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Red Lobster

Privacy Policy

1. Introduction
IControl Systems USA, LLC dba iControl Data Solutions (“iControl”, “we”, “us” or “our”) provides
data synchronization and B2B payment outsourcing for food, drug, convenience and restaurant
retailers and the vendors who service them. This Privacy Policy describes our practices
concerning the information we receive or collect when you visit our website located at (“Website”) or access our online platform through a sister-link or
through the website of one of our partners (collectively, “Services”). Specifically, it describes
the information we collect, how and for which purposes we may use such information, where
we store it and for how long we retain the information, with whom we may share it, our use of
tracking technologies and communications, our security practices, your choices and rights
regarding such information, our policy concerning children, and how to contact us if you have
any concerns regarding this Policy or your privacy.
Please read this Privacy Policy and make sure that you fully understand and agree to it. If you
do not agree to this Policy, please discontinue and avoid using our Services.

2. Information Collection
We collect the following main categories of information (and to the extent one or more of them
may enable the identification of a specific person or is linked to such potentially identifying
data, we will deem it “Personal Information”):
Information You Provide. You may provide us Personal Information such as your name, e-mail
address, phone number, and hashed password when you use our Services, create a user
account, or contact us. If you choose to make any payments via our Services, you may also
provide us with your payment information and preferences, as well as information about any
vendors receiving payment.
Information We Collect Automatically. When you visit, interact with or use our Services, we
may collect certain technical data about you. We collect or generate such data either
independently or with the help of third party services, including through the - 2 -
use of “cookies” and other tracking technologies (as further detailed in Section 6 below). Such
data consists of sensor, location, connectivity, technical and aggregated usage data, such as
your GPS/GNSS location data; home and work locations; IP addresses, wireless networks, cell
towers and Wi-Fi access points; non-identifying data regarding a device, operating system, and
browser; activity, communication, and performance logs; issues and bugs; and user activity on
our Services. This data does not enable us to learn your true identity or contact details, and
serves mostly to improve the overall performance of our Services, and to better understand
how our users typically use our Services and how we could improve their user experience.
Information from Third Parties. We may receive information about you from third parties. For
example, we may receive information about you from outside records of third parties, such as
marketing-related or demographic information. We may supplement the information we collect
about you through the Website and the Services with such information from third parties in
order to enhance our ability to serve you, to tailor our content to you and/or to offer you
opportunities to purchase products or services that we believe may be of interest to you. If we
combine such data with information we collect through the Website or the Services, such
information is subject to this Privacy Policy unless we have disclosed otherwise.

3. Information Use
We use your Personal Information as necessary for the performance of our Services; for
complying with applicable law; and based on our legitimate interests in maintaining and
improving our Services and offerings, understanding how our Services are used, optimizing our
marketing, customer service and support operations, and protecting and securing our users,
ourselves, and members of the general public.
Specifically, we use Personal Information for the following purposes:
• To facilitate, operate, and provide our Services;
• To authenticate the identity of our users, and to allow them to access and use our Services;
• To provide our users with assistance and support;
• To further develop, customize and improve the Services and your user experience, based on
common or personal preferences, experiences, and difficulties;
• To contact our users with general or personalized service-related messages (such as
password-retrieval); or with promotional messages (such as newsletters, special offers, new
features etc.); and to facilitate, sponsor and offer certain events and promotions;
• To support and enhance our data security measures, including for the purposes of preventing
and mitigating the risks of fraud, error, or any illegal or prohibited activity;
• To create aggregated statistical data, inferred non-personal data or anonymized or
pseudonymized data (rendered non-personal), which we or our business partners may use to
provide and improve our respective services;
• To enforce our Terms of Service and any other agreements between you and iControl; and
• To comply with any applicable laws and regulations

4. How We Share Your Information in Connection with the Services
a. Payors and Payees. In connection with the iControl Services, we may share some of your
Personal Information with the business with which you are transacting in order to effect your
b. iControl Partners. If you access our online platform through the website of one of iControl’s
partners, then we may share your Personal Information with that partner.
c. iControl Service Providers. We may engage selected third party companies and individuals to
perform services complementary to our own (e.g. hosting and server co-location services, data
analytics services, marketing and advertising services, data and cyber security services, fraud
detection and prevention services, payment processing services, e-mail and SMS distribution
and monitoring services, session recording, and our business, legal and financial advisors)
(collectively, “Service Providers”). These Service Providers may have access to your Personal
Information, depending on each of their specific roles and purposes in facilitating and
enhancing our Services, and may only use it for such purposes.
d. Subsidiaries and Affiliated Companies. We may share Personal Information internally within
our family of companies, for the purposes described in this Policy.
e. Business Transfers. Should iControl or any of its affiliates undergo any change in control,
including by means of merger, acquisition, or purchase of substantially all of its assets, your
Personal Information may be shared with the parties involved in such event. If we believe that
such change in control might materially affect your Personal Information then stored with us,
we will notify you of this event and the choices you may have via e-mail or prominent notice on
our Services.
f. Legal Compliance. We may disclose or allow government and law enforcement officials access
to certain Personal Information, in response to a subpoena, search warrant, or court order (or
similar requirement), or in compliance with applicable laws and regulations. Such disclosure or
access may occur if we have a good faith belief that we are legally compelled to do so, or that
disclosure is appropriate in connection with efforts to investigate, prevent, or take action
regarding actual or suspected illegal activity, fraud, or other wrongdoing.
g. Protecting Rights and Safety. We may share your Personal Information with others if we
believe in good faith that this will help protect the rights, property, or personal safety of
iControl, any of our users, or any members of the general public.
h. With Your Permission. iControl may share your Personal Information pursuant to your
explicit consent.

5. Location, Retention, and Protection of Information
a. Your Personal Information may be maintained, processed, and stored by iControl and our
authorized affiliates and Service Providers in the United States of America, Israel, and other
jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law.
While privacy laws may vary between jurisdictions, iControl, its affiliates, and Service Providers
are each committed to protect Personal Information in accordance with this Policy and industry
standards, regardless of any lesser legal requirements that may apply in their jurisdiction.
b. We will retain your Personal Information for as long as you use the Services or as necessary
to fulfill the purpose(s) for which it was collected, provide our products and services, resolve
disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce
our agreements, and comply with applicable law. If we are required to maintain a record of any
information, you may not be able to delete such information due to such requirements. Please
be aware that your personal information may be stored on backup tapes and locations,
third-party servers, and other repositories that may not be erasable and residual information
may be retained. We are under no obligation to store such information indefinitely and disclaim
any liability arising out of, or related to, the destruction of such information.
c. We maintain administrative, technical, and physical safeguards that are designed to protect
the privacy and security of your Personal Information. For example, all information you provide
is accessible only to designated staff. In addition, all information is protected by SSL/TLS
encryption when it is exchanged between your web browser and the Website or via the
Services. We note, however, that the transmission of information via the internet is not
completely secure. Although we do our best to protect your Personal Information, we cannot
guarantee the security of information transmitted to our Website or via the Services. Any
transmission of personal information is at your own risk. We are not responsible for
circumvention of any privacy settings or security measures contained on the Website. In
addition, where you have chosen a password for access to certain parts of our Website, you are
responsible for keeping this password confidential.

6. Cookies and Tracking Technologies
Session Trackers. In operating the Website and the Services, we may use cookies and similar
session tracking technologies (“Session Trackers”). Session Trackers help provide additional
functionality to the Website, customize users’ experiences with the Website and help us
analyze Website usage more accurately for research and product development purposes. We
(including third parties that we work with) may place session trackers on your device for
security purposes, to facilitate navigation of the Website or the Services, and to personalize
your experience while using our Website or the Services. If you would prefer not to accept
Session Trackers when using the Website or the Services, please follow the instructions
provided by your website or mobile browser (usually located within the “Help”, “Tools” or
“Edit” facility) to modify your Session Tracker settings. Please note that if you disable Session
Trackers, you may not be able to access certain parts of our Website or Services and other parts
of our Website or Services may not work properly. As a result, we recommend that you leave
Session Trackers turned on when accessing the Website or the Services because they allow you
to take advantage of some of the Website and Services’ features.
Web Beacons. In addition to Session Trackers, we may use web beacons (also known as “clear
GIFs”), which are transparent graphic images placed on a web page or in an email and indicate
that a page or email has been viewed or tell your browser to get content from another server.
We use web beacons to measure traffic to or from, or use of, our online forms, tools or content
items and related browsing behavior and to improve your experience when using the Website
or the Services. We may also use customized links or other similar technologies to track
hyperlinks that you click and associate that information with your Information in order to
provide you with more focused communications.

7. Managing Your Preferences
a. We want to communicate with you in the most effective manner, whether by sending you
relevant marketing materials or by operating an intuitive and informative website. At the same
time, we appreciate that your preferences regarding marketing, promotions, and online privacy
will continue to evolve. This section provides you with information on how you can fine-tune
your preference settings.
b. We may use your Personal Information to provide you with marketing or other promotional
communications via mail or email. If, at any time, you would like to stop receiving these
promotional e-mails, you may follow the opt-out instructions contained in any such e-mail or by
contacting us as set out below. Please note that by opting out, you may prohibit iControl from
informing you of offerings that may be of interest to you. It may take up to ten (10) business
days for us to process opt-out requests.
c. In addition, we may use your Personal Information to send you push notifications from
time-to-time in order to update you about any events or promotions that we may be running. If
you no longer wish to receive these types of communications, you may turn them off on your

8. Accessing, Updating, and Correcting Your Information
a. Updating Your Information. If you are a registered user of the Services, you may update and
correct your information and delete inaccuracies through your account. Specifically, you can
review and edit specific types of information at any time by logging in to the Website or the
Services and making changes.
b. Correcting Information from Third Parties. iControl may receive from its customers Personal
Information about third parties (notably, payees) and may have no direct relationship with the
individuals to whom that information relates. An individual who is not a iControl registered user
who seeks to access, correct, amend, or delete data provided to us by our customers should
direct those requests to the customer as they will have access to that information through their
own account. If requested to remove data, we will respond within a reasonable timeframe.

9. Social Media
You may also find additional information regarding the Services on our social media sites such
as Facebook, LinkedIn, or Twitter. Please keep in mind that any information you share through
such social media sites is visible to all participants on these social media sites and you should
never post any sensitive information (such as account numbers) to such social media sites.
Please carefully review the terms of use and privacy policies of these social media sites as they
may be different from our own policies.

10. Other Websites and Businesses
This Privacy Policy covers the privacy practices of iControl only. This Privacy Policy does not
apply to the practices of third party websites, services, or applications, including third parties
with which we partner. These third party services are governed by their own privacy policies.
iControl is not responsible for the privacy policies and practices of these third parties.

11. Do-Not-Track Settings
Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences
regarding tracking by advertisers and other third-parties. We do not respond to DNT signals.

12. Children Under 13 Years of Age
Our Services are not directed to children under 13 years of age, and we do not knowingly
collect information from children under 13. If we become aware that a child under 13 has
provided us with Personal Information, we will prohibit and block such use and will make all
efforts to promptly delete any Personal Data stored with us with regard to such child.

13. Your California Privacy Rights
California law provides California residents the right to request from iControl: (i) a list of the
categories of Personal Information that we have disclosed to third parties for direct marketing
purposes; and (ii) the names and addresses of all such third parties. If you would like to request
this information, please email your request to In your request,
please specify that you want a “Your iControl California Privacy Rights Notice”. Please allow
thirty (30) days for a response.

14. Contact Us
If you have questions or concerns regarding this Privacy Policy, please contact us by mail at
9710 Traville Gateway Drive, Suite 306, Rockville, MD 20850 or by email at

15. Changes to This Privacy Policy
Please read this Privacy Policy carefully. iControl will occasionally update this Privacy Policy.
When we do, we will also revise the “last updated” date at the top of this page. Any changes to
our Privacy Policy will become effective upon our posting of the revised Privacy Policy on the
Website. Use of the Website following such changes constitutes your acceptance of the revised
Privacy Policy then in effect. To the extent iControl makes any material change to this Privacy
Policy, it will provide you with notice via email, on the Website, or through the Services prior to
the change becoming effective.

Join 44,000+ Retailers and 3,600+ Vendors. And Growing.

See how iControl has helped thousands instantly improve their financial transactions and margins.