Effective Date: March 11, 2026 

  

* California residents, please review additional privacy information in our California Privacy Notice listed below this General Privacy Policy. 

Residents of the state of Colorado, Connecticut, Iowa, Montana, Nevada, Oregon, Virginia, and Utah may have rights in addition to or different from the terms in this Privacy Policy and should consult their state-specific pages set forth below, if any are provided. 

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1. About Camo Eats and this Privacy Policy. 

  

Camo Eats, Inc. and its group companies (collectively, “Camo,” “Camo Eats,” “we,” “us,” or “our”) are committed to protecting your privacy. Camo Eats is a hospitality technology company that connects partner kitchens with nearby hotels and their guests by enabling local businesses to meet consumers’ needs of ease and convenience. Through our platform, we facilitate connections between consumers, merchant partners, and third-party delivery service providers (such as Uber and other similar services), generating new ways for people to earn, work, and live. Please note that in certain instances, Camo Eats may also directly operate the kitchen and/or manage the delivery of orders in-house, rather than through a third-party merchant partner or delivery service provider. In those instances, Camo Eats is acting not only as a platform facilitator but also as a direct service provider, and your personal information may be processed by Camo Eats in that additional capacity accordingly. 

  

This Privacy Policy (“Policy”) explains how we process (e.g., collect, use, disclose and/or protect) personal information when we are acting in the data processing role or capacity of a Controller (as defined below). This Policy applies to personal information relating to: (i) individuals who are registered users of or subscribers to our Services (as defined below) (“Users”); and (ii) individuals who are not Users but who visit our platforms (e.g., websites, apps, etc.) (collectively “Non-Users”). Please note that when you use our Services, you may also be accepting the terms of service and privacy policies of our third-party delivery service providers. By accepting our terms and using our Services, you acknowledge that you are also accepting the applicable terms of service and privacy policies of our third-party service providers, which will be provided to you at the time of service. Links to such third-party terms and privacy policies are available within our Services. 

  

Notice to Certain California Individuals: Please note that the disclosures regarding the collection, processing/use and disclosure of personal information of, from or about certain users are only covered by the California Privacy Rights Act of 2020, as amended (“CPRA”). The disclosures regarding the collection, processing/use and disclosure of personal information of, from, or about Users and Non-Users, are set forth in both this Policy and the California Privacy Notice. If you are an individual referenced in this section, please read our California Privacy Notice and note that certain sections of the California Privacy Notice reference back to this General Privacy Policy (such as detailed information on how to exercise privacy rights).  

  

When we are processing personal information in the role or capacity of a processor, Camo Eats’ processing is subject to the instructions received by Camo Eats from the appropriate Controller, in which case this Policy will not apply. The term “Controller” means the natural or legal person that, alone or jointly with others, determines the purposes and means of processing personal information.  

  

This Policy applies to all Camo Eats platforms (e.g., websites, apps, etc.) that contain a link to this Policy, including, without limitation www.camoeats.com and any subdomain of www.camoeats.com. The term “Services” means Camo Eats’ services offered on or through such platforms from time to time, all of which are subject to change in the sole discretion of Camo Eats. 

  

If you are a User, your access to and use of our Services are subject to our Terms and Conditions, which define some of the terms used throughout this Policy. Please make sure that you have carefully read and understand the Terms and Conditions before you use our Services. By using our Services, you accept the Terms and Conditions, and acknowledge and agree that you have read and fully understand and agree to our privacy practices as described in this Policy. If you do not feel comfortable with any part of this Policy or our Terms and Conditions, you must not use or access our Services. 

  

2.Processing of Personal Information Covered Under this Policy. 

  

A. USERS. 

  

i. Collection of Personal Information 

  

When you use our Services, we may collect personal information about you. The types of categories or personal information that we may collect about you include: 

  

a. Information You Provide to Us Directly 

  

You may provide your personal information to us when you use our Services, including when you register with Camo Eats, search within or place orders through our Services, contact us with inquiries, engage with our chatbot or other similar technology on the platforms or Services, respond to surveys, or otherwise access or use our Services. This information may include: 

• Personal Identifiers and records information – We may collect and process information such as name, alias, email address, postal or delivery address, account name, phone number, signature, date of birth, or other similar identifiers.   

• Transactional/Commercial Information – When you place an order through our Services, we collect information related to that order. This may include information such as items purchased, special instructions, date and time of order, subtotal, , or other purchasing or consuming histories or tendencies.   

• Financial Account or Payment Information – Payment information collected such as bank name, payment method, or other financial information. We use third-party payment processors (such as Stripe, Square) that collect your payment information and process payments made on or through the Services. The payment processor, not Camo Eats, stores your complete payment card information. We obtain limited information about your payment card from our payment processor, such as the last four digits of your card and the expiration date. 

• Identification Documentation – We may collect identification documentation (e.g., drivers’ license, Federal or state identification card, passport, etc.) in certain limited scenarios (e.g., to verify identity and age when delivering an age-restricted product, good, and/or other item). 

• Access Credential Information – In connection with your User account, we will process username, password, unique User identification number, etc. Please note that in certain instances, you may complete a transaction through a "Guest Checkout" or "App-less Transaction" using a digital wallet (such as Apple Pay or Google Pay) without creating a User account. In those instances, we do not collect or store account credentials such as a username or password. However, we may still collect and process certain transactional and device-level information necessary to fulfill your order and comply with applicable legal obligations, including payment confirmation data received from the applicable digital wallet provider, order details, and delivery information. Such information is retained in accordance with Section 5 (Data Retention) of this Policy. 

• Sensitive Data or Sensitive Personal Information – as these terms are defined under applicable data protection and privacy laws, including precise geolocation (see below for further information); a social security, driver’s license, state identification card, or passport number; racial or ethnic origin; religious beliefs; mental or physical health diagnosis; sex life or sexual orientation; or citizenship; etc. We do not use or disclose your sensitive data or sensitive personal information for purposes other than to perform the services reasonably expected by an average consumer, for security and legal reasons, with your consent, and/or for other purposes permitted by applicable law.  

b. Information Received From You as Part of Your Communications 

  

When you use our Services, complete electronic forms, or contact us, by online chat, email, phone or text, we may automatically collect and store certain information about you and the activity you engaged in, for example: your name and contact information; your order details; information that you voluntarily provide to us; the nature and content of your communication; the purpose of the interaction; and the action we took in response to your inquiry or request. 

  

c. Information Collected Automatically 

  

We also may collect and store certain information about you and your device(s) automatically when you access or use our platforms and Services, including, without limitation, on our websites and engaging with our online chat functionality. This collection may include the use of, among other technology, cookies and similar technologies as described in Section 3 (Cookies and Similar Technologies) of this Policy. This information may include: 

• Technical Information – We collect technical information associated with your activity on our platforms and/or Services and may include information related to your browser and operating system, IP address (the Internet address of your computer), unique device identifiers, personal and online identifiers, and other information such as your device type and version of the app that is in use. 

• Usage Information – This may include the webpage that you were visiting before accessing our platforms and Services, the pages or features of our platforms and Services that you browsed to inform us which part of our platform and Services you visit and how much time you spend there.  

• Platform Preferences – We collect information about your preferences to make your use of the platforms and Services more productive. 

d. Location Information 

  

When you use the Services, we may collect and store general location information (such as IP address). We may also collect route information and delivery pick-up or drop-off information. If you permit the Services to access location services through the permission system used by your mobile operating system or browser, we may also collect and store the precise location of your device when our apps are running in the foreground or background of your device. In addition, location data may also be collected when a user interacts with property-specific QR codes, NFC hardware, or location-encoded smart URLs (for example, when scanning an in-room or on-property QR code to access the Services), as these mechanisms may encode or transmit location or property-specific information that allows us to determine or approximate your location at the time of access. This information may be used to help you select your delivery address, to provide more accurate deliveries of your orders, to provide recommendations on Merchants to you based upon your location, and to enhance your user experience and improve the services. You can choose whether to enable the location tracking feature through the settings on your device or when prompted by our mobile apps. If you choose to disable the location feature this may impact some of your use of our Services. 

  

e. Information Collected from Payment Providers 

  

We may collect or receive limited personal information from payment providers (such as Stripe, Square) and third-party service providers (including delivery service providers) in connection with our processing of transactions or orders in connection with our Services. 

  

ii. Use of Your Personal Information 

  

We may use the information we collect about you for various purposes as described below. 

  

a. To Provide You with the Services 

  

We use your information to provide you the Services. For example, we use credit card information to complete a transaction. In performing or providing the Services, we may disclose your information to another party or person to facilitate the performance or delivery of the Services, including to our merchant partners, third-party payment processors (such as Stripe, Square), third-party delivery service providers (such as Uber and other similar services), and other service providers. In such an event, we enter into contractual agreements with such parties or persons to protect your information. In certain instances, however, Camo Eats may directly operate the kitchen and/or manage the delivery of your order without engaging a third-party merchant partner or delivery service provider. In those instances, your personal information necessary to fulfill your order will be processed directly by Camo Eats in its capacity as a direct service provider, and will not be shared with a third-party merchant or delivery provider for that purpose. 

  

b. To Maintain and Improve the Platforms and Services 

  

We use your information for our everyday business operations such as auditing, administration of the Services and business activities, fulfillment, analytics, debugging to identify and repair errors that impair existing intended functionality, conducting internal research for technological development and demonstration, and undertaking activities to verify or maintain the quality or safety of our Platforms and Services. Your information may also be used to improve the content and/or functionality of the Services. We may use your information to help us enhance offerings for Camo Eats and our Merchants. We may process your information, either on an individual level or aggregated with information from or about Users, to analyze trends in the use of our Services and to improve and enhance our Services. We may also use aggregate information about Users and their activities in connection with our Services to provide suggestions or recommendations to Merchants relating to the Merchants’ use of our Services.  

  

c. To Communicate with You 

  

We use your information to communicate with you. For example, we may send you text messages or other notifications about the status of your orders and deliveries. We may also contact you with promotional offerings or other communications that may be of interest to you.  In the event you contact us, we use certain information to respond to your questions and assist you with any issues that may arise in your use of the Services. We monitor these messages for fraud prevention, to ensure appropriate charging of fees, to enforce our Terms and Conditions, and for quality and training purposes. As part of this process, Camo Eats and its service provider will receive in real time and store data about your direct messages, such as chat or text messages, including the date and time of the text message, your phone number, and the message.  

  

d. For Account and Network Security Purposes 

  

We care about keeping you secure and safe while using our Services. Keeping you safe requires us to process your personal information, such as your device information, activity information and other relevant information. We use such information to combat spam, malware, malicious activity or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information. 

  

e. To Maintain Legal and Regulatory Compliance 

  

Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to pay our taxes, to fulfill our business obligations or as necessary to manage risk as required under applicable law. 

  

f. To Enforce Compliance with Our Agreements and Policies 

  

When you access or use our Services, you are bound to our Terms and Conditions (if you are a User), and this Policy. To ensure you comply with them, we process your personal information by actively monitoring, investigating, preventing and mitigating any alleged or actual prohibited, illicit or illegal activities on our Services. We also process your personal information to investigate, prevent or mitigate violations of our internal terms, agreements or policies; enforce our agreements with third parties and business partners. 

  

g. To Protect You, Others, and Our Business 

  

We use your information to protect you, others, and our business, including, without limitation, using information for fraud prevention, for enforcement of our Terms and Conditions, to comply with the law, and to protect against security risks. 

  

We also use your information to personalize your experience. For example, we may personalize the content and features you see when visiting our Services. In addition, we may personalize advertisements, marketing communications, and recommendations to make them more tailored to your interests. 

 

We may also use aggregate information about Users and their activities in connection with our Services to provide suggestions or recommendations to Merchants relating to the Merchants marketing activities and the Merchant’s use of our Services. 

  

i. For Our Business Purposes 

  

We may use your information for any other purpose disclosed to you at the time we collect the information, or otherwise with your consent. 

  

iii. Disclosing Personal Information 

  

We may provide your personal information, as described in Section 2.A.i of this Policy, to third parties as described below, including to merchant partners, third-party delivery service providers, and other service providers necessary to fulfill your orders and provide the Services. 

   

a. To Third Parties when Required or Permitted by Law 

  

We may be required to provide your personal information to third parties including law enforcement agencies when required to protect and defend our legal rights, protect the safety and security of users of our Services, prevent fraud, comply with the law, respond to legal process, or a request for cooperation by a government entity. 

  

b. With Your Consent or at Your Direction or Instruction 

  

We also may provide your information to third parties with your consent or at your direction. This includes sharing your delivery information, order details, and contact information with third-party delivery service providers to fulfill your orders. 

  

B. NON-USERS.  

  

In connection with our Services, we may process information about Non-Users, which can occur when a User is using the platform but not making an order and becoming a User. This information is limited to how they use the platform. We do not sell or share (as these terms are defined under applicable data protection and privacy laws) the personal information of Non-Users.  

  

3. Cookies and Similar Technologies. 

  

We use cookies, web beacons, pixels, session replay/screen capture, and similar technologies to collect information and personalize your experience with our Services. When we use session replay technology, we may collect on a real-time basis information on how you use and navigate the Services. This may include mouse movements and how you scroll through the Services, but we do not collect keystroke data. Additional information on other technologies we may use is set forth below. 

  

For information on your opt-out rights under applicable data protection and privacy laws, please see Section 87 (Your Rights and Choices) of this Policy. Please note that even if you opt-out, you may still receive advertisements from us. However, in that case, the advertising will not be tailored to your interests. Please further note that the opt-out mechanisms will not impact or affect Camo Eats’ non-interest based advertising on our platforms or Services.  

  

A. Cookies 

  

Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information. 

  

How We Use Cookies – We use first-party and third-party cookies for the following purposes: 

• to make our Services function properly; 

• to improve our Services; 

• to recognize you when you return to our platforms and to remember information you have already provided, such as items already in your order cart; 

• to collect information about your activities over time and across third party websites or other online services in order to deliver content and advertising tailored to your interests; and 

• to provide a secure browsing experience during your use of our Services. 

How to Manage Cookies – You may disable the use of cookies by modifying your browser settings. If you choose to disable cookies you may not be able to fully experience the interactive features of our Services. For more information on cookies and how to disable cookies visit www.ftc.gov/ftc/cookies.shtm or https://www.usa.gov/optout_instructions.shtml. 

  

B. Web Beacons 

  

Web beacons, also known as web bugs, pixel tags or clear GIFs, are tiny graphics with a unique identifier that may be included on our platforms to deliver or communicate with cookies, in order to track and measure the performance of our platforms and Services, monitor how many web visitors we have, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the user’s hard drive, web beacons are typically embedded invisibly on webpages (or in an email). 

   

4. Security. 

  

Camo Eats has implemented administrative, organizational, technical, and physical security controls that are designed to safeguard personal information. However, no online activity is ever fully secure or error-free. While we strive to protect your information, we cannot guarantee that your personal information is absolutely secure. Please keep this in mind when disclosing any information to Camo Eats. 

  

Please recognize that protecting your personal information is also your responsibility. We urge you to take every precaution to protect your information when you are on the Internet, or when you communicate with us and with others through the Internet. Change your passwords as appropriate, use a combination of letters and numbers, and make sure you use a secure browser. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account might have been compromised), or if you suspect someone else is using your account, please let us know immediately by contacting us as indicated in Section 12 (Contact Us) of this Policy. 

  

5. Data Retention. 

  

Our retention of your personal information is based upon several factors, including without limitation, the following: 

• The length of time necessary to fulfill the purpose(s) for which we collected the personal information; 

• When your relationship with us ceases or terminates or when the company or business that you are affiliated, associated, or connected with, ceases to maintain a business relationship with us;  

• The length of time it is reasonable to keep records to demonstrate that we have fulfilled our business and legal duties and obligations and contractual commitments (as applicable); 

• Any limitation periods within which claims can be made; 

• Any retention periods prescribed by law or recommended by regulators, professional bodies, or associations; and 

• The existence of any relevant legal proceedings.   

6. Children’s Information. 

  

A. Our Services are not intended for children under 16 years of age, and we do not knowingly collect personal information from children under the age of 16. If you are a parent or guardian of a child under the age of 16 and believe he or she has disclosed personal information to us, please contact us at privacy@CamoEats.com. A parent or guardian of a child under age 16 may review and request deletion of the child’s personal information. Parents or guardians should closely monitor their User accounts to ensure that the accounts are properly used.  

  

B. In connection with our business-to-business relationships, we do not knowingly process any personal information of or about a child.  

  

C. If we become aware that personal information we collected is associated with a minor under 16 years of age, we will delete that personal information.  

  

7. Your Rights and Choices. 

  

A. Your Rights. 

You may have rights under certain data protection and privacy laws pertaining to our processing of your personal information. These rights are not absolute, meaning that, as permitted under applicable data protection and privacy laws, we may not be obligated to comply with your request and we can limit the frequency of your requests. For all requests, we will need to verify the identity of the data subject and, if applicable, the identity and authority of the person submitting the request on behalf of the data subject. If we are unable to confirm or validate the identity of the data subject and, if applicable, the identity and authority of the requestor if different than the data subject, then we may reject or deny the request. Subject to applicable data protection and privacy laws, you can exercise your rights free of charge.  

 

Subject to applicable data protection and privacy laws, the following rights may be available: 

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