Privacy Policy California

Effective Date: January 1, 2020

This Privacy Notice for California Residents supplements the information contained in Shamrock Food Company’s General Privacy Notice found on our website and applies to visitors, users, and others who reside in the State of California (”consumers” or “you”). Consumers residing in California have certain rights with respect to their personal information under the California Consumer Privacy Act or (“CCPA”) (California Civil Code Section 1798.100 et seq.).

 

1. Information We Collect

“Personal information,” as defined in the CCPA, includes “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Cal. Civ. Code § 1798.140(o).  Personal information does not include:

– Publicly available information from government records.

– Deidentified or aggregated consumer information.

– Information excluded from the CCPA’s scope, like:

– health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

– personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Shamrock has collected the following categories of personal information from its consumers within the last twelve (12) months:

– Identifiers;

– Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e));

– Commercial information;

– Internet or other similar network activity information;

– Professional or employment-related information;

– Characteristics protected under California or federal law;

– Inferences drawn from other personal information.

Shamrock obtains the categories of personal information listed above from the following categories of sources:

– Directly from you. For example, from forms you complete or products and services you purchase.

– Indirectly from you. For example, from observing your actions on our website, social media or through third-party marketing services.

 

2. Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business or commercial 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. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

– To provide, support, personalize, and develop our website, products, and services.

– To process your requests, purchases, transactions, and payments and prevent transactional fraud.

– To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

– To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via email or text message (with your consent, where required by law).

– To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.

– For testing, research, analysis, and product development, including to develop and improve our website, products, and services.

– To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

– To better target or customize our messaging.

– Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

– Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

– Debugging to identify and repair errors that impair existing intended functionality.

– Short-term, transient use, provided the personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

– Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

– Undertaking internal research for technological development and demonstration.

– Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

– As described to you when collecting your personal information or as otherwise set forth in the CCPA.

 

3. Disclosures of Personal Information for a Business or Commercial Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business or commercial purpose:

– Identifiers;

– Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e));

– Commercial information;

– Internet or other similar network activity information;

– Professional or employment-related information;

– Characteristics protected under California or federal law;

– Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

– Our affiliates.

– Service providers like website developers, website hosts, and automated marketing software companies to facilitate marketing emails.

– Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

 

4. Your Rights and Choices

If you are a California resident, you have the right to (1) request more information about the categories and specific pieces of personal information we have collected, sold and disclosed for a business purpose in the last 12 months, (2) request deletion of your personal information, (3) opt out of the sale of your personal information, if applicable, and (4) be free from discrimination for exercising your rights under the CCPA.

You may make these requests by using the contact information found below.

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 verifiable consumer request on behalf of your minor child.

Note also that Shamrock may deny your deletion requests as permitted under the CCPA if it is necessary for the business or service provider to maintain the consumer’s personal information in order to:

– Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.

– Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.

– Debug to identify and repair errors that impair existing intended functionality.

– Comply with the California Electronic Communications Privacy Act.

– To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.

– Comply with a legal obligation.

– Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

Similarly, Shamrock may deny your deletion requests if:

– Shamrock is unable to verify your identity.

– Your information is maintained in a deidentified manner.

– If your information is stored on archived or back-up systems, your deletion request may be delayed until the archived or backup system is next accessed or used.

 

5. Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 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, write us at the address provided below.

 

6. Changes to Our Privacy Notice

We may change this privacy notice from time to time.  If we make changes, we will notify you by revising the date at the top of the privacy notice and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification).  We encourage you to review the privacy notice whenever you access our website or services or otherwise interact with us to stay informed about our information practices and the choices available to you.

 

7. Contact Information

If you have any questions or comments about this notice, please do not hesitate to contact us at:

Toll-free phone number: 833-415-0411

Website: https://shamrockfoods.truyo.com/consumer/index

Postal Address:

Shamrock Foods Company

Attn: Legal Department

3900 E. Camelback Road, Suite 300

Phoenix, AZ 85018