Privacy Statement for Cluck-U, Corp. Operating under

 (Cluck-U Chicken & Cluckster’s) for the
Website &

Online Services

Effective Date: January 1, 2025

At Cluck-U, Corp., we value your privacy. This Privacy Statement (“Statement”) outlines how we collect, use, store, protect, share, and otherwise handle your personal information when you engage with us. This includes visits to our restaurants, interactions through our websites and mobile applications, and other forms of communication.

Scope of this Privacy Statement

Please note that many Cluck-U restaurants are independently owned and operated by franchisees. These franchisees are separate business entities, and this Statement does not apply to their operations or the digital platforms they manage. For information on their privacy practices, please refer to the privacy policies of the respective franchisees.

Information We Collect and How We Use It

We collect personal information through various means when you interact with us in person, through our online platforms, or via third-party services (collectively, the “services”). This information falls into three primary categories:

1. Information You Provide
2. Information Collected Automatically
3. Information Obtained from Other Sources

While you are not obligated to provide personal information, certain services may not be available to you if such information is withheld.

We may combine data you provide with data collected automatically or obtained from third-party sources. For instance, if you add a payment method to your profile in our mobile app, we may merge that information with transaction data received from our payment processors.

1. Information You Provide to Us

Depending on your interaction with Cluck-U, Corp., you may provide:

• Contact details (e.g., name, mailing and email addresses, phone number, date of birth) when registering online, connecting to Wi-Fi, entering promotions, or contacting us.
• Demographic information (e.g., age, gender).
• Purchase and transaction details, including items ordered, payment methods Credit/Debit Card Information, and pricing.
• Account credentials (e.g., username, password).
• Preferences, such as favorite products or visit times.
• Additional personal details shared during customer service interactions, including via social media or call centers.

2. Information Collected Automatically

We may gather information automatically through technologies such as cookies, web beacons, and local storage when you use our online services or in-store technologies. This may include:

• IP address
• Operating system and browser details
• Mobile device type and configurations
• Unique device identifiers (e.g., UDID, MEID)
• Serial numbers of devices/components
• Advertising identifiers (e.g., Apple’s IDFA)
• Referring web pages or applications
• Activity on third-party sites, apps, or social media
• Video recordings from visits to our restaurants (where applicable)
• Online behavior and navigation through our services

Some of our digital services may also access location information from your device using GPS, Wi-Fi, Bluetooth, or cellular data. Most devices allow you to disable location tracking through settings. If you need help disabling this feature, please consult your device manufacturer or service provider. Note that disabling location services may affect functionality of some features.

3. Information from Third Parties

We may also receive personal information from other sources, including:

• Other Cluck-U, Corp. entities and franchisees
• Business partners and vendors such as delivery platforms, data service providers, and payment processors
• Publicly available sources, including public social media profiles

How We Use the Information We Collect

We utilize the various categories of personal information we collect for the following purposes:

• To deliver our products and services and fulfill our contractual obligations, including processing payments and providing customer support;
• To manage our relationship with you, such as gathering feedback and conducting customer satisfaction surveys;
• To enhance and personalize your experience with our products and services, including improving existing technologies, developing new offerings, and utilizing profiling techniques (note: this does not involve automated decisions with legal or similarly significant effects unless separately disclosed);
• To deliver both general and customized marketing communications—via electronic and non-electronic means—about our products, services, promotions, contests, and sweepstakes, as well as those of our business partners;
• To conduct business and operational analytics, including research into customer behavior, sales performance, marketing effectiveness, and future demand forecasting;
• To maintain the integrity and security of our online platforms and in-restaurant technology, including the prevention and investigation of unauthorized access or attacks;
• To detect, prevent, and respond to fraudulent activity, unlawful behavior, claims, and other potential liabilities;
• To safeguard the rights, safety, health, and property of our customers, employees, franchisees, and the public;
• To anonymize your data for internal and external uses that do not personally identify you;
• To comply with legal requirements, internal policies, and our Standards of Business Conduct; and
• To establish, exercise, or defend legal claims.

We may also use your information for other purposes, which will be disclosed to you at the time of collection or before such use begins.

How We Share Your Information

We may disclose any category of personal information to the following entities:

• Other members of the Cluck-U, Corp. group of companies;
• Service providers and vendors who support our operations (e.g., IT providers, marketing firms, fraud prevention services), some of whom may also use this data in providing services to others;
• Government authorities or judicial bodies, as legally required;
• Parties involved in a potential or actual business transfer, merger, or acquisition involving Cluck-U, Corp.;
• Professional advisors, including legal counsel, auditors, and insurance brokers; and
• Business partners involved in fulfilling your experience with us, such as delivery service providers.

We do not sell your personal information for monetary gain. However, certain U.S. state laws may define “sale” more broadly to include data sharing for valuable consideration. Some of our partnerships with online advertising and analytics providers may fall within these definitions.

Children’s Privacy Statement

Protecting children's privacy is a priority for Cluck-U, Corp. Our online services are not intended for use by children without appropriate parental supervision. We encourage parents to actively monitor their children’s online activities.

Marketing Communications

If you have subscribed to our marketing communications, you may opt out at any time by following the unsubscribe instructions provided in our messages. You can also manage your preferences through your online profile or device settings, or by contacting us.

Please note that opting out of marketing communications does not affect service-related messages about your transactions, account, or participation in contests or promotions. Opting out of one form of communication (e.g., email) does not automatically unsubscribe you from others (e.g., SMS), unless you adjust each separately.

We do not share your personal information with third parties for their own direct marketing purposes without your explicit consent. If you authorize such sharing, we will do so only in accordance with your instructions.

Online Surveys

Cluck-U, Corp. values opinions and comments from members, so we frequently conduct online surveys. These surveys are entirely optional for all members. Typically, the information is aggregated and used to make improvements to CluckUChicken.com and to develop appealing content, features and promotions for members. Survey participants are anonymous unless otherwise stated in the survey.

Use of Cookies and Related Technologies

Cluck-U, Corp. and our authorized service providers may utilize cookies, web beacons, pixels, and other similar technologies across our online services and related business operations, including advertising activities. These tools are used to collect data and deliver the products or services you request, as well as to enhance your experience.

Understanding Cookies, Pixels, and Tracking Technologies

Our online platforms use cookies, tracking pixels, and related technologies to operate effectively and securely, remember your preferences, personalize content and communications, combat fraud, analyze usage, and improve performance. These technologies also support functions described throughout this Privacy Statement.

A cookie is a small text file stored on your browser or device that helps remember your activity and preferences. A cookie typically includes the domain of origin, its duration, and a unique identifier. You can adjust your browser settings to decline cookies or receive alerts when cookies are sent. However, disabling certain cookies may limit some functionality of our services.

Some pages on our websites, social media accounts, and in our emails may include web beacons (also known as pixels or tags). These are small graphic elements embedded in content that help monitor user interaction and improve our services. When used with cookies, they provide deeper insights into customer engagement.

Please note the following regarding cookies and tracking technologies:

• You may receive cookies when using our services;
• Certain features are only available with the use of cookies or similar technologies;
• We may use both session cookies (active during your visit) and persistent cookies (which remain for a fixed time unless deleted);
• We may implement emerging technologies as they become available;
• Web beacons may be used across our platforms and communications.

Types of Cookies Used on Our Online Services

We may use the following categories of cookies, either placed by us directly or by approved third-party providers:

• Strictly Necessary Cookies: Essential for the operation of our services. These cookies enable core functions like security, system administration, and fraud prevention. They cannot be disabled via user settings, though your browser may allow you to block them (which may impair service functionality).
• Performance Cookies: Help us analyze traffic and user behavior to improve the efficiency and usability of our services. These cookies track which pages are visited most often and how users navigate our platforms.
• Functional Cookies: Enable advanced features and personalized settings, such as language preferences or saved login details. Disabling these cookies may affect service performance.
• Targeting Cookies: May be placed by us or our advertising partners to build a profile of your interests and display relevant ads across other websites. These cookies can set or modify third-party cookies through your browser.
• Social Media Cookies: Set by social platforms integrated with our services to allow content sharing. These may track your browsing behavior across other sites and contribute to personalized advertising.
• YouTube Cookies: Used to load and display embedded video content from YouTube. Disabling these cookies may prevent video playback on our platforms.

We and select third-party partners (such as advertising networks) may use these technologies to track your activity over time and across different websites and devices, to enhance and tailor your digital experience with Cluck-U, Corp.

How to control and delete cookies

You have options to control and/or delete cookies as described below.  Please be aware that restricting cookies may have an impact on online services’ functionality. Disabling these cookies may limit your experience, including your ability to find pricing and availability of products and services in your area. 

Cluck-U, Corp.’s Cookie Settings Tool 

You may accept or reject cookies, except strictly necessary cookies, by using the cookie preference section of the online service.

Browser Controls:  Use the options in your web browser if you do not wish to receive a cookie or if you wish to set your browser to notify you when you receive a cookie. Select the “Help” section of your browser to learn how to change your cookie preferences. If you disable all cookies, you may not be able to take advantage of all the features available on a website.

Links to Third-Party Websites and Social Media

Our online services may contain links to third-party websites or digital platforms not operated or controlled by Cluck-U, Corp. When you access these linked sites, we encourage you to review their respective privacy policies, terms of use, and related policies. We are not responsible for the privacy practices or content of any third-party websites or services. Any information you provide to those entities will be governed by their policies.

Additionally, our services may incorporate third-party applications, tools, widgets, or plug-ins—such as social media buttons (e.g., Facebook “Like” buttons)—which may collect information about your interactions with those features through automated technologies. These third parties may use your information in accordance with their own privacy practices.

Security of Your Personal Information

Cluck-U, Corp. implements a combination of technical, physical, and organizational safeguards to help protect your personal information from unauthorized access, disclosure, alteration, or loss. These include commercially reasonable security practices, both internally and in collaboration with our third-party service providers. However, no method of data transmission or storage can be guaranteed to be completely secure. We encourage you to take appropriate precautions, such as protecting your login credentials and avoiding sharing them with others.

Data Retention

Unless a longer retention period is required or permitted by law, Cluck-U, Corp. retains your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Statement and any applicable regional addendums. Retention periods are based on legal requirements and business needs.

We retain and use your information as needed to:

• Maintain your relationship with us;
• Enhance and personalize your customer experience;
• Comply with legal obligations (e.g., tax or revenue recordkeeping);
• Resolve disputes;
• Enforce our agreements; and
• Support other uses consistent with this Privacy Statement

Updates to This Privacy Statement

We may update this Privacy Statement from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make changes, we will revise the “Last Updated” date at the top of this Statement and, where appropriate, notify you through our online services or by other means. We encourage you to review this Privacy Statement periodically to stay informed about how we protect your personal information.

Your continued use of our services after any updates constitutes your acceptance of the revised Privacy Statement, except where your express consent is required by applicable law.

If you have any questions about this Privacy Statement or how your personal information is handled, please contact us at info@cluckuchicken.com.