Chipotle

"When you give the App permission to collect your precise geolocation, the App (in conjunction with a provider of map services, such as Google Maps or Apple Maps) may use your mobile device's location services to collect real-time information about the location of your device (using GPS, WiFi, Bluetooth or other methods, including in store beacons) to provide requested location services and ensure your orders are placed at the correct location... If location services are disabled, other means of establishing or estimating your general location (e.g., connecting to or proximity to Wi-Fi, Bluetooth, beacons, or our networks) may still be active."

Chipotle collects precise real-time geolocation using multiple methods, and even when location services are disabled, general location estimation via WiFi, Bluetooth, and beacons may remain active. General location data is also shared with data brokers and used for targeted advertising.

"We may share, your personal information... the contents of your searches or forms you complete with service providers who assist us with offering the Services or as otherwise described in this Privacy Policy, such as delivery services, analytics providers, marketing and advertising services (including to provide you with targeted or personalized advertising), providers of payment services, providers of other support for our transactions... Some of our service providers may view, edit, or set their own tracking technologies/cookies on our Services."

Chipotle shares personal information broadly with analytics companies, data brokers, third-party advertisers, and various service providers, some of whom set their own tracking technologies directly on Chipotle's services.

"We and our service providers may use first-party cookies or other first-party identifiers as well as third-party cookies or other third-party identifiers to provide Chipotle with insight into behavior information relating to inferred visitor age range... your interests, and to deliver advertisements to you, create a profile of you, measure your interests, detect your demographics, personalize content, and detect and associate online and offline behaviors such as site visitation, dwell time and actions taken."

Chipotle and its service providers create user profiles by correlating online and offline behavior, using cookies, pixels, SDKs, and other identifiers to track users across websites, apps, and devices for interest-based advertising.

"Depending on your personal device and App permission settings, when using the App, we may collect or have access to your: Precise geolocation... Camera. When enabled, this may allow the App to access the camera to scan and input payment method details... Wi-Fi connection information. When enabled, this may allow the App to view Wi-Fi connections... The App will send and receive data to and from the Internet, and may view network connections, have full network access, control vibration of your device, or prevent your device from sleeping."

The app requests access to the camera, WiFi connection information, and network connections, and can control device vibration and prevent the device from sleeping — capabilities that extend beyond core food ordering functionality.

"We retain personal information for as long as necessary to achieve the purposes for which the information was collected. In certain cases, we may need to retain personal information for purposes required under applicable law, for tax or audit purposes, or for other purposes permitted under law. In deciding how long to retain personal information that we collect, we consider many criteria, including, but not limited to the business purposes for which the personal information was collected; relevant federal, state and local recordkeeping laws; applicable statutes of limitations for claims to which the information may be relevant; and legal preservation of evidence obligations."

Chipotle provides no specific retention periods or deletion timelines, using vague language like 'as long as necessary' and citing broad criteria that could justify indefinite retention.

"From time to time, Chipotle may change this Privacy Policy. Changes will be indicated by the "Last Updated" date at the top of this page. If we make material changes, we will provide you with additional notice, such as adding a statement on the homepages of our Website, within our cookie banner, at account sign up or log-in, or by sending you a notification."

Chipotle can change the privacy policy at any time, with changes potentially indicated only by updating a date on the page. While material changes get 'additional notice,' there is no requirement for user consent before new terms take effect.

"Please also note that if you submit a request to delete your personal information, this will also automatically withdraw you from the Rewards Program and will result in the forfeiture of your incentives, including your Rewards points that you may have accumulated. Requesting the deletion of your personal information results in the deletion of your Rewards account and accumulated incentives because we require your personal information (e.g., your name, email address, and log-in information) to be able to associate you to your account."

Exercising your privacy right to delete personal data automatically forfeits all accumulated Rewards points, creating a financial penalty that discourages users from exercising their data deletion rights.

"Please also note that if you submit a request to delete your personal information, this will also automatically withdraw you from the Rewards Program and will result in the forfeiture of your incentives, including your Rewards points that you may have accumulated... Note that there are some reasons we will not be able to fully address your request, such as if we need to complete a transaction for you, for our internal purposes, or to comply with a legal obligation."

Deleting your account results in forfeiture of all accumulated rewards, and Chipotle reserves broad exceptions to deny deletion requests for 'internal purposes,' creating disincentives to exercise deletion rights.