PURPOSE AND SCOPE. This Privacy Policy describes the personally identifiable information (“PII”) that Best American Hospitality Corp. on behalf of Shoney’s North America, LLC and its related companies (collectively, “Shoney’s”) collects on shoneys.devdigdev.com and any other website and mobile application (“app”) operated by Shoney’s (collectively, the “Sites”) and describes the privacy and information security practices of the Sites.  These Sites are operated by: Best American Hospitality Corp. 1717 Elm Hill Pike, Suite B-1, Nashville TN 37210 (877) 377-2233, option 9 privacy@shoneys.devdigdev.com Some of these Sites, including the Shoney’s® E-Club and the Shoney’s® Kids’ Club, may be directed at children under the age of 13 (“Children”).  Please see the section below, labeled “Compliance with the Children’s Online Privacy Protection Act,” for more information regarding the privacy and information security practices of these Sites directed at children under the age of 13. Please read this Privacy Policy carefully because it identifies certain legal rights afforded to users of these Sites.  By accessing, viewing and/or using these Sites, you agree to be bound by this Privacy Policy and all other terms and conditions set forth in the Sites.  By continuing to access, view, or use these Sites, you are expressly granting Shoney’s the right to use and disclose your PII in accordance with this Privacy Policy.

• INFORMATION COLLECTION –NON-PERSONALLY IDENTIFIABLE INFORMATION. We may collect non-personal identification information about our users whenever they interact with our Sites. Non-personally identifiable information may include the browser name, the type of computer and technical information about our users means of connection to our Sites, such as the operating system and the Internet service providers utilized, statistical information on user browsing patterns, page view information, unaffiliated sites visitors come from or go to when visiting the Sites, and other similar information. We also collect geolocation data such as real-time information about the location of your device (GPS and network-based), even when the Site is closed, to enable the locations and directions features.
• INFORMATION COLLECTION–PERSONALLY IDENTIFIABLE INFORMATION. When any visitor links or connects to the Sites, our web server automatically recognizes the visitor’s domain name and e-mail address where possible.  Personally Identifiable Information Shoney’s may collect PII through these Sites.  PII includes, but is not limited to, a person’s name, address, email address, password, relationship information, date of birth, anniversary or any other information that a person chooses to share, such as by including it in a message to Shoney’s.  We are prohibited by law from conditioning your child’s use of this Site or your child disclosing more personal information than is reasonably necessary to use the Site.
• USE OF COOKIES. These Sites use data collection devices such as “cookies” on certain pages of the Sites as a convenience to users so that users do not have to repeatedly input the same information in different parts of the Sites or on repeat visits to the Sites.  Cookies are small text files that are transferred from your browser to a Web server which a Web site can use to recognize a repeat visitor to the Sites.  Most browsers are initially set to accept cookies. You can set your browser to notify you when you receive a cookie, which gives you the chance to decide whether or not to accept it.  While Shoney’s uses cookies to track visitors to the Sites, our Web servers automatically log the IP/Internet address of your computer.  This information does not identify you personally and you remain anonymous unless you have otherwise provided Shoney’s with PII about you.
• INFORMATION USAGE AND DISCLOSURE. Shoney’s uses the PII our users provide to provide them with enhanced products and services, for internal marketing purposes, to improve the content of our Sites, for registration in our promotions, and to provide PII to those visitors who ask for their own PII.  Shoney’s does not sell, trade, exchange, or otherwise provide PII it receives from a visitor to any third party except as disclosed in this Privacy statement. Shoney’s may use certain third-parties to provide specific services on our behalf (“Third-Party Service Providers”), such as collecting and maintaining PII and sending out marketing materials, including emails.  Shoney’s may disclose information about its users, including Children, to such Third-Party Service Providers.  These Third-Party Service Providers are required to maintain the confidentiality of this information and must agree to use such information only in a manner consistent with this Privacy Policy and not for their own purposes. Finally, Shoney’s may disclose information, including PII, as necessary to protect against actual or potential fraud, liability, loss, or other claims and as reasonably necessary to respond to any and all legal processes.
• OPT IN/OPT OUT. If any visitor wishes to opt out of personal information sharing, he or she may do so by contacting Shoney’s at (877) 377-2233, option 9 or sending an email to privacy@shoneys.devdigdev.com.
• CORRECTION OF INFORMATION. Visitors to the Sites who previously provided information to Shoney’s can change or remove the information at any time.  The Sites give all registered visitors the opportunity to update or correct their information previously provided.  Parents/guardians also have the right to delete information collected about their Children by sending an email request to privacy@shoneys.devdigdev.com.
• SECURITY. We have instituted physical, electronic and procedural safeguards to store and maintain the personal information collected through this Site in a secure environment.  Access to the data collected through the Sites is limited to authorized Shoney’s employees and its agents acting under express instruction from Shoney’s.  You should also be aware that despite our efforts, factors beyond our control may result in disclosure of personal information.  Accordingly, we are not in a position to guarantee that your information will be secure under all circumstances.
• BUSINESS TRANSITIONS. In the event that Shoney’s goes through a business transition, such as a merger, acquisition, liquidation or sale of all or a portion of its assets, the information collected through this Site will, in most instances, be part of the assets transferred.
• YOUR CALIFORNIA PRIVACY RIGHTS. California Civil Code Section 1798.83 permits customers of Shoney’s who are California residents to request certain information regarding its disclosure of personal information to third parties for their direct marketing purposes.  Shoney’s does not make such disclosures.
• CHANGES TO THIS POLICY. We may amend this Privacy Policy at any time by posting the amended terms on the Web site. In addition, we will place a prominent notice that this Policy has changed on the main Web site page.  All amended terms are immediately effective after they are initially posted on the Web site.
• COMPLIANCE WITH THE CHILDREN’S ONLINE PRIVACY PROTECTION ACT. Certain Sites and features, such as the Shoney’s® E-Club and Shoney’s® Kids’ Club, are intended for or may be used by children under the age of 13 years of age (“Child” or “Children”).  In order to use such Sites or features, Shoney’s may need to collect and use personally-identifiable information about a Child registrant, such as a name, date of birth, email address, and physical address.  Shoney’s fully complies with the Children’s Online Privacy Protection Act in the collection and use of information.  Shoney’s Sites are operated by: Best American Hospitality Corp. 1717 Elm Hill Pike, Suite B-1, Nashville TN 37210 (877) 377-2233, option 9 privacy@shoneys.devdigdev.com Shoney’s may use a Child’s PII provided by the Child to respond directly on a one-time basis to his or her specific request. Shoney’s® E-Club and Shoney’s® Kids’ Club are designed to provide children of all ages and their parents, grandparents, or legal guardians with information about special offers and promotions.  Users over the age of 13 may register by providing PII about themselves on the registration form.  However, Children are not allowed to register at the Kids’ Club and may not provide PII about themselves to Shoney’s through the Kids’ Club registration form. To register a Child under the age of 13 for the Shoney’s® E-Club and/or Shoney’s® Kids’ Club, Shoney’s will collect that Child’s parent’s or legal guardian’s email address.  Shoney’s will use the contact information it initially collects only to obtain the parent’s or legal guardian’s consent.  Once Shoney’s receives the parental or legal guardian verifiable consent, we will collect or use the Child’s PII in accordance with this Privacy Policy. A Child’s parent or legal guardian may revoke his or her consent at any time. Children’s PII Collection and Usage Notice Shoney’s primarily collects information about Children for the same reason it collects information about adults – to provide information or materials about Shoney’s® Restaurants.  Shoney’s may not condition a Child’s participation in any activity on the Sites on the disclosure of more information than is reasonably necessary to participate. Shoney’s only collects a Child’s name, address, e-mail address, date of birth, password, and relationship with parent or guardian.  Such PII is collected actively by the direct submission of such information by a parent or legal guardian. By providing consent, a Child’s parent or guardian agrees that Shoney’s may use the Child’s PII in compliance with this Privacy Policy.  Shoney’s uses the PII our users provide to provide them with enhanced products and services, for internal marketing purposes, to improve the content of our Sites, for registration in our promotions, and to provide PII to those visitors who ask for it.  Shoney’s does not sell, trade, exchange, or otherwise provide PII it receives from a visitor to any third party except as disclosed in this Privacy Policy. Shoney’s will not make a Child’s PII available through any chat rooms, message boards, or in videos posted to the Sites. Shoney’s may use certain third-parties to provide specific services on our behalf (“Third-Party Service Providers”), such as collecting and maintaining PII and sending out marketing materials, including emails.  Shoney’s may disclose information about its users, including Children, to such Third-Party Service Providers.  These Third-Party Service Providers are required to maintain the confidentiality of this information and must agree to use such information only in a manner consistent with this Privacy Policy and not for their own purposes. Finally, Shoney’s may disclose information, including PII, as necessary to protect against actual or potential fraud, liability, loss, or other claims and as reasonably necessary to respond to any and all legal processes, or to improve our products and services. Verifiable Parental or Guardian Consent When a person tries to register a Child in the Shoney’s® E-Club and/or Shoney’s® Kids’ Club, Shoney’s will collect contact information about the Child’s parent or guardian in order to send a notice that the Child wants to register or someone else wants to register the Child for the Kids’ Club.  The parent or guardian will be required to respond to the notice giving their affirmative consent to collecting and using PII about the Child. Parental Access, Correction, Deletion of a Child’s PII A parent or guardian may, at any time, prevent Shoney’s from collecting additional information about their Child and can request that we delete PII we already collected.  A parent or guardian may access, correct or delete a Child’s information by emailing us at privacy@shoneys.devdigdev.com or logging into the parent’s or guardian’s account established at registration. Change of COPPA Privacy Policy Shoney’s may amend its Privacy Policy, including this section on Compliance with the Children’s Online Privacy Protection Act, at any time.  In the event we make such a change that materially affects the way we collect, use, or disclose PII about Children already registered, we will provide email notice to the parents and guardians of such Children.  Any other changes will be posted in this Privacy Policy and a “Update” notice will be displayed with the link to this Privacy Policy.
• QUESTIONS. Parents or guardians may contact Shoney’s at any time with questions, concerns, or comments about this Privacy Policy or our Compliance with the Children’s Online Privacy Protection Act by contacting us at: Best American Hospitality Corp. 1717 Elm Hill Pike, Suite B-1, Nashville TN 37210 (877) 377-2233, option 9 privacy@shoneys.devdigdev.com

4/2021