INTRODUCTION

Last modified: April 10, 2024

Chubby Cattle International, LLC., (“Chubby Group”) is committed to protecting your privacy. This Privacy Policy describes how we collect, use, protect, and disclose Personal Data (defined below) that we may collect from or about you or that you may provide when you visit our website at https://chubbygroup.com, applications, platforms, and any other services provided by Chubby Media, LLC or Chubby Group (collectively, the “Services”).

Chubby Group may update this Privacy Policy at any time by posting the amended Privacy Policy to the Services and/or by sending a notice to the email address you have provided. Your continued use of the Services shall constitute your consent to such changes, and you will be subject to the then-current Privacy Policy.

Please read this Privacy Policy carefully.

WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?

Chubby Group may collaborate with other companies to make Chubby Group’s content and/or services available via their websites (“Host Sites”) or vice versa. Personal and/or demographic information you provided to Host Sites may be included in Chubby Group’s database, and we will handle such information received or gathered via Host Sites subject to this Privacy Policy. Information gathered via Host Sites or a website co-sponsored by Chubby Group will remain the sole property of Chubby Group.

You may contact us with questions, comments, and requests regarding this Privacy Policy at hi@chubbygroup.com.

WHAT TYPES OF PERSONAL DATA DO WE PROCESS?

In this Privacy Policy, we use the term “Personal Data” to refer to information that can be used to identify you.

When you interact with our Services, we may collect certain Personal Data directly from you or automatically from the devices you use to access our Services. Chubby Group receives and may store any information you enter in on the Services or provide us in any other way. This may include personal information by which users are identified (user name, email address, first and last name, street address, telephone number, and credit card number).

If you have voluntarily provided information, you consent to the collection and use of your Personal Data as described in this Privacy Policy. We do not sell or rent Personal Data collected through the Services to anyone, although we may provide aggregate statistics about visitors to the Services such as volume, traffic patterns, and related site information to reputable third parties. These statistics will not include any Personal Data.

Chubby Group also may receive and store information on our server logs about your browser and/or computer, including, but not limited to, IP address, pages viewed and requested, referring website and web browser software (e.g. Internet Explorer, Mozilla, etc.).

When you use the Services, Chubby Group may collect information from you automatically through “cookies” or similar technology. Web cookies are small-unique identifier text files that allow a web server to recognize that you are a user that accessed the server on previous occasions. For more information on cookies and other trackers, please see our Cookie Policy below.

FOR WHICH PURPOSES DO WE PROCESS YOUR PERSONAL DATA?

Personal Data may be used for general purposes including, but not limited to, sending you Chubby Group’s newsletters and text messages, notifying you of updates and other concepts, products or services that may be of interest to you, requesting your voluntary opinion/feedback, communicating with you in general, and/or other services.

Chubby Group processes Personal Data based on legal reasons to comply with data protection laws and improve user experiences. When providing services or managing relationships with users, including personalizing experiences and communications, the basis lies in fulfilling contractual obligations or the company’s legitimate interests. These interests also support internal business analyses aimed at service improvement, and efforts to protect the company’s rights, ensure safety, and comply with legal requirements.

Marketing activities and user engagement efforts, such as sending information about new concepts, products, events or promotions, are conducted based on Chubby Group’s legitimate interests or user consent when needed. Organizing contests or promotions might require entering a contract or obtaining user consent.

For questions or additional information regarding the purposes and legal bases for processing Personal Data, please contact us at hi@chubbygroup.com.

HOW DO WE DISCLOSE YOUR PERSONAL DATA?

Chubby Group does not sell, rent or share the information with other people or nonaffiliated companies except when we have your permission or under the following instances:

(1) To send marketing and other communications to our visitors about Chubby Group restaurants, concepts, products or services;

(2) To third party vendors that provide business services to Chubby Group, including customer service, marketing, etc.;

(3) In response to court order, subpoena, other legal process, or as otherwise required by law;

(4) To exercise or establish our legal rights and/or defend against claims;

(5) When Chubby Group believes it to be reasonably necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of Chubby Group’s Terms of Service or as otherwise required by law;

(6) In connection with a corporate transaction (e.g. consolidation, merger, sale of assets, etc.); or

(7) Providing anonymous or aggregate information (i.e. non-personal and non-billing information) to third parties (e.g. investors, advertisers, business partners and clients) to the extent necessary to allow them to understand the kinds and number of visitors to the Services and how those visitors use the Services.

Chubby Group may also disclose information in special cases when we have a good faith belief that such action is necessary to: (a) conform to legal requirements or comply with legal process; (b) protect and enforce our rights or property; (c) enforce the website Terms & Conditions or this Privacy Policy; (d) act to protect the interests of our users or others; (e) resolve disputes, or (f) troubleshoot website problems.

COOKIES

We collect technical information from and about your device using cookies and other data collection technologies. Please see our Cookie Policy available at https://chubbygroup.com/cookie-policy for further information.

One of the data collection technologies we use is Google Analytics. Google Analytics helps us understand how visitors use our website. You can learn more about how Google uses data collected through Google Analytics at www.google.com/policies/privacy/partners.

YOUR CHOICES

Marketing Communications. You can opt out of our promotional emails by clicking the “unsubscribe” link in the email received or by sending us an email stating your request to hi@chubbygroup.com. Please note that you may continue to receive administrative, legal, and other important emails from us even if you opt out of receiving promotional messages.

Cookies. You can disable cookies using your web browser’s settings. Disabling cookies will generally not interfere with your use of the Services. However, refusal of a cookie may, in some cases, preclude you from using or negatively impact the display or function of the Services or certain areas or features of the Services.

You have the right to access, correct, or request deletion of the Personal Data that we collect, subject to certain exceptions. To protect the privacy and the security of your personal information, we may request information from you to enable us to verify your identity and your right to access such data, as well as to search for and provide you with the personal information we maintain. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes. Please note that there may be instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal information that we maintain. Below are the rights that every user is entitled to:

The Right to Access – You have the right to request copies of your personal data held by Winger Trading. We may charge you a small fee for this service.

The Right to Rectification – You have the right to request that Winger Trading correct any information you believe is inaccurate. You also have the right to request Winger Trading to complete any information you believe is incomplete.

The Right to Erasure – You have the right to request that Winger Trading erase your personal data, under certain conditions.

The Right to Restrict Processing – You have the right to request that Winger Trading restrict the processing of your personal data, under certain conditions.

The Right to Object to Processing – You have the right to object to Winger Trading’s processing of your personal data, under certain conditions.

The Right to Data Portability – You have the right to request that Winger Trading transfer the data that we have collected to another organization, or directly to you, under certain conditions.

To exercise any of the rights set forth above, please contact us by email at hi@chubbygroup.com.

HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

We will retain your Personal Data for as long as necessary for the purposes disclosed in this Privacy Policy, unless required by our legal obligations to retain it for longer. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we process data, whether we can achieve those purposes through other means, and applicable legal, regulatory, and compliance requirements.

WHAT SECURITY MEASURES HAVE WE IMPLEMENTED?

We use measures and controls designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, no security measures can be completely secure, and we cannot guarantee the security of your Personal Data.

THIRD-PARTY WEBSITES

Our Services may contain links or references to third party websites outside of our control. Please be aware that this Privacy Policy does not apply to those websites and we are not responsible for the privacy practices of those third parties. We encourage you to read the privacy policies of those third parties.

CHILDREN’S DATA

The Services are intended for use by persons aged 13 or older, and by your use of these Services you affirm that you are at least 13 years of age. In addition, if you are under the age of 18, you are only permitted to use the Services with the consent of your parents or an adult guardian. Chubby Group does not knowingly allow registration of an account for any person that Chubby Group believes to be younger than 13. We also do not collect any Personal Data from any persons under the age of 13 and if we discover that we have been provided any such information, we will delete this information from our records. If you believe we might have any information from or about a child under the age of 13, please contact us at hi@chubbygroup.com.

DO NOT TRACK SIGNALS

Web browsers and other technologies you may use to access the Services may include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Currently, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As a result, we do not currently respond to DNT browser signals.

HOW DO WE HANDLE INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA?

The Personal Data that we collect about you will be stored in the United States and shared with third parties located in the United States. If you are located in the European Economic Area (“EEA”), Switzerland, or United Kingdom and we transfer your Personal Data to third parties in other countries that do not provide adequate legal protection as defined by applicable data protection laws, we will ensure that appropriate safeguards are implemented to secure such data transfers in compliance with applicable data protection laws. Such safeguards may include the EEA or United Kingdom Standard Contractual Clauses. For more information about the safeguards adopted by the Company, contact us at hi@chubbygroup.com.

ADDITIONAL INFORMATION FOR USERS IN THE EEA, SWITZERLAND, AND UNITED KINGDOM

If you are located in the EEA, Switzerland, or the United Kingdom, you have the following rights:

· Right to access. You have the right to obtain confirmation from us as to whether or not we process your Personal Data.

· Right to data portability. You may receive your Personal Data that you have provided to us in a structured, commonly used, and machine-readable format in certain cases.

· Right to rectification. You have the right to request the rectification of inaccurate, incomplete, or outdated Personal Data concerning you.

· Right to erasure. You have the right to request that we erase your Personal Data in certain cases.

· Right to restrict processing. You have the right to request that we restrict processing of your Personal Data in certain cases.

· Right to objection. You have the right to object to the processing of your Personal Data in certain cases.

· Right to withdraw consent. Where our processing of your Personal Data is based on consent, you have the right to withdraw such consent at any time. The lawfulness of processing based on your consent before its withdrawal will not be affected.

· Right to lodge a complaint. You have the right to lodge a complaint with a supervisory authority concerning our processing of your Personal Data.

· Right to not be subject to automated decision-making. You have the right to not to be subject to a significant decision based solely on automated processing and to be given more information about why any such decision was made.

The rights described in this section can be exercised at any time by contacting us at hi@chubbygroup.com.

ADDITIONAL INFORMATION FOR CANADIAN USERS

If you are in Canada, the disclosures set out below apply to you in addition to the general sections of this Privacy Policy.

Your Rights. You may request access to or correction of Personal Data about you in our control by contacting us at hi@chubbygroup.com. These rights are subject to certain exceptions, and we may take steps to verify your identity before responding to your request.

We and other parties with whom Personal Data about you may be shared as described in this Privacy Policy may process Personal Data about you outside of Canada, including in the United States and in other countries. While outside of Canada, Personal Data about you will be subject to applicable local laws, which may not afford the same level of protection to Personal Data about you as the laws of Canada.

CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you may request certain information regarding our disclosure of certain categories of Personal Data to third parties for those third parties’ direct marketing purposes. To make such a request, please contact us at hi@chubbygroup.com. This request may be made no more than once per calendar year, and we reserve our right not to respond to requests submitted other than to the designated email address.

ADDITIONAL INFORMATION FOR RESIDENTS OF NEVADA

We do not sell your Personal Data. If that were to change in the future, we will update this Privacy Policy.

PRIVACY POLICY UPDATES

We reserve the right to change this Privacy Policy at any time. If we make material changes to how we treat your Personal Data, we will notify you by posting the updated version to this page. The date this notice was last revised is identified at the top of the page.

CONTACT US

If you have questions about this Privacy Policy or would like to contact us about it, you may do so by contacting us at:

Email: hi@chubbygroup.com