.
INFORMATION WE COLLECT OR RECEIVE
In the course of operating the Apps,
we collect and/or receive the following types of information:
2.1 Personal Information
Personal information is information that identifies
you or could reasonably be used to identify you personally, such as your name,
email address, phone number, and postal address. We collect personal
information when you voluntarily provide it to us, such as when you create an
account, place an order, or contact our customer service.
2.2 Payment Information
When you make a purchase through our Apps, we collect
payment information, which may include credit card numbers, billing addresses,
and other financial account information. This information is processed through
our secure payment processors, and we do not store complete credit card
information on our servers. We are not responsible for any payment matters, and
do not collect or store any payment information.
2.3 Geolocational Information
With your consent, we may collect precise location
information from your mobile device or the kiosk running the Apps when you use
our App. This helps us provide location-based services, such as finding nearby
participating stores, identifying special menu items, delivery options, and
special offers. You can disable location services through your device settings,
but this may limit certain features of our Apps.
2.4 Usage Information
2.4.1 Information From Your Activity
We automatically collect information about your
interactions with our Apps, including:
·
IP address, which may consist of a static
or dynamic IP address and will sometimes point to a specific identifiable
computer or device
·
Browser type and language
·
Referring and exit pages and URLs
·
Date and time of your visit
·
Details regarding your activity on the
Apps, such as search queries, ordering history, and other performance and usage
data
2.4.2 Mobile Device Information
When you use our mobile app, we may collect
information about your mobile device, including:
·
Device type and model
·
Operating system and version (e.g., iOS,
Android)
·
Unique device identifiers (such as IDFA or
AdID)
·
Mobile carrier
·
Network type (WiFi, 3G, 4G, 5G)
2.4.3 Cookies and Similar
Technologies
We use cookies, pixel tags, web beacons, and similar
technologies to collect information about how you use our Apps. These
technologies help us:
·
Remember your preferences and settings
·
Understand how you interact with our Apps
·
Analyze which portions of our Apps are
visited and used most frequently
·
Measure and optimize advertising and
promotional effectiveness
You can set your browser or device to refuse all
cookies or to indicate when a cookie is being sent. However, some features of
our Apps may not function properly if cookies are disabled.
3.
HOW WE USE YOUR INFORMATION
We use the information we collect for various
purposes, including to:
3.1 Provide and
Improve Our Services
· Process
and fulfill your food orders
· Enable
businesses to create and update their food menus
· Provide
customer support and respond to your inquiries
· Improve
and optimize our Apps and services
· Develop
new features and functionality
3.2 Personalization
· Personalize
your experience with our Apps
· Recommend
products, services, or features that may interest you
· Provide
location-based services and content
3.3 Communication
· Send
you transactional messages about your orders or account
· Payment
processing associated with your orders or account
· Provide
updates about our services
· Deliver
promotional offers, newsletters, and marketing communications (subject to your
preferences)
· Solicit
feedback about our Apps and services
3.4 Security and
Compliance
· Protect
the security and integrity of our Apps
· Prevent
and address fraud, unauthorized use, and other illegal activities
· Enforce
our Terms of Service and other policies
· Comply
with applicable laws, regulations, and legal processes
3.5 Hardware
· The
Apps may include deployed hardware, and collect information related to device
health, telemetry, and operational logging used for reliability, security, and
support.
4.
HOW WE SHARE YOUR INFORMATION
We may share your information in the following
circumstances:
4.1 Service
Providers
We
share information with third-party service providers who perform services on
our behalf, such as:
· Payment
processors to process transactions
· Cloud
storage providers to store our data
· Analytics
providers to help us understand user behavior
· Marketing
and advertising partners to promote our services
· Delivery
services to fulfill food orders
These
service providers are contractually obligated to use your information only as
necessary to provide services to us and in accordance with this Privacy Policy.
4.2
Participating Businesses
When you place an order through our Apps, we share
necessary information with the relevant business (e.g., convenience store or
restaurant) to fulfill your order. This may include your name, order details,
delivery address (if applicable), and contact information.
4.3 Business
Transfers
If we are involved in a merger, acquisition,
financing, reorganization, bankruptcy, or sale of our assets, your information
may be transferred as part of that transaction. We will notify you of any such
change in ownership or control of your personal information.
4.4 Legal
Requirements
We may disclose your information if
required to do so by law or in response to valid requests by public authorities
(e.g., a court or government agency). We may also disclose your information to:
· Enforce
our Terms of Service and other agreements
· Protect
and defend our rights and property
· Prevent
or investigate possible wrongdoing in connection with our Apps
· Protect
the personal safety of users of our Apps or the public
4.5
With Your Consent
We may share your information with third parties when
you have given us your consent to do so.
5. THIRD-PARTY
ADVERTISING AND ANALYTICS
5.1.1 Third-Party Advertising
We may allow third-party advertising companies to
collect information about your activity on our Apps to display targeted
advertisements to you on our Apps and on third-party websites and applications.
These companies may use cookies, web beacons, and other technologies to collect
information about your use of our Apps and other websites and applications.
5.1.2 Analytics
We use third-party analytics services, such as Google
Analytics, to help us understand how users engage with our Apps. These services
may use cookies and similar technologies to collect information about your use
of our Apps and report website trends.
5.2 How to Opt Out
You can opt out of third-party interest-based
advertising through your device settings or by visiting industry opt-out pages,
such as:
· Digital
Advertising Alliance (DAA): http://www.aboutads.info/choices/
· Network
Advertising Initiative (NAI):
· http://www.networkadvertising.org/choices/ Mobile Device Opt-Out
· Android
Users: For Android devices with OS 2.2 and up and Google Play Services version
4.0 and up, open the Google Settings app, select Ads, and then select "Opt
out of interest-based advertising."
· iOS
Users: For iOS 7 or higher, go to Settings> Privacy> Advertising, and
toggle "Limit Ad Tracking" to the "on" position.
6. DATA
SECURITY
We implement reasonable and appropriate technical and
organizational measures to protect your information against unauthorized
access, alteration, disclosure, or destruction. However, no method of
transmission over the Internet or electronic storage is 100% secure. Therefore,
while we strive to use commercially acceptable means to protect your
information, we cannot guarantee its absolute security.
7. DATA
RETENTION
We retain your information for as
long as necessary to fulfill the purposes outlined in this Privacy Policy,
unless a longer retention period is required or permitted by law. When
determining how long to retain information, we consider the amount, nature, and
sensitivity of the information, the potential risk of harm from unauthorized
use or disclosure, and the purposes for which we process the information.
8. YOUR
RIGHTS AND CHOICES
8.1 Account Information
You can review, update, or delete your account
information by logging into your account settings. If you cannot access certain
information or have questions about the information we have on file about you,
please contact us using the information provided in the "Contact Us"
section below.
8.2 Communication Preferences
You can opt out of receiving promotional emails from
us by following the unsubscribe instructions in those emails. Even if you opt
out, we may still send you non-promotional communications, such as those about
your account or our ongoing business relations.
8.3 Mobile Push Notifications
We may send push notifications to your mobile device.
You can disable these notifications by changing the settings on your mobile
device.
8.4 Location Information
You can prevent us from collecting precise location
information by changing the location settings on your mobile device, but this
may limit your ability to use certain features of our Apps.
8.5 Cookies and Similar Technologies
Most web browsers are set to accept cookies by
default. You can usually set your browser to remove or reject cookies, but this
may affect the availability and functionality of our Apps.
9. CHILDREN'S
PRIVACY
Our Apps are not directed to children under the age of
13, and we do not knowingly collect personal information from children under
13. If we learn that we have collected personal information from a child under
13, we will promptly delete that information. If you believe we might have any
information from or about a child under 13, please contact us using the
information provided in the "Contact Us" section below.
10.
STATE PRIVACY RIGHTS
10.1 Do Not
Track
Some browsers have a "Do Not Track" feature
that signals to websites that you visit that you do not want your online
activity tracked. Our Apps do not currently respond to "Do Not Track"
signals.
10.2 Additional
State Privacy Rights
10.2.1 Some
states provide you with additional rights regarding our use of your personal
information. The following describes
state specific rights, which may or may not apply to Company and your use of
the Websites.
10.2.2
California's "Shine the
Light" law (Civil Code Section § 1798.83) permits California residents to
request certain information, under certain circumstances, regarding our
disclosure of personal information to third parties for their direct marketing
purposes. To make such a request, please
contact the address listed below in the Contact Information section of this
Policy, and Company will respond to the extent applicable.
10.2.3
Collection Notice – This Privacy
Policy is our Notice at Collection as required under the California Privacy
Rights Act, and any other applicable law, and this Privacy Policy describes the
personal information categories we collect, the purpose we collect and use
personal information, and the retention periods for each personal information
category. We do not collect sensitive
personal information, and we do not sell personal information as those terms
are defined under California and other privacy law.
10.2.4 Colorado, California,
Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee,
Texas, Virginia, and Utah each provide their state residents with rights to:
·
Confirm whether we process their personal
information.
·
Access and delete certain personal
information.
·
Data portability.
·
Opt-out of personal data processing for
targeted advertising and sales.
·
Correct inaccuracies in their personal
information, taking into account the information's nature processing purpose.
·
Opt-out of profiling in furtherance of
decisions that produce legal or similarly significant effects.
·
Either limit (opt-out of) or require
consent to process sensitive personal data.
Nevada provides its residents with a limited right to
opt-out of certain personal information sales.
10.2.4
To make a request under any of the
foregoing, please contact the address listed below in the Contact Information
section of this Policy, and we will respond to the extent applicable. By listing these provisions, we are not
agreeing to comply with theses law, unless Company is separately obligated
under the terms of these laws to so comply.
10.2.6 Minnesota Residents
Privacy Rights
(a)
We provide methods for Minnesota residents
to exercise their rights under the Minnesota Consumer Data Privacy Act (MCDPA).
(b)
The MCDPA grants Minnesota residents
certain rights with respect to their personal information. These rights may be
exercised by a Minnesota resident through the contact information listed below.
(c)
Please note that requests made under the
MCDPA will not apply to data exempt from the requirements of the MCDPA, such as
publicly available data, data lawfully obtained from a governmental
entity, data the consumer has made
available to the general public, data subject to the Fair Credit Reporting Act,
the Health Insurance Portability and Accountability
Act, the Gramm-Leach-Bliley Act, the
Driver's Privacy Protection Act (DPPA), and certain other laws. Additionally,
data may be exempt if it is deidentified.
(d)
You may request a State Privacy
Act Report containing your personal information collected and
sold or disclosed for a business purpose. The Report will contain (i) the
categories of personal information we collected about you and the categories of
sources from which we collected such information; (ii) the specific pieces of
personal information we collected about you; (iii) the business or commercial
purpose for collecting or selling personal information about you; and (iv) the
categories of personal information about you that we sold or disclosed for a
business purpose and the categories of third parties to whom we sold or to whom
we disclosed for a business purpose such information. You may also request that
we disclose to you, as required by law, the third parties to whom we have
disclosed your personal data.
(e)
Your Opt-Out Rights - you may make an
opt-out request to restrict data subject to the MCDPA from being processed for
(i) targeted advertising, (ii) the sale of personal data, and (iii) profiling
in furtherance of solely automated decisions that produce legal or similarly
significant effects concerning you, if applicable. In some instances, you may
request the deletion of your personal information. Some exemptions apply to the
right to deletion. You have the right to
request the correction of inaccurate personal information maintained about you.
You have the right to not be discriminated against in pricing and services
because you exercise any of your rights under the MCDPA. To submit a request
contact us at the address below.
11.
INTERNATIONAL USERS
Our Apps are operated in the United
States. If you are located outside of the United States, please be aware that
information we collect will be transferred to, processed, and stored in the
United States. The data protection laws of the United States may differ from
those of your country of residence. By using our Apps, you consent to the
transfer of your information to the United States and the use and disclosure of
your information as described in this Privacy Policy.
12. KIOSK-SPECIFIC
PRIVACY CONSIDERATIONS
12.1 Public Use
Environment
Our kiosk applications are typically installed in
public locations such as convenience stores. Please be aware of your
surroundings when entering personal information on a kiosk. We recommend taking
appropriate precautions to protect your privacy when using our kiosk
applications in public settings.
12.2 Session
Data
Our kiosk applications are designed to clear user
session data after each transaction or after a period of inactivity. However,
we recommend manually canceling your session if you decide not to complete a
transaction.
12.3 Payment
Processing
When making payments through our mobile applications
or kiosks, payment information is transmitted securely via encrypted
connections and processed by third-party payment processors. Neither the mobile
applications nor the kiosk applications store complete payment card information
locally on the device or within National Checking Company (d/b/a
NCCO)-controlled systems.
13. CHANGES
TO THIS PRIVACY POLICY
We
may update this Privacy Policy from time to time to reflect changes in our
practices or for other operational, legal, or regulatory reasons. We will post
the revised Privacy Policy on our Apps with an updated effective date. We
encourage you to review the Privacy Policy whenever you access our Apps to stay
informed about our information practices. Your continued use of our Apps after
the posting of changes constitutes your acceptance of such changes.
14.
CONTACT US
If you have any questions, concerns, or requests
regarding this Privacy Policy or our privacy practices, please contact us at:
National Checking Company (d/b/a NCCO)
Email: [email protected]
Phone: 1-800-328-6508
Address: 899 Montreal Circle St. Paul, MN 55102
We will make every effort to respond to your inquiry
in a timely manner.
RightBytes Platform Privacy Addendum
This
Addendum supplements the primary Privacy Policy and applies specifically to the
RightBytes platform, which is a business-to-business software and hardware
solution used by merchants, operators, and their authorized personnel.
Scope
and Audience This Addendum applies to:
· Business
customers using the RightBytes platform
· Authorized
employees, operators, and administrators of those businesses
· Devices
deployed as part of the RightBytes solution (including tablets, kiosks,
scanners, and related hardware)
· This
Addendum does not replace the consumer-facing privacy disclosures applicable to
end users placing food orders through white-labeled applications.
Business User and
Operational Data
In connection with providing the
RightBytes platform, we may collect and process businessrelated and operational
data, including:
· User
account credentials and role-based permissions
· Employee
actions within the system (e.g., task completion, acknowledgements, menu
updates)
· Operational
and compliance data (e.g., inventory activity, temperature logs, audit records)
· Support
and troubleshooting information
This information is used solely to provide, maintain,
secure, and improve the RightBytes platform and related services.
Hardware, Device,
and Telemetry Data
RightBytes includes physical devices deployed at
customer locations. In connection with those devices, we may collect limited
technical and operational data, such as:
· Device
identifiers and configuration details
· Device
health, connectivity status, and error logs
· Usage
and performance metrics necessary for reliability, security, and support
This data is used for system functionality,
diagnostics, security, and customer support purposes and is not used for
consumer advertising.
Shared and Public
Device Environments
Some RightBytes devices operate in shared or public
environments. The platform is designed to:
· Clear
user sessions after inactivity or completion of workflows
· Limit
persistent storage of user-specific data on local devices
· Rely
on secure, centralized systems for data storage and processing
Customers are responsible for managing user access and
permissions within their organizations.
Data
Roles and Responsibilities Depending
on the context:
· RightBytes
may act as a data processor on behalf of business customers, and
· Business
customers may act as the data controller with respect to employee or
operational data entered into the system.
Data is processed in accordance with contractual
agreements and applicable law.
Retention and
Access
Business and operational data is retained for periods
necessary to:
· Provide
the service
· Meet
contractual and regulatory requirements
· Support
audit, compliance, and troubleshooting needs
Authorized business users may access, correct, or
request deletion of data in accordance with applicable agreements and law.
No Consumer
Advertising Use
Data collected through the RightBytes platform is not
used for third-party consumer advertising purposes.
End of Addendum