PRIVACY POLICY
VERSION 1.2
LAST REVISED ON: November 13, 2025

COMPANY:
GA Franchising, LLC and its affiliated entities (“Company”, “we”, “us”, or “our”)

ADDRESS:
Attention: Michael Hill
1926 Miller Dr.
Olney, IL 62450
Telephone: (618) 204-8994
Email: office@gingeralesfranchise.com

WEBSITE:
www.mygingerales.com (including any related domains or subdomains)

MOBILE APPLICATIONS:
The “Ginger Ale’s” mobile and online applications

1. AGREEMENT
This Privacy Policy (“Policy”) explains how we collect, use, disclose, and protect personal information when you use our website, mobile applications, loyalty programs, or any other products or services offered by the Company (collectively, the “Services”).
By accessing or using the Services, you agree to the terms of this Policy.

2. INFORMATION WE COLLECT
We may collect the following categories of information, consistent with federal and state laws applicable where you reside:
2.1 Personal Information:
Name, email, phone number, address, date of birth, identification documents, loyalty program information, and similar data.
2.2 Device Information:
IP address, operating system, device identifiers, location data, and device interaction data.
2.3 Payment Information:
Card numbers, bank data, transaction history, billing information, and receipts.
2.4 Purchase Information:
Orders placed, frequency of visits, loyalty activity, preferences, and related behavioral data.
2.5 Usage Information:
Pages visited, links clicked, search history, timestamps, and application usage patterns.
2.6 Aggregated & De-Identified Data:
Information that does not identify an individual user.

3. HOW WE COLLECT INFORMATION
3.1 Directly From You:
When you provide information during account creation, ordering, signing up for loyalty programs, or contacting us.
3.2 Automatically:
Using cookies, web beacons, analytics tools, and similar technologies.
3.3 From Third Parties:
Service providers, analytics partners, payment processors, and publicly available sources.
3.4 From Vendors:
Including POS systems, loyalty program partners, and marketing platforms.

4. HOW WE USE INFORMATION
We may use information for business and legal purposes, including:
4.1 To provide and operate the Services
4.2 To deliver marketing, promotions, and loyalty program benefits
4.3 To process payments and fulfill orders
4.4 To improve and personalize user experience
4.5 For security, fraud prevention, and compliance
4.6 For analytics, reporting, and business operations
4.7 To enforce agreements and resolve disputes

5. HOW WE SHARE INFORMATION
We may share information as permitted by law:
5.1 With your consent
5.2 With service providers (payment processors, analytics services, marketing partners, POS systems, cloud storage vendors)
5.3 For marketing and advertising delivery
5.4 For legal, security, or regulatory reasons
5.5 In connection with business transfers such as mergers or acquisitions
We do not sell personal information for monetary consideration. However, certain states may classify sharing for advertising as a “sale” or “targeted advertising,” and your rights are addressed in Section 8 below.

6. SMS COMMUNICATION & PRIVACY POLICY (TCPA COMPLIANT)
6.1 Consent to Receive SMS Communications
By providing your phone number and opting in—whether at a restaurant POS, through our mobile app, or online—you consent to receiving SMS and/or MMS messages from the Company. These may include:
• Loyalty program updates
• Account notices
• Promotions and exclusive offers
• Transactional confirmations
• Other information relevant to your membership
Your consent is not required as a condition of purchasing goods or services.
6.2 Data Usage and Privacy
We do not sell, rent, or share your phone number with third parties for their independent marketing.
Your number is used solely for communications described above.
6.3 Opt-Out Instructions (TCPA-Compliant)
You may opt out at any time by replying “STOP” to any message.
After opting out:
• You will receive a confirmation message.
• You will no longer receive SMS communications unless you opt back in.
Standard message and data rates may apply. Message frequency varies.
6.4 Support
If you have issues or privacy concerns related to SMS communications, email us at:
privacy@mygingerales.com (or specify preferred email)

7. DATA SECURITY
We use commercially reasonable security measures, including administrative, technical, and physical safeguards, to protect personal information.
No system is completely secure, and we cannot guarantee absolute protection.
In the event of a security breach, we will comply with all applicable notification laws, including those specific to Illinois and Indiana.

8. STATE-SPECIFIC PRIVACY NOTICE
This section includes additional rights and disclosures applicable to residents of certain U.S. states. Because our operations are based in Illinois and Indiana and available nationally, this Policy incorporates the broadest applicable state privacy standards.
8.1 Illinois Privacy Rights
Illinois residents are protected under:
• Illinois Personal Information Protection Act (PIPA)
• Illinois Biometric Information Privacy Act (BIPA) – We do not knowingly collect biometric identifiers under BIPA.
If you believe your data has been compromised, you may contact the Illinois Attorney General.
8.2 Indiana Consumer Data Protection Law (Effective 2026)
Indiana residents may request:
• Access to personal information
• Correction of inaccurate information
• Deletion of personal information
• A copy of data in portable format
• The ability to opt out of targeted advertising or certain sharing
Requests can be submitted using the contact information in Section 11.
8.3 California (CCPA/CPRA)
For California residents, you may have rights to:
• Know categories of information collected
• Access specific pieces of personal information
• Request deletion
• Request correction
• Opt out of “sale” or “sharing”
• Limit use of sensitive personal information
We honor all California privacy rights to the extent required by law.
8.4 Other State Laws
We also comply with emerging privacy laws in:
• Colorado Privacy Act
• Virginia Consumer Data Protection Act
• Connecticut Data Privacy Act
• Utah Consumer Privacy Act
Residents of these states may have similar rights to access, delete, or opt out of specific data uses.
8.5 How to Exercise Privacy Rights
Submit requests by emailing:
privacy@mygingerales.com
or writing to the Company address above.
We may require verification to protect your information.

9. CHILDREN’S PRIVACY
Our Services are not directed to children under 13, and we do not knowingly collect information from children under 13. If we learn that a child’s data has been collected, we will delete it promptly.

10. CHANGES TO THIS POLICY
We may update this Policy periodically. If material changes are made, notice may be provided by:
• Email (if available)
• Notification within the App
• Posting on the Website
Continued use of the Services constitutes acceptance of the updated Policy.

11. CONTACT INFORMATION
For questions, privacy requests, or concerns:
Email: office@gingeralesfranchise.com
Alternate Privacy Email: privacy@mygingerales.com
Mail: GA Franchising, LLC
Attention: Privacy
1926 Miller Dr.
Olney, IL 62450