Skytale Digital, L.L.C. (“Restaurant Growth,” “we,” “us,” or “our“) operates the website at restaurantgrowth.com (the “Site“) and provides marketing services and membership-program administration services to restaurants (collectively, the “Services“). This Privacy Policy explains what personal information we collect, why we collect it, who we share it with, and the choices and rights you have. It applies to (1) visitors to our Site, (2) restaurant owners, operators, and their personnel who inquire about or use our Services (“Clients” and prospective Clients, or “Leads“), and (3) consumers who join a restaurant membership program that we administer (“Members“).

Effective date: October 19, 2026
Last updated: October 19, 2026

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1. Our Role: When We Act for Ourselves and When We Act for a Restaurant

We wear two hats, and the distinction matters:

• Our own business. When you visit our Site, book a call, or become a Client, we decide how your information is used. For that information, we are the “business” (under California law) or “controller” (under other state laws).
• Membership programs. When a restaurant hires us to build and run its paid membership program, the restaurant decides what the program is; we operate the signup, billing, member communications, and support on the restaurant’s behalf. For Member information processed in that role, the restaurant is the business/controller and we act solely as its “service provider” or “contractor” (as those terms are defined in the California Consumer Privacy Act, as amended by the CPRA) and as a “processor” under other applicable state laws. We process Member information only on the restaurant’s documented instructions, only to operate the program, and never for our own independent marketing. The restaurant owns its Member relationships and Member data. Section 7 explains this in more detail.

If anything in this Policy conflicts with a written agreement between us and a Client regarding Member data, the written agreement controls for that data.

2. Information We Collect

2.1 Information you give us directly

• Leads and Clients: name, business name, email address, phone number, restaurant details (locations, cuisine, point-of-sale system, revenue range, and similar business information), call recordings and notes from sales and onboarding calls, messages you send us (including through Facebook Messenger and Instagram), and billing information for your engagement with us.
• Members: when you join a membership program we administer, we collect your name, email address, mobile phone number, and membership details (program joined, start date, plan, and renewal terms). Payment is processed by Stripe, Inc. (see Section 2.4), we do not collect or store your full card number.

2.2 Information collected automatically

When you visit the Site, we and our analytics and advertising partners automatically collect device and usage information through cookies, pixels, and similar technologies: IP address, browser and device type, pages viewed, links clicked, referring URLs, approximate location (derived from IP), and identifiers such as cookie IDs and advertising IDs. Section 5 describes these technologies and your controls.

2.3 Information from third parties

We receive information from advertising and social platforms (for example, Meta and Google) about ad interactions; from scheduling, CRM, and communication tools you interact with; from point-of-sale and ordering integrations a Client authorizes (such as Clover or Toast) in the form of transaction and redemption data; and from publicly available business sources used to identify restaurants that may benefit from our Services.

2.4 Payment information

Payments are processed by Stripe, Inc. and its affiliates. When you pay, whether as a Member or as a Client paying for Services, your card details are submitted directly to Stripe (through Stripe-hosted payment fields or pages) and are handled under Stripe’s privacy policy. Stripe returns to us a token, the card brand, the last four digits, and the transaction record. We never receive or store your full card number or CVV on our systems.

2.5 Membership program data

For programs we administer, we process: Member signup and consent records (see Section 7.3), subscription and billing status, renewal and cancellation dates, transaction and benefit-redemption history, member-support communications (email, chat, and SMS threads), and program-level reporting for the restaurant.

3. How We Use Information

We use personal information to:

• Provide, operate, and improve the Site and Services;
• Respond to inquiries, schedule and conduct calls, and prepare proposals;
• Run advertising campaigns for Clients and measure campaign performance, including redemption and return-on-spend attribution;
• Administer membership programs on behalf of Clients: signup, recurring billing through Stripe, renewals, cancellations, refunds, dunning (failed-payment recovery), benefit tracking, and Member support;
• Send communications described in Section 6 (email and SMS marketing and transactional messages);
• Process payments, prevent fraud, and manage chargebacks and disputes;
• Comply with legal obligations, enforce our agreements, and protect our rights, property, and safety and that of others;
• Analyze and improve our marketing, Site, and Services in aggregated or de-identified form.

We do not use Member information obtained in our service-provider role for any purpose other than operating the restaurant’s program, and we do not use it to market our own Services to Members.

4. How We Share Information

We share personal information only in the following circumstances:

• Service providers and sub-processors. Vendors that perform services for us under contract and are restricted to using the information for those services, including: Stripe (payment processing, billing, and dispute handling); Meta and Google (advertising delivery, measurement, and analytics); website hosting and infrastructure providers; CRM, scheduling, email, SMS, and customer-support platforms; and point-of-sale integration partners a Client authorizes. A current list of material sub-processors for membership-program operations is available on request at luke@restaurantgrowth.com.
• The restaurant that hired us. Member and program information is shared with the Client restaurant that operates the program, as it is their customer relationship. Clients are responsible for their own use of that information under their own privacy policies.
• Advertising partners. As described in Section 5, we share limited identifiers and event data (such as hashed email addresses and on-site actions) with Meta and Google to measure campaigns and reach similar audiences.
• Legal and safety. When required by law, subpoena, or court order; to enforce our terms; to investigate fraud or security incidents; or to protect the rights, property, or safety of any person.
• Business transfers. In connection with a merger, acquisition, financing, or sale of all or part of our business, subject to confidentiality protections.

We do not sell personal information, and we do not “share” personal information for cross-context behavioral advertising in our service-provider role. To the extent our own advertising practices on the Site (Section 5) could be characterized as a “sale” or “share” under California law, you may opt out as described in Sections 5 and 9.

5. Cookies, Pixels, and Advertising Technologies

We use the following on the Site:

• Essential cookies: required for the Site to function (security, load balancing, form submission).
• Analytics cookies: including Google Analytics, to understand Site usage.
• Advertising pixels: including the Meta Pixel and Google Ads tags, which measure ad performance, build audiences, and allow Meta and Google to show our ads to people who visited the Site or who resemble our Clients.

Your controls. You can block or delete cookies in your browser settings (essential features may stop working). You can opt out of Google Analytics at tools.google.com/dlpage/gaoptout, adjust ad personalization in your Google and Meta account settings, and, if you are a California resident, exercise the opt-out described in Section 9. We honor Global Privacy Control (GPC) signals as an opt-out of sale/share for the browser sending the signal. A “Do Not Track” disclosure appears in Section 10.

6. Email and Text Message (SMS) Marketing

• Email. If you provide your email address, we may send marketing emails about our Services. Every marketing email contains an unsubscribe link, and we honor opt-outs as required by the CAN-SPAM Act. Transactional emails (receipts, billing notices, service alerts) are not marketing and may be sent as needed to operate your account or membership.
• Text messages. We send marketing text messages only with your prior express written consent, as required by the Telephone Consumer Protection Act (TCPA). Consent is not a condition of purchasing any product or service. Message frequency varies; message and data rates may apply. Reply STOP to opt out at any time; reply HELP for help. Opting out of marketing texts does not stop transactional texts necessary to administer a membership (for example, payment-failure or renewal notices), which are sent under the consent and contact information you provided at signup.
• Member messages. Texts and emails sent to Members are sent on behalf of the restaurant operating the program, in our service-provider role.
• We maintain records of marketing consents (see Section 7.3) and do not buy or use lists of phone numbers for parties who have not consented.

7. Membership Programs: Data Ownership, Our Service-Provider Role, and Signup Records

7.1 Ownership split

As between us and a Client restaurant, the restaurant owns its Member relationships and the Member data collected for its program. We claim no ownership of Member data and no right to use it independently of the program.

7.2 Service provider / contractor commitments

For Member data, we act as a service provider and contractor (CCPA/CPRA) and processor (other state laws). Accordingly, we: (a) process Member data only on the restaurant’s documented instructions to operate the program; (b) do not sell or share Member data; (c) do not retain, use, or disclose Member data outside the direct business relationship with the restaurant or for any commercial purpose of our own; (d) do not combine Member data across Clients except as permitted by law to operate the Services; (e) impose equivalent obligations on our sub-processors; and (f) assist the restaurant, on request, in responding to Member privacy requests and in meeting its legal obligations.

7.3 What we record at signup

To protect Members, restaurants, and the integrity of recurring billing, we log the following for every membership enrollment: the date and time of signup; the IP address and device/user-agent information; the price, billing frequency, trial or promotional terms, and renewal and cancellation disclosures presented; the version of the Membership Terms accepted; and the affirmative action taken to agree (for example, the unchecked-by-default consent checkbox or button click). These records are retained for the life of the membership plus four (4) years, and serve both as consent evidence under auto-renewal and telemarketing law and as documentation in payment disputes.

7.4 If a restaurant leaves us

If a Client’s engagement with us ends, Member data for that program is returned to the restaurant and/or migrated as described in the Membership Terms and our agreement with the restaurant, so that Members keep the benefits they paid for. We delete or de-identify Member data after migration or, if no migration occurs, within a commercially reasonable period after the program winds down, except records we must retain by law or for dispute resolution (including the signup records in Section 7.3).

8. Data Retention

We retain personal information only as long as reasonably necessary for the purposes in this Policy:

• Lead data: up to three (3) years after last contact, unless you become a Client or ask us to delete it sooner.
• Client data: for the duration of the engagement plus up to seven (7) years for tax, accounting, and legal records.
• Member data: as described in Sections 7.3–7.4, for the life of the membership, with consent and billing records retained four (4) years thereafter.
• Site analytics data: up to twenty-six (26) months.

When information is no longer needed, we delete it or de-identify it.

9. Your Privacy Rights

Depending on your state of residence, you may have rights to: know/access the personal information we hold about you; correct inaccuracies; delete personal information; obtain a portable copy; opt out of the sale of personal information, its sharing for cross-context behavioral advertising, and targeted advertising; and not be discriminated against for exercising your rights.

• California (CCPA/CPRA). California residents have the rights listed above, plus the right to limit the use of sensitive personal information. We do not collect sensitive personal information beyond what is needed to operate the Services, and payment data is handled by Stripe (Section 2.4). Categories collected in the last 12 months: identifiers, contact information, commercial information (transactions and subscriptions), internet activity, and business information, as described in Section 2. We will not sell your information, and Site visitors may opt out of any sale/share via luke@restaurantgrowth.com or the GPC signal (Section 5).
• Texas (TDPSA). Texas residents have the rights listed above, including the right to appeal a decision on a request. If we decline your request, we will explain why and how to appeal; appeals may be submitted to luke@restaurantgrowth.com.
• Other states. If your state provides privacy rights, use the same contact method and we will process your request under your state’s law.
• Members. Because we process Member data on behalf of restaurants, we will forward Member requests to the operating restaurant and assist it in responding, and we will also respond directly where the law requires.

How to make a request. Email luke@restaurantgrowth.com. We will verify your identity against the information we hold, respond within the period your state’s law requires (generally 45 days), and tell you if we need more time. Authorized agents may submit requests with proof of authorization. We never charge a fee for a legitimate request and never require you to create an account.

10. Do Not Track

Some browsers send a “Do Not Track” (DNT) signal. Because there is no industry consensus on how to interpret DNT, we do not respond to it; we do honor Global Privacy Control as described in Section 5.

11. Security and Breach Cooperation

We protect personal information with administrative, technical, and physical safeguards appropriate to its sensitivity, including access controls (least-privilege), encryption in transit, vendor security review, and tokenized payment processing through Stripe (we never store full card numbers; see Section 2.4). No system is perfectly secure, and we cannot guarantee absolute security.

If a security incident affects Member data we process for a restaurant, we will notify the affected restaurant without undue delay after discovery, cooperate with its investigation, and support any notifications the law requires. Restaurants likewise agree in our service terms to cooperate with us if an incident originates in their systems.

12. Children’s Privacy

The Site and Services are intended for adults operating businesses, and membership programs are intended for consumers aged 18 and over. We do not knowingly collect personal information from children under 16. If you believe a child has provided us information, contact luke@restaurantgrowth.com and we will delete it.

13. Third-Party Links and Platforms

The Site and Services interact with third-party platforms (including Meta, Google, Stripe, and point-of-sale systems). Their handling of your information is governed by their own privacy policies, not this one.

14. Changes to This Policy

If we materially change this Policy, we will post the updated version on the Site with a new “Last updated” date, and where the law requires, notify affected individuals or obtain consent. Continued use of the Site or Services after a change takes effect signifies acceptance of the updated Policy for information collected after that date.

Skytale Digital, L.L.C.
7400 N Oracle Rd Suite 150-415, Tucson, AZ 85704
Email: luke@restaurantgrowth.com