SABROSURA FOODS PRIVACY POLICY

Introduction

Sabrosura Foods, LLC (“Company” or ”We”) respects your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit each of our websites, including those located at sabrosurafoods.com, panchoscheesedip.com, lamorenitafoods.com, and elviajerofoods.com (collectively, the “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. 

Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 is authorized to use, or provide any information to, the Website. We do not request, or knowingly collect, personal information from children under 13. If we learn of any mistaken or inadvertent collection or receipt of personal information from a child under 13 through their misuse of the Website, we will delete that information from our records. We ask all parents and guardians to assist us in our efforts by prohibiting children under the age of 13 from providing the Company with any personal information or using the Websites without parental oversight and assistance. If you believe we might have any information from or about a child under 13, please contact us at the contact information below. 

Information We Collect About You and How We Collect It

For the purposes of this Policy, “personal information” is any information that identifies, relates to, or can be used to contact a particular individual. 

We collect several types of personal information from and about users of our Website, including the following categories of information:

• Contact information – first name, last name, email address, mailing address, billing address, and telephone number.
• Account information – If you create or have an account with us, account username, account password, account number, and other information that we may request or that you may provide relating to your account.
• Transactional information – If you purchase a product from us or one of distributors, details about your organization’s transactions with us, including method of payment, payments received, payment details, transaction history, and other information relating to the products purchased by you.
• Marketing information – details regarding informational and promotional materials you may have requested or received from us, the services in which you are interested, your receipt of promotional communications, and information on your marketing or communication preferences.
• Communication information – copies of communications and inquiries you have submitted to us, including through email, calls, and chatbots or other features available on our Website.
• Device and usage information – details regarding how and when you use our Website, including the device used to connect to our Website or software, your IP address and device identifier, the frequency and duration of your usage, the pages you view, what websites or search terms referred you to our website, and information about your interaction with our Website.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, for example, our business partners and vendors that provide us with website hosting, email marketing and consumer survey services.

Information You Provide to Us 

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, posting material, uploading your resume or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• If you engage in a transaction with us via the Website, the details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
• Your search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies 

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. For further information about cookies, including how to refuse cookies, please visit www.allaboutcookies.org. 
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Log Files and Device Identifiers. We use log files to track actions occurring on the Site and collect data about visitors, including IP address, browser type, Internet service provider, referring/exit pages, date/time stamps, and device identifiers.
• Analytics. Our Website may also use third-party analytics tools such as Google Analytics. You can find more information about how data is collected and processed in connection with the Google Analytics service here. You can also read Google’s privacy policy here.
• Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). 

The information collected through these technologies may be combined with personal information or aggregated with other information on Site visits. We may share information about your use of our Website with our advertising and analytics partners, who may combine it with other information that you previously provided to them. 

Information About You We May Receive from Third Parties

We may receive personal data about you from various third parties and public sources including:

• Analytics providers such as Google;
• Advertising networks such as Google, Bing, Facebook and Instagram.
• Contact, financial and transaction data from providers of technical, payment and delivery services.
• Identity and contact data from publicly available sources.

Please note that we may aggregate or anonymize the foregoing types of information such that they are no longer capable of identifying you, in which case they are not considered “personal information.” 

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. 

How We Use Your Information

We, and our authorized third party service providers, may use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To display advertisements for our products on the Website or on other websites you may visit.
• If you place an order for products with us, to fulfill that order, including shipping it to the address provided and process your payment.
• To analyze trends and conduct research about improving our products, services and Website.
• To correlate information with other commercially available information to identify demographics and preferences to assist us in marketing efforts.
• To contact users for research, informational or marketing purposes.
• To learn about our users’ needs.
• To track traffic patterns and usage of the Website, including customizing our recommendations and promotions to you based on your information.
• To address information security and/or privacy practices control, network functioning, engineering, and troubleshooting issues.
• To investigate claims and/or legal actions, violations of law or agreements, and compliance with relevant applicable laws and legal process.
• To comply with law, or based on our good-faith belief that it is necessary to conform or comply with the law, or otherwise to disclose information to prevent fraud and reduce credit risks, to cooperate with police and other governmental authorities, or to protect the rights, property or safety of visitors to the Website or the public.
• To process or engage in a sale of all or part of our business, or if we go through a reorganization or merger.
• To provide you with notices about your account.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• For any other purpose with your consent.

Our Marketing Efforts

We may send you direct marketing communications from time to time including news, updates, offers, and other promotions relating to our services and activities. We will only send marketing messages where the law allows us to do so and, in the event that you no longer wish to receive marketing from us, then you can always unsubscribe using the option provided in the footer of the communication you have received or by contacting us using the information below.

Lawful Basis of Processing

We collect and process your personal information under the following lawful bases:

(i)                With your consent as provided hereunder;

(ii)             To fulfill our legitimate interest in conducting our business, where your interests and fundamental rights do not override those interests including, but not limited to:

a.      Considering you as a Job Applicant;

b.     to keep our records updated;

c.      to study how customers use our products/services, to develop them and grow our business and inform our marketing strategy;

d.     for running our business, including facilitating contests, promotions and sweepstakes; and

e.      contacting you about our products, or responding to your requests.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To business partners, service providers, and third-party vendors necessary for the performance of any contract we enter into with you. For example, we may disclose your information to our carriers assisting with a specific shipment, shipping logistics planners, insurance providers, and legal counsel in the event of a dispute.
• To contractors, service providers, and other third parties we use to support our business , such as (i) IT and system administration providers, (ii) data storage providers, and (iii) vendors to facilitate payments and payment processing.
• To marketing and advertising vendors that may assist with lead generation, hosting information relating to clients and potential clients, marketing automation, advertisement placement and targeting, and marketing campaigns and communications.
• To analytics vendors in order to understand our Website traffic and usage patterns, optimize our Website, and identify potential new customers.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it. For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use or terms of sale and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

·        Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

·        Marketing Emails. As required by applicable laws, you can opt-out of receiving promotional emails from us by clicking the “opt out” link in any such promotional emails and following the instructions provided.

·        Google Analytics. As discussed above, we use Google Analytics in connection with the Site. If you would like to refrain from having your data collected by Google Analytics, Google has developed an opt-out browser that you can use. You can find more information on how Google uses information it collects here.

·        Declining to Provide Information.  You can choose not to provide us with information we may request through our Website, but that may result in you being unable to use certain features of our Website, request information about our products, or initiate other transactions with us.

·        Do Not Track Mechanisms. Please note that our Website does not honor “Do Not Track” signals, and such signals will not impact the operation of this Website. 

In addition to the above, you may contact us using the details provided at the end of this Policy with any questions about the choices relating to your personal information.

Notice for California Residents

This section supplements the information in this Policy. This section applies to the personal information we collect from California residents who use our Website, communicate or request information from us, or otherwise interact with us.

This section explains our collection, processing, and disclosure of “personal information” relating to California consumers. Specifically, this section applies to our processing activity when we are acting as a “business” under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”)—meaning that we control the purposes and means of processing your personal information. Some of the personal information we collect may be exempt from some or all of the requirements under the CCPA.

Please read this section carefully before sharing information with us so you understand our practices regarding your information.

Information We Collect and Disclose

As defined by the CCPA, “personal information” includes any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include information that is:

• Lawfully made available from government records;
• We have a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media, or by the consumer;
• Made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience;
• Lawfully obtained, truthful information that is a matter of public concern; 
• Deidentified or aggregate consumer information; or
• Information excluded from the CCPA’s scope, including personal information covered by certain sector-specific privacy laws such as the Fair Credit Reporting Act.

In the past 12 months, Sabrosura has collected the following categories of personal information from consumers and disclosed such information to the following categories of third parties for the business purposes described below. 

Please note that we may also use, disclose, or transfer your information in connection with the sale, merger, dissolution, restructuring, divestiture, or acquisition of our company or its assets. We may also disclose your personal information in response to a court order, subpoena, search warrant, law, or regulation.

How We Collect Your Information

Sabrosura collects the categories of personal information listed above from the following sources:

• Direct collection: We collect information directly from you when you choose to provide it to us by filling out forms on our website, engaging in transactions with us, signing up to receive promotional or information communications from us, communicating with us about our products, or otherwise directly providing the information to us. 
• Indirect and technology-based collection: We also collect certain information from you indirectly when you visit, use, or navigate our website or mobile application.  Sabrosura collects certain identifiers (such as IP addresses) and internet and similar network activity (such as website usage data) from you indirectly using cookie, pixels, and passive tracking technologies, as described in our Privacy Policy.
• Collection via social media: We may collect personal data about social media users, including basic user profile information (such as username), user-generated content (such as posts, comments, pages, profiles, or feeds) and associated metadata (such as time and location of a post or comment); contact details (such as name, email address, telephone number if made public by the user); and additional individual information published by the user (such as employer, profession, age, location, education information, habits, etc.). The type and scope of personal data obtained from social media platforms depends on the type of APIs and permissions set out by the respective platforms and the administrative permissions granted by individuals, where applicable.
• Third-party collection: From time-to-time, we may obtain marketing or lead lists from third party vendors. We use these, for example, to send you marketing communications.

Use of Personal Information

We collect and use your personal information for the following business or commercial purposes (as well as any other purposes as set forth in our Privacy Policy). 

• Providing and optimizing your experience on our website and ensuring that our content is presented to you in the most effective manner.
• Fulfilling transactions with you, processing payments, and managing the business relationship and transaction process.
• Communicating with you and responding to your inquiries about our services and products, including to provide you with promotional and informational communications regarding our services, informing you about new services and products, updating you about changes to our services and products, and investigating any concerns you may have.
• Developing, updating, and improving our services and products, customer service, customer experience, and marketing efforts, and otherwise improving our knowledge and insights regarding actual or potential providers, customers, and business partners.
• Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with Sabrosura or our services and products, or our affiliates and their services.
• Enforcing our agreements and complying with our legal or regulatory obligations.
• Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.

Applicable Retention Periods

For each category of personal information identified above, Sabrosura will only retain such information only for as long as necessary to fulfill your requests or the purposes for which it was obtained, as set forth in this section. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you, (ii) as required by a legal obligation to which we are subject, and (iii) as necessary to resolve any disputes or enforce our legal agreements with you.

Sensitive Personal Information

Sabrosura does not collect “sensitive personal information” (as defined by the CCPA) for the purposes of inferring characteristics about California consumers. Accordingly, Sabrosura treats any such information as “personal information” consistent with applicable provisions of the CCPA.

Sale or Sharing of Personal Information

In the past 12 months, Sabrosura has not “sold” any categories of personal information or “shared” any such information for the purposes of cross-context behavioral advertising. Likewise, Sabrosura does not have actual knowledge of any sales or sharing of personal information regarding minors under 16 years of age. 

Your Rights Under the CCPA

The CCPA provides California residents with the rights discussed below. For convenience, and as required by the CCPA, we explain how you can exercise those rights, to the extent they are applicable. 

1.                  Right to Request Information. You have the right to request that we disclose certain information about our collection and use of your personal information during the past twelve (12) months. Specifically, you may request that we disclose:

• The categories of personal information we collected about you;
• The categories of sources for the personal information we collected about you;
• The business and commercial purposes for collecting your personal information;
• The categories of third parties to whom we disclose your personal information;
• The specific pieces of personal information we collected about you; and
• If we disclosed your personal information for a business purpose, the categories of personal information received by each category of third party.

2.                  Right to Data Portability. You have the right to request that we provide copies of the specific pieces of personal information we collected about you. If a verifiable consumer request is made, and subject to any exceptions or limitations under the CCPA, we will take steps to deliver the personal information to you either by mail or electronically. If we provide the information to you electronically, it will be in a portable and readily useable format, to the extent technically feasible. Consistent with the CCPA and our interest in the security of your personal information, we will describe but may not provide copies of certain personal information we may receive from you (e.g., driver’s license number, other government-issued identification number, financial account number, health or medical identification number, account password, or security questions or answers) in response to a CCPA request, to the extent any of those items are in our possession.

3.                  Right to Request Deletion. You have the right to request that we delete personal information we collected from you, subject to any exceptions or limitations under the CCPA.

4.                  Right to Correct Inaccurate Information. If we maintain inaccurate personal information about you, you have the right to request that we correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.

5.                  Right to Opt-Out. Consumers in California have the right to opt-out of (a) the sale of personal information, or (b) the sharing of their personal information for the purposes of cross-context behavioral advertising (as defined in the CCPA). Because Sabrosura does not “sell” or “share” personal information, these rights are not available.

Exercising Your Rights

To exercise the rights described above, you—or someone authorized to act on your behalf—must submit a verifiable consumer request to us by sending an e-mail to customerservice@sabrosurafoods.com with the subject line: “CCPA Request” or calling us at 1-800-332-6518. Your request must include your name, e-mail address, mailing address, phone number, the nature of your inquiry and the context in which we may have received your information. If you are an agent submitting a request on behalf of a consumer, we may request that you submit a signed permission from the consumer authorizing you to make the request. In order to protect the privacy and data security of consumers, the verifiable consumer request must:



• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such consumer; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

As indicated above, please be aware that the CCPA provides certain limitations and exceptions to the foregoing rights, which may result in us denying or limiting our response to your request.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.  We may also request that you provide additional information if needed to verify your identity or authority to make the request.  We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you or the consumer on whose behalf you are making the request. 

Response Timing and Format

The CCPA requires us to respond to a verifiable consumer request within forty-five (45) days of its receipt; however, we may extend that period by an additional 45 days.  If we require more time, we will inform you of the reason and extension period in writing.  We will deliver our written response via e-mail.  Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request, provided that you may request disclosure beyond the 12-month period as permitted by the CCPA.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select the format of our response; the format will be readily useable and should allow you to transmit the information from one entity to another.  We will not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing the request. 

Our Commitment Not to Discriminate

Consistent with the CCPA, we will not discriminate against you for exercising any of your CCPA rights by: 

• Denying you services or products.
• Charging you different prices or rates for services or products, including through granting discounts or other benefits, or imposing penalties.
• Providing you a different level or quality of services or products.  
• Suggesting that you may receive a different price or rate for services or a different level or quality of services or products.

Data Sharing for Direct Marketing Purposes

California Civil Code § 1798.83 (California’s Shine the Light Act) further permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your personal information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at the contact information below.

Users Outside of the United States

If you are visiting the Website from a location outside of the United States, your connection will be through and to servers located in the United States. All information you receive from the Website may be created on servers located in the United States, and all information you provide may be maintained on web servers and systems located within the United States. The data protection laws in the United States and other countries might not be the same as those in your country. By using the Website or submitting information to us, you specifically consent to the transfer of your information to the United States and to the facilities and servers we use, and to those with whom we may share your information.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account and/or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Sabrosura Foods

Attn: Customer Service

105 3^rd St., Monroe, WI 53566

customerservice@sabrosurafoods.com