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.

10.2.5    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:

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 business-related and operational data, including:

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:

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:

Customers are responsible for managing user access and permissions within their organizations.

 

Data Roles and Responsibilities

Depending on the context:

Data is processed in accordance with contractual agreements and applicable law.

 

Retention and Access

Business and operational data is retained for periods necessary to:

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