Your privacy is important to us, and we are committed to protecting it through our compliance with this Privacy Policy.  Cohn Restaurant Group, Inc. and its subsidiaries and affiliates (collectively, “CRG,” “we,” or “us”), respects concerns with regard to how information about you is used and shared, and we appreciate your trust that we will use and share information about you carefully and sensibly.  This Privacy Policy describes the types of Personal Information that we may collect about you, how we may collect it, how we may use it, who we may share it with and what choices you have regarding it.  This Privacy Policy applies to your use of our Internet and mobile Web sites, the CRG mobile application (the “App” or “Mobile Application”), your participation in the CRG Loyalty Club (the “CRG Loyalty Club”) and other online services (collectively, the “Sites”), and other means by which we may collect information from you, including information you may provide to us other than on the Sites or via the App.  We encourage you to carefully read this Privacy Policy and our Terms of Use.  By accessing and using the Sites, by participating in the CRG Loyalty Club, or by downloading, installing, accessing or using the App, you agree that you have read and understand this Privacy Policy and that you accept and consent to the privacy practices (and any uses and disclosures of information about you) that are described in this Privacy Policy.  If you do not agree with our policies and practices, do not use or access the Sites, do not participate in the CRG Loyalty Club and do not download, register with or use the App.

This Privacy Policy does not apply to any other websites or mobile applications or to information that may be collected by any other websites or mobile applications.  Other third parties (such as online reservation platforms or social media networks that you may use in connection with our Sites) may also use, collect and share information about you.  We are not responsible for, and this Privacy Policy does not apply to, the privacy practices of other companies or other websites or mobile applications.  We encourage you to seek out and read the privacy policy of each website that you visit and each mobile application that you use.

We may revise this Privacy Policy from time to time by posting an updated Privacy Policy accessible to users of the Sites.  Changes to this Privacy Policy will be effective when posted.  In the event of a change to the Privacy Policy, we will update the “Last Modified” date above and notify you on our homepage that the Privacy Policy has been recently updated.  Your continued use of the Sites, the Mobile Application or the CRG Loyalty Club after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children under the Age of 16

We are committed to protecting the privacy of visitors under the age of 16.  We do not knowingly collect Personal Information from children under the age of 16.  If we learn we have collected or received Personal Information from a child under the age of 16, we will delete that information.  If you believe we might have any Personal Information from or about a child under the age of 16, please email us at privacy@dinecrg.com or contact us at the contact information provided below.

What information do we collect?

We may collect several types of information from and about users of our Sites, which may consist of information that personally identifies, describes, or could be reasonably linked, directly or indirectly, with a particular individual or household (“Personal Information”).  In the last 12 months, we may have collected the following categories of Personal Information about you when you use our Sites, interact with us through our Sites, or visit our locations, including through the CRG Loyalty Club:

• Identifiers (e.g., name, mailing address, unique personal identifier, online identifier, internet protocol (IP) address, email address);
• Personal information described in California Civil Code § 1798.80(e), such as telephone number, credit card number, debit card number, or any other financial information;
• Characteristics of protected classifications under California or federal law (e.g., age, gender);
• Commercial information (e.g., products or services purchased, or other purchasing or consuming histories or tendencies);
• Internet or other electronic network activity information (e.g., browsing history, search history, information regarding a consumer’s interaction with an internet website application, or advertisement);
• Geolocation data;
• Audio, electronic, visual, or similar information (e.g., Closed Circuit television information);
• Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, predispositions, and behavior;
• Sensitive personal information, such as precise geolocation data.

We collect Personal Information either directly from you when you provide it to us (including when you place an order with one of our restaurants or using a third-party delivery service) or automatically as you navigate through the Sites and/or use the App.  We may also obtain information when you provide it to us on websites, applications and services operated by third parties (each, a “Third-Party Platform”) and combine that with information we collect on our Sites.  The information we collect is subject to this Privacy Policy.  The information you provide may separately be collected by those Third-Party Platforms and be subject to their own privacy policies.  Our Sites and App may contain links to other websites, applications, and services that we do not own or control.  We encourage you to read the privacy policies of those third parties that may apply.

How do we collect this information?

We may directly ask you to provide Personal Information on our Sites.  This is obtained by any of the following means:

• Information that you provide directly to us by filling in forms on the Sites. This includes information provided at the time of registering to use the App, posting material, subscribing to the CRG Loyalty Club, providing feedback on your dining experience at our restaurants and/or you requesting further services;
• Information that you provide when signing up for a contest or promotion sponsored by CRG, which may include your name, phone number, email address, social media handle and other information requested when you sign up for the contest or promotion;
• Information that we gather indirectly from you, such as by observing your actions on our Website, when you use the Mobile Application, or visit one of our restaurants;
• Records and copies of your correspondence (including e-mail addresses and phone numbers) if you contact us;
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through the Sites and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the Sites;
• Your search queries on the Sites;
• From third party service providers that we use to support our business, including those that help us process online orders or manage the CRG Loyalty Club;
• From third party meal delivery services;
• From third party service providers who provide us with information regarding consumers who may have an interest in our menu items and services;
• Any other sources specified in our Privacy Notice or Privacy Policy.

Like many websites, we automatically collect certain information about your visit. This may include details such as your location, computer operating system, IP address, access times, browser type, language, and the website you visited before or after accessing our Sites.

In addition, our Sites may send one or more “cookies” to your computer. Cookies are small data files that help us remember your preferences and understand how you interact with our Sites. Most browsers accept cookies by default, but you can change your settings to refuse cookies or notify you when a cookie is being sent. Please note that disabling cookies may limit some functionality of our Sites.

We may also use web beacons—tiny electronic images embedded in our web pages and emails—to help deliver cookies, count visits, measure usage, and evaluate the effectiveness of our marketing campaigns (for example, to determine if you opened an email).

Some parts of our Sites, including advertisements and applications, are provided by third parties such as advertisers, ad networks, and content providers. These third parties may use cookies, web beacons, or similar tracking technologies to collect information about your online activities over time and across different websites. The information they collect may be linked to your personal information or used to deliver interest-based advertising or other targeted content. We do not control these third-party tracking technologies. If you have questions about any advertisements or targeted content, please contact the provider directly.

At this time, our Sites do not have the technical capability to automatically respond to Do Not Track signals. However, we are actively reviewing options to better honor these preferences in the future.

How will we use the information you provide to us?  

We use the Personal Information we collect about you or that you provide to us:

• To provide you with information, menu items or services that you request from us and our restaurants;
• To allow you to participate in the CRG Loyalty Club and receive its benefits;
• To fulfill the purpose for which you’ve provided the information, to analyze and improve the content, materials and services that we make available on the Sites, to notify you of changes made to the Sites, to evaluate user needs and improve the Sites’ content, to send you promotional materials and to support our continuing efforts to offer users the information and services we think they want most;
• To contact you (including through interest-based/behavioral advertising and other targeted advertising) about our own or third parties’ products and services that may be of interest to you;
• To provide service and support to you and to respond to your inquiries, and to investigate and address your concerns to improve our services and our restaurants;
• To enhance, personalize and customize your experience and enjoyment using our Sites, products and services, such as understanding your dining history, to make recommendations about our other restaurants you may like;
• To create, maintain, customize, and secure your CRG Loyalty Club or other online ordering account with us;
• To process your requests, purchases, transactions, and payments and prevent transactional fraud;
• To deliver targeted advertisements to you and other visitors of our Sites;
• To help maintain the safety, security, and integrity of our Website, Mobile Application, restaurants, products and services, databases and other technology assets, and business;
• For testing, research, analysis, and menu item development, including to develop and improve our Website, Mobile Application, menu items, and services;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of CRG’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by CRG about our restaurant guests (including CRG Loyalty Club members) are among the assets transferred;
• In any other way we may describe when you provide the information or to fulfill the purpose for which you provide it;
• For any other purpose with your consent.

CRG will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Unless otherwise described in this Privacy Policy, Personal Information will be used solely for our business purposes.  We and our third-party vendors, consultants, and other service providers who work for us may use this information to help administer the Sites and the servers that provide the Sites, generate statistical information, monitor and analyze traffic and usage patterns on the Sites and improve the Sites’ content and content delivery, including any online content, materials and services that we describe or make available on the Sites.

We and our third-party service providers may use some Personal Information for security reasons and to confirm the integrity of the Sites.

With whom do we disclose the information we collect?

We do not share, sell, or otherwise disclose your Personal Information for purposes other than those outlined in this Privacy Notice. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose information that we collect about you or that you provide to us (as described in this notice):

• With our subsidiaries and affiliates (including our restaurants);
• With our vendors, service providers, and consultants to support our business, including those that help us manage and administer the CRG Loyalty Club, and process online orders, subject to obligations to use your Personal Information only to provide services to us and to protect your Personal Information consistent with this Privacy Policy;
• With other third parties that provide us with marketing and advertising services;
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of CRG’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by CRG about our restaurant guests (including CRG Loyalty Club members) are among the assets transferred;
• For any purpose disclosed by us when you provide the Personal Information, and with your consent.

We may disclose Personal Information to the proper authorities if we become subject to a subpoena or court order, or if we believe that we are otherwise legally compelled or requested to disclose such information.  We may also use and disclose information about you to establish or exercise our legal rights, to assert and defend against legal claims, to protect the safety and security of our personnel and property, or if we believe such disclosure is necessary to investigate, prevent, or take other action regarding actual or suspected illegal or fraudulent activities or potential threats to the physical safety or well-being of any person.

How long do we retain this information?

We retain the Personal Information we collect for the business and commercial purposes described in the “How do we collect this information” and “How will we use the information you provide to us” sections above.  We may also keep this information to provide products and services you request, to maintain our business relationship with you, including your CRG Loyalty Club membership, or to fulfill a legal obligation.

What choices do you have?

You are under no obligation to provide us with Personal Information, but without it we may not be able to provide you with the products or services you request.  You can review and change your Personal Information by logging into the Sites and visiting your account profile page.  You may contact us as indicated below to request access to, correct or delete any Personal Information that you have provided to us.  You may contact us as indicated below if at any time you would like to ask us about our data collection practices and our information security policy.  If you disagree with our privacy policies, please do not access, use or register with our Sites. You may opt out of receiving promotional emails from us by following the instructions in those emails.  If you do opt out, we may still send you non-promotional emails, such as emails about your CRG Loyalty Club account or our ongoing business relations.  You may also send requests about your contact preferences or changes to your information, including requests to opt out of sharing your Personal Information with third parties, to our contact information below. Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies.   In addition, most mobile devices allow you to turn off location services.  For more information about how to do this, please contact your mobile service carrier or your device manufacturer.  If you choose to remove or reject cookies in your browser, or turn off location services, certain features or services of our Sites may not function as intended.  You may opt out of push notifications within the Mobile App by following the instructions within the Mobile App Notification Settings.  To opt out of the text messaging program, text the keyword STOP to (619) 354-5938.

How Do We Protect Information Collected About You?

CRG and our Contractors have in place certain commercially reasonable security measures to protect the information we collect from you, but the storage and communication of such information can never be completely secure.   If you become aware of any breach of Site security, this Privacy Policy, or the Terms of Use, please notify us immediately.

We use a third-party payment service to process payments made through our Sites. If you wish to make a payment through our Sites, your Personal Information will be collected by such third party and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.

Any questions? Please contact us at:

Cohn Restaurant Group, Inc. 2225 Hancock Street, San Diego, CA 92110. Toll Free Telephone: 833-991-3879; or Email: privacy@dinecrg.com.

STATE-SPECIFIC PRIVACY NOTICE

This page provides additional information for residents of certain US states that have state-specific data privacy laws and regulations.  This page should be read in combination with our Cohn Restaurant Group Privacy Policy.

Effective Date: March 11, 2025

CALIFORNIA

This portion of the State-Specific Privacy Notice supplements the information contained in the Cohn Restaurant Group, Inc. (“CRG”) Privacy Notice that this is attached to and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act (“CCPA”) in effect as of the Effective Date shown above and any terms defined in the CCPA have the same meaning when used in this notice. We may update this Privacy Notice for California Residents as necessary and in the event of changes in the CCPA. Note that this notice does not apply to our employees. Please contact your supervisor if you are an employee and would like additional information about how we process your Personal Information.

Information We Collect We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”) when you use our Website or Mobile Application or when you participate in the CRG Loyalty Club. Within the past 12 months from the Effective Date of this State-Specific Privacy Notice, CRG has collected, through its restaurants, Website, and Mobile Application and through the CRG Loyalty Club the following categories of Personal Information from its guests (consumers) (note that we may not collect all of the examples listed below):

Category	Examples
Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Personal information categories listed in the California Customer Records statute	A name, signature, address, telephone number, bank account number (for catering or other applicable orders), credit card number, or debit card number. Some Personal Information included in this category may overlap with other categories.
Protected classification characteristics under California or federal law	Age (40 years or older) (through date of birth) or sex (including gender and gender identity).

Commercial information	Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Geolocation data	Physical location or movements.
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information (including Closed Circuit TV information).
Inferences drawn from other Personal Information	Profile reflecting a person’s preferences.

CRG obtains the categories of Personal Information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or from orders you place for our menu items and services at CRG restaurants;
• Indirectly from you. For example, from observing your actions on our Website, when you use the Mobile Application, or visit one of our restaurants;
• From third party service providers that we use to support our business, including those that help us process online orders or manage the CRG Loyalty Club;
• From third party meal delivery services;
• From third party service providers who provide us with information regarding consumers who may have an interest in our menu items and services; and
• Any other sources specified in our Privacy Notice or Privacy Policy.

Use of Personal Information We may use or disclose the Personal Information we collect for one or more of the following business or commercial purposes:

• To fulfill a request or provide the services or goods that you requested. For example: if you share your name and contact information to ask a question about our products or services, we will use that Personal Information to respond to your inquiry; if you provide your Personal Information to order menu items (whether through our Website, through our Mobile Application, or in one of our restaurants), we will use that information to process your payment and facilitate fulfilling your order. We may also save your information when you participate in the CRG Loyalty Club and to facilitate new orders;
• To provide, support, personalize, and develop our Website, Mobile Application, menu items, and services;
• To create, maintain, customize, and secure your CRG Loyalty Club or other online ordering account with us;
• To process your requests, purchases, transactions, and payments and prevent transactional fraud;
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our services;
• To personalize your Website and Mobile Application experience and to deliver content and offers on menu items and services relevant to your interests, including targeted offers and ads as a result of your participation in the CRG Loyalty Club or otherwise through our Website, Mobile Application, third-party sites, and via email or text message (with your consent, where required by law);
• To help maintain the safety, security, and integrity of our Website, Mobile Application, restaurants, products and services, databases and other technology assets, and business;
• For testing, research, analysis, and menu item development, including to develop and improve our Website, Mobile Application, menu items, and services;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA;
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of CRG’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by CRG about our restaurant guests (including CRG Loyalty Club members) are among the assets transferred;
• Any other purpose described in our Privacy Notice or Privacy Policy.

CRG will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.  

Disclosing Personal Information We do not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate your Personal Information to another organization for monetary or other valuable consideration. However, CRG may disclose your Personal Information to a third party for one or more business purposes. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and to not use it for any purpose except performing the contract. In the past 12 months, we have disclosed your Personal Information with the following categories of third parties:

• Service providers.

Sale and Sharing of Personal Information In the twelve (12) months preceding the effective date of this State-Specific Privacy Notice, CRG has not sold Personal Information.  

Your Rights and Choices The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.  

Rights to Know and Access You have the right to request that CRG disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting or disclosing that Personal Information.
• The categories of third parties with whom we disclose that Personal Information.
• The specific pieces of Personal Information we collected about you (also called a data portability request).

Right to Delete You have the right to request that CRG delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We are not required to delete information where we are permitted or required to retain it, such as for tax, or record keeping purposes, to process orders and transactions, and for solely internal uses consistent with your relationship with us. If we deny your request to delete based on any of these exceptions, we will inform you in writing of the reason.

Right to Correct If you believe there are any inaccuracies in the Personal Information that we have collected, processed, or otherwise obtained about you in the last 12 months, you may submit a request to us, and subject to our verification of that request, we will correct the inaccuracies, subject to applicable legal exceptions.

Exercising Your Data Privacy Rights To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by any of the following methods:

• Contacting us at Cohn Restaurant Group, Inc., 2225 Hancock Street, San Diego, CA 92110
• Calling us toll free at 833-991-3879
• Emailing us at privacy@dinecrg.com

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. We will ask you to provide certain additional information about yourself, such as name, physical address, email address and phone number, or other identifying information, to compare to information we have on file for you to verify your identity. We cannot fulfill your request if we cannot verify your identity. It may take up to forty-five (45) days to fulfill your request. If we cannot complete your request within the initial forty-five (45) day period, we will notify you in writing within forty-five (45) days of your initial request.

Making a verifiable consumer request does not require you to create an account with us. However, if you have an account, you may also exercise some of the above rights through our Mobile Application. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Personal Information Sales and Sharing Opt-Out Rights We may disclose certain Personal Information to third parties, including third parties who may process your personal information for targeted advertising. These activities may be considered a “sale” or “share” under the CCPA.  If you are a resident of California you have the right to opt-out of sharing your Personal Information by contacting us using any of the following methods:

• Contacting us at Cohn Restaurant Group, Inc., 2225 Hancock Street, San Diego, CA 92110
• Calling us toll free at 833-991-3879
• Emailing us at privacy@dinecrg.com

Non-Discrimination We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not, solely as a result of your exercise of your rights under the CCPA:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. However, we will continue to offer you discounts and other benefits if you choose to participate in the CRG Loyalty Club.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. You may voluntarily participate in our CRG Loyalty Club. If you elect to participate, we may collect certain Personal Information about you as described in this State-Specific Privacy Notice or our general CRG Privacy Notice. As part of your participation in the CRG Loyalty Club, we may from time to time provide you with certain offers for menu items, which may result in different prices for certain menu items. You may find out more about the specific terms of your participation in the CRG Loyalty Club in our Mobile Application or on our Website.

Virginia

If you are a resident of Virginia, you have certain rights under the Virginia Consumer Data Protection Act (“VCDPA”), including: the right to access, the right to know, the right to delete, the right to correct, and the right to non-discrimination (as provided in the California – Your Rights and Choices section above). You may exercise these rights as described in the California – Exercising Your Data Privacy Rights section above.

In addition, you have the right to opt out of processing your Personal Information for purposes of targeted advertising by sending a request by contacting us using any of the following methods:

• Contacting us at Cohn Restaurant Group, Inc., 2225 Hancock Street, San Diego, CA 92110
• Calling us toll free at 833-991-3879
• Emailing us at privacy@dinecrg.com

Nevada

If you are a resident of Nevada, you may request that we do not “sell” certain of your “Covered Information” as defined in Nevada Revised Statutes Chapter 603A, by sending a request by contacting us using any of the following methods:

• Contacting us at Cohn Restaurant Group, Inc., 2225 Hancock Street, San Diego, CA 92110
• Calling us toll free at 833-991-3879
• Emailing us at privacy@dinecrg.com