Last Updated: March 9th, 2021
You can access the Sites in many ways, including from a computer or mobile device, and this Policy will apply regardless of the means of access. To the extent we provide you notice through the Sites of different or additional privacy policies or practices (e.g., at the point of collection), those additional terms shall govern such data collection and use.
1. PERSONAL INFORMATION WE COLLECT
Our primary goal in collecting Personal Information are to provide and improve our Sites, to conduct our Operations, to communicate with you and to enable visitors to our Sites to enjoy and easily navigate them. This section describes what Personal Information we collect. When we refer to “Personal Information” in this Policy, we mean information that identifies, relates to, describes or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular individual. Please note, as used in this Policy, “Personal Information” does not include publicly available information from government records or information that has been deidentified or aggregated in a way that it cannot be used to identify a specific individual.
1.1 Categories of Personal Information We Collect.
The Personal Information we collect primarily consists of business contact information, such as a name, business email address, business mailing address and business telephone number, in connection with our relationships with commercial entities that submit orders for our products and services. However, we may collect other Personal Information depending on the type of activity you are performing on the Sites or how you use or interact with our Operations. Generally, we may collect and disclose the Personal Information listed below in connection with our Operations. Please note, depending on how you interact with us, we may not collect all (or any) of the Personal Information identified below.
a. Identifiers and contact information, such as your real name or alias, physical address, email address, IP address and similar information;
b. Online identifiers you use, such as your username, social media handles and similar information;
c. Account information, such as your username, password, account activity and similar information; and
d. Other information you or third parties provide us.
When you apply for employment with us, we collect Personal Information such as your name, address, e-mail, phone number, demographic information, and military status. In addition, we may collect information relating to your education and employment history when you submit that information as part of an employment application. Not all requested information is required, however, and we specifically indicate what information is required in order to submit your employment application.
1.2 Usage Information.
We may collect information about the devices that access or interact with our Sites (“Usage Information”), which may include:
a. Device information, such as the IP address, general geographic location, operating system, browser type, language preferences, mobile phone number, device identifier and other similar information associated with a computer or mobile device used to access or interact with our Sites;
b. Information about interactions with our Sites, such as links that are clicked, pages or screens that are viewed, access and session times, interactions with emails we send and other similar information associated with activities on our Sites;
c. Information about internet and network activity, such as websites visited, search engine results and similar information associated with a computer or mobile device that accesses or interacts with our Sites;
d. Information automatically collected by cookies and other technologies on our Sites; and
e. Any other information that a browser or device automatically sends whenever connecting to a website or an online application.
Usage Information, by itself, generally does not identify the specific person using the computer or mobile device that generated the Usage Information. This means that it usually will not be considered Personal Information and our use of such Usage Information is not subject to this Policy. However, if we link Usage Information directly with other Personal Information or other information that could identify a specific person, we will treat the linked Usage Information as Personal Information and use the linked Usage Information as described in this Policy.
For more information about how we collect Usage Information, please see the “How We Collect Usage Information” section below.
2. HOW WE COLLECT PERSONAL INFORMATION
2.1 Directly From You.
When you use our Sites or otherwise engage with us in connection with our Operations, such as requesting more information about our organization, communicating with us or otherwise interacting with us, we may ask you to provide certain Personal Information. Some components of our Operations require us to collect your Personal Information. If you not provide us with the Personal Information we request, we may not be able to provide you with those components of our Operations if the Personal Information is necessary or we are legally required to collect it.
2.2 From Third Parties.
We may obtain Personal Information about you from third parties through or in connection with our Platform. These third parties may include our business partners, our service providers, third parties on whose behalf you place orders or otherwise interact with our Operations (collectively, these third parties are referred to as “your employer”), social media sites, ad networks, analytics providers and other third parties that are authorized to share information about you with us. We may also collect Personal Information about you from others that refer you to us.
3. HOW WE COLLECT USAGE INFORMATION
We collect Usage Information in a variety of ways. Some Usage Information, such as the IP address of the device or computer attempting to access our Platform, is necessary to for us to make the Platform available. Other Usage Information, such as information about what features that are popular, helps us improve our Platform. This section describes the primary ways we collect Usage Information in connection with our Platform.
When you access our Sites, our systems automatically record Usage Information that your browser or device sends whenever you visit a website as well as Usage Information about how long your device is connected to our Sites and the activities that device engages with while connected to our Sites.
3.3 Other Tracking Technologies.
We may collect information using web beacons, clear gifs, pixel tags or other similar technologies. These technologies are electronic images that may be used on our Sites or in emails we send. We use these technologies to deliver cookies, count visits, understand usage and observe data on email delivery, open rates, click rates, bounces, unsubscribes and other information.
Please note that we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.
4. HOW WE USE PERSONAL INFORMATION
We use the Personal Information we collect for various purposes in connection with our Operations. This section describes the primary purposes for which we use the Personal Information we collect.
4.1 Marketing Purposes.
We may use the Personal Information we collect for our own marketing purposes, including notifying you of special promotions, opportunities, offers and events via push notifications, e-mail and other means, all subject to our compliance with applicable laws. We may also link Personal Information (including your name, mobile phone number, and e-mail address) with non-personal information (including information automatically collected as described in this Policy) and use such linked information for our own marketing purposes. If you do not want us to use your Personal Information for marketing purposes, you may opt-out in accordance with the “Managing Your Personal Information” section below.
4.2 Non-Marketing Purposes.
We may use the Personal Information we collect for non-marketing purposes, including: (1) validating your identity; (2) fulfilling orders; (3) communicating with you and other third parties about orders; (4) sending you emails to provide you with alerts and updates about your engagement with our Operations; (5) conducting statistical or demographic analysis; (6) complying with legal and regulatory requirements; (7) customizing your experience with our Operations; (8) protecting and defending Semper Foods against legal actions or claims; (9) preventing fraud; (10) satisfying contractual obligations; (11) cooperating with law enforcement or other governmental agencies for purposes of investigations, national security, public safety or matters of public importance when we believe that disclosure of Personal Information is necessary or appropriate to protect the public interest; and (12) for other business purposes permitted under applicable law.
4.3 Use of Anonymized and Other Non-Identifying Information.
We may also use anonymized or aggregated information to conduct research studies and for other purposes.
5. SHARING PERSONAL INFORMATION WITH THIRD PARTIES
For business purposes, we may share certain Personal Information we collect in connection with our Platform from and about you, and about your relationship with us, with certain third parties. Doing so allows us to conduct our Operations. This section describes the categories of third parties we may share your Personal Information with and the purposes for that sharing.
5.1 Your Employer.
We may provide your Personal Information and other information about your interaction with our Operations to your employer, including, but not limited to, your activities on our Sites, where we need to do so in order to fulfill orders, submit invoices, or otherwise fulfill our obligations under our agreements or other arrangements with your employer.
5.2 Third Party Service Providers.
Your Personal Information may be shared with or collected by third parties who provide services to us, including, but not limited to, marketing, data hosting or processing. We require these third party service providers to exercise reasonable care to protect your Personal Information and restrict their use of your Personal Information to the purposes for which it was provided to them.
5.3 Sale of our Business; Bankruptcy.
5.4 Compliance with Laws and Law Enforcement.
We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. To the extent permitted under applicable law, we may disclose any information about you to government or law enforcement officials or private parties as we believe is necessary or appropriate to investigate, respond to, and defend against legal claims, for legal process (including subpoenas), to protect the our property and rights or those of a third party, to protect us against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive, or legally actionable activity, to protect the security or integrity of our Operations and any equipment used to make the Sites available, or to comply with applicable law.
5.5 As Directed by You.
Upon your consent and/or pursuant to your instructions, we will share your Personal Information, including your authorization to disclosure such Personal Information, with others.
5.6 Anonymous Information.
We may provide anonymized information to third parties. Any anonymized information we provide to third parties is not considered Personal Information and is not subject to the terms of this Policy.
6. THIRD PARTY PERSONAL INFORMATION COLLECTION
Based on the nature of our Operations, third parties may collection information from or about you. This section describes the different categories of third parties that may collect information about you in connection with our Operations.
6.1 Linked Third Party Content.
Any links to other websites, applications or other third party content on our Websites or Apps, are not an endorsement, authorization or representation of our affiliation with that third party and we are not responsible for the content, privacy and security policies and practices of any third party. We encourage you to read the privacy policies or statements applicable to any third party websites, applications or content you access.
6.2 Third Party Cookies and Other Tracking Technologies.
d. LinkedIn Insight Tag. We may use LinkedIn Insight Tag, a web analytics service provided by LinkedIn that places a cookie enabled by LinkedIn, to enable us to measure the effectiveness of advertising campaigns served on LinkedIn. The information collected by that cookie will be transmitted and stored by LinkedIn. For more information about LinkedIn’s privacy practices, please refer to https://www.linkedin.com/legal/privacy-policy. To opt out, you can update your advertising preference through your LinkedIn account. If you do not have a LinkedIn account, LinkedIn allows you to opt-out of targeted advertising by visiting https://www.linkedin.com/psettings/guest-controls.
7. MANAGING YOUR PERSONAL INFORMATION
We offer you several choices with respect to how we use your Personal Information. This section describes the mechanisms available to you to control the Personal Information we use about you in connection with our Operations.
7.1 Tools to Contact Us.
If you want to update any Personal Information you have provided us, update your preferences, control communications we need to send you or otherwise contact us about your Personal Information, you can:
a. Send us an email at email@example.com; or
b. If you have an account with us, by accessing the Account Settings feature available when you are logged into our Sites.
7.2 Additional Tool for Communications.
For email communications you receive from us, you may opt-out of receiving such communications by following the unsubscribe instructions contained in most email messages from us. Your unsubscribe request or email preference changes will be processed promptly, though this process may take several days. During that processing period, you may receive additional emails from us. Please note, opting out of email communications will only apply to marketing and other promotional emails and will not apply to any email or other communications sent for non-marketing purposes, including, but not limited to, emails and other communications about your use of the Platform.
7.3 Targeted Advertising.
If you do not want us to use Personal Information that we collect, or that you provide, to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an email with your request to firstname.lastname@example.org. We do not control third parties’ collection or use of your Personal Information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your Personal Information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website, located at https://www.networkadvertising.org/.
8. SECURITY OF YOUR PERSONAL INFORMATION
We are committed to protecting the security of your Personal Information. We maintain commercially reasonable safeguards to maintain the security and privacy of Personal Information we collect and use in connection with our Operations. Nevertheless, when disclosing Personal Information, you should remain mindful that there is an inherent risk in the use of email and the internet. Your Personal Information and other information may be intercepted without our knowledge or consent, collected illegally and/or used by third parties that are not affiliated with and/or controlled by us. We cannot guarantee the security of any information, including your Personal Information, that you disclose online, and you do so at your own risk.
9. CHILDREN’S PRIVACY
Our Operations are not intended for anyone under 18 years of age. We do not knowingly collect or allow the collection of Personal Information in connection with our Operations from anyone under the age of 13. If we learn that we have collected the Personal Information of anyone under the age of 13, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 13 and discover that your child has submitted Personal Information to us, you may contact us at email@example.com and ask us to remove your child’s Personal Information from our systems.
10. INTERNATIONAL TRANSFERS.
Personal Information collected through our Operations may be stored and processed in any country in which we or our parent companies or other affiliates, suppliers, service providers or agents maintain facilities. By using the Sites, or otherwise engaging with us or our Operations, you expressly consent to any transfer of Personal Information outside of your country (including to third countries that may not have been assessed as having adequate privacy laws). Nevertheless, we take steps to ensure that our parent companies or other affiliates, suppliers, service providers and agents comply with our standards of privacy regardless of their location.
11. CALIFORNIA PRIVACY RIGHTS
Under California’s Shine the Light Law, you have the right, once per calendar year, to request information from us regarding the manner in which we share certain categories of Personal Information with third parties for their direct marketing purposes, in addition to the other rights described in this Policy. Under California’s Shine the Light Law, you have the right to send us a request at the designated email address provided below to receive the following information:
a. the categories of Personal Information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
b. the names and addresses of the third parties that received the information; and
c. if the nature of the third party’s business cannot be determined from their name, examples of the products or services they market.
This information may be provided in a standardized form that is not specific to you. The designated email address for these requests is firstname.lastname@example.org.
12. UPDATES TO THIS POLICY
You agree that your use of the Sites and otherwise providing us with Personal Information in connection with our Operations constitutes your agreement with this Policy. We reserve the right to change this Policy at any time. If we decide to change this Policy, we will post those changes on this page so that you are always aware of what Personal Information we collect, how we use it and under what circumstances we disclose it. As we may make changes to this Policy from time to time, with or without notifying you, we suggest that you periodically consult this Policy for any changes. Your continued use of the Sites or other engagement with our Operations after the effective date of any modification to this Policy will be deemed to be your agreement to the changed terms.
13. CONTACT US
We welcome your questions, comments and concerns about privacy. Please email us at email@example.com with your feedback pertaining to privacy. You may also write to us at:
Semper Foods, LLC Attention: Semper Foods - Data Team 7000 W Palmetto Park Rd #210 Boca Raton, FL 33433