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Privacy Policy

Last Revised: May 2025

STARR Restaurants respects your privacy and is committed to protecting your personal information. You can generally browse our websites without giving us any information about yourself. When we need your personal information to provide the services you request or when you choose to provide us with your personal information, this policy (“Privacy Policy” or “Policy”) describes how we collect, use, and protect this information.

INFORMATION COLLECTION

Personal information means any information that may be used to identify an individual, including but not limited to a first and last name, email address, telephone number, a postal or other physical address, birth date, gender, occupation, credit or debit card numbers to process payment for products and/or services, and such other information as needed to provide a service that you requested.

We may collect personal information about you when you visit our restaurants, visit our websites or mobile apps (“online services”), and otherwise interact with us (collectively, “services”). The information we collect falls into three categories: (a) information you provide to us; (b) information we collect through automated methods when you use our services; and (c) information we collect from other sources (as set forth below).

Generally, you are under no obligation to provide your personal information. However, in certain cases, we may be unable to provide you with our services unless you provide your personal information.

We may combine the information you provide to us with information that we collect through automated methods, and with information we receive from other sources.

Information you provide to us

We may collect the following information that you provide to us, depending on how you interact with us:

  • personal details, such as your name, postal and email addresses, phone number, birthday information, and other contact information, when you register with our online services, log-in to Wi-Fi, or contact us by phone or through our online services;
  • demographic information, such as your age or gender;
  • transaction information, including information about the products and/or services you buy, pricing, method of payment, and payment details;
  • account information, such as your username or password used to access our online services or to buy or use our products and/or services;
  • profile information, including products and services you like, or times you prefer to visit us; and
  • other personal information you choose to provide us when you interact with us (including through social media).

Information collected through automated methods

We may collect information from your computer system or mobile device through automated technology when you visit our restaurants or website, or use our online services or in-restaurant technology. Automated technology may include cookies, local shared objects, and web beacons.

We may collect information about your:

  • internet protocol (IP) address;
  • computer or mobile-device operating system and browser type;
  • type of device and its settings;
  • unique device identifier (UDID) or mobile equipment identifier (MEID) of your mobile device;
  • device and component serial numbers;
  • advertising identifiers (for example, an Identifier for Advertising (IDFA) on Apple devices) or similar identifiers;
  • referring webpage (a page that has led you to ours) or application;
  • online activity on other websites, applications, or social media;
  • visits to our restaurants, where recorded using digital technology (e.g. video recordings); and
  • activity related to how you use our online services or in-restaurant technology, such as the pages you visit on our websites or in our mobile apps.

Our online services and in-restaurant technology may collect information about the exact location of your mobile device or computer using geolocation and technology such as GPS, Wi-Fi, Bluetooth, or cell tower proximity. For most mobile devices and computer systems, you can disable the collection of this information by using the device or web browser settings. If you have any questions about how to prevent us from collecting precise information about your location, we recommend you contact your mobile-device service provider, the device manufacturer, or your web-browser provider. Some online services and in-restaurant technology may not work properly without information about your location.

Information collected from other sources

We may collect information about you from our business partners and vendors (e.g., food delivery platforms, data providers, or payment processors) or from public sources (e.g., your public social media posts).

STARR Restaurants only uses such information that has been collected in accordance with this Privacy Policy and applicable laws.

COOKIES AND OTHER TRACKING TECHNOLOGIES

A cookie is a small data file that is placed onto an Internet user’s web browser or device and is used to remember and/or obtain information about the user. A cookie can contain information that a website uses to track the pages you’ve visited. STARR Restaurants’ websites use cookies to track user traffic patterns. We do this to determine the usefulness of our website information to our users and to measure the effectiveness of our navigational structure in helping users reach that information.
In addition to cookies, our websites use other technologies, including web beacons (also sometimes referred to as pixels and tags). Web beacons are small objects or images embedded into a web page, application, or email that can be used to track user activity. STARR Restaurants also uses these technical methods to analyze traffic patterns, such as the frequency with which our users visit various parts of our websites.

Please note the following:

  • You might be assigned a cookie when using our online services.
  • We offer certain features that may be available only through the use of cookies and other similar technologies.
  • We may use both session (for the duration of your visit) and persistent (for the duration of a fixed period of time) cookies and other tracking technologies.
  • Our online services, apps, and websites may have web beacons.

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, use the options in your web browser to update your cookie preferences. If you disable all cookies, you may not be able to take advantage of all the features available on our website.

Please note that Starr Restaurants does not support “Do Not Track” browser settings at this time.

HOW WE USE INFORMATION COLLECTED

STARR Restaurants uses personally identifiable information for several general purposes:

  • to provide our products and services and contract with you, including payment processing and customer support;
  • to manage our relationship with you, including feedback management and customer surveys;
  • to personalize and improve our products and services and your overall customer experience, in particular by improving our existing technologies, developing new products and services, and employing profiling technology (unless we notify you separately thereof, this will not include automated individual decisions that have legal effects for you or similarly significantly affect you);
  • to provide you with general and personalized electronic and non-electronic direct marketing information and support our targeted advertising initiatives concerning our products and services, as well as our business partners’ products and services (including promotions, contests, and competitions);
  • to run business analytics, including consumer and operations research, to assess the effectiveness of our sales, online services, marketing, and advertising efforts, and to analyze market trends and (future) customer demand;
  • to ensure the security of our website, online services and in-restaurant technology, including the prevention, detection, and investigation of cyber attacks;
  • to protect against, identify, and prevent fraud and other crimes, claims, and other liabilities;
  • to protect the rights, safety, health, and security of our customers, our employees, and the general public, and to protect our property;
  • to anonymize your information for further internal and external use in a manner that does not identify you;
  • to comply with legal obligations, our policies, or our Standards of Business Conduct;
  • to establish, exercise, or defend legal claims; and
  • for other purposes as permitted by applicable law.

We may use the information we collect about you in other ways not stated in this Privacy Policy. If we do, we will notify you through an update to this policy at the time or before we begin using it for those other purposes.

INFORMATION SHARING AND DISCLOSURE

We do not sell your personal information and only share your information as described in this Privacy Policy or as otherwise communicated to you at the time we collect your information. Please note that some US state statutes may define a “sale” to include the disclosure of personal information to third parties for valuable consideration.

We may share your personal information with:

  • members of the STARR Restaurants portfolio of companies and their affiliates, and subsidiaries;
  • vendors who help us operate our business (including information technology service providers and marketing agencies that we use, as well as those who use the information to detect or prevent fraud for us and who may use the information to
  • provide fraud detection and prevention services to others);
  • public authorities and courts, as required to comply with legal obligations;
  • buyers or other parties involved in a corporate transaction if we decide to sell or transfer all or part of our business;
  • our professional advisers, such as our legal representatives, auditors, and insurance brokers;
  • business partners if they are involved in your customer experience, including product or service delivery (e.g., food delivery platforms) or reservation scheduling; other third parties as necessary, such as to protect and defend the rights or property of STARR Restaurants and to act in urgent circumstances to protect the personal safety of STARR Restaurants’ employees, customers, or members of the public.

We may share non-identifiable, aggregate information about our users (for example, the percentage of male and female visitors to our site) with advertisers, business partners, and other third parties in an effort to customize or enhance the content and advertising on our website for our users.

If you choose to provide us with your personal information, we may transfer that information within STARR Restaurants or to STARR Restaurants third-party service providers without your permission. We may transfer your information across borders and from your country or jurisdiction to other countries or jurisdictions around the world, but in the event we transfer your information, we will do so in accordance with applicable laws and regulations.

In addition, STARR Restaurants may share your personal information under any of the following circumstances:

  • When we have your consent to share the information;
  • When we need to share your information to provide the products and/or services you have requested;
  • When we send updates to keep you informed on the latest product announcements, program updates, special offers, or other information we think you’d like to hear about either from us or from our business partners (unless you have opted out of these types of communications).

YOUR DATA RIGHTS

Certain jurisdictions provide their residents with specific rights regarding their personal information. These rights may include:

  • Right to Know.  You have the right to know the personal information we have collected from you.
  • Right to Delete. You have the right to request that we delete certain information that we collected or maintain about you, subject to certain exceptions.
  • Right to Correct. You have the right to request that we correct inaccurate personal information we maintain about you, considering the nature of the information and purposes for processing it.
  • Right to Opt-out of the Sale or Sharing. If a business sells or shares your personal information for targeted advertising, you have the right to opt-out of the sale or sharing of your personal information.
  • Right to Limit Use of Sensitive Personal Information. If a business uses or discloses sensitive personal information for reasons other than those permitted by law, you have the right to limit the use and disclosure of that information. We use and disclose sensitive personal information only as permitted by law.
  • Right Not to Receive Discriminatory or Retaliatory Treatment. You have the right not to be discriminated or retaliated against for exercising any of your privacy rights.

You can always ask to review any personal information we have collected from and about you, to update, correct, or delete this information. If you wish to exercise these rights, contact us at privacy@starr-restaurants.com. Please include your full name, email address, and phone number associated with your use of our services, along with the rights you would like to exercise, so that we can process your request.

You may also designate an authorized agent to submit a request on your behalf. To designate an authorized agent, please provide a power of attorney or a written and executed document signed by both you and the agent authorizing them to act on your behalf.

We will take reasonable steps to verify your identity before responding to your request. We may not accommodate your data subject request in certain situations, such as if we believe that doing so would violate any law, negatively impact the accuracy of the information, require disproportionate effort, or if we are unable to verify your identity. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We may also decline to honor your request where the personal information that we maintain is not subject to applicable access, correction, and/or deletion rights.

DATA RETENTION

We retain personal information we collect from you for only as long as necessary to carry out the purposes for which the information was collected as outlined in this Privacy Policy and in accordance with our recordkeeping policies (unless a longer period is required by applicable law). We will retain and use your information to the extent necessary to manage your relationship with us, personalize and improve your overall customer experience, to comply with our legal obligations, resolve disputes, enforce our agreements, and as otherwise described in this Policy.

DATA SECURITY

Your personal information is protected for your privacy and security. STARR Restaurants safeguards the security and confidentiality of your personal information with physical, technical, and operational procedures. Please be aware that despite our best efforts, no security measures are perfect or impenetrable. While we strive to protect your personal information, we cannot ensure the security of the device(s) or system(s) you use to access our website or to transmit information to us, and so we urge you to take every precaution to protect your personal data when you are on the Internet. Change your passwords often, use a combination of letters, numbers, and special characters, and make sure you use a secure browser.

PROTECTION OF CHILDREN’S PERSONAL INFORMATION

Our website does not target and is not intended for children under the age of 18. STARR Restaurants does not knowingly solicit or collect personal information from children under the age of 18.

We are especially committed to protecting the privacy of children who may visit or use our online services. We urge parents to monitor and supervise their children\\\’s online activities regularly. If you have any questions about our children’s privacy practices, please contact us at the addresses provided below.

THIRD-PARTY WEBSITES AND SOCIAL MEDIA

Our website may contain links to websites operated by other companies. Some of these third-party sites may be co-branded with a STARR Restaurants logo, even though they are not operated or maintained by STARR Restaurants. We may also have providers of other apps, tools, widgets, and plug-ins (“Plug-Ins”) on our online services, such as Facebook “Like” buttons, which may use automated methods to collect information about you and how you use these features. Although we choose our business partners carefully, STARR Restaurants is not responsible for the privacy practices of websites operated by third parties that are linked to our site.

If you visit one of these linked websites, or engage third-party Plug-Ins, please note that these third parties have their own privacy policies, and that we do not accept any responsibility or liability for these policies. Any information you give to those organizations is dealt with under their privacy policy, terms and conditions, and other policies. Please check these policies before you provide any personal information to these third parties.

CHANGES TO THIS PRIVACY POLICY

STARR Restaurants will update this Privacy Policy from time to time. If we make any substantial changes to this Policy, we will make that information available by posting a notice on this site.

This Privacy Policy is in effect as of the date noted at the top of this page. You should check here regularly for the most up-to-date version of the Policy.

CONTACT INFORMATION

STARR Restaurants welcomes your comments regarding this Privacy Policy. We hold ourselves to ethical standards regarding data privacy and protection, and we welcome any feedback you may have concerning the handling of your personal data. If you have any questions or concerns regarding this Privacy Policy or our privacy practices, please contact us via mail or email at the address provided below.

STARR Restaurants
ATTN: Privacy Policy
134 Market Street
Philadelphia, PA 19106
privacy@starr-restaurants.com