SURF BAGEL PRIVACY POLICY ARCHIVE
Version: June 13, 2025
Surf Bagel Holdings, LLC (“Surf Bagel,” “we,” “us,” or “our”) values your trust. This Privacy Policy describes how we collect, use, disclose, and protect personal information when you:
visit our websites or mobile services,
order food or merchandise online or in-store, or
join our loyalty or promotional programs
(collectively, the “Services”). It also explains the rights that Delaware residents enjoy under the Delaware Personal Data Privacy Act (“DPDPA”) and how to exercise them.
Using our Services means you consent to the practices below. If you disagree, please do not use the Services.
1. Scope
This Policy applies to personal information we collect from consumers. It does not cover employee or job-applicant data, nor data collected by unaffiliated third-party sites or apps that link to or from us.
2. Information We Collect
2.1 Data you provide
Identifiers & contact details — name, postal address, e-mail, telephone
Account & loyalty credentials — username, password, membership ID, points balance
Payment data — card brand, last 4 digits, expiration date (processed by PCI-DSS-certified partners; we never store full numbers or CVVs)
Commercial records — items ordered, purchase date, location, payment method, refunds
Demographics — date of birth or age (for age verification or birthday rewards)
Preferences & feedback — reviews, survey responses, contest entries, messages you send us
2.2 Data collected automatically
Device & browser data — IP address, device identifiers, operating system, browser type
Online activity — pages visited, links clicked, cart actions, timestamps, referring URLs
Approximate location — city or region inferred from IP
Precise geolocation — only if you actively grant permission (e.g., “find nearest store”)
2.3 Cookies and similar technologies
We use essential cookies to operate the site, functional cookies to remember preferences, and first-party analytics cookies (e.g., Google Analytics) to measure traffic. We do not use third-party advertising cookies that track you across non-Surf Bagel websites. Your browser settings let you refuse or delete cookies; doing so may limit certain features.
2.4 Sensitive data
We do not intentionally collect sensitive personal data—such as health details, biometric identifiers, or children’s data—unless you provide it voluntarily or enable a feature that requires it. Any such data is handled only with your explicit consent and subject to heightened protections.
3. How We Use Information
We use personal information only for legitimate business purposes:
Provide & improve Services – process orders and payments, arrange delivery or pickup, and enhance performance.
Manage accounts & loyalty – create, authenticate, and maintain membership and reward balances.
Communicate with you – confirmations, digital receipts, service notices, policy updates, and responses to inquiries (via e-mail, SMS, or phone, consistent with CAN-SPAM and other rules).
Marketing with choice – send you news about menu items, offers, or events similar to those you already enjoy; every marketing e-mail includes an opt-out link and we send promotional texts only with your express consent.
Personalize experience – remember preferred store, suggest menu items based on prior orders, and tailor digital content.
Analytics & security – detect fraud, monitor usage patterns, debug, and compile statistics.
Legal & compliance – meet tax, accounting, food-safety, and privacy-rights obligations, and document compliance.
Corporate events – evaluate or complete mergers, acquisitions, or asset transfers; the protections of this Policy follow any transferred data.
Other purposes you request or consent to.
We do not engage in fully automated decisions that produce legal or similarly significant effects.
4. Disclosure of Information
Surf Bagel does not sell personal data for money and does not share data for third-party targeted advertising. We disclose information only:
To service providers (processors) that perform tasks for us—payment processors, online ordering and delivery partners, hosting and IT support, e-mail and text distributors, analytics providers, and fraud-prevention vendors. Each is bound by contract to safeguard data, use it solely for our instructions, and delete it when services end.
To affiliates under common ownership or control (none at present, but included for completeness) for internal operations and under the same privacy commitments.
To co-promotion partners when you enter a joint contest or event and explicitly agree to sharing.
For legal reasons or safety—to comply with a lawful subpoena or protect rights, property, or personal safety. We evaluate each request, seek to narrow overly broad demands, and disclose only what is legally required.
In business transfers—as part of a merger, acquisition, sale of assets, or similar change in control. If ownership changes, we will give you notice before new privacy terms apply.
With your consent—for any other purpose that you direct.
5. Retention
We keep personal information only as long as needed for the purposes above or as required by law. Once no longer necessary, we securely delete or de-identify it. If data resides in backup archives, it is isolated until deletion is possible.
6. Security
We maintain administrative, technical, and physical safeguards: TLS encryption of payment traffic, firewalls, role-based access controls, multifactor authentication for critical systems, employee privacy training, routine vulnerability scans, and annual penetration testing. Despite these measures, no system is perfectly secure; if a breach occurs, we will notify affected individuals and regulators as required.
7. Your Rights (Delaware Residents as outlined by DPDPA)
Access / Know – request confirmation and a copy of personal data we hold.
Correction – ask us to fix inaccuracies.
Deletion – request erasure of data we collected from you, subject to legal exceptions.
Portability – receive data you provided in a portable format.
Opt-out – direct us not to sell or share data or to use it for targeted ads or significant profiling.
Appeal – contest a refusal of your request within 60 days.
We will not discriminate against you for exercising these rights.
How to submit a request
Online – use the “contact us” form on our website’s About Us page.
Mail – write to Surf Bagel Holdings, LLC — Privacy Team, P.O. Box 1618, Rehoboth Beach, DE 19971.
Email - email info@surfbagel.com
Provide enough information for us to verify your identity (e.g., name plus a recent order number or loyalty ID). We will respond within 45 days (15 days for opt-out requests); if we need up to 45 additional days, we will explain why.
You may designate an authorized agent to act for you, but we will require proof of identity and written authorization or power of attorney.
Global Privacy Control (GPC)
A browser signal such as GPC indicating “do not sell or share my data” will be honored for that device no later than January 1, 2026 (and sooner wherever feasible).
If you feel your request was improperly denied, you may appeal by replying to our decision e-mail or resubmitting via the contact form. Unresolved appeals may be filed with the Delaware Department of Justice through its Personal Data Privacy Portal.
8. Children
Our online Services are not directed to children under 13 and we do not knowingly collect their data. Parents who believe a child has provided information should contact us; we will delete it promptly. We also do not process teen (13-17) data for targeted advertising or sale without the teen’s affirmative consent.
9. Changes to This Policy
We may update this Policy from time to time. Material changes will be highlighted on our site or sent directly to you if we have your e-mail. The “Last Updated” date tells you when revisions take effect. Continued use of the Services after that date signifies acceptance.
10. Contact Us
For privacy questions or requests:
use the contact form on our website’s About / Contact Us page
email info@surfbagel.com
or write to:
Surf Bagel Holdings, LLC – Privacy Team
P.O. Box 1618
Rehoboth Beach, DE 19971 USA
We will respond as promptly as possible.
VERSION: October 1, 2024
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.
Interpretation and Definitions
For the purposes of this Privacy Policy:
Account means a unique account created for You to access our Service or parts of our Service.
Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Application refers to Surf Bagel App, the software program provided by the Company.
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Surf Bagel Holdings, LLC PO BOX 1618 Rehoboth Beach, DE 19971.
Country refers to: Delaware, United States
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Personal Data is any information that relates to an identified or identifiable individual.
Service refers to the Application or the Website or both.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
Usage Data refers to data collected automatically, either generated by use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Website refers to Surf Bagel, accessible from www.surfbagel.com
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
your name;
contact details such as your phone number and email;
your address and other location details if you choose to share them;
your payment card information, such as the brand, card number, security code and expiration date;
transaction information and order history details (e.g., goods/services ordered, order location, date, payment method and amount of payment);
your date of birth (if you choose to provide it);
account and profile information such as your username and password;
if you are a member of the loyalty program, information in relation to your points balance and redemptions;
your feedback in relation to your experience at The Company (if you choose to provide it).
Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (IP address), browser type, location (if you choose to share it), browser version, the pages of our Service that You visit, the time and date of Your visit, the items You purchase, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, device location (if you choose to share it), the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:
Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.
We use both Session and Persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We may share Your personal information in the following situations:
With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company-
With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside:
With Your consent: We may disclose Your personal information for any other purpose with Your
consent.
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
Delete Your Personal Data
You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You. Our Service may give You the ability to delete certain information about You from within the Service.
You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.
Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.
Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (eg. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of transmission
over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
Children's Privacy
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We will take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.
Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, You can contact us: https://surfbagel.com/about