SAGE Dining Services, Inc. Privacy Statement

Last Updated: March 20, 2025 SCOPE This Privacy Statement is designed to help you understand how SAGE Dining Services, Inc. and its affiliates and subsidiaries (“SAGE,” “we,” “us,” or “our”) collect, use, process, and disclose your personal information, and to help you understand and exercise your privacy rights. This Privacy Statement applies to personal information processed by us, including on our websites (“Sites”), the Touch of SAGE mobile app (“App”), other online or offline offerings, online communications, and through other platforms and programs that link to this Privacy Statement (collectively, the “Services”). For information regarding how we collect, use, process, and disclose certain health-related data, such as information related to allergies, please see our Consumer Health Data Privacy Notice. If you work for us or apply for a job with us, please see our Applicant and Worker Privacy Notice which describes how we process your personal data. For residents of certain U.S. states with comprehensive privacy laws, additional disclosures about the information we collect is contained in the Supplemental Notices below.
1. PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect personal information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below. A. Personal Information You Provide to Us Directly We may collect personal information that you provide to us.

• Account Creation. We may collect personal information when you register and create an account with us, such as through the App, which may include your name, age, role (e.g., parent, student), e-mail address, health-related data (e.g., allergies), food preferences, and other similar information.
• Communications with Us. We may collect personal information that you include in any communications with us, such as e-mail address, phone number, or mailing address when you request information about our Services, provide feedback about our products or interactions with our services, register for newsletters, request customer or technical support, or otherwise communicate with us.
• Surveys, Market Research & Product Improvement Studies. We may invite eligible adults to participate in research related to our Services – for example our menus and educational programming. If you are invited to participate and elect to participate in market research or product improvement studies, we may collect personal information from you. All personal data that we may collect will be described at the time you agree to take a survey or enroll in the research or study and processed in accordance with the terms of this Privacy Statement, if not the explicit, informed consent you provide at the time.
• Promotional Activities. We may collect personal data from you if you elect to participate in various promotional activities that we may offer from time to time. Any promotions we offer will be conducted and managed in compliance with applicable law, which may dictate the type of personal data we collect and whether and how we disclose it.
• Conferences, Trade Shows, and Other Events. We may collect personal information from individuals we interact with when we attend or host conferences, trade shows, and other events, including any of our in-person or online events or programs for which registration is required.
• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
• Social Media Content. We maintain a social media presence. Any content or personal data you provide on these channels will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.

B. Personal Information We Collect Automatically. We, as well as third parties that provide content, analytics, or other functionality on our Services, may use cookies, pixel tags, and other technologies (collectively, “Technologies”) to automatically collect information through your use of our Services. This includes information about your equipment, browsing actions and patterns. C. Information We Collect from Third-Party Services and Other Sources. We may obtain personal information about you from other sources, including from other individuals, through third-party services and organizations, and from publicly available sources. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings. Our sources may also include advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, social networks, and data brokers.
2. HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information for a variety of business and commercial purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below. A. Provide Our Services We use your information to provide you with our Services, such as:

• To fulfill your request for which you provided the information.
• Providing access to certain areas, functionalities, and features of our Services.
• Answering requests for customer or technical support.
• Communicating with you about activities on our Services, and policy changes.
• Allowing you to register for events.

B. Administrative Purposes We use your information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research, and development (including marketing research), network and information security, and fraud prevention.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Measuring interest and engagement in our Services.
• Short-term, transient use, such as contextual customization of ads.
• Improving, upgrading, or enhancing our Services.
• Developing new products and services.
• Ensuring internal quality control and safety.
• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Statement.
• Debugging to identify and repair errors with our Services.
• Auditing relating to interactions, transactions, and other compliance activities.
• Sharing personal information with third parties as needed to provide the Services.
• Enforcing our agreements and policies.
• Carrying out activities that are required to comply with our legal obligations; or
• For other legitimate business purposes permitted by applicable law.

C. Marketing and Advertising our Products and Services We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. We may also use and disclose your personal information to measure and predict the effectiveness of advertising and marketing, to find audience for marketing and advertising, and other analytics and operations related to advertising and marketing. We may also permit third parties to collect your information over time and across third-party websites, mobile applications and/or online services, including those that assist us in operating our Services, including to serve ads or provide messaging to you on our websites and mobile applications or on third-party platforms. We also use third-party advertising companies to serve and load ads on certain parts of our Services, including an ad server to provide advertising when you use our Services. These companies may use internet or electronic information about our Services and other websites and mobile applications to provide advertisements about goods and services of interest to you. Some of the ways we market to you may include e-mail campaigns, custom audiences advertising and “interest-based” or “personalized advertising,” including through cross-device tracking. D. With Your Consent We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent. E. De-Identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information, such as demographic information, information about the device from which you access our Services, or other analyses we create. We use this de-identified or aggregated data for the purposes outlined in this Privacy Statement and afford it appropriate protections as required by applicable data protection and other laws. F. Other Purposes We also use your personal information for other purposes as requested by you or as permitted by applicable law.
3. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
We disclose your personal information to third parties for a variety of business and commercial purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, and as otherwise described below. A. Disclosures to Provide our Services The categories of third parties with whom we may disclose your personal information are described below.

• Service Providers. We may disclose your personal information to our third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, and related services.
• Business Partners. We may share your personal information with business partners to conduct market research, data analysis, and general research and development purposes, and to provide you with a product or service you have requested.
• Affiliates. We may disclose your personal information to our company affiliates for example: for our administrative purposes, IT management, or for them to provide services to you or support and supplement the Services we provide.
• Advertising and Analytics Partners. Through our Services, we may disclose your personal information to third-party advertising partners. These third-party advertising partners may set Technologies on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising,” “cross-context behavioral advertising,” “targeted advertising,” or “personalized advertising.”

B. To Protect Ourselves or Others We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity. We may also disclose your information to third parties as appropriate and permitted by law. C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
4. ONLINE TECHNOLOGIES
We, as well as third parties that provide content, analytics, or other functionalities in relation to our Services, may use Technologies to automatically collect information through your use of our Services and to distinguish you from other users of the Services. Our uses of these Technologies fall into the following general categories:

• Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality.
• Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services.
• Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed.
• Advertising- or Targeting-Related. We may use first party or third-party Technologies, including cross-device tracking, to deliver content, including ads relevant to your interests, on our Services or on third-party digital properties.
• Analytics and Customer Support Tools. We may use Technologies and other third-party tools to process analytics information. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services. We may use other Technologies to provide customer support to individuals on our Services. One of our analytics partners may include Google. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here or Contact Us below.
• Social Media Platforms. Our Services may contain social media buttons which might include widgets such as the “share this” button or other interactive mini programs. These features may collect personal information such as your IP address and which page you are visiting on our Services and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

5. YOUR PRIVACY CHOICES
The privacy choices you may have about your personal information are determined by applicable law and are described below.

• E-mail Communications. If you receive an unwanted marketing e-mail from us, you can use the unsubscribe link found at the bottom of the e-mail to opt out of receiving future marketing emails. Note that you will continue to receive transaction-related e-mails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Statement).
• Online Technologies. You can control our use of certain Technologies in the following ways:
  • Browser Controls. You may also stop or restrict the placement of certain Technologies in your browser or remove them by adjusting your preferences as your browser permits. These tools are generally available in the help section of browsers. You can also use the quick links, based on the browser type that you are using: Internet Explorer, Google Chrome, Firefox, and Safari.
  • Device Controls. You may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others. Please note that cookie-based opt-outs may not stop all mobile tracking, such as tracking done on mobile applications.
  • Ad Industry Opt-Outs. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, and the Digital Advertising Alliance of Canada. Please note you must separately opt out in each browser and on each device.
  • “Do Not Track”/ “Global Privacy Control.” You may exercise your opt-out right by broadcasting a uniform opt-out preference signal, called the Global Privacy Control (“GPC”) on the browsers and/or browser extensions that support such a signal. You can learn more about the GPC here. Please note that your request to opt-out of sale/sharing will be linked to your browser identifier only. If you use a different computer or Internet browser to access the Corporate Sites, you will need to renew your opt-out request. Note that while we honor the GPC, we do not listen for or respond to older, Do Not Track (“DNT”) technologies that users may set in certain web browsers. (Note you must turn the GPC signal on for each supported browser or browser extension you use to connect with our Services.) Please note you must separately opt out in each browser and on each device.

6. YOUR PRIVACY RIGHTS
The privacy rights you may have about your personal information are determined by applicable law and described below. If you would like to exercise any of these rights, please Contact Us at any time, or as otherwise instructed the Notice at Collection and Supplemental Notice below. We will process such requests in accordance with applicable laws and will not discriminate or retaliate against you for the exercise of any of these rights. Note that to protect your privacy, we will take steps to reasonably verify your identity before fulfilling your request. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of that person.

• • Obtain Access to and Portability of Your Personal Information, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information including specific pieces of personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format.
  • Request Access to Your Personal Information, including that we disclose to you, free of charge, the following:
    • The categories of personal information, including sensitive personal information, that we have collected about you.
    • The categories of sources from which the personal information, including sensitive personal information, is collected.
    • The business or commercial purpose for collecting or selling or sharing personal information, including sensitive personal information.
    • The categories of third parties with whom we disclose personal information, including sensitive personal information, which may include a list of specific third parties, other than natural persons, to which we have disclosed personal information.
    • The specific pieces of personal information, including sensitive personal information, we have collected about you, which may include a copy of all personal information we are processing or have processed.
  • Request Correction of your personal information where it is inaccurate or incomplete (subject to exceptions as permitted by applicable law). When correcting inaccuracies, we will take into account the nature of the personal information and the purpose for processing the personal information.
  • Request Deletion of your personal information (subject to exceptions as permitted by applicable law).
  • Request Disclosure of Your Personal Information, including that we disclose to you, free of charge, with respect to personal information that we sell or disclose for a business purpose:
    • The categories of personal information, including sensitive personal information, that we have collected about you.
    • The categories of personal information, including sensitive personal information, that we have sold about you and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party.
    • The categories of personal information, including sensitive personal information, that we have disclosed about you for a business purpose.
  • Request Restriction of or Object to our processing of your personal information where the processing of your personal information is based on our legitimate interest or for direct marketing purposes, including (i) the right to opt-out of the sale or sharing of personal information, (ii) object to or restrict our use of or your sensitive personal information, including the right to opt-out of the use and disclosure of sensitive personal information, and (iii) opt out of the processing of your personal information for purposes of (a) targeted advertising, and (b) profiling in furtherance of automated decisions that produce legal or similarly significant effects concerning you. Such opt-out right may be available through an opt-out preference signal.
  • Opt-out of “Sale” or “Sharing”. Although we do not “sell” your personal information as the term “sale” is typically understood, we may “share” your information with analytics providers and advertising networks to understand how visitors use our Sites and serve ads on and off our Sites. Such opt-out right may be available through an opt-out preference signal such as the GCP.
  • Withdraw your Consent if previously given to permit our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.

Exercising Your Privacy Rights

• Generally. If you would like to exercise a privacy right, please Contact Us below or as otherwise instructed in the additional privacy notices provided at the time we collect your personal information. We will process such requests in accordance with applicable laws and do not discriminate against any individual who exercises or seeks to exercise their privacy rights.
• Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize an agent, provide written authorization signed by you and your designated agent or Contact Us for additional instructions.
• Verification. To protect your privacy, we will take steps to reasonably verify your identity before fulfilling your request. These steps may involve asking you to provide information to enable us to reasonably verify you are the person about whom we collected personal information or an authorized representative, or to answer questions regarding your account and/or your use of our Services.
• Appeal. You may have the right to appeal our decision or response to your request. To exercise your right to appeal, please Contact Us for additional instructions.

We will not discriminate against you because you exercise any of the rights as described in this section.
7. INFORMATION SECURITY
We take steps to ensure that your information is treated securely and in accordance with this Privacy Statement. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.
8. DATA RETENTION
We store the personal information we collect as described in this Privacy Statement for as long as necessary to fulfill the purpose(s) for which it was collected, or based upon other criteria, including, but not limited to, the sensitivity and volume of such data, in each case in line with our data retention policies.
9. CHILDREN’S INFORMATION
Our Services are not directed to individuals under the age of 13 (or other age as required by local law), and we do not knowingly collect personal information from children. We provide online menus which are intended to be viewed by parents as well as by their children, but do not collect personal information from children in this regard. If you are a parent or guardian and believe your child has provided personal information to us through the Services without your consent, please Contact Us below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it.
10. THIRD-PARTY SITES AND APPLICATIONS
Our Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
11. CHANGES TO THIS PRIVACY STATEMENT
We may revise this Privacy Statement from time to time in our sole discretion. If there are any material changes to this Privacy Statement, we will notify you as required by applicable law, such as by sending you an e-mail. If you continue to access the Services after the new Privacy Statement takes effect, as indicated by the Last Updated Date above, we will assume you have read and acknowledged the new terms.
12. INTERNATIONAL TRANSFERS
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States, which may have data protection laws that are different from the laws where you live. We will safeguard your information consistent with the requirements of applicable laws.
13. CONTACT US
SAGE is the controller of the personal information we process under this Privacy Statement. If you have any questions about our privacy practices or this Privacy Statement, or to exercise your rights as detailed in this Privacy Statement, please contact us at:
SAGE Dining Services, Inc.
Attn: Legal Department
1402 York Road
Lutherville, Maryland 21093
Telephone: 410-339-3950
E-mail: privacyrequest@sagedining.com

This Notice at Collection and Supplemental Notice describes the practices of SAGE Dining Services, Inc. and its affiliates and subsidiaries (“SAGE,” “we,” “us,” or “our”) regarding the collection, use, and disclosure of personal information of consumers who are residents of California or other states with comprehensive privacy laws (“you”) that apply to us.
Personal Information. We may have collected the categories of personal information from you in the last 12 months as described in the section above titled, Personal Information We Collect.
Sensitive Personal Information. We may have collected sensitive personal information, a type of Personal Information, from you pertaining to your health, such as information related to allergies. Please see our Consumer Health Data Privacy Notice for more information about our potential collection of consumer health data.
Purposes for Processing Personal Information. We may use the personal information we collect about you for the business purposes described above in the section titled, How We Use Your Personal Information. We do not process sensitive personal information without obtaining your consent and only process sensitive personal information for the purposes outlined above and to the extent permitted under applicable law.
Retention of Personal Information. The above section titled, Retention of Personal Information, outlines the criteria we utilize for determining how long to retain your personal information.
You may learn more about our privacy practices by reviewing our full Privacy Statement.