Privacy Policy

Effective Date: September 10, 2026

Introduction

This Privacy Policy describes how 23 Restaurant Services, LLC ("23RS," "we," "our," or "us") collects, uses, shares, and protects information about you.

This Privacy Policy applies to information collected through:

websites, online ordering platforms, ecommerce stores, gift card platforms, career portals, Wi-Fi networks, mobile experiences, digital advertisements, and other online services operated, managed, or supported by 23 Restaurant Services;
marketing communications, including email and SMS programs;
social media pages and digital interactions;
restaurant guest Wi-Fi services; and
any website, application, landing page, or service that links to this Privacy Policy.

These services include, without limitation, websites and services associated with 23 Restaurant Services, Tiki Docks, Don the Beachcomber, Yeoman's, Morgan's Cove, Ford's Garage, and other brands, locations, concepts, or services currently operated or supported by 23 Restaurant Services or added in the future.

By using our Services, you acknowledge that we collect, use, and disclose information as described in this Privacy Policy.

Some restaurants, websites, ordering channels, Wi-Fi services, and marketing programs may be operated by affiliated entities, franchisees, licensees, or other third parties. Where a third party operates a service or collects information directly from you, that party's privacy practices may also apply.

This Privacy Policy is intended to describe our general privacy practices. It is not intended to create contractual rights or obligations beyond those required by applicable law.

Information We Collect

Information You Provide Directly

We may collect personal information that you voluntarily provide to us, including when you:

make a reservation;
place an order;
purchase gift cards;
submit an event inquiry;
join a marketing or loyalty program;
enter a contest or promotion;
contact us;
apply for employment;
connect to restaurant Wi-Fi;
subscribe to email or SMS communications.

Information collected may include:

name;
mailing address;
email address;
telephone number;
date of birth;
company affiliation;
payment-related information;
reservation details;
employment information;
preferences and interests;
other information you choose to provide.

We do not intentionally collect full payment card numbers through our own websites or systems. Payment information is generally processed by third-party payment processors, ordering platforms, gift card providers, or other vendors that maintain their own security and privacy practices.

Information Collected Automatically

When you use our Services, we and our vendors may automatically collect information including:

IP address;
device identifiers;
browser type;
operating system;
mobile carrier information;
device model;
language preferences;
referring URLs;
pages viewed;
visit duration;
clickstream data;
MAC address;
approximate location information;
website interactions;
marketing campaign interactions.

We may collect this information through cookies, pixels, tags, web beacons, analytics tools, advertising technologies, and similar tracking technologies.

When you connect to guest Wi-Fi at one of our restaurants, we or our Wi-Fi service providers may collect information such as device identifiers, MAC address, IP address, connection times, access point information, approximate location within or near the restaurant, pages or services accessed through the network, and information submitted through the Wi-Fi login or splash page.

Information Received From Third Parties

We may receive information about you from ordering providers, reservation platforms, gift card providers, delivery partners, marketing technology vendors, social media platforms, recruiting providers, background screening companies, loyalty and customer engagement platforms, and analytics providers.

We may combine information obtained from these sources with information we already maintain about you.

Categories of Personal Information We Collect

Depending on how you interact with us, we may collect the following categories of personal information:

Category	Examples
Identifiers	Name, email address, phone number, mailing address, online identifiers, IP address.
Commercial Information	Orders, purchases, reservations, gift card transactions, event bookings, loyalty activity.
Internet and Network Activity	Browsing activity, website interactions, advertising interactions, device information.
Geolocation Data	Approximate geolocation information and location information obtained through devices or Wi-Fi services where permitted.
Employment Information	Job applications, recruiting information, employment-related communications.
Inferences	Preferences, interests, and guest engagement patterns.

Sensitive Personal Information

We do not use or disclose sensitive personal information for the purpose of inferring characteristics about individuals. Any sensitive personal information we collect, if any, is used only as reasonably necessary to provide requested services, process transactions, administer employment-related activities, comply with legal obligations, detect fraud, maintain security, or otherwise as permitted by applicable law.

Employment Applicants

If you apply for employment with us, we may collect information related to qualifications, employment history, education, references, background checks, and recruiting communications.

Employment-related information may also be governed by separate applicant, employment, onboarding, or background screening notices where applicable.

If an application is unsuccessful, we may retain information for legitimate business purposes, legal compliance, future employment opportunities, and recordkeeping.

How We Use Personal Information

We may use guest Wi-Fi information to provide network access, maintain network security, troubleshoot connectivity, prevent misuse, enforce applicable Wi-Fi terms, understand guest traffic patterns, and support marketing or analytics where permitted by law.

We may use personal information to:

process transactions;
manage reservations;
process gift card purchases;
fulfill orders;
respond to inquiries;
provide customer service;
improve our Services;
personalize user experiences;
operate loyalty and rewards programs;
conduct promotions and contests;
process employment applications;
communicate with guests and applicants;
send marketing communications;
prevent fraud and misuse;
protect our legal rights;
meet legal and regulatory obligations;
operate and maintain our business.

We may also create aggregated or de-identified information that does not identify any individual.

Email and SMS Marketing

If you subscribe to receive marketing communications from us or one of our brands, we may send promotional emails, event announcements, special offers, marketing newsletters, loyalty communications, ecommerce promotions, and brand updates.

Email Marketing

Our marketing emails may include tracking technologies that help us understand whether emails are opened, which links are clicked, and how recipients interact with our communications.

You may opt out of marketing emails by clicking the unsubscribe link contained in our marketing emails.

SMS Marketing

You may opt out of marketing text messages by replying "STOP" to a marketing message.

Opting out of marketing messages will not prevent us from sending transactional communications, reservation confirmations, order updates, employment application updates, service notices, legal notifications, or customer service responses.

We send marketing SMS communications only to individuals who have provided the required consent under applicable law. Message frequency may vary, and message and data rates may apply. Consent to receive marketing text messages is not required to make a purchase.

We may share information with subsidiaries and affiliates, service providers, technology vendors, marketing providers, reservation providers, payment processors, gift card providers, delivery services, recruitment providers, professional advisors, and government authorities when required by law.

These parties may use information only for authorized business purposes consistent with our instructions and applicable law.

We require service providers and vendors that process personal information on our behalf to maintain reasonable administrative, technical, and physical safeguards designed to protect personal information and to use such information only for authorized business purposes consistent with our instructions and applicable law.

Business Transfers

If we participate in a merger, acquisition, sale, reorganization, financing transaction, or transfer of assets, personal information may be transferred as part of that transaction.

Legal Compliance

We may disclose information if necessary to comply with legal obligations, respond to lawful requests, enforce our agreements, protect our business, detect or prevent fraud, or protect guests, employees, or the public.

Analytics and Advertising

We use third-party analytics and advertising technologies to help us understand how our Services are used, improve website functionality, measure marketing performance, personalize user experiences, and support our advertising efforts. These technologies may include Google Analytics, Google Ads, Meta/Facebook technologies, advertising networks, attribution providers, audience measurement tools, and similar services.

These providers may use cookies, pixels, tags, web beacons, software development kits (SDKs), local storage technologies, and similar technologies to collect information regarding interactions with our websites, devices, advertisements, and services.

The use of analytics and advertising technologies is subject to applicable consent requirements and user privacy preferences. Depending on applicable law and a visitor's location, analytics and advertising technologies may remain disabled until consent is provided.

We utilize Google Consent Mode v2 to communicate applicable consent choices to supported Google services and adjust the operation of Google tags based on those choices. Depending on our technical configuration, applicable law, and the consent choices made, certain Google services may operate in a restricted manner when consent has not been provided.

We do not knowingly sell personal information for monetary compensation. However, certain uses of cookies, advertising technologies, analytics tools, audience measurement services, and similar technologies may constitute a "sale," "sharing," or "targeted advertising" under certain privacy laws.

Where required by law, users may exercise applicable opt-out rights through our Cookie Settings tool, browser controls, recognized privacy preference signals, or by contacting us using the information provided in this Privacy Policy.

Cookies and Similar Technologies

We use cookies, pixels, tags, web beacons, local storage technologies, and similar technologies ("Cookies") to operate our websites, provide requested services, maintain security, authenticate users, remember preferences, analyze website usage, improve website performance, measure marketing effectiveness, and support advertising activities.

We utilize Cookiebot by Usercentrics as our consent management platform ("Cookiebot") to manage cookie preferences and assist in complying with applicable privacy laws.

Cookiebot automatically scans our websites on a recurring basis to identify Cookies and tracking technologies used on our websites and categorizes them based on their purpose.

Except for Cookies that are strictly necessary for website functionality, security, fraud prevention, consent management, and other essential operations, Cookies are not activated until consent is provided where required by law.

Visitors may accept, reject, or customize Cookie preferences through the Cookie Banner presented on our websites.

The cookie banner, consent choices, default settings, and treatment of particular technologies may vary based on the visitor's location and the privacy laws applicable in that jurisdiction.

Visitors may change or withdraw consent at any time through the Cookie Settings link available on our websites.

We may periodically request that visitors renew or confirm their cookie preferences. Under our current consent-management configuration, consent is generally renewed every 12 months, or sooner when required by applicable law, when material changes are made to our use of Cookies, or when otherwise appropriate.

Categories of Cookies

Our websites may utilize the following categories of Cookies:

Necessary Cookies

Necessary Cookies are required for website operation, security, fraud prevention, network management, user authentication, consent management, and related functionality. These Cookies cannot be disabled because the website cannot function properly without them.

Preference Cookies

Preference Cookies allow websites to remember information that changes the way the website behaves or appears, such as language choices, geographic preferences, accessibility settings, and similar selections.

Statistics Cookies

Statistics Cookies help us understand how visitors interact with our websites by collecting information regarding website usage, page visits, traffic patterns, and other analytical data. Statistics Cookies remain inactive until consent is provided where required by law.

Marketing Cookies

Marketing Cookies help us measure advertising effectiveness, perform attribution analysis, create advertising audiences, deliver relevant advertisements, and evaluate marketing campaigns. Marketing Cookies remain inactive until consent is provided where required by law.

A current list of Cookies and tracking technologies used on our websites is available through our Cookie Declaration. The Cookie Declaration is automatically updated based upon recurring scans performed through our consent management platform.

Most web browsers permit users to modify cookie settings through browser controls. In addition, users may update, modify, or withdraw cookie preferences at any time using the Cookie Settings link made available on our websites.

Disabling certain Cookies may affect website functionality and user experience.

To demonstrate compliance with applicable privacy laws, consent requirements, and recordkeeping obligations, we maintain records of cookie consent transactions and preference selections.

These records may include: consent status and preferences; date and time of consent; consent identifier; version of the consent notice presented; browser information; device information; approximate geographic region; IP address or portions thereof where permitted by law; and technical information necessary to document and verify consent activity.

We retain such records for compliance, auditing, legal defense, security, and recordkeeping purposes consistent with applicable law.

When you interact with our social media pages or use social media features connected to our Services, both we and the applicable social media provider may collect information about those interactions.

Your use of those platforms is also governed by the privacy policies and terms of the respective platform.

Promotions and Sweepstakes

We may conduct contests, sweepstakes, raffles, and promotions.

Participation may require you to submit personal information. Additional terms and privacy disclosures may apply to a specific promotion.

If promotion-specific terms conflict with this Privacy Policy, the promotion terms will govern.

Third-Party Websites and Services

Our Services may contain links to websites or services operated by third parties.

This Privacy Policy applies only to websites, services, and communications that link to or expressly reference this Privacy Policy.

Third-party websites, ordering platforms, commerce platforms, social media platforms, loyalty providers, and other services may maintain their own privacy practices, which we encourage you to review.

Data Retention

We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, provide Services, meet contractual obligations, comply with tax, accounting, legal, or regulatory requirements, resolve disputes, prevent fraud and misuse, and maintain security.

Retention periods vary based upon the type of information and business purpose involved. Even if you request deletion of your personal information, we may retain certain information where necessary to comply with legal obligations, satisfy tax or accounting requirements, resolve disputes, enforce agreements, detect or prevent fraud, maintain security, establish or defend legal claims, fulfill employment-related obligations, or otherwise as permitted by applicable law.

Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, loss, theft, misuse, alteration, disclosure, and destruction.

No method of internet transmission or electronic storage can be guaranteed to be completely secure.

Children's Privacy

Our Services are intended for a general audience and are not directed to children under the age of 13.

We do not knowingly collect personal information online from children under 13. If we become aware that we have collected information from a child under 13 without appropriate consent, we will take reasonable steps to delete the information.

Privacy Rights

Depending upon where you reside, you may have rights under applicable privacy laws, including rights to:

access personal information;
correct inaccurate information;
delete personal information;
restrict or object to processing;
opt out of certain advertising practices;
receive a portable copy of information;
withdraw consent where applicable.

We will respond to qualifying requests in accordance with applicable law.

U.S. State Privacy Rights

Residents of states that provide privacy rights under applicable law may have the right to:

know what personal information we collect, use, disclose, sell, or share;
access personal information we maintain about them;
correct inaccurate personal information;
delete personal information;
obtain a portable copy of personal information;
opt out of targeted advertising;
opt out of the sale or sharing of personal information;
opt out of certain profiling activities; and
exercise other rights provided under applicable law.

We will not discriminate against individuals for exercising privacy rights afforded under applicable law.

Requests may be submitted using the contact information provided below or through other methods made available on our websites.

Certain requests may require verification of identity before processing.

Florida residents may have privacy rights under applicable Florida laws when those laws apply to our business, our processing activities, and the type of information involved. We will honor qualifying requests and provide required disclosures in accordance with applicable law.

Where permitted by applicable law, you may designate an authorized agent to submit a privacy request on your behalf. We may require proof of the agent's authority and may also require you to verify your identity directly with us.

California Privacy Rights

California residents may have the following rights under applicable California privacy laws:

right to know the personal information collected about them;
right to access specific pieces of personal information;
right to correct inaccurate information;
right to request deletion;
right to opt out of the sale or sharing of personal information;
right to limit use of certain sensitive personal information where applicable;
right to non-discrimination for exercising privacy rights.

To exercise these rights, contact us using the information below.

Do Not Track and Global Privacy Control

Some browsers offer a "Do Not Track" setting. Because there is not a uniform industry standard for responding to Do Not Track signals, our Services do not currently respond to those signals. This statement does not apply to Global Privacy Control signals, which we recognize and honor where required by applicable law as described below.

Our websites recognize and honor browser-based privacy preference signals, including Global Privacy Control ("GPC"), where required by applicable law.

When a valid GPC signal is detected, we will process the signal as a request to opt out of activities that may constitute a sale, sharing, or targeted advertising under applicable privacy laws, except where a different treatment is permitted by law.

Users may continue to manage privacy preferences through Cookie Settings in addition to browser-based privacy controls.

European Union and United Kingdom Residents

Where applicable, individuals located in the European Union, United Kingdom, or other jurisdictions with similar privacy protections may have rights including access, correction, deletion, restriction, objection, and data portability.

To exercise available rights, please contact us using the information below.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When changes are made, we will update the Effective Date above.

Your continued use of our Services after changes become effective constitutes acceptance of the revised Privacy Policy.

Contact Information

If you have questions regarding this Privacy Policy, wish to exercise your privacy rights, or would like to submit a privacy-related request, please contact us:

Company	23 Restaurant Services, LLC
Email	privacy@23restaurants.com
Mailing Address	505 E. Jackson Street, Suite 302 Tampa, Florida 33602
Phone	(800) 767-0882
Privacy Requests	Please provide your name, contact information, relevant brand or restaurant location, the nature of your request, and any information reasonably necessary for us to locate your records. We may need to verify your identity before processing certain requests.