Cohn Restaurant Group Privacy Policy

Cohn Restaurant Group and its affiliated companies (“Cohn Restaurant Group”, “we” or “us”) respect the privacy of every individual who visits our websites and restaurants. This Privacy Policy describes what information we collect about you and how we may collect, use and disclose it. It also describes your rights regarding your personal information. By visiting our websites and restaurants, you are accepting the practices described in this Privacy Policy.

Information We Collect.

We collect information you provide directly to us, information from third parties and information we collect through automated means.

Personal Information We Collect Directly From You and Through Third Parties
Cohn Restaurant Group collects information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with you or your household (referred to herein as “personal information”) that you voluntarily provide to us or our third party web servers or service providers. The categories of personal information we collect and have collected within the past 12 months include:

• Identifiers: Including without limitation your real name, account name, unique identifiers, email address, postal address, birthdates or other similar identifiers.
• Characteristics of Protected Classifications: Including without limitation your age, gender, or race and ethnicity.   
• Payment Data: Including without limitation your credit card information, billing address or any financial information you provide in connection to your purchase of our products or services.
• Commercial Information: Including without limitation our products or services you purchased, obtained or considered, restaurants you have visited or booked reservations at, details about events you planned or executed at our restaurants or any other information relating to your purchasing or consuming histories or tendencies as it relates to our restaurants, products and services.
• Internet or Other Electronic Network Activity Information: Including without limitation your browsing history, search history and any other information regarding your interaction with our websites, advertisements, or third party applications.
• Profile Data: Including without limitation records of restaurants you frequently visit, neighborhoods you dine in, your areas of interest and any other information you provide regarding your interests, characteristics and preferences. 
• Messages You Send Us:  Including without limitation your event inquiries, marketing, sales or advertising proposals, feedback and reviews of our restaurants, products and services, or questions and information you provide to our staff and customer support.

If you apply for a job at Cohn Restaurant group, your personal information may be collected and used as further set forth in our Employee Privacy Policy.  By providing us with your information, you agree that we may contact your former employers, organizations, schools or professional associations provided by you to verify the accuracy of such information. 
 
Personal Information We Collect Automatically
We may collect information automatically which may not necessarily identify you as an individual. For instance, we may collect and have collected within the past 12 months the following types of information from you:

• Device and Internet Identifiers: You can visit our websites without telling us who you are or revealing any personally identifiable information about yourself. Our web servers automatically collect unique identifiers that can be used to recognize you or your device, including without limitation your domain name, Internet Protocol address, beacons, pixel tags or other device and mobile identifiers or similar technology.  We do not require anyone to provide us with personally identifiable information to view our websites.
• Traffic and Device Count:  We may track devices which have communicated with our Wi-Fi systems in our restaurants pursuant to our Terms of Service that you will need to agree to before accessing our Wi-Fi systems. Such tracking may include information that is personally identifying or specific to your mobile device (e.g. MAC addresses), and may be stored up to 30 days from the date of our collection. 
• Cookies: To enhance your experience on our websites, we use “cookies” or similar technologies.  A "cookie" is a text file that websites send to a visitor's computer or other Internet-connected devices to uniquely identify the visitor's browser or to store information or settings in the browser. We may use cookies to among other things, personalize your experience, recognize you when you return and enable you to use our third party applications on our website (e.g.  our shopping cart).
• Video Surveillance:  As a security measure and to ensure the safety of our properties, we use video surveillance technology at our restaurants. This collection is subject to applicable privacy laws and may be shared only in limited circumstances, as detailed in this Privacy Policy.  

How We Use It
 
Cohn Restaurant Group collects and uses information for business and commercial purposes in accordance with the practices described in this Privacy Policy.  Our business purposes for collecting and using information include without limitation:

• Sending you alerts regarding our restaurants’ happy hour specials, wine and beer events, gift card promotions, member-only discounts, and other updates regarding our services and products we think may interest you, but only if you voluntarily provide such information when signing up for our e-Cuisine Club.  You may withdraw your membership or update your information at any time by contacting us via email at letseat@dinecrg.com or clicking the “unsubscribe from this list” or "update your preferences" links in the footer of any e-Cuisine email.  If you cancel your membership to our e-Cuisine Club or decide not to enroll, you may not benefit from the promotions and discounts that may be exclusively offered to our e-Cuisine Club members.
• Processing your purchases and reservations.
• Operating, managing and improving our websites, restaurants, customer outreach, advertisements, services, products and promotions.
• Performing services requested by you, such as responding to your comments and dining requests, processing, servicing or enforcing transactions and sending related communications.
• Maintaining the security and integrity of our systems, operations and restaurants.
• Preventing and addressing fraud, unlawful access and breach of our policies and terms.
• Sending you technical notices, updates, security alerts, information about our policy changes and administrative messages.
• Analyzing trends and usage, such as the efficiency of deliveries and restaurant operations, and troubleshooting problems with our website, software or Wi-Fi systems.
• Helping to establish and verify the identity of users and complying with all applicable laws and regulations.
• Fulfilling any other business or commercial purposes at your direction or with your consent. 

Who We Share Your Data With
 
We disclose information we collect in accordance with the practices described in this Privacy Policy. The categories of entities to whom we disclose and have shared information within the last 12 months, include:

• Service Providers: Cohn Restaurant Group shares information with entities that help us with maintaining and operating our websites, payment processing, data analytics, marketing and advertising, and other business purposes. These companies may only use such information to perform those functions and may not use it for any other purpose, although we may permit them to use aggregate information which does not identify you or de-identified data for any purpose except as prohibited by applicable law.
• Vendors: We may share information with vendors and other entities in connection with tailoring advertisements, measuring and improving our websites and advertising effectiveness, processing your specific requests and reservations, executing events at our restaurants (e.g. weddings), and enabling other enhancements to our restaurants, products and services. These companies may act as our service providers, or in certain contexts, independently decide how to process your information.
• Affiliates: We share information with our related entities including without limitation our parent, subsidiaries and sister companies, or to their employees, agents, contractors, representatives, legal counsel and/or accountants, for: operational, management and administrative purposes; internal audit, legal, regulatory, security, insurance, financial, processing and other similar purposes; or as otherwise permitted or required by law.
• Promotions: If you voluntarily enroll in our e-Cuisine Club, we share information to help us provide and operate our e-Cuisine Club offerings.  This includes without limitation sharing your information with our service providers that maintain our e-Cuisine newsletters, our third party partners (if applicable) participating in our promotions or other third parties for administrative purposes.
• Merger or Acquisition: We may share information if Cohn Restaurant Group is involved in a merger, acquisition, or sale of all or a portion of its assets.  We will not provide you with notice before disclosure in such cases. 
• Security and Compelled Disclosure: Cohn Restaurant Group must disclose information about you in response to lawful requests by public authorities, including but not limited to meet national security or law enforcement requirements. We may share information about you in connection with legal requirements, such as in response to an authorized subpoena or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others or investigate fraud. Such disclosures may be carried out without notice to you.
• Facilitating Requests: We share information at your request or direction, such as when you purchase a gift card and direct us to send it to a certain recipient. 
• Consent: We may share your information with notice and as required by applicable law, with your consent.

 
Security

We believe our websites incorporate safeguards to protect the security, integrity, completeness, accuracy and privacy of the personal information we have collected.  We have put in place reasonable precautions to protect information from loss, misuse and alteration.  However, despite our efforts, please be aware that no security measures are perfect or impenetrable and we cannot guarantee that the information you transmit or provide to us will be completely secure.

Do Not Track
 
Cohn Restaurant Group does not track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such websites, most web browsers (like Safari) allow you to set the DNT signal on your browser so third parties (particularly advertisers) know you do not want to be tracked.

Privacy Policies of Third Parties and External Links
 
Our websites contain links to several third party websites not owned or controlled by Cohn Restaurant Group and this Privacy Policy does not apply to such websites or the use of any data by such websites. Should you decide to navigate to any websites or webpages external to the our websites, you do so entirely at your own risk. We are not responsible for the actions, privacy, security or content of such third party websites. If you are asked to provide information on one of these websites, we encourage you carefully to review their privacy policy before sharing your information.
 
Please note most reservations at Cohn Restaurant Group’s restaurants are managed by third party service providers, including without limitation Open Table.  All information shared with such third party providers, like Open Table, are governed by such third party’s terms and conditions and privacy practices. The services of Open Table, and any other third party websites linked to our websites, are not within the scope of this Privacy Policy and Cohn Restaurant Group expressly disclaims any liability, obligation or responsibility whatsoever for the content or use of such third-party websites or services.  For more information on how Open Table collects and uses your personal information, please visit its privacy policy at https://www.opentable.com/legal/privacy-policy.
 
Policy Changes

Cohn Restaurant Group may at any time amend the provisions in this Privacy Policy. Changes to this policy will be reflected by the “Effective Date” as displayed in the upper right hand corner of this policy. If the changes are significant, we may provide a more prominent notice. You may have the ability to opt-out of new non-essential uses or disclosures.
 
Children
 
Our websites are intended for general audiences and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you become aware that a child has provided us with personal information without parental consent, please contact us at ccparequests@dinecrg.com. If we become aware that a child under 13 has provided us with personal information without parental consent, we will take reasonable steps to remove such information and terminate the child’s account.
 
California Residents: Your California Privacy Rights
 
Under the California Consumer Protection Act of 2018 (“CCPA”), California residents have certain rights regarding the collection, use and sharing of their personal information by Cohn Restaurant Group. 
 
If you are a resident of California, you have the right to request to know what personal information has been collected, used and disclosed about you within the past 12 months of the date of your request, and to access that information. You may also request deletion of your personal information, though exceptions under the CCPA may allow Cohn Restaurant Group to retain and use certain personal information notwithstanding your deletion request.  We will not discriminate against you for exercising your rights under the CCPA.
 
Separate from the CCPA, California’s Shine the Light law gives California residents who provide personal information in obtaining products or services for personal, family, or household use the right to request and obtain from us, once each calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared your personal information for the immediately preceding calendar year.  We do not disclose your personal information to third parties for the purpose of directly marketing their goods or services to you unless you request such disclosure.
 
Cohn Restaurant Group does not sell your personal information and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law.
 
You may exercise any of your rights described in this section by contacting us via the methods listed under “How to Contact Us” below.
 
We will take reasonable steps to verify your identity before responding to a request, which may require you to provide (a) three specific pieces of data we have on file for you (e.g. your name and email address you used when signing up for our e-Cuisine Club and your billing information such as the last 4 digits of your credit card or billing address you disclosed when purchasing a gift card) and (b) a statement that you “declare under penalty of perjury that you are the person about whom the Right to Know/Delete request has been made.”
 
You are also permitted to designate an authorized agent to submit certain requests on your behalf. For an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity according to the above method before processing the authorized agent’s request.
 
If we cannot successfully verify you according to the above methods, then we will not be able to comply with your request.
 
Nevada Residents: Your Nevada Privacy Rights
 
Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt-out of the sale of certain information that the website operator may collect about them. Cohn Restaurant Group does not sell your personal information to third parties as defined in Nevada law, and will not do so without providing you with notice and an opportunity to opt-out of such sale as required by law. If you have any questions regarding our data privacy practices or our compliance with Nevada data privacy law, please contact us via the methods listed under “How to Contact Us” below .
 
Geographic Restrictions
 
We may limit the availability of our websites to any person or geographic area at any time.  If you access our websites from outside the United States, you do so at your own risk.
 
OUR WEBSITES ARE INTENDED FOR UNITED STATES RESIDENTS ONLY.  IF YOU ARE A USER ACCESSING OUR WEBSITES FROM ANY OTHER COUNTRY WITH LAWS OR REGULATIONS GOVERNING PERSONAL DATA COLLECTION, USE AND DISCLOSURE THAT DIFFER FROM THE LAWS OF THE UNITED STATES, PLEASE BE ADVISED THAT THROUGH YOUR CONTINUED USE OF OUR WEBSITES, YOU ARE TRANSMITTING YOUR PERSONAL DATA TO THE UNITED STATES AND YOU CONSENT TO THAT TRANSMISSION. ADDITIONALLY, YOU UNDERSTAND THAT YOUR PERSONAL INFORMATION MAY BE TRANSMITTED TO AND PROCESSED IN COUNTRIES (INCLUDING THE UNITED STATES) WHERE LAWS REGARDING PROCESSING PERSONAL INFORMATION MAY BE LESS STRINGENT THAN IN YOUR COUNTRY.
 
How to Contact Us

If you have questions or concerns regarding our Privacy Policy or need to obtain a copy of this Privacy Policy in alternate format due to a disability, please contact us at 1-800-991-3879, by email at ccparequests@dinecrg.com or by mail at:

Cohn Restaurant Group
2225 Hancock Street
San Diego, CA 92110