Effective Date January 1, 2023

PRIVACY POLICY

This Privacy Policy (“Privacy Policy”) applies to those websites owned or controlled by Ventura Foods, LLC (“Ventura Foods,” “we,” “our” or “us”) that post a link to this Privacy Policy (individually, “Site” and collectively, the “Sites”), (however the Sites are accessed or used, whether via personal computers, mobile devices or otherwise). The Privacy Policy describes Ventura Food’s information and privacy practices with regard to our Sites, including the types of information we may collect from you and how we may use and share that information. Except as specifically stated otherwise, this Privacy Policy does not apply to information collected offline by Ventura Foods.

This Privacy Policy as posted on the Site is the sole statement of our privacy policy with respect to the Sites, and no summary, modification, restatement or other version thereof, or other privacy statement or policy, in any form, is valid unless we post a new or revised policy to the Sites.

Table of Contents

  1. Personal Information Ventura Foods Collects
  2. How Ventura Foods Uses Personal Information
  3. When Ventura Foods Discloses Personal Information
  4. Links to Third Party Websites
  5. Updating Your Personal Information and Subscriptions
  6. Your Rights With Respect to Your Personal Information
    a. Data Security
    b. Transfer Outside of Canada
    c. Changes to this Privacy Policy
    d. Contact Us

PERSONAL INFORMATION VENTURA FOODS COLLECTS

“Personal Information” is any information that can be used to identify and/or locate a specific person. The types of Personal Information we collect through our Sites will vary depending on the activity involved, but may include: first and last name, address, e-mail address, phone number and mobile phone number. We do not require that you provide Personal Information to obtain access to public parts of the Sites, however, some areas of the Sites may ask you to submit Personal Information in order for you to benefit from specific features or to participate in a particular activity. For example, we may collect Personal Information when you:

  • register on the Site;
  • subscribe to a newsletter or other communications, whether by e-mail, mobile device or other method;
  • send questions or comments to us;
  • “sign” one of our guest books and participate on message boards; or
  • participate in sweepstakes, events, or other promotional events (collectively, “Promotions”) offered through the Site.

You can always choose not to provide us with your Personal Information but you may not be able to participate those Sites’ features that are conditioned upon collecting Personal Information.

From time to time, we may obtain Personal Information that has been collected by third parties. For example, our sponsors may provide us Personal Information about users that choose to participate in a promotional opportunity (collectively, “Third Party Information”). We may use such Third Party Information in combination with Personal Information that we have collected from you on the Site, in which case we will apply this Privacy Policy to the Third Party Information. However, because the Third Party Information is not collected on this Site, we are not responsible for the accuracy of this data or how such third parties collect and use such data.

We may passively collect certain non-personal information about you on our Sites, such as how you use the Sites or which pages you view (collectively, “Usage Information”). We may utilize such Usage Information for many purposes, including to customize the Site based on your preferences, compile and analyze statistics and trends including the number of Site visitors, and otherwise administer and improve the Site. When we associate Usage Information with your Personal Information, we will treat that information as Personal Information. We may utilize various technologies that may collect Usage, including those described as follows:

Cookies – Cookies are small files that a web site transfers to your computer for many purposes such as facilitating your web page display preferences and web site login features. While most browsers are set up to accept cookies, you can configure your browser to refuse cookies. However, if you decline to accept the Site’s cookies, you may not be able to take advantage of or participate in certain features of this Site. We do not save Personal Information in cookies but we may link cookies to any Personal Information or other information we collect.

IP Addresses – An IP address is a number automatically assigned to your computer or mobile device when you are using the Internet. When you view pages on this Site, our servers may record your IP address. We may use IP address records for a number of purposes, such as system administration, to report aggregate information to our business partners or to audit the use of the Site. We may associate your IP address with the Personal Information you provide in which case we will treat it as Personal Information.

Web Beacons – The Sites’ pages and any communications sent by the Site, including newsletters, may contain a small graphic image or other web programming code called a web beacon. Web beacons can be very small or invisible to the user, although any image or other component viewed as part of a web page or e-mail can act as a web beacon. We may use web beacons to count visitors to our Site or to monitor how visitors navigate our Site, and we may include web beacons in communications sent from the Site in order to count how many messages we sent were actually opened or acted upon, among other purposes.

Embedded Scripts – An embedded script is programming code that is designed to collect information about your interactions with the Site. It is temporarily downloaded onto your computer from our web server or a third party we with whom we work, is active only while you are connected to the Site, and is deleted thereafter.

HOW VENTURA FOODS USES PERSONAL INFORMATION

Ventura Foods may retain and use your Personal Information for many purposes, including:

  • to send newsletters and other communications for which you have subscribed or otherwise agreed to receive;
  • provide you with services or fulfill transactions that you have requested;
  • send you offers or promotional materials on behalf of Ventura Foods or third parties;
  • communicate with you regarding information, features or offers that we believe will be of interest to you;
  • contact you regarding promotions in which you have participated;
  • respond to your questions or other requests;
  • contact you with regard to your use of the Site, including, without limitation, changes to the Site’s Privacy Policy, Terms of Use or other Site policies;
  • to improve or customize the Site and its content, features and services;
  • allow you to access specific sections of Site for which you have registered;
  • for other business purposes or for other purposes disclosed at the time you provide your Personal Information;
  • send you e-mail communications or otherwise contact you regarding your job search; and
  • facilitate your job search and prepare governmental and internal statistics reports.

As part of our routine record keeping practices, we retain Personal Information for as long as necessary to fulfill the purposes for which the information was collected, or otherwise meet our legal, regulatory and business requirements. Personal information is maintained on our servers and is accessible to our authorized employees, representatives and agents who require access for the purposes described in this Policy. We may delete records that contain Personal Information you have submitted through the Site in accordance with our record retention policies. We have no obligation to store such Personal Information and disclaim any liability arising out of, or related to, the destruction of such Personal Information. You should also be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons.

WHEN VENTURA FOODS DISCLOSES PERSONAL INFORMATION

Ventura Foods may share anonymous and aggregated information, including aggregated statistics and Usage Information that does not constitute Personal Information, with third parties for any lawful purpose. Ventura Foods may share Personal Information (including Usage Information that constitutes Personal Information) with third parties or affiliated companies as follows:

  • Affiliated companies – We may share Personal Information with our affiliated companies who perform services on our behalf, such as data processing, marketing, analytics, customer service and similar services. With your consent or as otherwise permitted by law, we may also share Personal Information with our affiliated companies for marketing purpose.
  • Service Providers – We may share Personal Information with outside parties who work on our behalf to support our business needs or to provide a product or service for you on our behalf.
  • Marketing Purposes – We may share Personal Information with a third party for marketing purposes. If you later decide that you do not want that third party to use your Personal Information, you will need to contact that third party directly.
  • Sale/Reorganization – We reserve the right to disclose and transfer Personal Information about you and you consent to such disclosure and transfer of Information: (i) to a subsequent owner, co-owner or operator of any of the Sites, including any applicable databases; and/or (ii) in connection with a corporate merger, consolidation, restructuring, reorganization, issuance of securities, the sale of substantially all of Ventura Foods’ stock and/or assets or other corporate change, including, without limitation, during the course of any due diligence process.
  • Legal and Safety Obligations – We may disclose your Personal Information: (i) at the request of governmental authorities; (ii) if we are required to respond to subpoenas, court orders, legal process or other valid law enforcement measures; (iii) when we believe in good faith that the law requires disclosure; (iv) to verify or enforce compliance with the Site’s Terms of Use or other policies governing the Site; (v) whenever we believe disclosure is necessary to limit our legal liability or to protect or enforce the rights, interests, or safety of the Site, visitors to the Site or other third parties; or (vi) to respond to an emergency.
  • Promotions – We may disclose your Personal Information to third parties in connection with the administration of Promotions, including, without limitation, in connection with winner selection, prize fulfillment, allowing the sponsor(s) of the Promotions to use your name, voice and/or likeness in advertising or marketing associated with the Promotion.
  • Submissions – Ventura Foods may publish your name, voice, likeness and other Personal Information in connection with any submissions you may make to our Sites as set forth in the Terms of Use.
  • Posting in Public Forums – The Site may provide message boards, blogs and other “public” forums (collectively, the “Public Forums”). Your use of Public Forums is subject to our Terms of Use. Please keep in mind that whenever you post your Personal Information in a Public Forum, that information can be collected and used by anyone. We cannot ensure the security of any information you choose to make public. Please exercise caution when deciding to disclose your Personal Information in these areas. You may not post any other person’s Personal Information in a Public Forum.
  • Advertisements – The Sites may display advertisements from third party advertisers, which may use cookies, web beacons and other methods of passively collecting Information.

LINKS TO THIRD PARTY WEBSITES

Our Sites may contain links to third party web sites that we do not control or maintain and we are not responsible for the privacy practices employed by any Third Party Site. We encourage you to note when you leave our Site and read the privacy statements.

UPDATING YOUR PERSONAL INFORMATION AND SUBSCRIPTIONSs

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. The Site may allow you to correct or update Personal Information you have provided to us through a Site registration form or otherwise. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable.

You may cancel or modify your subscriptions to e-mails from the Site by following the instructions contained within an e-mail you receive from the Site. However, even if you opt-out from receiving our newsletters or other marketing/promotional communications, we reserve the right to send you certain communications relating to our Site, such as service announcements or notices of changes to this Privacy Policy or our Terms of Use without offering you the opportunity to opt-out of receiving such information.

YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION

You have the right to request access to your Personal Information under our control, to receive information about how we have used and disclosed that information, and to request corrections or updates if your Personal Information is found to be incomplete, out of date or inaccurate. You may also withdraw your consent to our processing of your Personal Information, subject to contractual and legal restrictions, and reasonable notice. In certain circumstances, you may also have the right to request that your Personal Information be deleted. These rights are subject to exceptions and we may take steps to verify your identity before honouring these requests. To exercise any of these rights, please contact our Privacy Officer in writing at [email protected]

DATA SECURITY

While we have taken steps to protect the Personal Information we collect from you on the Site, you should keep in mind that no Internet, wireless or mobile phone transmission is ever completely secure. In particular, unencrypted e-mail and web traffic are subject to potential interception by unauthorized third parties. Likewise, we cannot guarantee the security of any information that you disclose to us, or that which we process or store. Accordingly, you disclose your Personal Information at your own risk. Please consider this when you choose the information, if any, you wish to transmit to the Sites.

TRANSFER OUTSIDE OF CANADA

The Site is intended for residents of Canada. Please be aware that Personal Information we collect will be transferred outside of your province of residence, and may also be transferred outside of Canada, including to the United States and other countries where our affiliates and service providers are located. While outside of Canada, Personal Information will be subject to applicable foreign laws, which may not provide the same level of protection for Personal Information as Canada.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to update or otherwise change this Privacy Policy at any time and will post any changes here. We encourage you to check the Privacy Policy periodically for updates. Such changes will become effective immediately upon being posted unless we inform you otherwise. We will use your Personal Information in a manner consistent with the Privacy Policy in effect at the time you submitted the information unless we receive your consent or as permitted or required by law.

CONTACT US

If you have any questions, comments, requests, or concerns about this Privacy Policy, or if you wish to make a complaint about our practices with respect to Personal Information, please contact us via our toll-free number at 1-877-VENTURA (1-877-836-8872) or email our Privacy Officer at [email protected].

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