HUSE CULINARY, INC. PRIVACY POLICY 

Last Updated: June 3, 2026 

Huse Culinary, Inc., including its affiliated brands and companies (collectively, “Huse Culinary,” “us,” “we,” “our,” or “Company”), respects your privacy and is committed to protecting it through compliance with this policy. This policy describes how we collect, process, retain, and disclose Information about you when providing services to you through our websites, our Huse Honors desktop or mobile applications, and the products and services that link to this policy (collectively, the “Services”), and our practices for using, maintaining, protecting, and disclosing that information. Our brand websites presently include www.huseculinary.com, www.stelmos.com, www.harryandizzys.com, www.1933lounge.com, www.atthehc.com, www.raresaint.com, www.barkeepvodka.com, store.stelmos.com, and shopstelmococktails.com. This policy will also apply to any new, modified, or acquired websites, applications, products, or services owned by or affiliated with Huse Culinary, Inc. 

This policy applies only to information we collect through the Services or in communications, including email, text, chat, and other electronic messages between you and the Services. It does not apply to information collected by us through any other means, including any other website operated by the Company or any third party that does not link to this policy, or through any application or content (including advertising) that may link to or be accessible from or through the Services. This policy does not apply to information collected by or provided in connection with an individual’s application for employment, current or former employment, or independent-contractor arrangement with Huse Culinary. 

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your information, you agree and consent to the collection, use, and sharing of your information as described in this privacy policy. We may, in our sole discretion, make changes to this policy from time to time. Any such changes are effective upon publication, and the “Last Updated” date will be revised accordingly. Your continued use of the Services after we make changes is deemed acceptance of those changes, so please check the policy periodically for updates. 

WHAT INFORMATION DO WE COLLECT? 

“Information” (also referred to as “Personal Information” or “Personal Data”) is information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, email address, telephone number, home address, or payment information. The types and categories of Information we may collect or process include: 

• Account and contact information, including name, username, date of birth, mailing address, email address, phone number, and other contact information you provide us. 

• Payment information, including credit or debit card information and information about the payment methods and services you use in connection with the Services. 

• Account history, including information about your account, Huse Honors loyalty activity, transactions, purchases, order history, rewards, redemptions, or discounts. 

• Commercial information, including products or services purchased, obtained, or considered, and your preferences. 

• Location information, including general geographic location and precise geolocation (including “background” location collected through our Huse Honors mobile app), if you have enabled and consented to location-information collection. 

• Device information, including your IP address, device identifiers, operating system and version, preferred language, browser type and settings, and other device information. 

• Communications and content, including messages, opinions, feedback, survey responses, and other content you elect to provide. 

Some of the information identified above, including precise geolocation information and payment-card information together with a required security or access code, may be considered “Sensitive Information” under certain laws. If required under applicable law, we will collect and process Sensitive Information only with your opt-in consent, and you may withdraw your consent at any time. We do not use or disclose Sensitive Information except as described in “Sale and Sharing of Your Information.” If you choose not to provide or allow us to collect some information, we may not be able to provide you with requested features, services, or information. 

We may also collect: 

• Statistical or aggregated information, which does not directly identify a specific person but which we may derive from Information (for example, the percentage of users accessing a specific feature). 

• Technical information, including details about your internet connection and your interactions with the Services, such as clickstream data (including date and time), pages or products you view, page response times, download errors, length of visits, page-interaction information, and methods used to browse away from a page. 

If we combine or connect non-personal statistical or technical data with Information so that it directly or indirectly identifies an individual, we treat the combined information as Information. 

HOW WE COLLECT YOUR DATA 

You Provide Information to Us 

We collect information about you when you interact with our Services — for example, when you create or update an account, place an order, subscribe, make a reservation, make a request, join our Huse Honors loyalty program, participate in surveys, sweepstakes, contests, or promotions, or create, upload, or post content to the Services. 

Automatically Through Our Services 

As you navigate through and interact with our Services, we may use automatic data-collection technologies to collect information that may include Information. Information collected automatically may include usage details, IP addresses, operating systems and browser type, and information collected through cookies, web beacons, and other tracking technologies, including details of your interactions with our Services such as traffic data, location data, and logs, and which resources and features you access and use. Using these technologies helps us improve our Services and deliver a more personalized experience. The technologies we use may include: 

• Cookies. A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies through your browser or device settings, but parts of the Services may then be unavailable. 

• Web Beacons. Some parts of the Services and our emails may contain small electronic files known as web beacons (also called clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited a page or opened an email and to gather related statistics. Our Services use retargeting pixels from Google, Facebook, and other ad networks. 

• Analytics and Fraud Detection. We may use tools such as Google Analytics to understand traffic to our Services, and reCAPTCHA to help distinguish humans from bots and protect against fraud, spam, and abuse. 

To the extent any of these automated technologies are considered a sale of Information, sharing, targeted advertising, or profiling under applicable laws, depending on where you live, you may opt out of their use for such purposes through our “Your Privacy Choices” mechanism below or by broadcasting an opt-out preference signal such as the Global Privacy Control (GPC). When we receive your opt-out request, including one received through a GPC signal, we will display confirmation that your request has been processed. Please note that some features may be unavailable as a result. 

When you interact with the Services, third parties may use automatic collection technologies to collect information about you or your device. These third parties may include: 

• Advertisers, ad networks, and ad servers; 

• Analytics companies; 

• Your device manufacturer; and 

• Your internet or mobile service provider. 

These third parties may use tracking technologies to collect information about you when you use the Services, which may be associated with your Information, and may use it to provide interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies. If you have questions about an advertisement or targeted content, you should contact the responsible provider directly. 

HUSE HONORS LOYALTY PROGRAM AND MOBILE APP 

Our Huse Honors Loyalty Program and mobile app let you join and participate in our loyalty program, create an account, and receive offers. The following additional terms apply to the app. In connection with the Huse Honors program, we may collect and process personal data including your name, contact information, purchase history, rewards point balance, and redemption activity. This information is used solely to administer the program and communicate program-related offers to you. 

Background and Precise Location 

The app offers a feature called Background Location. When you choose to enable it, the app may access your device’s precise location even when the app is not open. We use this to support location-based features powered by our loyalty platform, Paytronix, specifically geofence push messaging, which can send you a relevant message or offer when your device enters or leaves a defined area near our locations.  

• Opt-in. Background Location is off unless you turn it on. The app will prompt you to allow location only while using the app, allow background location, or deny location entirely. 

• Withdrawing consent. You can change or withdraw your choice at any time in your device’s operating-system location settings for the Huse Honors app and within the app’s settings menu. Turning off background location disables geofence push messaging but does not otherwise prevent you from using the app. 

• How it is used and shared. Precise location collected for this feature is used to deliver the geofence messaging you have enabled and is processed by Paytronix as our service provider. We do not sell or share precise geolocation, and we treat it as Sensitive Information. 

Account Creation and Deletion 

The app supports account creation. If you create an account, you may delete your account and associated personal data at any time: 

• In the app — open the app’s settings or profile menu and select the option to delete your account; 

• Contact us — email husehonors@huseculinary.com, call 317.637.1811, or use our online form at https://www.huseculinary.com/contact/. 

When you delete your account, we will delete or de-identify the personal data associated with it within 45 days, except where we are permitted or required to retain it (for example, to complete a transaction, comply with a legal obligation, detect security incidents, or as otherwise allowed by law).  

Availability of This Policy in the App 

This Privacy Policy is available from the app’s store/download listing and from within the app’s settings menu, so you can review it before and after installing the app. 

THIRD-PARTY SERVICE PROVIDERS AND PROCESSORS 

We use the following third-party service providers, among others, to operate our Services. You can review their privacy practices at the links below: 

• AccelPay (online payment processing): https://www.accelpay.io/company/privacy-policy 

• OpenTable (reservations and reservation-related text messages): https://www.opentable.com/legal/privacy-policy 

• Paytronix (loyalty program and location-based messaging): https://www.paytronix.com/privacy-policy/  

• Shopify (online payment processing): https://www.shopify.com/legal/privacy 

• Stripe (in-restaurant payment processing): https://stripe.com/privacy 

• Toast (point of sale): https://pos.toasttab.com/privacy  

These providers are authorized to use your Information only as necessary to provide services to us. 

HOW WE USE YOUR INFORMATION 

We use and process your Information for purposes that may include: 

• Providing you with the Services and information you request and operating the Huse Honors loyalty program; 

• Responding to your inquiries and questions and providing customer service; 

• General or targeted marketing and advertising, including promotional material or special offers, provided you have not opted out; 

• Fulfilling obligations we have to you; 

• Maintaining, improving, customizing, and administering the Services, performing business analyses, resolving technical problems, improving security, and developing new products and services; 

• Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity; 

• Complying with applicable legal requirements, relevant industry standards, and our policies and procedures; and 

• Other purposes we describe when you provide the information, or for any other purpose with your consent. 

We may also use Information that has been de-identified and/or aggregated for purposes not listed above. 

HOW WE DISCLOSE YOUR INFORMATION 

We may disclose your Information in the following circumstances: 

• Service providers that perform functions on our behalf, such as hosting, database management, analytics, payment processing, reservations, loyalty-program operation, customer service, and communications. 

• Legal and administrative reasons, including to comply with law or legal process; to cooperate with an investigation or audit; to comply with governmental requirements; to protect the rights, property, or safety of us, our affiliates, and our users; to enforce our Terms; and to verify the identity of a user. 

• Business transfers, where we merge with or are acquired by another entity, sell all or substantially all of our assets, are adjudicated bankrupt, or are liquidated or reorganized. 

• De-identified or aggregated data, for any purpose where your specific Information is blinded, masked, or otherwise not identifiable. 

• With your consent, consistent with this Privacy Policy. 

SALE AND SHARING OF YOUR INFORMATION 

For purposes of this policy, “sell,” “sold,” or “sale” means disclosing Information for monetary or other valuable consideration, but does not include transferring Information as an asset in a merger, bankruptcy, or other disposition of all or part of our business. “Sharing” means disclosing or making Information available to a third party for cross-context behavioral or targeted advertising. 

While we do not disclose Information to third parties in exchange for monetary compensation, we disclose identifiers and internet/network-activity information to third-party advertising networks and analytics providers for marketing and advertising and to improve and measure our ad campaigns. Such disclosures may be considered “sales” or “sharing” under applicable laws. We do not sell or share Sensitive Information, and we do not sell or share Information about individuals we know are under sixteen (16) years of age. You may exercise your opt-out choices through “Your Privacy Choices” below. 

Use and Disclosure of Sensitive Information 

We do not collect, use, or disclose Sensitive Information beyond the purposes authorized by applicable law. We use and disclose it only as reasonably necessary and proportionate: (i) to perform the services you request; (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents; (iii) to detect, prevent, and respond to malicious, fraudulent, deceptive, or illegal conduct; (iv) to verify or maintain the quality and safety of our services; (v) to comply with our legal obligations; (vi) with service providers who perform services on our behalf; and (vii) for purposes other than inferring characteristics about you. 

CATEGORIES OF INFORMATION WE COLLECT, USE, AND DISCLOSE 

In the twelve (12) months prior to the Last Updated date of this policy, we may have collected, used, and disclosed the following categories of Information from the sources, for the purposes, and to the categories of third parties described below. 

We may disclose identifiers and internet/network activity to advertising and analytics partners; such disclosures may be considered a “sale” or “sharing” under certain laws. We do not sell or share sensitive Information or the personal data of individuals we know are under 16. 

NOTICE OF FINANCIAL INCENTIVE (HUSE HONORS) 

Our Huse Honors loyalty program may be considered a “financial incentive” under certain privacy laws because it offers benefits, such as points, rewards, discounts, and special offers, in connection with the collection and use of your Information. 

• Material terms. When you enroll, we collect identifiers and commercial information (such as your contact details and purchase/redemption activity) to administer the program and provide rewards. The specific benefits and how to earn and redeem them are described in the program’s terms. 

• Opt in and withdraw. Enrollment is voluntary and opt-in. You may withdraw at any time by closing your account in the app, using the methods in “Contact Information,” or unsubscribing from program communications. Withdrawing may mean you no longer earn or redeem rewards. 

• Value of your Information. Any difference in price or service offered through the program is reasonably related to the value provided to us by the relevant Information, calculated in good faith based on factors such as the expenses related to operating the program and the average annual margin contribution attributable to enrolled members versus non-members.  

AUTOMATED DECISION-MAKING AND PROFILING 

We do not use your Information for automated decision-making or profiling that produces legal or similarly significant effects concerning you (for example, decisions about credit, employment, housing, or the denial of products or services). We may use analytics and audience tools for marketing and to improve our Services, and you may opt out of the use of your Information for targeted advertising as described in “Your Privacy Choices.” If our practices change, we will update this policy and provide any rights required by law. 

INFORMATION SECURITY 

We use commercially reasonable and appropriate administrative, physical, and technical security measures to provide our Services and safeguard your Information. However, no data transmitted over the Internet or stored by us or our third-party service providers can be 100% secure. Therefore, we do not promise or guarantee, and you should not expect, that your Information or private communications will always remain private or secure. We are not responsible for the circumvention of any privacy settings or security features. If you believe your Information has been accessed or acquired by an unauthorized person, please contact us promptly at https://www.huseculinary.com/contact/ so that necessary measures can be taken. 

DATA RETENTION 

We retain your Information for as long as needed to provide the Services and for the purposes described in this policy, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. To determine the appropriate retention period for each category of Information, we consider: 

• The length of our ongoing relationship with you and provision of the Services (for example, while you maintain a Huse Honors account); 

• Whether we have a legal, tax, accounting, or regulatory obligation to retain the Information; 

• Whether retention is advisable in light of our legal position (such as limitation periods, litigation, or investigations); and 

• The sensitivity of the Information and the risks presented by its retention. 

When Information is no longer needed, we will delete or de-identify it in accordance with our routine record-keeping. We are under no obligation to store Information indefinitely. 

YOUR CHOICES 

• Marketing communications. To stop receiving marketing emails, click “unsubscribe” in any marketing email or contact us as described below. We will process unsubscribes within 10 business days. 

• Text messages. Although we do not use text messaging for marketing, you may agree to receive texts from OpenTable on our behalf regarding reservations. You can opt out anytime in your OpenTable account settings or by replying STOP. 

• Location. You can enable or disable precise/background location for the Huse Honors app at any time in your device settings and in the app’s settings menu. 

• Third-party advertising. You may opt out of certain tailored mobile advertising via the AppChoices app at aboutads.info/appchoices; opt out of certain targeted ads via the NAI opt-out tool or About Ads at optout.aboutads.info; and opt out of Google Analytics via the Google Analytics opt-out browser add-on. 

SMS 

Consent for SMS Communications: If you grant consent to receive SMS communications from us, directly or through our third-party partners, the information obtained as part of the SMS consent process will not be shared with any other third parties for marketing purposes. 

Types of SMS Communications: If you have consented to receive text messages from us, you may receive text messages related to: Shifts and approvals, information related to customer requests, and other similar issues or conversations. 

Message Frequency: Our SMS message frequency will vary depending on your inquiry regarding the services we provide to you. 

Potential Fees for SMS Messaging: Many carriers charge a fee for each message sent or received. This can vary depending on the carrier’s pricing structure and whether the message is sent domestically or internationally. 

Opt-In Method: You may opt in for SMS messaging from us through intake forms located on our website or through our mobile application. This agreement for SMS will not be shared with third parties for marketing purposes, except any third-party partner that processed the opt-in. 

Opt-out: You may opt out of SMS messaging from us by replying STOP at any time to any received SMS message. Once opted-out, you will receive no further SMS communication. You may, however, opt back in at any time by replying START to any SMS message. 

Standard Messaging Disclosures: Message and data rates may apply. Message Frequency May Vary. You can opt-out at any time by texting ‘STOP.’ For assistance, text ‘HELP.’ 

YOUR PRIVACY CHOICES 

To opt out of the sale or sharing of your Information for cross-context behavioral or targeted advertising, and to limit the use and disclosure of your sensitive Information, you may use any of the following: 

• Online form: https://www.huseculinary.com/contact/ 

• Email: contact@huseculinary.com  

• Phone: 317.637.1811 

You may also broadcast an opt-out preference signal, such as the Global Privacy Control (GPC), and we will treat it as a valid opt-out of sale/sharing for the applicable browser or device. When we receive your opt-out request, including through a GPC signal, we will display confirmation that your request has been processed. Closing a banner or otherwise not acting is not treated as consent. We do not support “Do Not Track” (DNT), which is different from GPC. 

NOTICE TO CALIFORNIA RESIDENTS (CCPA / CPRA) 

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), provides you the rights described below, subject to certain exceptions. 

Your Rights under the CCPA: 

• Right to know and access the categories and specific pieces of Information we have collected about you, the categories of sources, the business or commercial purposes for collecting, selling, or sharing it, and the categories of third parties to whom we disclose it; 

• Right to delete Information we collected from you, subject to exceptions; 

• Right to correct inaccurate Information; 

• Right to opt out of the sale or sharing of your Information; 

• Right to limit the use and disclosure of your sensitive Information; and 

• Right to non-discrimination for exercising your rights. 

Non-Discrimination: 

We will not discriminate against you for exercising your CCPA rights, except for differences reasonably related to the value provided by a financial-incentive program you have chosen to join. 

Minors: 

We do not sell or share the Information of consumers we know are under sixteen (16). Where we have actual knowledge that a consumer is under 16, we treat that Information as Sensitive Information. Certain Huse Culinary brands relate to alcohol; where required, access to those properties and offers is intended for individuals of legal drinking age (21+), independent of the 16-year privacy threshold. 

Shine the Light: 

If you are a California resident with an established business relationship with us, you may request a notice disclosing the categories of Information we shared with third parties for their direct-marketing purposes during the preceding year. To request this notice, contact us using the information in “Contact Information.” We will respond within 30 days at no cost to you. 

NOTICE TO RESIDENTS OF OTHER U.S. STATES 

The States of Arkansas, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia (collectively, the “Regulated States”) have adopted comprehensive consumer data-protection acts that generally define a “consumer” as a resident of the state acting only in an individual or household context (and not in a commercial or employment context). If you are a consumer in one of the Regulated States, you may have some or all of the following rights, subject to exceptions: 

• Right to confirm whether we are processing your Information and to access it; 

• Right to correct inaccuracies in your Information; 

• Right to delete your Information; 

• Right to obtain a copy of the Information you previously provided, in a portable format; and 

• Right to opt out of the processing of your Information for targeted advertising, the sale of Information, or profiling in furtherance of decisions that produce legal or similarly significant effects. 

In some Regulated States, processing of Sensitive Information, including precise geolocation, requires your opt-in consent, and we obtain consent before processing such data as described above. Some states also provide a right to appeal a denial of your request, as described under “How to Exercise Your Rights.” 

HOW TO EXERCISE YOUR RIGHTS 

To exercise any of the rights above, please submit a verifiable request using the methods in “Your Privacy Choices” or “Contact Information.” Your request must provide enough information for us to reasonably verify you are the person about whom we collected Information (or an authorized representative), and describe your request with enough detail for us to understand and respond to it. 

Verification: 

To protect your privacy and maintain security, we will take steps to verify your identity before granting access to, deleting, or correcting, your Information, and we may require you to provide certain information for that purpose. If you ask us to confirm specific pieces of Sensitive Information we hold (such as a financial-account or identification number), we may ask you to verify your identity and provide that information so we can confirm it, rather than disclosing it to you directly. You may use an authorized agent where permitted by law; we may deny a request if the agent does not submit proof of valid authorization. You may also make a verifiable request on behalf of your minor child. 

Our response time: 

We will respond to a verifiable request without undue delay and within forty-five (45) days of receipt. The response period may be extended once by an additional 45 days when reasonably necessary; we will inform you of any such extension within the initial 45-day period, together with the reason. 

Right to appeal: 

If we decline to act on your request, we will inform you of our decision and the reasons. To appeal, contact us using the information in “Contact Information.” Within the time required by applicable law of receipt of an appeal (usually 45 or 60 days, depending on the applicable state), we will respond in writing. Our written response will include an explanation of the reasons for our decision and any action taken or not taken in response to your appeal. If your appeal is denied, you may contact the Attorney General or other authority in your state, whom we will help you identify. 

GEOGRAPHIC LOCATION OF DATA STORAGE AND PROCESSING 

Our Services are directed to individuals located inside and outside the United States, and we maintain significant operations in the United States. The Services collect Information and process and store it in databases located in the United States. If you visit the Services from outside the United States, you should be aware that you may transfer personally identifiable Information to the United States, and that U.S. data-protection laws may not be as comprehensive as those in your own country. By visiting the Services and submitting personally identifiable Information, you consent to that transfer. 

CHILDREN’S INFORMATION 

The Services are intended only for users aged sixteen (16) and older. We do not knowingly collect personal data from children under 16, and where we have actual knowledge that a user is under 16, we treat that data as Sensitive Information and do not sell or share it. If we become aware that a user under 16 (or a higher age threshold where applicable) has provided us with Information, we will take steps to comply with applicable legal requirements to remove it. Please contact us if you believe we have mistakenly collected Information from a child under 16. 

DIFFICULTY ACCESSING OUR PRIVACY POLICY 

Individuals with disabilities who are unable to usefully access our Privacy Policy online may contact us to learn how to obtain a copy in another, more easily readable format. 

CHANGES TO THIS PRIVACY POLICY 

We reserve the right to change, modify, or amend this Privacy Policy at any time to reflect changes in our products and services, new technologies, regulatory requirements, or other purposes. If we modify this policy, we will update the “Last Updated” date, and changes are effective upon posting. Please check the current Privacy Policy for any changes. 

CONTACT INFORMATION 

To contact us about this Privacy Policy and our privacy practices: 

• By email: contact@huseculinary.com  

• By phone: 317.637.1811 

• By mail: Huse Culinary, Inc., 280 E. 96th Street, Suite 200, Indianapolis, IN 46240 

• Online form / data-subject request: https://www.huseculinary.com/contact/