Effective Date: January 1, 2024

CALIFORNIA PRIVACY RIGHTS ACT – PRIVACY NOTICE

Pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, the “CCPA”), Ventura Foods, LLC, and its subsidiaries (“Ventura Foods,” “we” or “our”) is providing the following details regarding the categories of Personal Information that we collect, use, retain and disclose about California residents. This Privacy Notice does not apply to our job applicants, employees, contractors, owners, directors, or officers where the Personal Information we collect about those individuals relates to their current, former, or potential role at Mitsui USA. Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household.

NOTICE AT COLLECTION

Categories of Personal Information Collected and Disclosed 

The following chart details which categories of Personal Information about California residents we collect, as well as which categories of Personal Information we have collected and disclosed for our operational business purposes in the preceding 12 months.

We may also disclose the above categories of Personal Information to a third party in the context of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). 

Purposes for the Collection, Use, and Disclosure of Personal Information  

We collect, use, or disclose Personal Information for the purposes of operating, managing, and maintaining our business, providing our products and services, and accomplishing our business purposes and objectives, including to:  

• Develop, improve, repair, and maintain our products and services; 
• Fulfill your requests and process your transactions;   
• Personalize, advertise, and market our products and services;  
• Conduct research, analytics, and data analysis;  
• Disclose Personal Information to our service providers to enable them to provide services to us such as information technology and related infrastructure provision, email delivery, customer service, auditing, and other services; 
• Maintain our property and our records, and undertake quality and safety assurance measures;  
• Conduct risk and security control and monitoring, and detect and prevent fraud;  
• Perform identity verification, accounting, audit, and other internal functions, such as internal investigations and record-keeping;  
• Carry out corporate transactions, such as mergers, joint ventures or acquisitions; and 
• Comply with law, legal process, and internal policies, and exercise and defend legal claims. 

Purposes for the Collection, Use, and Disclosure of Sensitive Personal Information  

We collect, use, and disclose Sensitive Personal Information for purposes of: performing services on behalf of our business; providing goods or performing services as requested by you; ensuring security and integrity, short term transient use such as displaying first party, non-personalized advertising; order processing and fulfillment; servicing accounts and providing customer service; verifying customer information; processing payments; providing financing; activities relating to quality and safety control or product improvement; securing the access to, and use of, our facilities, equipment, systems, networks, applications, and infrastructure; preventing, detecting, and investigating security incidents; resisting and responding to fraud or illegal activities; and other collection and processing that is not for the purpose of inferring characteristics about an individual.   

We do not sell or “share” (for purposes of cross-context behavioral advertising, as defined under the CCPA) Personal Information, and we have not engaged in such activities in the preceding 12 months.  Without limiting the foregoing, we do not sell or “share” the Personal Information, including the Sensitive Personal Information, of minors under 16 years of age.  

You can view the Ventura Foods Privacy Policy here. 

Retention Period 

We retain each category of Personal Information, including Sensitive Personal Information, for as long as needed or permitted in light of the purpose(s) for which it was collected.  The criteria used to determine our retention periods include:   

• The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using our services) and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;  
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or  
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations). 

Sources of Personal Information  

We collect Personal Information from: 

• Our interactions with you, such as through our websites, surveys and questionnaires, emails, social media, and any other online or offline interactions, such as when you contact us via phone or attend one of our events; and 
• Our affiliates, publicly available online sources, joint marketing partners, and business partners.   

Individual Rights and Requests 

If you are a California resident, you may make the following requests: 

1. You may request that we disclose to you the following information:  
   1. The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information; 
   2. The business or commercial purpose for collecting Personal Information about you; and 
   3. The categories of Personal Information about you that we disclosed, and the categories of third parties to whom we disclosed such Personal Information (if applicable). 
2. You may request to correct inaccuracies in your Personal Information. 
3. You may request to have your Personal Information deleted. 
4. You may request to receive the specific pieces of your Personal Information, including a copy of the Personal Information you provided to us in a portable format. 

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA. 

To make a request, please contact us utilizing the CCPA Web-form or at [email protected] or 1-877-VENTURA (1-877-836-8872). We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request.  We may need to request additional Personal Information from you, such as mailing address, telephone number and/or email address, in order to verify your identity and protect against fraudulent requests.  If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information.  If you make a deletion request, we may ask you to verify your request before we delete your Personal Information.  

Authorized Agents 

If an agent would like to make a request on your behalf as permitted by applicable law, the agent may use the submission methods noted in the section entitled “Individual Rights and Requests.”  As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent.  In addition, we may require that you verify your identity as described in the section entitled “Individual Requests” or confirm that you provided the agent permission to submit the request. 

De-Identified Information  

Where we maintain or use de-identified information, we will continue to maintain and use the de-identified information only in a de-identified fashion and will not attempt to re-identify the information. 

Changes to this Privacy Notice 

We may change or update this Privacy Notice from time to time.  When we do, we will post the revised Privacy Notice on this page with a new “Last Updated” date.  

Contact Us 

If you have any questions regarding this Privacy Notice, please contact us at [email protected] or at: 

Ventura Foods, LLC 

40 Pointe Drive 

Brea, CA 92821 

Attention:  Chief Privacy Officer/General Counsel 

Telephone: (714) 257-3710 

Facsimile: (714) 262-4115