Privacy Policy

Effective Date: May 12, 2022

California Privacy Rights

Thank you for your interest in Gosh Enterprises, Inc. This Privacy Policy sets forth the terms and conditions with respect to how we and some of our affiliated brands (collectively, “Company,” “we,” and “us”) process personal information about you and other third parties. For the avoidance of doubt, this Privacy Policy applies to the processing of personal information by the following brands:

Bibibop Asian Grill – Charleys Philly Steaks – Lennys Grill & Subs

This Privacy Policy describes, among other issues, the types of personal information that we collect, the purposes for which we use it, the types of third parties with whom we share it, and any rights and responsibilities you may have with respect to such personal information. This Privacy Policy applies to the personal information that you provide to us when you (i) access and use our website or mobile applications (collectively, our “Website and Apps”), (ii) visit one of our locations, (iii) apply for a job with the Company, or (iv) otherwise contact or engage with us. For purposes of this Privacy Policy, our Website and Apps and all products, goods and services furnished by the Company shall be referred to collectively as the “Services.”

PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT DESCRIBES YOUR RIGHTS, RESPONSIBILITIES, AND LIABILITIES. BY ACCESSING OR USING THE SERVICES OR OTHERWISE PROVIDING US WITH PERSONAL INFORMATION, YOU ARE CONSENTING TO THE TERMS OF THIS PRIVACY POLICY AND TO OUR APPLICABLE WEBSITE TERMS OF SERVICE AND COOKIE POLICIES. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AND TO OUR WEBSITE TERMS OF SERVICE AND COOKIE POLICIES, YOU SHOULD NOT USE THE COMPANY’S SERVICES, AND YOU SHOULD LEAVE OUR WEBSITE AND APPS IMMEDIATELY AND NOT PROVIDE US WITH ANY PERSONAL INFORMATION.

1. Scope

This Privacy Notice applies to personal information that the Company processes during its business operations as a data controller, which means we determine the purpose and means of processing such personal information. For purposes of this Privacy Policy, the term “personal information” means any information that, alone or in conjunction with other information or data, identifies or is linked to a particular individual, household, or device and that is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation. The term “personal information” does not include anonymized or de-identified data that is not attributable to a particular individual, household, or device and that is not otherwise subject to a data protection law, statute, or regulation. The Company may anonymize or de-identify personal information, and such data is not subject to this Privacy Policy, and the Company may use such data for any purpose.

2. The Types and Categories of Personal Information We Collect

The Company collects personal information in order to provide our Services, comply with our legal obligations, promote our business interests, and for the other reasons set forth in this Privacy Policy. When you do not provide personal information to the Company, we may not be able to provide you the Services or to complete a transaction that you have requested. Generally, we collect the following types and categories of personal information during our business operations:

Mobile Messaging Program

If you participate in our Mobile Messaging Program, we collect various information from and about you, including information you directly provide when you participate in the Mobile Messaging Program. For example, we collect the phone number and email address you provided when signing up for the Mobile Messaging Program. When you send messages via the Mobile Messaging Program, we will also collect your messaging history and any information included in those messages. We may also collect information about you using cookies or similar technologies to enable personalization of your experience on the Mobile Messaging Program (e.g., sending you personalized text messages such as shopping cart reminders). If you participate in a contest, sweepstakes, research study, or email survey associated with the Mobile Messaging Program, we will collect basic contact information and any other information you choose to provide in connection with these activities. We will also collect your contact information if you contact us with questions about the Mobile Messaging Program or for customer service.

3. Technical Data

When you access our Website and Apps, we collect certain data automatically using technical means and tools. This data relates to your device and your experience on our Website and Apps and other websites, including the following:

Usage and Device Data. When you access and use our Website and Apps, we automatically collect details of your access to and use of our Website and Apps, including traffic data, usage logs and other communication data, and the resources that you access and use on or through our Website and Apps (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. Our Website and Apps may collect “diagnostic” data related to your use of our Website and Apps, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics.

Cookies and Tracking Data. We use “cookies” and other tracking technologies within our Website and Apps. A cookie is a small file placed on your smartphone or other device. It may be possible to refuse to accept cookies by activating the appropriate setting on your smartphone or device. However, if you select this setting, some parts of our Website and Apps may become inaccessible or not function properly. In addition, our Website and Apps may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to analyze data on your use of our Website and Apps (e.g., recording the popularity of certain content and verifying system and server integrity). Our Website and Apps may collect data about the advertisements you have seen or engaged. For more information, see our Cookie Policies.

4. Sources of Information

We collect the personal information identified herein directly from you when you use our Services, through automated means when you are using our Website and Apps, and from third parties. More specifically, we collect personal information from the following sources:

First Party / Direct Collection. We collect personal information directly from you when you use our Services (e.g., registering accounts, completing purchases, signing-up for subscriptions), when you provide a Product Review (as defined below), or whenever you directly engage with us, such as when you visit our offices or premises or otherwise contact us.

Automated Collection. As described above, we may collect information and data, such as usage data and cookies, through automated means when you use our Website and Apps (see “Technical Data” above).

Third-Party Sources. We collect personal information from third parties, such as publicly available databases, social networking providers, advertising companies, our service providers, and third-party references. Examples of the information we receive from other sources include: social media profile information (e.g., your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links).

5. How We Use your Information / Purpose of Collection

We may use the personal information we collect about you in order to perform our Services, comply with our legal obligations, and promote our business interests, including to (i) provide, operate, maintain, improve, and promote our Services, (ii) enable you to access and use our Services, (iii) process and complete transactions, and send you related information, including purchase confirmations and invoices, (iv) send transactional messages (e.g., responses to your comments, questions, and requests) and provide customer service and support for our Services, (v) furnish technical notices, updates, security alerts, and support and administrative messages to you, (vi) provide you promotional and marketing communications (e.g., information about our Services, features, surveys, newsletters, offers, promotions, contests, and events), (vii) process and deliver contest or sweepstakes entries and rewards, (viii) monitor and analyze trends, usage, and activities in connection with our Services to promote our business interests (e.g., marketing), (ix) investigate and prevent fraudulent transactions, unauthorized access to or use of our Services, and other illegal activities, and (x) personalize our Services, including providing features or advertisements that match your interests and preferences. Notwithstanding the foregoing, the Company may collect and use your personal information for any other purpose for which we obtain your consent. For the avoidance of doubt, you hereby agree that the Company may contact you via any means, including SMS/text message and email, to furnish you information regarding a product order, shipping status, and similar data and information pertaining to a commercial transaction.

Mobile Messaging Program. In the event you opt-in to our Mobile Messaging Program, we will collect and use your personal information to maintain and administer our Mobile Messaging Program. By participating in the Mobile Messaging Program, you agree to receive autodialed or prerecorded marketing mobile messages and you understand that you are not required to make any purchase from us to participate in our Mobile Messaging Program. Message and data rates may apply to such communications. You hereby agree to immediately notify the Company, in writing, in the event you no longer own, license, or use the telephone number which you used to enroll into our Mobile Message Program. Any personal information collected or provided as part of our Mobile Messaging Program shall be used, disclosed, and retained in accordance with this Privacy Policy and all your obligations set forth in this Privacy Policy shall apply to such personal information.

6. Sharing Information / Third-Party Disclosures

We may share your personal information with certain organizations and third parties in accordance with applicable law, including as set out below. However, we do not share personal information with third parties that we have reason to believe use such information for their own direct marketing purposes.

Affiliates. We may share personal information with, and among, all of our affiliated brands (Bibibop Asian Grill, Charleys Philly Steaks, Lenny’s Grill and Subs) in order to promote and defend our business interests.

Service Providers. We may share your personal information with companies that provide services on our behalf, such as hosting and analyzing our Website and Apps, conducting surveys and marketing on our behalf, processing transactions, and performing analyses to improve the quality of our Services.

Payment Card Transactions. All payments for purchases made through our Website and Apps are completed using a third-party vendor’s online payment system. the Company does not have access to your credit card information and does not store or disclose your full credit card information. Any personal or financial information you provide to our online payment system is subject to the third party’s privacy policy and terms of use, and we recommend you review these policies before providing any personal or financial information.

Intra-Group Sharing. We may share your information with our affiliates, in which case we will require those entities to honor this Privacy Policy. For purposes of this Privacy Policy, our affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Distributors and Business Partners. We may share your personal information with third parties that distribute our goods, products, and marketing materials.

Business Restructuring. Circumstances may arise where for strategic or other business reasons the Company decides to sell, buy, divest, merge or otherwise reorganize our businesses. We may disclose your personal information to the extent reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or sale of all or a portion of the Company’s assets.

Disclosure for Other Reasons. We may disclose personal information (i) if required by law or government order, or with a legal process, (ii) to protect and defend our rights or property, or (iii) in urgent circumstances, to protect the health and personal safety of any individual. In addition, the Company may disclose your personal information with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, or business interests. We may also disclose your information upon your express consent.

In the event that you facilitate a transaction with the Company, or request information from or otherwise engage with us, and such activities require the Company to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct the Company to intentionally disclose your personal information to the service provider or third party, provided the Company has determined, in its reasonable judgment, that either (i) the service provider or third party will not sell the personal information or (ii) disclosing the personal information is required or permitted by law.

7. Social Media

We may engage with you on various social media platforms (e.g., Facebook, Twitter, Pinterest, Instagram). If you contact us on one of these platforms for customer support or otherwise, we may contact you via the social media’s direct message tools. Those communications are governed by this Privacy Policy as well as the policies and terms of the relevant social media platform. The information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. Our Website and Apps include social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button) or interactive mini-programs that run on our Website and Apps. These features may collect your IP address and which Website and Apps page you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website and Apps. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them.

Our Website and Apps offer you the ability to register and login using your third-party social media account details. Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public. If you login using Facebook, we may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission. We will use the information we receive only for the purposes that are described in this Privacy Policy or that are otherwise made clear to you on our Website and Apps. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

8. Links to Other Websites; Your Direct Third-Party Disclosures

As a resource to you, our Website and Apps may include links to third-party websites or provide you the opportunity to disclose information directly to third parties (e.g., credit card processors, social media), and our Privacy Policy does not apply to such third-party websites or organizations. You assume all privacy, security, and other risks associated with providing any data, including personal information, to third parties via the Services. For a description of the privacy protections associated with providing information to third parties, you should refer to the privacy statements, if any, provided by those third parties.

9. Data Retention and Localization

The period during which we retain your personal information varies depending on the purpose for the data processing. For example, we retain personal information needed to provide you with our Services, to facilitate transactions you have requested, or to engage in marketing activities, and for as long as is necessary to defend our legal or business interests (e.g., tax reporting purposes). In all other cases, we retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy.

The Company is based in the United States, and the personal information that we collect and process is retained and stored in the United States. The Company uses service providers that store personal information on our behalf in the United States and in other third countries. Please be aware that the United States, and these other third countries, may not provide the same level of protection of personal information as in your country, state, or other jurisdiction of residence or nationality, and when transferred to the United States or elsewhere, your personal information may be accessible by, or otherwise made available to, local government authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations. By continuing to provide us such information, you hereby consent to your personal information being transferred to, and stored in, the United States and in other third countries.

10. Security

We seek to protect the security of your personal information and use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. HOWEVER, NO INFORMATION SYSTEM CAN BE FULLY SECURE AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO OUR WEBSITE AND APPS OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access our Services, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately if you have reason to believe that your username or password to our Services has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.

11. No Data Collected from Children

Our Website and Apps are not directed at, nor intended for use by, children. As a result, we will not knowingly collect information from children under sixteen (16) years of age without verified consent from their parents or guardians. If you are under the age of sixteen (16), you are prohibited from accessing or using the Services (including our Website and Apps) or from providing us with your personal information, unless you provide us written and verifiable authorization from your parent or legal guardian permitting you to do so.

12. Product Reviews; Feedback

Our Website and Apps may provide you with the ability to submit a comment on, provide an opinion about, rate, or otherwise discuss our Services (a “Product Review”) or provide other information on our Website and Apps which may be posted to a publicly available portion of our Website and Apps. Any information or content you post in a Product Review will be available to other users of our Website and Apps and may be retrievable by third-party search engines, and third parties may also be able to download or share your Product Review to social media websites or elsewhere. We recommend that you guard your privacy and anonymity and not upload any information in your Product Review that you wish to remain confidential. Any third party with access to your information via our Website and Apps will be permitted to use the information in the same manner as if you submitted the information directly to that third party. Publicly posting any information on our Website and Apps is entirely voluntary on your part, and we recommend you carefully consider the information you choose to make publicly available. You have no obligation to provide us with a Product Review, or any other ideas, suggestions, or proposals (collectively, “Feedback”). However, if you submit Feedback to us, then you hereby grant the Company a non-exclusive, worldwide, royalty-free license that is sub-licensable and transferable, to make, use, sell, have made, offer to sell, import, reproduce, publicly display, distribute, modify, or publicly perform the Feedback in any manner without any obligation, royalty or restriction based on intellectual property rights or otherwise.

13. Your Responsibilities

You are permitted, and hereby agree, to only provide personal information to the Company if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon a person’s data privacy rights or privileges. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO THE COMPANY, YOU EXPRESSLY REPRESENT AND WARRANT TO THE COMPANY THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE THE COMPANY WITH SUCH PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) AND THAT THE COMPANY’S USE AND PROCESSING OF SUCH PERSONAL INFORMATION AS SET FORTH HEREIN WILL NOT VIOLATE ANY PERSON’S RIGHTS OR PRIVILEGES, INCLUDING RIGHTS TO PRIVACY. YOU HEREBY AGREE TO FULLY AND COMPLETELY INDEMNIFY THE COMPANY, AND ITS AFFILIATES, SUBSIDIARIES, PARTNERS, AGENTS, AND REPRESENTATIVES FOR ANY CLAIMS, HARM, OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO THE COMPANY.

14. Updating Your Information

It is important that the personal information that you provide to us is accurate and reliable. In certain circumstances, you may have the ability to directly edit your account to update and change your personal information (e.g., name, telephone number, email, shipping address), and you must do so when such changes are warranted. If your account does not contain such features, then you must directly notify the Company of any changes or updates to your personal information in accordance with the “Contact Us” section listed below.

15. Email Marketing and Your Rights

You have the right to opt out of receiving email marketing communications from us. Generally, the email marketing communications that you receive from us will provide you an option to “unsubscribe” from receiving future email marketing communications from us. You may also unsubscribe from such email marketing by contacting us in accordance with the “Contact Us” section listed below. You hereby agree to immediately notify the Company, in writing, in the event you no longer own, license, or use an email address to which you subscribed to receive email marketing from us. In certain circumstances, you may have the ability to directly change your marketing preferences within your account profile.

16. California Privacy Rights

Data Privacy Rights. Pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), California residents have additional data privacy rights, including the following:

• The Right to Know: The right to know about what personal information is collected about you, and our intended use and purpose for collecting your personal information. The personal information that we collect from you, the purposes for which it is used, the source of such personal information, and the parties to whom we share your personal information, among other issues, are set forth in this Privacy Policy (see above).
• The Right to Access: The right to access general categories and/or the specific pieces of personal information we have collected, used, disclosed, or sold about you over the past twelve (12) months, including the personal information we have collected, used, disclosed, or sold about you, the sources from which the personal information was collected, the business or commercial purpose for which your personal information was collected, used, disclosed, or sold, and the third parties with whom we have shared your personal information.
• The Right to Deletion/Erasure: The right to request that we delete/erase your personal information under certain circumstances.
• The Right of Data Portability: The right to request the Company to transfer, to the extent feasible, personal information in certain forms and formats.
• The Right to Nondiscrimination: The right not to be subject to discrimination for asserting your rights under the CCPA.

To exercise any of the CCPA’s data privacy rights set forth herein, please contact us in accordance with the “Contact Us” section listed below. If you would prefer, you may designate an authorized agent to submit a CCPA privacy request on your behalf.  An authorized agent must be registered with the California Secretary of State to conduct business in California. For information pertaining to your rights with respect to our financial incentive programs, please see below (“Rewards Programs and Financial Incentives”).

Privacy Request Verification Process. If you (or your authorized agent) makes any request related to your personal information under the CCPA, the Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. the Company will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email or other means and match at least two pieces of personal information we have previously collected from you before granting you access to, or erasing, specific pieces or categories of personal information, or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein, unless you have provided the authorized agent with power of attorney pursuant to California Probate Code §§ 4121 to 4130. None of the CCPA’s rights are absolute and are subject to legal and regulatory exceptions and exemptions. For more information on the CCPA, please see https://oag.ca.gov/privacy/ccpa.

Opt-Out Rights / Do Not Sell My Personal Information. California residents have the right to opt out of the sale of their personal information. The Company does not sell your personal information to third parties for profit or other valuable consideration. In addition, our Website and Apps are not directed at, and should not be used by, minors under the age of sixteen (16), and therefore the Company does not knowingly collect (or sell) the personal information of minors under sixteen (16) years of age.

17. Nevada Privacy Rights

The Company does not currently conduct “sales” of personal information for purposes of Nevada law. Notwithstanding the foregoing, Nevada residents may submit a request directing us to not sell personal information we maintain about them to third parties who will sell or license their information to others. If you would like to exercise this right, please contact us in accordance with the “Contact Us” section listed below.

18. Do-Not-Track Signals

Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.

19. Persons with Disabilities

The Company strives to ensure that every person has access to information related to our Services, including this Privacy Policy. Please contact us in accordance with the “Contact Us” section listed below if you would like this Privacy Policy provided in an alternative format, and we will seek to meet your needs.

20. Rewards Programs and Financial Incentives

We collect and use personal information, including personal information provided by a third party (e.g., refer-a-friend program), to administer and maintain our financial incentive, rewards, and loyalty programs (“Rewards Programs”). We use the personal information you provide in these programs to verify your identity, offer unique rewards, track your program status, and facilitate the exchange of program points for products, promotional materials, training workshops, and other items. If you consent to participate in any of our Rewards Programs, you may withdraw that consent at any time by contacting us in accordance with the “Contact Us” section listed below or in accordance with the instructions set forth in the applicable Rewards Program’s terms and conditions. The Company may use personal information gathered from, or related to, participants in our Rewards Programs for any other purpose or in any other manner set forth in this Privacy Policy.

California Rewards Program Rights. Pursuant to the CCPA, you may be entitled to be informed as to why financial incentive programs, or price or service differences, are permitted under the law, including (i) a good-faith estimate of the value of your personal information that forms the basis for offering the financial incentive or price or service difference, and (ii) a description of the method we used to calculate the value of your personal information. Generally, we do not assign monetary or other value to personal information. However, in the event we are required by law to assign such value in the context of Rewards Programs, or price or service differences, we have valued the personal information collected and used as being equal to the value of the discount or financial incentive provided, and the calculation of the value is based upon a practical and good-faith effort often involving (i) the categories of personal information collected (e.g., names, email addresses), (ii) the transferability of such personal information for us and our Rewards Programs, (iii) the discounted price offered, (iv) the volume of consumers enrolled in our Rewards Programs, and (v) the product or service to which the Rewards Programs, or price or service differences, apply. The disclosure of the value described herein is not intended to waive, nor should it be interpreted as a waiver to, our proprietary or business confidential information, including trade secrets, and does not constitute any representation with regard to generally accepted accounting principles or financial accounting standards.

21. SMS Marketing and Your Rights

In the event you participate in our Mobile Messaging Program, you may opt-out of the Program at any time. Please review our Mobile Messaging Program Terms, including information on how to unsubscribe or update your personal information therein and your responsibilities and liabilities related thereto.

22. Employment Applications and Talent Management

As part of our recruitment and talent management process, we collect personal information with respect to individuals who are interested in working for us. In this context, we collect employment and application data, such as the following: contact information (e.g., name, title, residential or postal address, telephone number, and personal email address); information in a curriculum vitae, résumé, cover letter, or similar documentation; details regarding the type of employment sought, willingness to relocate, job compensation and benefit preferences; health data (e.g., medical conditions); information related to your background, education, criminal record, credit history and similar data; information provided about or by your references or other third parties related to your employment history, skills, qualifications, or education; and information related to previous applications to us or previous employment history with us. When permitted by law, we may collect information about your race and ethnicity to assist with our diversity and inclusion programs. We use this information for the following purposes: to identify and evaluate job applicants; to verify your information; to complete employment, education, background and reference checks; to communicate with you about the recruitment process and your application; to comply with our legal, judicial, regulatory, administrative, or other corporate requirements; to analyze and improve our application and recruitment process; to accommodate individuals who may have specialized needs during the employment process; and to protect the rights, interests, and property of our business, other job applicants, employees, or the public, as required or permitted by law. We share this personal information with third parties (see “Sharing Information / Third-Party Disclosures”), and we may also use this employment and application data for any other purpose set forth in this Privacy Policy.

23. Events and Video Teleconferencing

The Company hosts and uses video teleconferencing platforms to facilitate conferences, meetings, training events, and other programs. We often use online platforms that are owned and administered by a third-party service provider (e.g., Google, Zoom, WebEx, Skype for Business). Please be aware that our video teleconferencing may record the content, conversations, and discussions thereon, and such records may be stored or retained by our third-party service providers. By participating in our events and video teleconferencing, you hereby consent to the collection and retention of any information provided therein, and you hereby consent to the recording of such activities.

24. Changes to the Policy

We reserve the right to amend this Privacy Policy at any time. We will notify you if this Privacy Policy is amended by updating the “Last Updated” section listed above. It is your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto. Your use of the Services, and continued use of the Services after any amendments are made to this Privacy Policy, signifies your consent to this Privacy Policy and any amendments hereto. We may, in our sole discretion, provide you communications, including via email or text messages, about changes to our Privacy Policy; however, such communications do not abrogate or otherwise limit your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto.

25. Contact Us

If you have questions regarding this Privacy Policy or our handling of your personal information, would like to request more information from us, or would like to exercise a data privacy right, please contact us at the following: privacy@charleys.com or Gosh Enterprises, Inc., Attn: LEGAL/PRIVACY, 2500 Farmers Drive, Suite 140, Columbus, Ohio 43235