California Privacy Policy

ROLAND FOODS, LLC
Website Privacy Policy for California Residents
Effective Date: October 27, 2021

Introduction

This Website Privacy Policy for California Residents (the “California Privacy Policy”) supplements the information contained in Roland Foods, LLC’s Privacy Policy (https://www.rolandfoods.com/privacy-policy/) and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). The purpose of this California Privacy Policy is to inform you of the business practices of Roland Foods, LLC (“Roland Foods” or the “Company” or “we” or “us”) regarding the collection, use, and disclosure of anonymous and/or personal information while on the Roland Foods website (“Website” or “Site”), and the categories of and purposes for which we use such personal information. We adopt this California Privacy Policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”); any terms defined in the CCPA have the same meaning when used hereafter. This California Privacy Policy addresses the various categories of personal information collected by the Site, the purpose of the collection, and the rights afforded to California residents in accordance with the CCPA.

1. Notice of Collection

Through the Website, we may collect two types of information from consumers: anonymous use information and personally identifiable information (“personal information”).

Anonymous use information may be collected by our Site automatically as you and others browse. Such information may include the identity of your Internet service provider and its approximate geographic location, the operating system of your computer, the type of web browser you are using, the identity of the website that referred you to our Site, the time and date that you access the Site, and the web pages or content that you view. This information may be aggregated and utilized to analyze web traffic and usage or to improve the design and content of the Site.

Personal information, by contrast, is 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, household, or device. Personal information is collected by Roland Foods only if you voluntarily provide it. Reasons for supplying the information to us include agreeing to receive a newsletter, requesting information about products, or otherwise participating in features of our Site that ask for personal information. Such requested information may include your name, company, and email address. If you correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we use to maintain information received by mail and telephone.

Personal information does not include:

• Publicly available information from government records;
• Deidentified or aggregated consumer information; or
• Information excluded from the CCPA’s scope, like personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, our Website has collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, address, or telephone number.
C. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

As previously mentioned, we obtain the categories of personal information listed above from the following categories of sources:

• Directly from you; for example, from forms you complete or correspondence you engage in.
• Indirectly from you; for example, from observing your actions on our Website.

2. Use of Collected Information

We may use or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry.
• To create, maintain, customize, and secure your account or newsletter subscription with us.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

3. Disclosure of Collected Information to Third Parties

The Company does not share users’ personally identifiable information with third parties. We do not disclose any user information other than aggregated statistics related to the Site’s traffic, customer demographics, and related information, which is measured using anonymous ClientID numbers assigned to visitors. We may provide this anonymous use data to third parties such as analytics consultants and website management vendors who assist with Website analysis and activity monitoring. We require that these third parties not use the disclosed information for any purpose other than the provision of these services, and we require them to comply with our privacy and security practices. Any anonymous data shared with these third parties is used strictly for internal reporting purposes.

In the event we sell or transfer all or a portion of our business assets, including a brand or line of business, consumer information may be one of the business assets that is transferred as part of the transaction.

We reserve the right to disclose any user information when we believe that doing so is required by law or necessary to protect the property, rights, or safety of ourselves, visitors to our Sites, or other persons, or in the context of a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, where there is a pledge of confidentiality from the receiving party.

4. Company’s Disclosure of Personal Information for a Business Purpose

In the preceding twelve (12) months, the Company has not disclosed personal information for a business purpose to third parties.

5. Company’s Sales of Personal Information

In the preceding twelve (12) months, the Company has not sold any personal information.

6. Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. Below we describe your CCPA rights and explain how to exercise those rights.

Right to Know and Data Portability

You have the right to request that the Company disclose certain information to you about our collection and use of your personal information over the past twelve (12) months (the “right to know”). Once we receive your request and confirm your identity, we will disclose to you:

• The categories of personal information we collected about you.
• Our business purpose for collecting that personal information.
• The specific pieces of personal information we collected about you.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, or take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a verifiable consumer request to us by either:

• Calling us at 800-221-4030; or
• Emailing us at [email protected].

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a request to know or delete on behalf of your child by contacting us via the methods described above.

You may only submit a request to know twice within a twelve (12)-month period. Your request to know or delete must:

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

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 that the personal information relates to you. You do not need to create an account with us to submit a request to know or delete. We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

Response Timing and Format

We will endeavor to respond to your request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Any disclosures we provide will cover only the twelve (12)-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by PDF. We will not charge a fee to process or respond to your 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 your request.

7. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; or
• Suggest that you may receive a difference price or rate for goods or services or a different level or quality of goods or services.

8. California Job Applicant Privacy Policy

Please read our California Job Applicant Privacy Policy to learn how we collect, use, and disclose the personal information of California residents when they apply for a job or other role with us.

9. Other California Privacy Rights

California’s "Shine the Light" law (Civil Code § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected] or write us at Roland Foods, LLC at 71 W. 23^rd Street, Suite 1200, New York, NY 10010.

10. Changes to Our California Privacy Policy

The Company reserves the right to amend this California Privacy Policy at its discretion and at any time. When we make changes to this California Privacy Policy, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

11. Contact Information

If you have any questions or comments about this California Privacy Policy, the ways in which Roland Foods collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 800-221-4030
Website: rolandfoods.com
Email: [email protected]

Postal Address:
Roland Foods, LLC
Attn: Legal Department
71 W. 23^rd Street, Suite 1200
New York, NY 10010

If you need to access this California Privacy Policy in an alternative format due to having a disability, please contact [email protected] or call 800-221-4030.