Privacy Policy

Last revised: August 28, 2025

At Cactus Restaurants Ltd. and Cactus Restaurants USA Inc. (collectively, “Cactus Restaurants”, “we”, “us”, “our”), we are committed to protecting your privacy and safeguarding your Personal Information (as defined below).

We are proud to demonstrate our commitment to your privacy, by complying with the laws and regulations under applicable privacy laws in Canada and the United States – including the Personal Information Protection and Electronic Documents Act and the regulations thereunder as well as applicable provincial privacy legislation, U.S. state privacy laws, and regulations.

The purpose of this Privacy Policy (“Policy”) is to inform you about the types of Personal Information we collect, use and disclose. It explains how we collect, use and disclose your Personal Information, the choices you have regarding such use and disclosure, and how you may access and correct your Personal Information.

1. Scope and Acknowledgment

This Policy applies to your use of our “Services,” which include the following:

Our “Offline Services”

Services you use when you visit our restaurants, make a reservation or inquiry or over the phone, or otherwise visit an event or venue owned, operated, promoted, or serviced by Cactus Restaurants.

Our “Digital Services”

Our website, located at https://www.cactusclubcafe.com (the “Website”), and any other website, application, or services where we post or link to this Policy; and
Our social media pages and any other online services.

This Policy does not apply to information processed by third parties, for example, when you visit a third-party website or interact with third-party sites, except to the extent those parties collect or process information on our behalf. Please review any relevant third party’s privacy policy for information regarding their privacy practices.

Your use of our Services indicates your acknowledgement of the notices provided in this Policy.

2. Changes to our Policy

From time to time, we may make changes to this Policy. The Policy is current as of the “last revised” date which appears at the top of this page. We will treat Personal Information in a manner consistent with the Policy under which it was collected, unless we have your consent to treat it differently, or as permitted by law. This Policy applies to any Personal Information we collect or receive about you, from any source.

3. How to Contact Us / Controller

The controller of your Personal Information under this Policy is Cactus Restaurants Ltd. All comments, questions, concerns or complaints regarding your Personal Information or our privacy practices should be forwarded to our Privacy Officer as follows:

Mailing from Canada:
Attn: Privacy Officer
Cactus Restaurants Ltd.
201-550 West Broadway
Vancouver, BC V5Z 1E9

Mailing from the U.S.:
Cactus Restaurants Ltd.
c/o Cogency Global Registered Agents
850 New Burton Rd., Suite 201
Dover, DE, 19904

By e-mail: privacyofficer@cactusclubcafe.com

Regional Data Rights: Visit the Privacy Rights Request Form, or mail to the address above.

Cookie Management: Visit our Manage Cookie Preferences widget.

4. What is Personal Information?

For purposes of this Policy, “Personal Information” refers to any information relating to identified or identifiable individuals or households. We may collect and process various types of Personal Information, including the following categories:

Audio/Visual Data: Recordings and images collected from surveillance cameras, as well as audio files and records, such as voicemails, call recordings, and the like.

Contact Data: Identity Data used to contact an individual, e.g. email address, physical address, phone number or employment contact information.

Device/Network Data: Personal Information relating to your device, browser, or application e.g. device identifiers, identifiers from cookies, session history and Website navigation metadata, and other data generated through applications and browsers, including via cookies and similar technologies.

General Location Data: Non-precise location data, e.g. location information derived from IP addresses.

Identity Data: Personal Information about you and your identity, such as your name, gender, birth date or IP address.

Inference Data: Personal Information we create or use as part of a profile reflecting your preferences, characteristics, aptitudes, market segments, likes, favorites or your interests.

Sensitive Personal Information: Personal Information deemed “sensitive” under California or other laws. We collect the following categories of Sensitive Personal Information:

Health Data: Information about your health, such as a food allergy.
Payment Data: Information such as bank account details, payment card information, including similar data protected as Sensitive Data under applicable law, and relevant information in connection with a financial transaction.

Transaction Data: Information about the products and services we provide to you and about transactions you make with us and similar information.

User Content: Personal Information included in content provided by users of the Website in any free-form or unstructured format, such as a text in a “contact us” box, in a file or document, or any other message to us.

5. How do we collect your Personal Information?

We will collect your Personal Information by fair and lawful means. We may collect Personal Information from you directly and/or from third parties, where we have obtained your consent to do so or as otherwise required or permitted by law. We collect Personal Information from various sources based on the context in which the Personal Information will be processed.

You: We collect Personal Information from you directly, for example, when you make a reservation, submit a delivery order, purchase a gift card, input information into an online form, or contact us directly.

Automatic Collection: We may collect certain Personal Information automatically when you use our Services. For example, to ensure that our website is optimized for ease of use, we or our service provider(s) may use cookies to automatically collect Device/Network Data and other data about your use of our site, including your language preferences, your browser type and version, and similar information. These cookies are intended to optimize your experience of our website and only collect anonymous information.

Service Providers: We receive Personal Information from service providers performing services on our behalf, including payment processors, reservation booking providers, analytics providers, web hosting service providers, or our delivery and installation partners.

Data we create or infer: We, certain partners, and third parties operating on our behalf create and infer Personal Information such as Inference Data based on our observations or analysis of other Personal Information processed under this Policy, and we may correlate this data with other data we process about you.

Social Media Companies: We receive Personal Information from Meta (e.g. Facebook and Instagram) and other social media companies when you interact with us on that social media company’s platform (e.g. our company page or account) on or in connection with our Services.

6. Data Processing Contexts / Notice at Collection

We generally process Personal Information in the following contexts. See below for information regarding our Data Retention practices.

Website

Generally
When you visit our Website, we automatically collect and process Identity Data, Inference Data, General Location Data, and Device/Network Data. We use this data as necessary to initiate or fulfill your requests for certain features or functions through our Website, such as delivering webpages or logging activities for security purposes. We may also process this Personal Information for our Business Purposes and Commercial Purposes.

Cookies and Similar Tracking Technologies
We process Identity Data, Device/Network Data, Contact Data, Inference Data, Transaction Data, and General Location Data in connection with our use of cookies and similar technologies on our Website. We may collect this data automatically.

We and authorized third parties may use cookies and similar technologies to process such data for the following purposes:

for “essential” purposes necessary for our Website to operate (such as maintaining user sessions, content delivery, and the like);
for “functional” purposes, such as to enable certain features of our Website (for example, to allow a customer to maintain an online shopping cart or similar tool);
for “analytics” purposes and to improve our Website, such as to analyze the traffic to and on our Website. For example, we may use these technologies to understand how you use our Website, how you book with us, the methods and devices you use to access our Website, to make improvements to our Website, to distinguish unique visits/visitors to our Website and what website they visited prior to visiting our Website, to understand user behaviors, and improve the design and functionality of the Website. Examples of the cookies we use include Google Analytics and Crazy Egg; and
for “Targeted Advertising”, or other advertising and marketing purposes, including technologies that process Inference Data or other data so that we can deliver, buy, or target advertisements which are more likely to be of interest to you, or to deliver our marketing to you on third party websites or services you may use. These technologies enable us, ad networks, and social media platforms to inform and serve you with advertisements tailored to your interests, or because you have used our Services. These technologies may associate data collected on this site with data from other sites or services to develop a profile of your interests and preferences. If you disable these technologies, you will still see ads, but they may be less relevant. Examples of the cookies we use include Meta, Google, LinkedIn and TikTok.

We may also process this Personal Information for our Business Purposes and Commercial Purposes. See “Your Rights and Choices” below for information regarding opt-out rights for cookies and similar technologies.

Please note, in some cases, third parties may view, edit, or set their own cookies or place web beacons on our Website. We, or third-party providers, may be able to use these technologies to identify you across Websites, devices, sites, and services. Third parties have their own privacy policies, and their processing is not subject to this Policy.

Reservations, Purchases, and other Transactions
We may process Transaction Data, Identity Data, Payment Data, Inference Data, and Contact Data when you make a booking or reservation or complete a purchase or sale transaction. We do not permanently store your Payment Data, except at your request (e.g. as part of your user account). If you choose to provide it, e.g. by indicating a food allergy, we process Health Data.

We process this Personal Information as necessary to perform or initiate a transaction with you, confirm your reservation, process your order, payment, or refund, carry out fulfillment and delivery, document transactions, and for our Business Purposes.

We may also process Identity Data, Transaction Data, Contact Data, and Device/Network Data for Commercial Purposes. We do not sell or “share” Payment Data or Health Data or use it for Business Purposes not permitted under applicable law.

Contact Us
We process Identity Data, Device/Network Data, and any Personal Information contained within any User Content when you contact us using a contact phone number or via email, to ask a question, or request support. We may process Audio/Visual Data if you contact us via phone, leave a voicemail, or submit a photo with your request.

We process Identity Data, Contact Data, User Content, and Audio/Visual Data as necessary to communicate with you about the subject matter of your request and related matters. We may also process this Personal Information for our Business Purposes and Commercial Purposes.

AI Customer Platforms
We may collect Contact Data, Device/Network Data, Identity Data, and User Content when you interact with one of our AI customer platforms. We use this Personal Information as necessary to fulfill your request, and for our Business Purposes. We do not train on any inputs or outputs from AI customer platforms.

Visiting our Restaurants
We process Identity Data, Transaction Data, Payment Data, Inference Data, General Location Data, and Contact Data when you visit one of our restaurants. If provided or due to an incident at one of our restaurants, we may also process Health Data. We may collect Audio/Visual Data in relation to the use of CCTV cameras.

We process Identity Data, Transaction Data, Payment Data, Inference Data, General Location Data Audio/Visual Data, and Contact Data as necessary to operate our restaurants and provide our Services to you, for our Business Purposes, and our other legitimate interests, including:

verifying your identity for authentication and security purposes;
helping us to ensure our customers are genuine and to prevent fraud;
to help us to return lost property to its rightful owner; and
managing access to specific areas of our restaurants.

We process Health Data only as necessary to provide you with appropriate services (for example, a wheelchair accessible space, or to accommodate a food allergy) or to help us investigate an incident which may have taken place at one of our restaurants, and for certain Business Purposes.

We use Identity Data, Transaction Data, Inference Data, and Contact Data collected in this context for our Commercial Purposes. We do not sell or “share” Payment Data, Health Data, or Audio/Visual Data, or use such data for Business Purposes not permitted under applicable law.

Social Media Posts
We process Identity Data, Contact Data, and User Content if you interact with or identify us on social media (e.g. if you post User Content that engages with or tags our official accounts). We process this Personal Information to communicate or interact with you on social media, and for our Business Purposes and Commercial Purposes.

Posts may be public or reposted on our Services. Content you provide may be publicly available when you post it on our Services, or in some cases, if you reference, engage, or tag our official social media accounts or communications platforms.

Transactional and Promotional Communications
We process Identity Data, Device/Network Data, Inference Data, and Contact Data in connection with email and SMS communications that we send in relation to our Services. For example, we send transactional email communications to you if you subscribe to our service, make a purchase or reservation, or in connection with our delivery of services that you request. Additionally, you may receive promotional email communications tailored to your interests and more general in nature if you contact us, choose to receive them, or interact with us in a way that allows us to send you those communications.

We may also automatically collect Device/Network Data when you open or interact with those communications so that we can better understand engagement with our communications.

We may also process this Personal Information for our Business Purposes and Commercial Purposes. However, we do not share Contact Data collected as part of Cactus Restaurants’ SMS marketing campaigns with third parties for their own marketing or Commercial Purposes. You can opt out of promotional communications at any time as specified in “Your Rights and Choices” below.

Opinions, Comments, and Feedback
We process Identity Data, Contact Data, and User Content collected in connection with our collection of opinions and comments regarding your experience at Cactus Restaurants. We may also process Audio/Visual Data if you provide it, such as if your review includes photos that include images of any individuals.

We process this Personal Information as necessary to respond to your feedback or concerns, for our Business Purposes, and other legitimate interests, such as analyzing user satisfaction or for marketing purposes. We may process this Personal Information for our Commercial Purposes. We may share feedback relating to any third-party service provider’s performance of services to you (e.g. food delivery) with those service providers, who may use it for their own purposes.

Contests and Promotions
We may collect and process Identity Data, Inference Data, certain Contact Data, and User Content when you enter a contest, sweepstake or giveaway, or take part in a promotion.

We process this Personal Information as necessary to provide the contest/promotion, notify you if you have won, or to process delivery of a prize, for our Business Purposes, including:

verifying your identity for authentication, anti-fraud, and security purposes (in which case we may process Government ID Data to complete verification);
to improve our Services and to create a personalized user experience; and
to contact you about relevant products or services, and in connection with marketing communications and Targeted Advertising.

We may process Identity Data, Contact Data, and User Content for our Commercial Purposes.

Some programs and offers are operated/controlled by our third-party partners or their affiliates or partners. We may receive this data from third parties to the extent allowed by the applicable partner; otherwise, this Policy will not apply to data processed by third parties.

Your Personal Information may be public. If you win a contest/sweepstakes, we may publicly post some of your data. We do not post Personal Information without consent where required by law. See any program agreement(s) for additional details and terms.

7. Purposes of Processing

Business Purposes
We identify the purposes for which we use your Personal Information at the time we collect such information from you and obtain your consent, in any case, prior to such use. In addition to the processing described above, we generally process your Personal Information for the following purposes depending on the context of collection and Your Rights and Choices (the “Business Purposes”):

Operate our Website and Fulfill Obligations
We process any Personal Information as is necessary to provide the Website, and as otherwise necessary to fulfill our obligations to you, e.g. to provide you with the information, features, and services you request.

Internal Processes and Service Improvement
We may use any Personal Information we process through our Services as necessary in connection with our improvement of the design of our Services, understanding how the Services are used, for customer service purposes, in connection with the creation and analysis of logs and metadata relating to Service use, and for ensuring the security and stability of our Services. Additionally, we may use Personal Information to understand what parts of our Services are most relevant to users, how users interact with various aspects of our Services, how our Services perform or fail to perform, etc., or we may analyze use of the Website to determine if there are specific activities that might indicate an information security risk to the Website or our users.

Security and Incident Detection
We may process Personal information to ensure that our Website is secure, identify and prevent crime, prevent fraud, and verify or authenticate users/individuals, and ensure the safety of our guests. Similarly, we process Personal information as necessary to detect security incidents, protect against, and respond to malicious, deceptive, fraudulent, or illegal activity. We may analyze network traffic, device patterns, and characteristics, maintain and analyze logs and process similar Personal information in connection with our information security operations and related.

Aggregate Analytics
We process Personal Information as necessary in connection with our creation of aggregate analytics relating to how our Services are used, the pages and content users view, and to create other reports regarding the use and performance of our Platform, and other similar information and metrics. The resulting aggregate data will not contain information from which an individual may be readily identified.

Compliance, Safety & Public Interest
Note that we may, without your consent or further notice to you, and to the extent required or permitted by law, process any Personal Information subject to this Policy for purposes determined to be in the public interest or otherwise permitted by law. For example, we may process information as necessary to fulfil our legal obligations, to protect the vital interests of any individuals, or otherwise in the public interest or as required by a public authority. Please see the data sharing section for more information about how we disclose Personal Information in extraordinary circumstances.

Commercial Purposes
We and certain third parties process Personal Information to further our commercial or economic interests (“Commercial Purposes”) depending on the context of collection and Your Rights and Choices.

Please Note: We may require your consent, or we may not engage in processing of Personal Information for Commercial Purposes in some jurisdictions, or in certain contexts (e.g., as a result of your enrollment in SMS campaigns). Some of this processing may involve “sales” or “sharing” of Personal Information. See Your Rights and Choices below for information on how you can opt-out of this processing.

We generally process your Personal Information for the following Commercial Purposes:

Targeted Advertising
We and certain third parties operating on or through our Services may engage in interest-based marketing in order to serve you with advertisements based on your preferences or interests (“Targeted Advertising”). The preferences, interests and related profiles used for Targeted Advertising may be inferred or derived from Personal Information that we or those third parties obtain or infer from your activities on our Services or across non-affiliated websites, applications, or services (e.g. through Cookies and Similar Technologies).

Note that Targeted Adverting includes various parties and service providers, including third party data controllers, engaged in the processing of Personal Information in connection with Targeted Advertising. These parties may be able to identify you across sites, devices, and over time. In some cases, these third parties may build or augment user profiles using your Personal Information, and may track whether you view, interact with, or how often you have seen an ad, or whether you purchased advertised goods or services.

8. To whom do we share your Personal Information?

We generally identify to whom, and for what purposes, we disclose your Personal Information, at the time we collect such information from you and, if applicable, obtain your consent to such disclosure. We generally transfer Personal Information to the categories of recipients or in connection with specific business purposes, described below.

Service Providers
We may share your Personal Information with service providers who provide certain services or process data on our behalf in connection with our general business operations, product/service fulfillment and improvements, to enable certain features, and in connection with our (or our Service Providers’) Business Purposes.

Corporate Affiliates
In order to streamline certain business operations and develop products and Website that better meet the interests and needs of our customers, we may share your Personal Information with any of our current or future affiliated entities, subsidiaries, and parent companies.

Corporate Events
Your Personal Information may be disclosed to a third party in the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Information may be part of the assets transferred or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.

Advertisers; Social Media Platforms
We may share certain Personal Information with social media platforms, advertisers, ad exchanges, data management platforms, or sponsors in support of our Commercial Purposes. We may also share certain Personal Information with social media companies when you interact with Cactus Club on social media. We may allow these third parties to operate through our Website, such as through social media pixels or cookies on our homepage. We do not share Contact Data collected in connection with Cactus Club’s marketing communications with these parties.

Legal Disclosures
In limited circumstances, we may, without notice or your consent, access and disclose your Personal Information, our correspondence with you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, or in the vital interests of us or any person. Note, these disclosures may be made to governments that do not ensure the same degree of protection of your Personal Information as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Information to such parties.

Public Disclosure
If you interact with us or our Services online or otherwise via social media, we may make your post available on our Services or to the general public. We may share, rebroadcast, or redisplay Personal Information or other information in the post to the extent permitted by the relevant social media service.

9. International Transfers

In addition, we may send Personal Information outside of the country (USA and Canada) for the Purposes, including for process and storage by service providers in connection with such Purposes. However, you should note that to the extent that any Personal Information is out of the country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. For written information about our policies and practices regarding service providers outside of the country, contact our Privacy Officer (see question 16 below).

10. Privacy and Security

We have implemented physical, organizational, contractual and technological security measures in an effort to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. We have taken steps to ensure that only employees who are granted access to your Personal Information are those with a business ‘need-to-know’ or whose duties reasonably require such information.

However, we sometimes share Personal Information with third parties as noted above, and though we may take certain measures to help ensure the security of your Personal Information, like contractually requiring third parties to observe the intent of this Policy and our privacy practices, we do not control third parties’ security processes. We do not warrant perfect security, and we do not provide any guarantee that your Personal Information or any other information you provide us will remain secure.

11. How long will we retain your Personal Information?

We will utilize, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by law. What is necessary may vary depending on the context and purpose of processing. We generally consider the following factors when we determine how long to retain data (without limitation):

Retention periods established under applicable law;
Industry best practices;
Whether the purpose of processing is reasonably likely to justify further processing;
Risks to individual privacy in continued processing;
Applicable data protection impact assessments;
IT systems design considerations/limitations; and
The costs associated with continued processing, retention, and deletion.

We will review retention periods periodically and may pseudonymize or anonymize data held for longer periods.

12. Children

Our Services are neither directed at nor intended for use by persons under the age of 13. We do not knowingly collect information from such individuals. If we learn that we have inadvertently done so, we will promptly delete such Personal Information if required by law. Do not access or use our Services if you are not of the age of majority in your jurisdiction unless you have the consent of your parent or guardian.

13. Your Rights and Choices

Your Rights
You may have certain rights and choices regarding the Personal Information we process. Please note, these rights may vary based on the country or state where you reside, and our obligations under applicable law. See the following sections for more information regarding your rights/choices in specific regions:

Canada
US States

Note: We are able to fulfill rights requests regarding Personal Information that we control or process. We may not have access to or control over Personal Information controlled by third parties. Please contact the third party directly to exercise your rights in third party-controlled information.

Verification of Rights Requests
We may request that you provide sufficient identification to permit access to the existence, use, or disclosure of your Personal Information. For example, we may require that you verify that you have access to the email on file in order to verify your identity. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf. Any such identifying information shall be used only for this purpose.

Your Choices
All users have the following choices regarding the Personal Information we process, subject to the limits under applicable law:

Withdraw Consent: If we rely on your consent to our processing of Personal Information, you may withdraw your consent at any time. You may be required to close your account in order to withdraw consent where your consent is necessary to perform essential aspects of our Services. You can withdraw your consent to receive marketing communications by clicking on the unsubscribe link in an email (for email), or for other communications, by contacting us using the information below. To opt-out of the collection of information relating to email opens, configure your email so that it does not load images in our emails.

Marketing Communications: You have the choice to opt-out of or withdraw your consent to email marketing communications. You may exercise your choice via the links in our communications. To opt-out of SMS communications, respond with “OPT-OUT”, “STOP”, or other supported unsubscribe message. For any other communications, contact us using the information above. To opt-out of the collection of information relating to email opens, configure your email so that it does not load images in our emails.

Cookies & Similar Technologies: If you do not want information collected through the use of cookies, you can manage/deny cookies and similar technologies using your browser’s settings menu or our Manage Cookie Preferences widget.

You may need to opt out of third-party services directly via the third party. For example, to opt-out of Google’s analytic and marketing services, visit Google Analytics Terms of Use, the Google Policy, or Google Analytics Opt-out.

Targeted Advertising: You may opt out or withdraw your consent to Targeted Advertising by visiting our Manage Cookie Preferences widget. In some cases, you may be able to opt-out by submitting requests to third party partners, including for the vendors listed below:

Do Not Track: Our Website does not respond to your browser’s do not track signal.

14. Canada Privacy Rights

In addition to your rights listed above, residents of Canada may have the following rights:

How can you review your Personal Information?
If you make a written request to access any Personal Information about you that we have collected, utilized or disclosed, we will provide you with any such Personal Information to the extent required by law. We will make such Personal Information available to you in a form that is generally understandable.

How do you know that the Personal Information we have on you is accurate?
We will attempt to ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. We will not routinely update your Personal Information, unless such a process is necessary. We expect you, from time to time, to supply us with written updates to your Personal Information, when required.

What if the Personal Information we have on you is inaccurate?
At any time, you can challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.

How fast will we respond to your written requests?
If you are a resident of Canada, we will attempt to respond to each of your written requests not later than thirty (30) days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit. You have the right to seek a review or make a complaint to the Privacy Commissioner of Canada or applicable provincial privacy commissioner in respect of this time limit.

Are there any costs to you for requesting information about your Personal Information or our privacy practices?
We will not charge any costs for you to access your Personal Information in our records without first providing you with an estimate of the approximate costs, if any.

What if I have questions or concerns?
If you have any questions or concerns about our privacy practices, please contact our Privacy Officer as set out in the Submission of Requests section below. We will consider all concerns and address them as appropriate and as required by law. If you are dissatisfied with how we have handled a concern you raise, you have the right to seek a review or make a complaint to the Privacy Commissioner of Canada or applicable provincial privacy commissioner.

15. U.S. State Privacy Rights

Data Rights
Under applicable U.S. state privacy laws, residents of certain US states may have the following rights, subject to your submission of an appropriately verified request:

Confirm: Right to confirm whether we process your Personal Information.

Access/Know: Right to request any of following: (1) the categories of Personal Information we have collected, sold or “shared,” or disclosed for a commercial purpose; (2) the categories of sources from which your Personal Information was collected; (3) the purposes for which we collected or sold or “shared” your Personal Information; (4) the categories of third parties to whom we have sold or “shared” your Personal Information, or disclosed it for a business purpose; and (5) the specific pieces of Personal Information we have collected about you.

Portability: Right to request that we provide certain Personal Information in a common, portable format.

Deletion: Right to delete certain Personal Information that we hold about you.

Correction: Right to correct certain Personal Information that we hold about you.

Opt-Out (Sales, Sharing, Targeted Advertising, Profiling): Right to opt-out of the following:

If we engage in sales of data (as defined by applicable law), you may direct us to stop selling Personal Information.
If we engage in Targeted Advertising (aka “sharing” of personal information or cross-context behavioral advertising,) you may opt-out of such processing.
If we engage in certain forms of “profiling” (e.g. profiling that has legal or similarly significant effects), you may opt-out of such processing.

Opt-out or Limit Use and Disclosure of Sensitive Personal Information: right to opt-out of the processing of certain Sensitive Data, or request that we limit certain uses of Sensitive Personal Information. This right does not apply in cases where we only use Sensitive Personal Information where necessary, or for certain business purposes authorized by applicable law.

Non-Discrimination: Residents of applicable U.S. states have the right to not to receive discriminatory treatment as a result of your exercise of rights conferred by applicable U.S. state privacy laws.

Submission of Requests
You may submit requests, as follows (please our review verification requirements section). If you have any questions or wish to appeal any refusal to take action in response to a rights request, contact us at privacyofficer@cactusclubcafe.com. We will respond to any request to appeal within the time period required by law:

Visit the Privacy Rights Request Form

Mail to the following address:

Cactus Restaurants Ltd.
c/o Cogency Global Registered Agents
850 New Burton Rd., Suite 201,
Dover, DE, 19904
Attn: Privacy Officer