Effective Date: January 2025

This Privacy Policy explains how HH LESOP Co., doing business as Live.Eat.Surf and its restaurant brands (including K38 Baja Grill and Tower 7), collects, uses, and protects guest information across all locations.

By using our websites, loyalty programs, waitlist, online ordering, or dining in our restaurants, you agree to the practices described in this policy.

1. Who We Are

This Privacy Policy applies to all Live.Eat.Surf restaurants and future concepts under HH LESOP Co.

Questions or requests relating to privacy can be sent to:
privacy@LiveEatSurf.com

2. Information We Collect

We collect the following information when you interact with our restaurants, websites, or loyalty program:

• Personal Information Provided by Guests
  First and last name
  • Email address
  • Phone number
  • Birthdate
  • Location selection when signing up for rewards
  • Guest feedback submitted through surveys or reviews
• Information Collected Automatically
  Order history and purchase preferences
  • Visit frequency and spend history
  • Location-related data during waitlist or online ordering
• Information We Do Not Collect
  We do not store or collect credit card numbers or full payment data
  • We do not collect device-level data or cookies directly
  • We do not collect sensitive personal information

3. How We Use Guest Information

We use your information to improve your experience with our restaurants. This includes:

• Running the Live.Eat.Surf Rewards program
  • Delivering personalized offers and rewards
  • Sending marketing emails and SMS communications (opt-in required)
  • Sending birthday rewards
  • Providing operational messages, such as order updates or waitlist alerts
  • Improving our service through internal analytics
  • Ensuring accurate guest segmentation by location

You may receive marketing messages for both K38 Baja Grill and Tower 7 because the loyalty program is cobranded under Live.Eat.Surf Rewards.

4. How Your Information Is Shared

We share your information only with trusted service providers that support our operations.

These include:
• Toast POS, Toast Loyalty, Toast Online Ordering, Toast CRM
• Google Analytics (www.google.com/policies/privacy/)
• GatherUp (review management)
• Website hosting provider
• Toast waitlist and check-in tools
• Approved marketing agencies working on our behalf

We only share data with service providers who help us operate the business, and we do not allow them to use guest data for their own marketing.

We do not sell your personal information to anyone.

5. SMS and Email Communications

By signing up for Live.Eat.Surf Rewards, you may opt in to receive email or SMS messages.

Guests may opt out at any time:
• Email: click the unsubscribe link in any message
• SMS: reply STOP to opt out

Standard messaging and data rates may apply.

6. Payments and Security

All card payments are processed securely through Toast.
Live.Eat.Surf does not store or retain credit card numbers.

We implement reasonable industry-standard security safeguards to protect guest information, but no system is fully guaranteed secure.

7. Where Data Is Stored

All guest data is stored in the United States.

This policy applies to all Live.Eat.Surf restaurants operating in North Carolina and any future locations.

8. Your Rights

Guests may at any time:

• Request a copy of the personal data associated with their loyalty account
  • Request correction of inaccurate information
  • Request deletion of their personal data
  • Opt out of marketing communications

To submit a request or ask a question:
Email: privacy@LiveEatSurf.com
or use the contact form on our website.

9. Minors

The Live.Eat.Surf Rewards program is intended for adults age 18 and older.
Minors may participate only with approval and enrollment by a parent or guardian.

10. Cookies and Tracking

Our websites may use analytics tools for performance measurement and ad-related tracking, including:

• Google Analytics
  • Meta Pixel (Facebook) https://www.facebook.com/privacy/policy/

These tools help us understand traffic patterns and improve the guest experience.

11. Updates to This Policy

We may update this Privacy Policy from time to time. When updated, the new version will be posted on our website with a revised date at the top of this page.

12. Contact Us

For any privacy questions, data requests, or concerns, contact:

privacy@LiveEatSurf.com