Last updated: July 7, 2021

 This Privacy Policy describes the policies and procedures of Digital Eats Inc. (“Digital Eats”, “we”, “our” or “us”) on the collection, use and disclosure of your information on www.catapultconcepts.io (the “Site”) and any other websites, domains, sub-domains, mobile applications and technology products associated therewith (collectively with the Site, the “Platform”), any hardware products (the “Products”), and the services, features, content, applications, and other products we offer (collectively with the Site and the Products, the “Services”). We receive information about you from various sources, including: (i) your use of the Services generally and (ii) from third party websites and services. When you use the Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy.

What Does This Privacy Policy Cover?

This Privacy Policy covers the treatment of personally identifiable information (“Personal Information”) gathered when you are using or accessing the Services. This Privacy Policy also covers our treatment of any Personal Information that our business partners share with us or that we share with our business partners.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to, any third party websites, services and applications (“Third Party Services”) that you elect to access through the Service or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.

What Happens When There Are Changes to this Privacy Policy?

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make material changes in the way we collect or use information, we will notify you by posting an announcement on the Services or sending you an email. When we make changes, we will revise the "last updated" date at the top of the policy. We encourage you to review this Privacy Policy whenever you visit the Platform. Unless applicable law requires your affirmative consent, a user is bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted. If applicable law requires your affirmative consent, we will require such affirmative consent the next time you access the Platform.

What If I Have Questions or Concerns?

 If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to suport@catapultconcepts.io. We will make every effort to resolve your concerns.

What Information Do We Collect?

 The information we gather enables us to personalize, improve and continue to operate the Services. In connection with certain aspects of the Services, we may request, collect and/or display some of your Personal Information. All Personal Information that we require and/or automatically collect are used to fulfill our contractual obligations and/or communicate with our users. To the extent that any Personal Information we request is optional (for example, phone numbers for contact purposes), we will identify this information and you will be informed that the information is optional. You will have to affirmatively provide this optional Personal Information and may always opt-out and stop providing it at any time. We collect the following types of information from our users.

Contact Information:

If you wish to contact us through the Site, you will have to provide information that could be Personal Information, such as your email address, name, and phone number. You acknowledge that this information may be personal to you, and by providing such Personal Information to us, you allow others, including us, to identify you and therefore may not be anonymous. We may use your contact information to send you information about our Services when we feel such information is important. You may unsubscribe from these messages by clicking the “Unsubscribe” link at the bottom of the messages.

User Content:

Some features of the Services allow you to provide content to the Services, such as written comments and posts. All content submitted by you to the Services may be retained by us. We may continue to disclose such content to third parties in a manner that does not reveal Personal Information, as described in this Privacy Policy.

Location Information:

Some of our Services may include features based on users’ actual locations and may report on users’ current locations (“Location-Based Services”). This information may help us better tailor your product options, optimize delivery and other location-specific features. To the extent you voluntarily opt to use any Location-Based Services, we may collect and store information about your location at the time you use those Location-Based Services. This information can come from a variety of sources depending on the client you use to access the Services; for example, a mobile phone may report its GPS location at the time Location-Based Services are used.

Financial Information:

We do not collect or store any user financial information, such as your payment method. All financial information is collected and stored by our third party payment processing company (the “Payment Processor”), and use and storage of that information is governed by the Payment Processor’s applicable terms of service and privacy policy. The Payment Processor maintains Payment Card Industry (PCI) compliance. If we need any financial information for authentication or security purposes (such as the last four digits of your credit card number), we request that information directly from the Payment Processor.

IP Address Information and Other Information Collected Automatically:

We automatically receive and record information from your web browser when you interact with the Services, including your IP address and cookie information. Your IP address is a number that is automatically assigned to your computer by your internet service provider. This information is used for fighting spam/malware and also to facilitate collection of data concerning your interaction with the Services (e.g., what links you have clicked on).

Generally, the Services automatically collect usage information, such as the number and frequency of visitors to the Platform. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them.

We may collect some device-specific information if you access the Services using a mobile device. Device information may include but is not limited to unique device identifiers, network information, and hardware model, as well as information about how the device interacts with our Services.

Information Collected Using Cookies:

Cookies are pieces of information that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit the Platform and otherwise use the Services through the Internet.

Our cookies do not, by themselves, contain Personal Information. As noted, however, we do use cookies to identify that your web browser has accessed aspects of the Services and may associate that information with your IP Address.

Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. However, if you refuse to accept cookies, you may experience some inconveniences, especially when interacting with some of the most popular features of the Services.

This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.

To learn more about cookies, please visit http://www.allaboutcookies.org.

Aggregate Information:

We collect statistical information about how users, collectively, use the Services (“Aggregate Information”). Some of this information is derived from Personal Information. This statistical information is not Personal Information and cannot be tied back to you or your web browser.

Information Regarding Your Social Networks:

Occasionally, you can use our Services to interact with your accounts on other services, such as Facebook or Twitter. By using your third party account credentials to access the Services, you can access posting and sharing tools on the Services, including a “share” button that allows you to post information to your social networks outside of the Services (“Share”).

By using these tools and affirmatively clicking on the “Share” button, you acknowledge that some Third Party Account Information may be transmitted to us, and that Third Party Account Information transmitted to our Services is covered by this Privacy Policy. Additionally, when you use one of these sharing tools, the Third Party Service that operates the tool may be collecting information about your browser or online activity through its own tracking technologies and subject to its own privacy policy. Lastly, when you use these tools, some of your information from the Services (such as the information you selected to Share) may be shared with the Third Party Service and others. Therefore, we encourage you to read the privacy policies and other policies of the social networks you use in connection with the Services.

How, and With Whom, Is My Information Shared?

The Services are designed to help you share information with others. As a result, some of the information generated through the Services is shared publicly or with third parties.

Public Information About Your Activity on the Services:

Some of your activity on and through the Services is public by default. This may include, but is not limited to, content you have posted publicly on the Platform or otherwise through the Services.

Information concerning a user’s use of the Services (such as what pages they have visited) may be tracked anonymously through the use of cookies and stored by us.

Please also remember that if you choose to provide Personal Information using certain public features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.

We may share this publicly available Personal Information with our service providers, including those who assist us with marketing, and with other trusted parties whom we believe offer products or services that may be of interest to you.

IP Address Information:

While we collect and store IP address information, that information is not made public. When permitted by applicable law, we do at times, however, share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy.

Information You Elect to Share:

You may access other Third Party Services through the Services, for example by clicking on links to those Third Party Services from within the Platform. We are not responsible for the privacy policies and/or practices of these Third Party Services, and you are responsible for reading and understanding those Third Party Services’ privacy policies. This Privacy Policy only governs information collected on the Services.

Aggregate Information:

We share Aggregate Information with our partners, service providers and other persons with whom we conduct business. We share this type of statistical data so that our partners can understand how and how often people use our Services and their services or websites, which facilitates improving both their services and how our Services interface with them. In addition, these third parties may share with us non-private, aggregated or otherwise non Personal Information about you that they have independently developed or acquired.

Email Communications with Us:

As part of the Services, you may occasionally receive email and other communications from us, such as communications responding to your inquiries.

Financial Information:

As stated above, we do not currently collect or store financial information, as that information is collected and stored by our Payment Processor. We may from time to time request and receive some of your financial information from our Payment Processor for the purposes of authentication, completing transactions you have initiated through the Services, enrolling you in discount, rebate, and other programs in which you elect to participate, protecting against or identifying possible fraudulent transactions, and otherwise as needed to manage our business.

Information Shared with Our Agents and Service Providers:

We employ and contract with people and other entities who are under our control (our “Agents”) and third-party service providers (the “Service Providers”) that perform certain tasks and services related to functionality, analytics, communications, and advertising. We may need to share Personal Information with our Agents and Service Providers in order to provide products or services to you. In these cases, we share data to our Agents and Service Providers through APIs (Application Programming Interfaces) and share only the information needed for the Agent or Service Provider to perform its services to us or to you. For example, we may share only your name and shipping address to FedEx for delivery services while withholding your email address information. Unless we tell you differently, our Agents and Service Providers do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. Other than in fulfillment of our contractual obligations, we do not share your Personal Information with third parties, including our Agents and Services Providers.

Below is a list of our primary Agents and Service Providers that we may provide your Personal Information to in fulfillment of our contractual obligations, and the services they generally provide.

• DoorDash - Shipping and Delivery

• Uber Eats - Shipping and Delivery

• GrubHub - Shipping and Delivery

• Postmates - Shipping and Delivery

 Information Disclosed Pursuant to Business Transfers:

 In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. We will notify you of such an occurrence as described in the "What Happens When There Are Changes to this Privacy Policy " section above. We reserve the right to disclose your Personal Information if required or permitted to do so by law.

Information Disclosed for Our Protection and the Protection of Others:

We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce this Privacy Policy and our Terms of Use, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

Information We Share With Your Consent:

Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and you will be able to prevent the sharing of this information.

Retention Period:

We will retain your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained. Generally, we maintain backups and historical records of Personal Information in the ordinary course of our business, and all data, except data stored solely by third party providers, are subject to this retention policy. Notwithstanding the above, there are certain criteria that may impact the retention period, including: (i) the length of time we have an ongoing relationship with you and provide the Service to you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

Is Information About Me Secure?

The security of your Personal Information is important to us. We follow generally accepted industry standards to help protect your Personal Information including without limitation:

• limiting access to your Personal Information to employees on a need-to-know basis;

• requiring employees to sign confidentiality agreements to protect confidential information, including your Personal Information;

• ensuring that Service Providers sign confidentiality agreements to maintain the confidentiality of your Personal Information and not to use it for any unauthorized purposes;

• ensuring that data shared with Agents and Service Providers is limited to only data needed to complete their respective duties or services;

• using HTTPS protocol for secure communication over a computer network, which is widely used on the Internet;

• not storing your billing information or credit card information within our system directly, but instead using the Payment Processor to store all payment information;

• not allowing employees to access your credit card or other financial information;

• evaluating of all Service Providers before implementation;

• conducting annual security reviews internally to reevaluate all Service Providers and our system, to continue to ensure the highest level of security; and

• storing your Personal Information in secure systems which protect it from unauthorized access or use.

We seek to protect Personal Information to ensure that it is kept private; however, no method of transmission over the Internet, or method of electronic storage, is ever 100% secure. Therefore, while we strive to protect your Personal Information, we cannot guarantee its absolute security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. If you have reason to believe that your interaction with us is no longer secure or that your Personal Information has been accessed, used or disclosed improperly or without your authorization, please immediately notify us at support@catapultconcepts.io.

What Information of Mine Can I Access?

Users can access and delete cookies through their web browser settings.

In addition, certain users may have additional Personal Information rights based on where they live. Please see Additional Privacy Rights and Data Protection Practices for more information.

What Choices Do I Have Regarding My Information?

You can use some of the features of the Services without providing certain Personal Information (e.g., phone numbers and email address), thereby limiting the type of information that we collect.

You can always opt not to disclose certain information to us, even though it may be needed to take advantage of some of our features. Please note that if you opt out of disclosing certain information, we may not be able to remove your Personal Information from the databases of our affiliates with which we have already shared your information (i.e., as of the date that we implement your opt out request).

In addition, certain users may have additional Personal Information rights and choices based on where they live. Please see Additional Privacy Rights and Data Protection Practices for more information.

Additional Privacy Rights and Data Protection Practices

The laws in certain jurisdictions require us to provide users, to the extent those laws apply to such users, with certain rights and information. This means that certain users may have additional rights and choices based on where they live, and with respect to those users, to the extent this portion of the Privacy Policy conflicts with any other portion of this Privacy Policy, this portion of the Privacy Policy shall supersede and control. We have tried to provide links to websites that provide more information below. If you feel that this list does not cover your rights, please immediately notify us at support@catapultconcepts.io.

If you are a resident of the European Union, we will process your Personal Information in compliance with the EU General Data Protection Regulation (“GDPR”).  For information submitted using the Services, Digital Eats is the data controller, as defined under GDPR.  In accordance with GDPR, as a data subject you will be accorded with any applicable rights under GDPR.

To learn more about your GDPR privacy rights, visit https://eugdpr.org/the-regulation/. Further, list of European Union data protection authorities is available at: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

If you are a resident of California, we will process your Personal Information in compliance with the California Consumer Protection Act (“CCPA”).  In accordance with CCPA, as a data subject you will be accorded with any applicable rights under CCPA. Also, under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: 17800 Laurel Park Drive North, Suite 200C, Livonia, Michigan 48152. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy.           

If you are a resident of Canada, Canadian law may provide you with additional rights regarding our use of your Personal Information. To learn more about your Canada privacy rights, visit https://www.priv.gc.ca/en/.

For example, certain users (such as users in California or the European Union/European Economic Area) may have the following rights with respect to their Personal Information:

• The right to know what information Digital Eats collects from you, why it is collected, and how it is shared.

• The right to have access to your Personal Information in a portable format, to the extent technically feasible.

• The right to have your Personal Information deleted by Digital Eats and its service providers and to be notified when such deletion has been completed, colloquially known as the “right to be forgotten.”

• The right to have incomplete or inaccurate Personal Information rectified and to be notified upon rectification.

• The right to withdraw your consent to the processing of your Personal Information.

• The right to request information about the categories of information that are sold and/or to opt out of the sale of Personal Information. (Note: what is covered as a “sale” under California law is not yet clear, but we currently do not “sell” your information, as we understand it.)

You may also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your Personal Information infringes applicable law. However, Digital Eats encourages any such user to contact us first at support@catapultconcepts.io, and we will do our very best to promptly address such user’s issue(s) and resolve the concern(s).

The rights and options described above are subject to limitations and exceptions under applicable law, including, without limitation, the GDPR and the CCPA. In situations in which we process Personal Information on behalf of a user, we may refer the request to the relevant user and cooperate with their handling of the request, subject to any special contractual arrangement with that user.  Typically, your exercise of any applicable rights will not have retroactive effect. These rights will not affect our ability to continue processing data in lawful ways.

Digital Eats is committed to the free exercise of these rights without fear of being denied the opportunity to use the Service. To exercise any right or make any request, please notify us at support@catapultconcepts.io. We will respond to your request in accordance with the applicable law that governs the collection, use and deletion of your data and information. The requested deletion will be as comprehensive as possible but is always subject to issues outside of our control, including applicable regulations and laws, your actions and the actions of third parties. It is important to note that we may retain a copy of the information for archival purposes and to avoid identity theft or fraud.