This Privacy Policy explains how Kings Hawaiian (“KH”) may collect, use, and share related to customer panel, survey, and marketing related activities associated with websites officially operated or sponsored by KH (the “Sites”).

1.Changes to the Privacy Policy As KH evolves its efforts at engaging the industry, consumers, and those interested in topics relevant to KH, this Privacy Policy may change to reflect this evolution. We reserve the right to amend the Privacy Policy at any time, for any reason. The date of the last revision to the Privacy Policy will be indicated by the “Last updated” date at the bottom of this page.

2.Information We Collect 

2.1.Personal Information: We may collect information (whether online, by phone, or by paper) that identifies you or relates to you, your interests, or your preferences (“Personal Information”) when you: provide such information on our Sites, apply or register for KH surveys, panels, or otherwise interact with KH. The types of Personal Information collectedmay include your name, address, phone number, birth date, Email address, information about your personal opinions, or other demographic and customer preference information.Note that cookies, tags and other tools placed by third parties may collect information about you and your visits to Sites and elsewhere on the Internet including, but not limited to: your industry, company size, job function, or seniority level. 

2.2.Navigational Data: As you interact with our Sites, we, or our service providers, may also collect information about your browsing history or certain other information through your use of, and visits to, Sites; and our use of a variety of technologies, including, but not limited to: cookies, tags, beacons, Internet Protocol (IP) address, and other tools. “Cookies” are pieces of code/text placed on your computer when you browse our Sites. Cookies may be placed by us or third party advertisers. “Tags” and web beacons refer to code scripts that are primarily used to track visitors’ activities on our Sites by web analytics software. The types of Navigational data collected on our Sites through the use of these, and other tools as KH may add from time to time, may include: the search terms you used, new or returning user, browser information, computer type, operating system, internet service providers, website usage, referring/exit pages, platform type, date/time stamp, number of clicks, ads viewed, etc. (collectively, all of the foregoing data the “Navigational Data”). 

3.How We Use and Share Personal Information 

3.1.Once collected, we may use your Personal Information in a variety of ways including: (a)Develop or improve KH products and services; (b)Understand customer preferences, including geographical variations in such preferences; (c)Provide service communications such as order confirmations, program registrations, and customer service messages; (d)Respond to your emails or online requests for products, services, or information; (e)Deliver and process surveys; (f)Personalize and improve the usability of the Sites; (g)Fulfill and/or deliver KH products and services; (h)Sharing with certain other companies to offer you products and services that may be of interest to you as described below; (i)Tailor content, advertising, and marketing to you; (j)Share with third parties as required by law, or to protect KH as described below; and (k)Share your email address, as permitted under KH Email Policy as described below. 

3.2.Sharing Your Personal Information to Fulfill Service Requests and Perform Business Functions. When fulfilling service requests initiated by you, we may share your Personal Information with certain third parties to fulfill the requests. We may also share such information with service providers that perform business functions for us. For example, KH occasionally hires other companies to provide limited services on our behalf including, but not limited to: website hosting, survey management, and social media enablement; answering customer questions about products or services; consulting services; data modeling; printing; sending postal mail; and processing panel registrations.In such cases, KH may share your Personal Information as needed. 

3.3.Sharing Your Personal Information with Certain Other Companies. KH may share Personal Information with certain other companies in order to provide them an opportunity to offer products or services that may be of interest to you. 

3.4.Sharing Your Personal Information When Legally Necessary or to Protect KH’s Interests. KH may disclose your Personal Information if required to do so by law or in the good-faith belief that such action is necessary to: (a) conform to legal requirements or comply with legal process served on KH; (b) protect and defend the rights or property of KH; or (c) protect the personal safety of KH personnel or members of the public in appropriate circumstances. In addition, if KH and/or its assets (or a portion of its assets) are sold, assigned, transferred, or merged, or if KH undergoes some other change including a change to its corporate form as part of a bankruptcy proceeding or otherwise, information may be transferred as part of that transaction or change. 

4.How to Manage the Sharing of Your Personal Information You can manage your profile and e-mail preferences, including opting out of e-mail either online or by contacting us. Additionally, if you prefer to receive mailings only from KH and have your name and address removed from lists we maintain, please contact us. For California residents, please consult the “Your California Privacy Rights” for additional considerations. 

5.How We May Use and Share Navigational Data Through the use of various technological tools, we may collect Navigational Data to improve the usability of our Sites and for other business reasons. We may share the Navigational Data we collect with third parties; or permit third parties to place tools like cookies, tags, and web beacons to collect additional Navigational Data when you browse our Sites. We or other third party companies may then use the Navigational Data to provide advertisements and targeted advertisements to you (ads based on the Navigational Data). Please note that you may be subject to the privacy policies of other non-KH companies when you select an advertising link or other link that takes you to sites not operated by KH.

The major browsers have attempted to implement the draft “Do Not Track” (“DNT”) standard of the World Wide Web Consortium (“W3C”) in their latest releases. As this standard has not been finalized, KH’s Sites are not compatible with DNT and so do not recognize DNT settings.

6.Cross Border Use and Sharing of Personal Information As part of your registration or other use of the Site, KH will process your Personal Information in countries which may not be your country of residence. By submitting your registration information or otherwise using the Site, you agree that your Personal Information may be processed in a country which may have lower privacy protections under local law than your country of residence. Should you not agree to such processing, please do not register for an event or otherwise use the Site.

7.California Privacy Rights California's Civil Code section 1798.100 et seq. provides residents of California a number of rights as they relate to Personal Information. These are the “right to know”, the “right to delete”, and the “right to opt-out”. 

7.1.Right to Know. You may request KH provide you the specific pieces of Personal Information that KH has about you; categories of Personal Information we have collected about you; categories of sources from which the Personal Information is collected; categories of Personal Information that KH sold or disclosed for a business purpose about you; categories of third parties to whom the Personal Information was sold or disclosed for a business purpose; and the business or commercial purpose for collecting or selling Personal Information. Please note that much of the information you can make a request for is already contained in this Policy. Should you wish to exercise this right, please see the section below which explains how to do so. If you do not have an account with KH, we may ask for some Personal Information in order to verify your identity and your rights to the data subject to your request. 

7.2.Right to Delete. California law gives residents a limited right to request deletion of their Personal Information. However, this right is limited by a number of exceptions. Fundamentally, if KH has a permissible need to retain Personal Information, we are not under an obligation to delete such information, even when requested. Generally, we retain Personal Information so we may complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; debug to identify and repair errors that impair existing intended functionality of our online properties; enable solely internal uses that are reasonably aligned with your expectations based on your relationship with KH; comply with a legal obligation; or otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which your provided the information. As such, we generally do not accept requests to delete Personal Information. However, we will respond to requests to remove Personal Information from some of our systems as a part of a request to close or otherwise disable a membership account. If you would like to request deletion of Personal Information, please see the section below which explains how to do so. If you do not have an account with KH, we may ask for some Personal Information in order to verify your identity and your rights to the data subject to your request.

7.3 Right to Opt-Out. If you would like to opt-out of any sale of your Personal Information, you may do so by contacting us as specified in section 11.

7.4.Designating an Authorized Agent. California law permits California residents to designate an agent to manage their rights under California law. If you would like to designate an agent to manage your privacy preferences, you may do so using the mechanisms noted below under “Exercising California Privacy Rights”. Note that If you do not have an account with KH, we may ask for some Personal Information in order to verify your identity and your rights to the data subject to your request. We will also need sufficient Personal Information about your authorized agent to be able to identify them. As part of this process, you must have permission from your authorized agent to disclose their Personal Information to us for the purpose of acting as your agent. 

7.5.Non-discrimination. California law does not permit KH to discriminate against you because you exercised any your rights under this title, including, but not limited to, by: denying you access to goods or services; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level or quality of goods or services; suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. 

7.6.Exercising California privacy rights. If you are a California resident and would like to exercise any of your rights you may do so by contacting us via the methods noted above in the section 11 below. Please be aware that KH will need to have sufficient information to be able to verify your identity and the rights you have in the data subject to your request. 

8.Canada Anti-Spam Law (“CASL”) KH complies with CASL. Registrants who have provided us a Canadian mailing address will not receive unauthorized Commercial Electronic Messages (“CEM” as defined under CASL) unless these individuals have opted-in to receive CEM.

9.Information Security KH implements commercially reasonable security measures to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. We restrict access to personal information to certain companies who may need to know that information in order to operate, develop, or improve our services. These individuals or partner organizations are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. Accordingly, and despite our efforts, KH cannot guarantee or warrant the security of any information you transmit to us, or to or from our online products or services. If you have questions about this Privacy Policy, please contact us.

10. Linking to Other Internet Sites You should be aware that other Internet sites that are linked from the Sites or from an KH email message may contain privacy provisions that differ from the provisions of this Privacy Policy. To ensure your privacy is protected, we recommend that you review the privacy statements of these other linked sites, applications, or other digital platforms.

11. How You Can Access and Change Information If you are a registered participant of a panel or community, subscriber to KH publications, or a purchaser of KH products and services, you may review and update/correct your information directly on the event’s website, or by contacting us at:

moderator@theohanacircle.com
King's Hawaiian, 1411 W. 190th Street, Suite 500, Gardena, CA 90248

Last updated November 21, 2019