PRIVACY AND TERMS

TGI FRIDAYS™ PRIVACY POLICY

TGI Friday’s Inc. and its subsidiaries and affiliates (collectively “Fridays”) are committed to respecting your privacy. We want to make your online and mobile experiences satisfying and safe. This Privacy Policy describes how we collect, use, disclose, store and otherwise process information through this website (“Site”), any mobile applications (“mobile application” or “app”), the Fridays Rewards® program, and related online services we provide (collectively, the “Services”). We will not use or share your information except as described in this Privacy Policy. This Policy also describes your choices about the collection and use of your information.

This Privacy Policy, together with our posted Terms & Conditions (“Terms”) governs our relationship and we urge you to read this Privacy Policy. By using the Services or signing up for Fridays Rewards Loyalty Program (“Fridays Rewards”), you acknowledge that you understand and agree to our Terms and this Privacy Policy. Please see our Terms regarding your legal rights in any dispute involving our Services.

1. HOW WE COLLECT INFORMATION

As further described below, we may collect information about you by various means, primarily through our Services, but also from our franchisee partners and other sources and from social media platforms that you may use to engage with us.

In some jurisdictions, in addition to you agreeing to this Privacy Policy, data privacy laws may require us to obtain your consent before we market to you or collect and use certain types of information. In certain circumstances, your consent may be implied (e.g. where communications are required in order to fulfill your requests and/or where you have volunteered information for use by us). In other cases, we may seek your consent expressly in accordance with applicable laws (e.g. where the information collected is regarded by law to be sensitive).

2. TYPES OF INFORMATION WE COLLECT

a. Information collected directly from you may include:

• Contact and Subscription Information when you voluntarily submit it to us through our Services, and this information may include name, email address, phone number, physical address, date of birth, gender, user name and password, and online identifiers like social media handles, if provided;
• Transactional information including payment details if you make an order and/or purchase through the Services;
• Survey information in response to questions that we may ask you through the Services, including for research purposes or to improve our Services;
• User content that you may provide for public posting (e.g., reviews, photos) along with any associated information that you provide about yourself or the submitted content;
• Communications between you and us, such as via e-mail, web form, phone or other channels; and
• Online User Activity described in the next section.

b. Information we receive when you participate in the Fridays Rewards^® program:

Our Friday Rewards program is voluntary. If you choose to join Fridays Rewards you will be asked to provide your name, email, phone number, date of birth and you will be asked to select your favorite TGI Friday’s location. We will communicate with you about earned rewards, program benefits, program changes, and all promotions and offers available to members. We collect transactional and payment information if you choose to make a purchase or conduct another transaction through the Services.

c. Information we receive from family or friends

Fridays may collect information about your friends and family through your interactions on our Services. Referring friends to our Services requires you to send their personal information to Fridays. Other instances, such as sharing content, may also require you to send their personal information to us. If you provide us with information regarding another individual, you represent that you have that person’s consent to give us his or her information and to permit us to use the information in accordance with this Privacy Policy.

d. Information received through social media

Our Services include social media features, such as the Facebook Like button and other widgets that run on our Services. These features may collect information such as your IP address and which page you are visiting, 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 through our Services. Your interactions with these features are governed by the privacy policy of the organization providing it.

e. Contests or Games

From time to time, we may run contests according to rules posted in connection with the contest. All contests are voluntary. If you choose enter a contest, you will be asked to provide the information required by the contest rules which will generally include your full name, email address, telephone number, date of birth and your favorite TGI Friday’s location. We will use the information provided to facilitate the operation of the contest and to select a winner or winners and to communicate with you about the contest. We will use the information to communicate with you about other contests, products, promotions and services that we believe you may be interested in.

f. Information received from other sources:

Fridays may also collect information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our service to you, and prevent or detect fraud. We work closely with third parties (for example, business partners, service providers, subcontractors, advertising networks, analytics providers, search information providers, fraud protection services) and may receive information about you from them. For example, some Services may be co-branded and offered in conjunction with another company. If you use such Services, both Fridays and the other company may receive the personal information that Fridays collected via that co-branded Service. In addition, certain Fridays’ Services may feature bulletin boards, blogs or forums, and any personal information submitted through those channels may be read, collected, or used by others who access those channels.

g. Non-personal information

Note also that we may collect and use information that does not personally identify you, or has been anonymized or de-identified so it no longer identifies you. Such information is outside the scope of this Privacy Policy.

3. ONLINE USER ACTIVITY

We may collect technical information about visitors to our Services (“Online User Activity”), through cookies and other technology. We, our service providers, and our business partners, may employ cookies and the other technologies described below to remember you when you return to our Services (or keep you logged in), collect information about how our Services are used, review website traffic patterns and improve the Services, and determine what Services are popular. We can also use such information to deliver customized content and advertising to users of the Services whose behavior indicates that they have particular interests.

Cookies are a commonly used web technology that allow websites to store and retrieve certain information on a user’s browser, and track certain online activities. Clear GIFs (also called “pixels”, “web bugs” or “web beacons”) are small transparent images placed on a web page or in an email message to monitor user behavior, deliver cookies, collect information, count visits, understand usage and campaign effectiveness and detect if a recipient has opened and acted upon an email. Other such technologies include Local Storage Objects (LSOs) which can store content information and preferences on a user device, and Software Development Kits (SDKs) from vendors or service providers may be embedded in our apps, if any, to provide various functionality, including an ability to collect information about user activity. Finally, our Services maintain network and system logs of activity on our Services and provide another way for us to gather statistics about users’ browsing habits, such as how many and how often users have accessed or used our Services, which pages were visited and other similar data.

These tools can enable us collect information such as:

• Usage Details about interactions with our Services (such as the date, time, and length of visits, and specific pages or content accessed during the visits, search terms, frequency of the visits, referring website addresses);
• Device Information including the IP address and other details of a device that you use to connect with our Services (such as device type and unique device identifier, operating system, browser type, mobile network information, and the device’s telephone number); and
• Location information where you choose to provide us with information about your device’s location.
• For guests who access our in-store Wi-Fi, we receive device ID and name if available.

4. HOW WE USE THE INFORMATION WE COLLECT

We use the information we collect from you for the following purposes, as permitted by law:

• For the reasons set forth above in connection with each Data Class of information collected
• To provide our Services to you (including account management, preferences, transactions, and our rewards program) and respond to your inquiries and other communications;
• To communicate with you with marketing offers via email, mail or (if applicable) push notifications, and if you register for any promotions, contests or giveaways, you may be asked whether you’d like to receive notifications via email and/or text message to your mobile device, and will be contacted accordingly;
• To tailor the content that we display to you in our Services and communications, including advertising, and offer opportunities and information that we believe may be of interest to you;
• To generally make guest experiences at our restaurants more satisfying (including in response to voluntary surveys, push notifications, and customized messages);
• Operate, evaluate, and improve our Services for you and our other customers, including to diagnose or fix technology problems;
• Monitor the performance of our Services including metrics such as total number of visitors, traffic, and demographic patterns, as well as analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read);
• Provide you with administrative notices, such as to inform you about changes to this Privacy Policy and our Terms; and
• Comply with and enforce as needed applicable legal requirements, industry standards, our policies, and our contractual rights.

5. HOW AND WHEN WE SHARE INFORMATION

We will not disclose your personal information to third parties without your consent, except in the following circumstances:

• We may share your information as permitted by law, including, for example, with our corporate affiliates, and service providers that we believe need the information to perform a technology, business, or other professional function for us (examples include IT services, rewards program management, gift card operations, maintenance and hosting of our Services, payment processors, shipping and returns partners, marketing partners, and other service providers). We provide such vendors with information so that they can perform their required functions on our behalf.
• We may share information with TGI Fridays franchisees in order to address and improve guest experiences at restaurants.
• If you voluntarily share or submit any user content for public posting (e.g., reviews, pictures) through the Services or social media platforms (including but not limited to activities associated with promotions or giveaways), such postings and any information associated with them may become available to the public.
• We may also disclose information about you: (i) if we are required to do so by law or legal process; (ii) when we believe disclosure is necessary to prevent harm or financial loss; (iii) in connection with an investigation of suspected or actual fraudulent or illegal activity; or (iv) under exigent circumstances to protect the personal safety of our staff, guests, or the public.
• We reserve the right to transfer the information that we maintain in the event that we sell or transfer all or a portion of our business or assets. If we engage in such a sale or transfer, we will make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Privacy Policy.

6. HOW LONG WE KEEP YOUR INFORMATION

The length of time that we keep information that pertains to you depends upon the data class in which the data is obtained. Information that we keep solely for marketing purposes is kept for at least 36 months from the last date it is received or updated after which time, it is marked for removal in the next relevant purge cycle, except where it is retained for other purposes. We will maintain information that we collect for longer periods or other purposes as long as we need it to provide our products and services, comply with legal obligations or protect our or other interests. We decide how long we need information on a case-by-case basis. Here’s what we consider when we decide:

• Whether we need it to operate or provide our products, services, reward programs or contests.
• We consider the particular data, why it was provided and the likelihood of usefulness in connection with that purpose in the future.
• We consider whether we need the data for other legitimate business purposes, such as to prevent harm; investigate possible violations of our terms of service, other policies or the law; promote safety, security and integrity; or protect ourselves, including our rights, property products, franchisees, contractors and other customers.
• In some instances and for specific reasons, we will decide to keep certain information for an extended period of time.

7. YOUR PRIVACY CHOICES

We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.

• Fridays Rewards and user accounts: You have the ability to access and edit the personal information that you have provided to Fridays Rewards or in connection with a user account. To update your information or to cancel your account, please visit our loyalty page. We may retain information for internal purposes or as otherwise provided in this Privacy Policy and our Terms.
• Marketing: From time to time, we may contact you via email or through other channels for the purpose of providing announcements, promotional information and/or other general communication. In order to improve our Services, we may be notified when you open an email from us or click on a link therein. You may choose not to receive marketing emails from us by clicking on the unsubscribe link in the marketing emails you receive from us. Even if you opt out of receiving such communications, we may continue sending you non-marketing email communications, such as administrative or transaction alerts, or information about changes to our Terms.
• You can opt-out of receiving postal mail from us at any time by following instructions in the mail or contacting us using the information below. If you have downloaded our app, if any, we may notify you through the app. You can opt-out on your personal device by following your device instructions on removing app push notifications.
• Cookies: Web browsers may offer users the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our Services may not function correctly. Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time.
• Contests, Giveaways & Promotions: To update your information or exercise any other right you may have as to your personal information that you have provided to Us in connection with a contest, giveaway or promotion that you entered, please visit https://tgifridays.com/contactUS. We may be entitled to retain information for internal purposes or as otherwise provided in this Privacy Policy and our Terms.

In the event you would like to access, update or delete your information in a manner not provided above, you can submit a request to Fridays via the contact information below, and Fridays will endeavor to address your request or concerns, consistent with any applicable laws and this Privacy Policy. To protect your privacy, we require those submitting a request to verify their identity before granting access to, or agreeing to update, correct or delete personal information. In addition, you may be entitled by law to submit certain requests, as covered in the next two sections.

8. NOTICE FOR EU/EEA, SWITZERLAND, UK AND BRAZIL RESIDENTS

Any personal information collected about EU/EEA, Switzerland, UK or Brazil residents through our Services is processed in the United States by Fridays or by a third party acting on our behalf. When you use our Services or provide personal information to Fridays, you consent to the processing of your information in the United States. Our Services are primarily hosted in the United States.

As a data controller with respect to your personal information, our legitimate interests in processing your personal information are mainly to provide the Services as described in the sections above. We may store personal information throughout the period of your relationship with us and retain it for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying legal, accounting, or reporting obligations or to resolve disputes.

If, at any point in time, you wish to know what data we process about you, you can request to access the information by completing the GDPR Contact Us online form.

Under applicable privacy laws like the GDPR, you have the right to access and limit the use and disclosure of your personal information. Fridays provides you many opportunities to access and update your personal information. You can ensure that any account, contact, or financial information is up-to-date and you can correct, update, or delete inaccuracies to the information by logging into your account or completing the GDPR Contact Us online form referenced above. Fridays will attempt to answer all requests that we correct the data if it is inaccurate or delete it, provided Fridays is not required to retain it by law or for legitimate business purposes.

You have the right to request that Fridays erase your personal information on a number of grounds, including if the data is no longer necessary for its original purpose or if you withdraw consent. If Fridays receives a request, we will inform all third parties who have the data of this request. You also have the right to object to your personal information being processed for profiling, direct marketing, scientific research, and statistics. If you wish to object, please complete the GDPR Contact Us online form referenced above. You have the right to transfer your personal information from one electronic processing system to another without being prevented from doing so by Fridays’ data processor.

To protect your privacy, we will require verification of your identity before fulfilling any request you make with respect to your personal information.

9. STATE-SPECIFIC NOTICES

    1. California Residents

For California residents, the California Consumer Protection Act (the “CCPA”) and California Privacy Rights Act (the “CPRA”) provide various rights to individuals and households with respect to the collection and use of personal information that we have collected about you. Among other rights under the CCPA and CPRA, you may have the right to request that we: (i) disclose the categories of personal information we have collected from you, the categories of sources from which such information has been collected, the business or commercial purpose for which your information has been collected, the categories of third parties with whom your personal information is shared, and the specific pieces of personal information that have been collected about you; (ii) request a copy of the personal information that we have about you; (iii) request that we correct inaccurate personal information that we have about you; (iv) delete personal information that we have about you (subject to certain exceptions);  (v) request that we not sell your information to a third party (excluding qualified service providers), (vi) request that we not share your information with a third party for purposes of cross-context behavioral advertising; and (vii) request that we limit the use and disclosure of “Sensitive Personal Information” to the minimum allowed use under the CPRA. Note that while we still allow you to register a request regarding these rights by using the CCPA Contact Us online form, Fridays does not “sell” consumer personal information as we interpret that term under the CCPA and CPRA, does not share your information with third parties for purposes of cross-context behavioral advertising, and does not use or disclose Sensitive Personal Information beyond the minimum extent permitted under the CPRA.

You can exercise any of these rights in regard to your personal information by using the CCPA/CPRA Contact Us online form or by calling us at 1-800-374-3297. For your security, we require you to prove your identity before fulfilling such requests, such as by having you login to authenticate your Fridays Rewards account, or we will ask you to verify the request via phone or email. The information we collect from you in connection with this verification of your identity will be used solely for purposes of verification.

You may designate an authorized agent to submit such requests on your behalf, but you must provide the agent with written permission to do so, and you must still verify your identity with us. If you wish to designate an agent in this way, please call us at 1-800-374-3297.

You have a right to not be discriminated against for exercising your rights under the CCPA, and we never discriminate in any way against consumers who choose to exercise any of these rights. Fridays may offer discounts or other benefits to consumers enrolled in certain subscription programs such as email promotions and our Fridays Rewards programs. Please refer to our Site and app, if any, for details about the benefits, terms and conditions for such offers, and please note that they are subject to change from time to time. Consumers can always opt-out of these programs as provided in this Privacy Policy or by contacting us. Fridays does not generally assign monetary value to consumers’ personal information or promotions activity we engage in. To the extent the CCPA requires that a value be assigned to such programs, or to the price or service differences they involve, Fridays values the information collected and used under each program as being equal to the value of the discounts or other financial incentives provided in each such program, based upon a practical and good-faith effort to assess, on an aggregate basis for all collected information: (i) the type of information collected in each program (e.g., email address), (ii) the use of such information by Fridays in connection with its marketing activities, (iii) the discounts provided (which can depend on purchases under such offers), (iv) the number of individuals enrolled in each program, and (v) the benefits (such as a discount) that can apply. These factors continue to change over time. This description is without waiver of any proprietary or business confidential information, including trade secrets, and it does not constitute any representation with regard to generally accepted accounting principles or financial accounting standards.

     2. Nevada and Texas Residents

For Nevada and Texas residents, please note that we do not sell personal information as defined by Nevada law (Ch. 603A, Sec. 1.6) or the Texas Data Privacy and Security Act. You can submit a request to us regarding your personal information via the contact information provided below.

    3. Residents of Colorado, Connecticut, Montana, Oregon, Virginia, and other states

You can submit a request to use regarding your personal information via the contact information provided below.

10. ONLINE ADVERTISING

You may see us promoted by other organizations, on various websites, web pages, social media and other platforms. Please note that we do not always have complete information about where our organization may be displayed or promoted, and if you believe that we are featured in venues that are inappropriate or offensive, please contact us as directed below.

We may serve advertisements, and allow third parties to serve advertisements, through our Services. Advertisements served through our Services may be targeted to users who fit a certain general profile category, which may be inferred from information that you provide to us, based on your website usage patterns, or based on your activity on other websites or online services as may be available to the ad networks.

11. SECURITY MEASURES TO PROTECT YOUR PERSONAL INFORMATION

The security of your personal information is of the utmost importance for Fridays. Fridays uses technical and physical safeguards designed to protect the security of your personal information from unauthorized access or disclosure. We operate secure data networks protected by industry standard firewall and password protection systems to keep all information secure. We have also implemented access controls to ensure that only the necessary people and third parties receive access to personal information. We take additional measures for particularly sensitive information like customer’s credit card number, such as encryption prior to transmission. Nevertheless, security measures cannot guarantee against the theft, loss, misuse, or alteration of personal information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. In the event of a security incident affecting your personal information, will notify governmental regulators and you as required by applicable laws. To the extent the law allows us to provide such notification via email or conspicuous posting on the Services, you agree to accept notice in that form.

Fridays retains your information for business purposes, for as long as your account is active, and/or for as long as is reasonably necessary to provide you with our Services. Fridays will also retain your information as reasonably necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may also retain cached or archived copies of your information for a reasonable period of time.

12. A NOTE REGARDING INTERNATIONAL USERS

Our Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any country or territory other than those of the United States and as otherwise required by law. Any information that you provide through use of the Services may be stored and processed, transferred between, and accessed from, the United States and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this Privacy Policy regardless of where your personal information is stored or accessed.

13. LINKS TO OTHER WEBSITES

Our Services may contain links to enable you to visit other websites or apps. However, once you have used these links to leave our Services, you should note that we do not have any control over other websites or apps. Please be aware that we are not responsible for the content or privacy practices of such other websites or apps, and we encourage you to be aware when you leave our Services and to read the privacy statements of any other website or app that collects personal information.

14. CHILDREN

Like you, we have children of our own and are concerned about their safety when they use the internet. We want you and your family to be safe while visiting our website. Please note that our Services are not designed for nor directed to children. We do not offer any program participation to children under the age of 13. We do not knowingly request or collect information about children under the age of 13 through the Services. If we learn that someone under 13 has provided personal information through our Services, we will use reasonable efforts to remove that information from our systems.

15. CHANGES TO THIS POLICY

We will occasionally update this Privacy Policy to reflect changes in our policies and practices from time to time. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Changes will be posted here, and we will also post an appropriate notice through our Services. Please review this Privacy Policy periodically, and especially before you provide any personal information to us through the Services.

16. CONTACTING US WITH REQUESTS, INQUIRIES OR COMPLAINTS

Please contact us with any requests, questions, concerns or inquiries about this Privacy Policy or how we handle personal information.

• EU/EEA, Switzerland, UK and Brazil residents with requests or complaints regarding this Privacy Policy are directed to contact us by completing the GDPR Contact Us online form.
• California consumers who seek to exercise privacy rights under the CCPA or CPRA can contact us by completing the CCPA /CPRA Contact Us online form or by calling us at 1-800-374-3297.
• Otherwise, please complete the Contact Us online form with any questions, concerns or complaints. Fridays is committed to addressing requests and complaints about your privacy and personal information. All submissions will be reviewed and we will reply as soon as reasonably possible.

Please note that while exercise of any rights herein will not result in any discriminatory practice, the exercise of certain rights (e.g., withdrawing consent, deleting information) may prevent our ability to provide certain Services to you.