Ventura Foods, LLC
Effective Date September 30, 2013
YOUR CALIFORNIA PRIVACY RIGHTS
Table of Contents
- Personal Information Ventura Foods Collects
- How Ventura Foods Uses Personal Information
- Posting in Public Forums
- Updating Your Personal Information and Subscriptions
- Data Security
- Note to Parents
- Consent to Transfer Outside United States
- 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.
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:
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;
- 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 may delete certain records that contain Personal Information you have submitted through the Site. 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.
Ventura Foods may share non-personally identifiable information, including aggregated statistics and Usage Information that is not associated with Personal Information, with third parties. Ventura Foods may share Personal Information and Usage Information (collectively, “Information”) with third parties or nonaffiliated companies as follows:
Service Providers – We may share 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 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 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.
Promotions – We may disclose your Personal Information to third parties in connection with the administration of such 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.
EEOC/Affirmative Action Reporting – We may ask you to provide us with self-identifying information (such as veteran status, gender and ethnicity) in conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission the Office of Federal Contract Compliance Programs and similar state and local regulatory agencies.
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.
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.
Note to Parents – This is a general audience site and does not knowingly collect Personal Information from children (“Child”). If you are a Child younger than 13 years of age, please do not send any information about yourself to us. If we are become aware that a Child has submitted Personal Information to the Site, we will delete that Child’s Personal Information.
Consent to Transfer Outside United States – The Site is operated in the United States and intended for residents of the United States. If you are located outside of the United States, be aware that Information we collect will be transferred to the United States. By using the Site, accessing the Site or providing your Information to the Site or Ventura Foods, you consent to this transfer.
CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT
Ventura Foods is dedicated to conducting business in a lawful and ethical manner. Doing so sustainably requires that we balance the social, environmental and economic benefits and risks of our products. Suppliers play a key role in our efforts to ensure that we manage our global supply chain in a sustainable way. Our policy is to only work with suppliers who share our commitment to socially responsible and ethical business practices. Ventura Foods expects its suppliers to obey all laws, regulations and other governmental authorities of any country in which they do business, and to conduct themselves in a professional and ethical manner.
Ventura Foods’ commitment to ensuring that its supply chain is maintained in a socially responsible way includes, among other things, an expectation that suppliers not use forced labor of any kind, including human trafficking and slavery, to produce the products they provide to Ventura Foods. To monitor compliance with its expectations, Ventura Foods encourages suppliers to sign a written certification that it complies with all laws and regulations, including those relating to slavery and human trafficking.
Further, Ventura Foods audits potential new and current suppliers from time to time to determine if they are meeting the requirements of Ventura Foods. On an annual basis, suppliers are selected for audit using a risk-based approach. Supplier participation in the audit process is mandatory and failure to meet the requirements of Ventura Foods may result in discontinuation of the supplier relationship.
Suppliers are also encouraged to enter into written agreements with Ventura Foods. Ventura Foods’ purchasing agreements require suppliers to comply with applicable laws within the country of business, including those laws regarding human trafficking and slavery, and specify the requirements by which our suppliers must abide.
Ventura Foods encourages its employees who are responsible for supply chain management to obtain training on how to mitigate risks within the supply chain. Such training may include internal presentations, seminars or webinars.
Ventura Foods recognizes the importance of fair labor practices and is committed to doing its part to eradicating slavery and human trafficking. Ventura Foods maintains internal accountability procedures for its employees and contractors. Ventura Foods also provides ethical and compliance training on the company standards and code of conduct for its employees and management.