Last Updated/Effective Date: January 2025

1.0 Introduction

Your privacy is important to us. We at Shooters Tavern understand your concerns regarding how information about you may be used and shared, and we appreciate that you trust us to use and share information about you carefully and sensibly. This Privacy Policy describes what personal information Shooters Tavern LLC and/or Toast may collect about you, how we may collect it, how we may use it, with whom we may share it, and what choices you may have regarding it. This Privacy Policy applies to your use of our websites, our mobile websites, our mobile apps, and any other platforms that link to this Privacy Policy. It does not apply to any websites or facilities operated by third parties. We are not responsible for, and this Privacy Policy does not apply to, the privacy practices of other companies or other websites. We encourage you to seek out and read the privacy policy of each website that you visit.

2.0 How We May Collect Your Personal Information?

“Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you. Shooters Tavern and Toast may collect Personal Information relating to you and your use of the Sites or Facilities to provide services and features that are responsive to your needs. We may collect Personal Information in the following ways:

• From you. We may collect information from you when you register an account with us, request information, send us email, send us postal mail, apply for a job with us, speak with us on the telephone, visit our Facilities, or otherwise interact with us.

• From our apps. We may collect information from your mobile device when our apps are installed on your mobile device, or you provide your information to us via the apps.

• From other third-party sources. We may receive information about you from our third-party service providers who help us to provide services to you, including our site and social media providers.

• Automatically as you navigate the websites and apps. Information collected automatically may include usage details, email address, IP addresses, and information collected through cookies and other tracking technologies.

3.0 Personal Information We May Collect

3.1 Personal Information You Provide to Us

We may collect the following information about you including, but not limited to:

• First and last name

• Postal address and/or zip code

• Email address

• Phone number

• Date of birth

• Gender

• Military or veteran status

• External social network credentials

• Credit card or other payment information

• Mobile app and/or website log-in credentials

• Location data

• Demographic information

• Dining preferences

• Who you typically dine with (e.g., family and friends)

• When you normally visit our restaurant locations (e.g., breakfast, lunch, and dinner)

• How often you visit our restaurant

• Feedback and/or guest relations data

3.2 Personal Information We May Collect from Third Party Sources

Such Personal Information may include information about your financial, educational, and criminal histories, as well as information concerning your character and reputation. We do not share this information with any third parties except its service providers and retain it for as long as necessary to evaluate your application. You may withdraw your consent at any time. To exercise any privacy rights that may be afforded to you under applicable data protection laws, including withdrawing your consent, please see the section below titled “Your Privacy Rights and How to Exercise Them.” For more information about our practices with respect to retention of your Personal Information, please see the section below titled “How Long We Retain Your Personal Information.”

3.3 Information We and Our Third-Party Service Providers May Collect

When you use our site, we and our third-party service providers may automatically collect information about how you access and use the Sites and information about the device you use to access the Sites. We typically collect this information through a variety of tools including cookies, web beacons, pixels, social media widgets, other tools to enable data recording and indexing, and similar technology (collectively, “tracking technologies”). We and our third-party partners may automatically collect information such as:

• IP or MAC address

• Device type

• Unique device identifier (UDID)/other device identifier (IMEI)

• Browser type

• Operating system or platform

• Name of Internet Service Provider (ISP)

• Referring website

• Exiting website

• Clickstream data

• Search terms entered on the websites(s)

• Pages visited on the website(s)

• Time, date, and duration of visit to the website(s)

• Whether you open emails from us

• Links you click on in our emails and on our Sites including ads

• Whether you access our Sites from multiple devices

• Other interactions you may have on our Sites

• Location/geo-location (e.g., latitude/longitude, Wi-Fi/cell tower location, etc.)

4.0 How We May Use Personal Information

We may process Personal Information to provide services to you and additional services you request, as well as to respond to communications from you. The precise purposes for which your Personal Information may be processed will be determined by the request and by applicable laws, regulatory guidance, and professional standards.

We may use information we collect from you and information that we may collect automatically to manage and improve our Sites and our business. We take steps to ensure that your rights are safeguarded. For example, we may use information to:

• To provide services to you.

• To provide our Sites and their functionalities to you.

• To provide you with location-specific services. If you elect to share your location information with us, we may use that information to tailor options, functionalities, or offers related to your location.

• To market our own services to you. If you join our rewards programs and other special marketing campaigns, we may use your personal information including demographic information, birthday, personal preferences, purchase history, and information about you from third-party sources—including your location information and online browsing across time and third-party sites—to send you real time, geographically relevant, and personalized offers, services, and promotions for our brands, affiliates, or third-party partners.

• To conduct data analytics to support our Sites and business.

• To manage our business needs, such as monitoring, analyzing, and improving the services and the Sites’ performance and functionality. For example, we analyze website user behavior and conduct research and analysis about the way you and other users use our Sites.

• To manage risk and protect the Sites and Facilities. We use data to better protect our services, our Sites, our Facilities, and you by helping to detect and prevent fraud and abuse.

• Tailor our offerings to your apparent interests.

• To operate and improve our business.

• To maintain our records.

• Conduct internal monitoring and training.

• Develop new services and products.

• Conduct processing is necessary to fulfill other contractual obligations for you.

• To comply with our legal and regulatory obligations. We may use your information as necessary to enforce the terms of our Sites and services to comply with all applicable laws and regulations.

• For other purposes for which you provide your consent. For other purposes which are disclosed to you at the time your information is collected or for purposes which can be inferred from or are obvious given the circumstances of collection.

5.0 Disclosure of Personal Information

We may disclose your Personal Information in the circumstances described below.

• Third-party service providers. We may disclose your Personal Information to our vendors and other third-party service providers, such as credit card processors and website hosts, that help us provide services, support features on our Sites or in restaurants, or otherwise market our brands.

• Legal requirements and business transfers. We may disclose Personal Information: (i) if we are required to do so by law, legal process, statute, rule, regulation, or professional standard, or to respond to a subpoena, search warrant, or other government official requests; (ii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss; (iii) in connection with an investigation of a complaint, security threat, or suspected or actual illegal activity; (iv) in connection with an internal audit; or (v) in the event that Toast is subject to mergers, acquisitions, joint ventures, sales of assets, reorganizations, divestitures, dissolutions, bankruptcies, liquidations, or other types of business transactions. In these types of transactions, Personal Information may be shared, sold, or transferred, and it may be used subsequently by a third party.

6.0 Your Choices

We offer certain choices about how we communicate with you and what Personal Information we may obtain about you and share with others.

• Profile. If you have created a profile or account on our Sites, you can update your contact information after you log into your account.

• E-mail. If you no longer wish to receive promotional or informational emails from us, you may opt out from receiving future emails from us by following the instructions for unsubscribing in the promotional or informational emails we send you or by contacting us at the email address or phone number below.

• Rewards programs and marketing campaigns. Your participation in our special rewards programs and other marketing campaigns is completely up to you, and if at any point you no longer wish to be a member or participate in these programs, you may opt out according to the instructions provided in the communication or by contacting us at shooterstavern@aol.com

• Cookies. We provide a variety of services on our site using cookies. We place cookies on your device to provide you with personalized access to essential services, enhance functionality, and show you offers and services tailored to your interests. A cookie is a small piece of data that a website can send to your browser, which may then be stored on your hard drive as a “tag” that identifies your computer. Cookies help to navigate from page to page on a website, provide secure connections, gather statistics about the usage and effectiveness of our Sites, and remember preferences from a previous visit when you return. We use third-party services for analytics and interest-based advertising purposes. These service providers and ad partners may use cookies alone or in conjunction with unique identifiers, beacons, and other tracking technologies to collect information about you when you use our Sites, open our emails, or interact with our ads. Most web browsers automatically accept cookies, but you can change your browser settings to disable all or certain cookies if you wish. Please note that by disabling or deleting cookies, you may not be able to access the full functionality of our Sites. Disabling or clearing cookies also may affect cookie-based opt-outs by either preventing you from using such cookie-based opt-outs or clearing opt-outs that you previously set.

• Do Not Track. Because there currently is not an industry or legal standard for recognizing or honoring Do Not Track (“DNT”) signals, we do not respond to them currently.

• Location data. You may opt out of having your location data collected by Toast at any time by editing the appropriate setting on your mobile device (which is usually located in the settings of your device).

7.0 Social Media

We are active on social media including, but not limited to, Facebook, Instagram, and LinkedIn (“Social Media”). Anything you post on social media is public information and will not be treated confidentially. We may post (or re-post) on the Sites and our Social Media pages any comments or content that you post on our Social Media pages.

Our Site allows you to connect and share data with Social Media platforms. These features may require us to use cookies, plug-ins, and APIs provided by such Social Media platforms to facilitate those communications and features. Our Sites may use advertising networks and services offered by Social Media platforms to deliver advertising content. Use of these services requires Social Media platforms to implement cookies or pixel tags to deliver ads to you while you access the Sites.

8.0 Location of Our Sites

Our Sites are hosted and operated in the United States. However, we and our service providers may store information about individuals in the United States, or we may transfer it to, and store it within, other countries.

9.0 How Long Do We Retain Your Personal Information?

We will retain your Personal Information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless otherwise required by applicable laws. Criteria we will use to determine how long we will retain your Personal Information include whether we need your Personal Information to provide you with our Sites, Facilities, or other services; you have requested information from us; we have a legal right or obligation to continue to retain your Personal Information; we have an obligation to a third party that involves your Personal Information; our retention or recordkeeping policies and obligations dictate that we retain your Personal Information; or we have another business purpose for retaining your Personal Information.

10.0 Third-Party Links

Occasionally, at our discretion, we may include or offer third-party products or services on our apps. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. We urge you to read the privacy policies of other websites before submitting any information to those websites. Please be aware that to submit job application materials online to work with us, you will be redirected from our Site to a website operated by our third-party service provider. You may be required to create an account with that vendor. We encourage you to review the terms and privacy policy posted on that vendor's website since this Privacy Policy does not govern your use of that website.

11.0 How We Protect Your Personal Information?

Toast has implemented reasonable physical, technical, and administrative security standards to protect Personal Information from loss, misuse, alteration, or destruction. We strive to protect your Personal Information against unauthorized access, use, or disclosure, using security technologies and procedures, such as encryption and limited access; however, we cannot guarantee the security of Personal Information during its transmission or storage on our systems. We collect Personal Information from the categories of sources detailed in the How We May Collect Your Personal Information section above. We collect Personal Information for business and commercial purposes detailed in the How We May Use Personal Information section above. The categories of third parties to whom we disclose Personal Information for a business or commercial purpose are detailed in the Disclosure of Personal Information section above. The categories of third parties to whom we sell or share Personal Information are summarized in the chart below. We do not knowingly sell or share the Personal Information of minors under the age of 16.

12.0 Notice of Financial Incentive

If you sign up for our Shooters Tavern Rewards Program, you may receive credit for each dollar spent at participating restaurants, which can be redeemed for reward items or free food.

When you sign up for the Shooters Loyalty program, we may ask you to submit the following Personal Information:

• First and last name

• E-mail address

• Phone number

• Zip code

• Birthday

No other information is necessary to sign up. We may sell or share the above Personal Information with our third-party advertising partners for monetary or other valuable consideration and/or cross-context behavioral advertising, but we do not disclose any Personal Information to data brokers. We also do not utilize any “Bona Fide Loyalty Program Partners” as such term is defined under the CPA to administer our loyalty/marketing program benefits.

Please note that by opting out of our loyalty/marketing programs, you will no longer have access to your rewards account, if applicable, but you can otherwise continue to make in-restaurant purchases and use our Sites. All rewards you have earned until the time of withdrawal will no longer be available. If you make a request to delete your Personal Information, you may not be able to participate in our loyalty/marketing programs until you sign up again. This is because we need your Personal Information to administer the loyalty/marketing programs.

Based on our reasonable and good faith estimate, the value of Personal Information provided in connection with our loyalty/marketing programs is approximately equal to the relevant expenses related to the collection and retention of such Personal Information. Any difference in price or benefits provided to customers who participate in our loyalty/marketing programs is reasonably related to the value of the Personal Information provided.

13.0 Your Privacy Rights and How to Exercise Them

Depending on where you live, you may have the following rights with respect to your Personal Information under applicable data protection laws:

• Access – The right to know what Personal Information we have collected about you and to access such Personal Information.

• Data portability – The right to receive a copy of your Personal Information in a portable and readily usable format.

• Deletion – The right to delete your Personal Information that we have obtained, subject to certain exceptions.

• Correction – You may have the right to correct inaccuracies in your Personal Information.

• Opt out of certain processing – The right to: (a) opt out of the processing of your Personal Information for purposes of targeted advertising and (b) opt out of the sale or sharing of your Personal Information.

• Objection/Restriction of Processing – The right to object or restrict us from processing your Personal Information in certain circumstances.

• Withdraw Consent – The right to withdraw your consent where we are relying on your consent to process your Personal Information.

• Lodge a Complaint – The right to lodge a complaint with a supervisory authority or other regulatory agency if you believe we have violated any of the rights afforded to you under applicable data protection laws. We encourage you to first reach out to us, so we have an opportunity to address your concerns directly.

To exercise any of the privacy rights afforded to you under applicable data protection laws, please submit a request to us by one of the following methods:

• Calling us at (603) 528 2444

• Submitting a request through our website

You will not be discriminated against in any way for exercising your rights listed in this Privacy Policy, which means we will not deny goods or services to you, provide different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you. Only you, or an authorized agent that you authorize to act on your behalf, may make a request related to your Personal Information.

We must verify your identity before fulfilling your requests, and if we cannot verify your identity, we may request additional information from you. If you are an authorized agent making a request on behalf of another person, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney. We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.

We do not charge a fee to process or respond to your requests unless they are excessive or repetitive. If we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We may deny certain requests, or only fulfill some in part, as permitted or required by law. If you are not satisfied with the resolution of your request and you are afforded a right to appeal such decision, you will be notified of our appeal process in our response to your request.

14.0 Children’s Information

Our Sites are not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Sites. We do not knowingly collect Personal Information from children under 13. If you are under 13, do not use or provide any information on the Sites or on or through any of its features, including your name, address, telephone number, email address, or any username you may use. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at shooterstavern@aol.com

15.0 Changes to Our Privacy Policy

We may change this Privacy Policy from time to time, and we will post any changes on this page. Each version of this Privacy Policy is identified at the top of the page by its Effective Date. If we make material changes to how we treat our users' Personal Information, we may notify you by email to the primary email address specified in your account and/or through a notice on our Sites’ home pages. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting our Sites and this Privacy Policy to check for any changes.

16.0 Contacting Us

For any questions, or to request further information regarding this Privacy Policy, please contact us at shooterstavern@aol.com or by calling 603 528 2444.