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Privacy Policy

Brekki Foods, LLC

INTRODUCTION

At Brekki Foods, LLC (“Brekki” or “we” or “us” or “our”) we take our responsibility to protect and respect your privacy seriously, and want to make sure that you understand how we use your data.

This policy describes the types of information Brekki may collect from you or that you may provide when you visit the website [www.brekki.com] (the “Website”) or when you fill out a form, send us your recipes, or contact us through the Website. It also explains how we collect, use, maintain, protect, and, in some circumstances, disclose that information. Simply put, we do not sell Website users’ personal information. As described more fully below, Brekki values the information it has about people who access or interact with the Website, which we use to enhance their experience.

Certain information we collect is necessary to complete our contractual or legal obligations, others are required for us to operate the Website. In some instances, the information we collect may be done only with your consent.

Please read this policy carefully to understand Brekki’s policies and practices regarding your information and how we will treat it. If you do not agree with Brekki’s policies and practices, you may choose to not provide us with the requested information or to decline to use the Website. By accessing or using the Website, and/or by providing Brekki with your information, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy).

We may change this policy from time to time. We encourage you to review this policy each time you visit our Website. By using our Website, you agree to the terms of the most recent version of this policy.

WHAT INFORMATION ABOUT ME DO YOU COLLECT AND HOW DO YOU COLLECT IT?

Information You Give Us:
Brekki receives and stores information you enter on the Website or give us in any other way. This information may include, for example, your:

  • Name
  • Telephone number
  • Postal Address
  • E-mail address
  • Date of birth

We’ll refer to this information, and any 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, as “personal information.” In some instances, we de-identify data by removing personal information. Once de-identified, the data is no longer attributed to a single unique individual. De-identified information is non-personal information that we may treat like other non-personal information.
You may submit this information to Brekki by, for example:

  • filling in forms on the Website;
  • contacting us through the Website or by email;
  • entering a contest or promotion sponsored by Brekki;
  • submitting a recipe through the Website;
  • taking a survey; or
  • running search query on the Website.

We use the information that you provide for such purposes as responding to your requests, keeping you informed of news and information about Brekki, customizing future visits to our site, improving Brekki’s Website or products, and communicating with you.

If you do not want us to have this information, you can choose not to provide it to us, but then you might not be able to take advantage of many of Brekki’s services or features. See “What Are My Choices?”

Information We Collect Automatically:

As you navigate through and interact with the Website, Brekki may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • browser and device information;
  • information collected through cookies, pixel tags and other technologies;
  • demographic information and other information provided by you;
  • your device location;
  • usage data including information about how you use our Website and what you do while you’re there;
  • information from referring website;
  • marketing and communications data including your preferences in receiving marketing from us and your communication preferences; or
  • your zip code, postal code or area code when they are not connected to other personal information.

We’ll refer to this information as “site-usage information” as it is information collected about your use of and interaction with the Website that does not reveal your specific identity, does not directly relate to an individual, and cannot be readily connected back to an individual.

The information Brekki automatically collects does not include your name or other directly personal data, but we may maintain it or associate it with personal information we collect in other ways.

HOW DO YOU USE COOKIES?

Brekki uses different types of cookies to automatically collect certain data to improve your experience with the Website, and to allow us to track certain information about how visitors use the Website. We do not share or sell any data collected by our cookies. Brekki uses the following kinds of cookies to enhance your Website experience:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. When you first visit the Website, you are alerted to the fact that we use cookies. You can decline the cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Website. Unless you have declined cookies when you first visit or adjusted your browser setting so that it will refuse cookies, Brekki’s system will issue cookies when you direct your browser to the Website. For information about managing your privacy and security settings for cookies, see “What Are My Choices?”
  • Flash Cookies. Certain features of the Website may use locally stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Website. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see “What Are My Choices?”
  • Web Beacons. Pages of the Website and Brekki emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Brekki, for example, to count users who have visited those pages or opened an email, and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
  • Social Media Pixel Tags. Brekki uses pixel tags, a type of web beacon, on social media sites, to serve relevant and targeted advertisements to you during or after your visits to our social media presence.

To learn more about cookies, please visit the external site https://allaboutcookies.org/.

MIGHT I ENCOUNTER ANY THIRD-PARTY COOKIES?

Some content or applications on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

Brekki does not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

WHAT ABOUT GOOGLE ANALYTICS?

This website uses functions of Google Analytics, a web analysis service provided by Google Inc. (“Google”), 1600 Amphitheatre Parkway, Mountain View, CA 94043. Google Analytics uses cookies, that are saved to your computer and that allow your usage of the website to be analyzed. The information generated by the cookie about your use of this website (including your IP address) is generally transmitted to and stored by Google servers.

This technology allows website visitors who are already interested in our website to be addressed with advertising on our partners’ websites. The inclusion of this advertising on our partners’ websites takes place using cookie technology and an analysis of previous

browsing behavior. This analysis is carried out using a pseudonym. No usage profile is connected with your personal data.

Google will use this information in order to assess your use of the website, in order to compile reports about website activities for the website operators and in order to provide further services related to the use of the website and the internet. Google may also forward this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Under no circumstances will Google associate your IP address with any other data held by Google. You can find more information about how your user data is handled by Google Analytics in Google’s data privacy Policy: https://support.google.com/analytics/answer/6004245?hl=en

By using this site, you agree to the processing of data about you by Google in the manner described above and for the aforementioned purpose.

You can prevent data collection by Google Analytics by clicking on the following link: https://tools.google.com/dlpage/gaoptout. This places an opt-out cookie, which prevents the future collection of your data when visiting this (or other) websites. This opt-out cookie must be stored permanently on your computer. If you delete this cookie or it is deleted automatically via browser settings, you will have to install this cookie again when visiting our website in the future.

HOW DO WE USE YOUR INFORMATION?

Brekki uses information that we collect about you or that you provide to us, including any personal information, in order to:

  • Present the Website and its contents to you
  • Send you important information regarding the Website, such as certain changes to our terms, conditions, policies and/or administrative information
  • Permit you to participate in sweepstakes, contests and similar promotions
  • To provide you with information via email about new Brekki product offerings on an ongoing basis, unless you opt out of receiving such emails
  • Respond to any questions or comments you have made to us
  • Allow you to participate in interactive features on the Website
  • Provide you with information about your recent visits
  • Determine your general location to enable you to access information relevant to you based on your location
  • For internal business purposes, including for improving our business, by making use of data analysis, audits, developing new products, enhancing our website, improving our services, identifying usage trends and determining the effectiveness of our promotional campaigns
  • In other way we may describe when you provide us the information
  • For purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy
  • For any other purpose, with your consent

Brekki may also, with your consent, use your information to contact you about goods and services that may be of interest to you.

If you want to remove yourself from this list at any time, please press the unsubscribe button on any of our emails or contact us at privacy@Brekki.com. For more information, see “What Are My Choices?”

DO YOU SHARE PERSONAL INFORMATION WITH OTHERS?

Brekki values the information it has about its people who access or interact with the Website and is not in the business of selling it to others. We do occasionally need to share your information for the purpose of conducting our business with you or to comply with legal obligations. For example, under certain circumstances, Brekki may need to disclose collected personal information in order to:

  • Disclose to trusted third parties, including service providers, who are bound by contractual obligations to keep personal information confidential, to support our business, and to use it only for the purposes for which we disclose it to them
  • Comply with any court order, law, legal process, or to respond to any government or regulatory request, including requests related to laws outside of your country of residence
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us
  • Protect the rights, property, or safety of Brekki, its employees, customers, or others
  • Enforce our terms and conditions
  • When you request information from or provide information to third parties
  • Permit us to pursue available remedies and/or limit the damages that we sustain
  • Fulfill our recordkeeping obligations and practices
  • Fulfill any other purpose disclosed by us when you provide the information
  • Comply with your instructions or, if allowed to do so, with your consent.

We may also need to provide the collected personal information to a buyer or other successor in the event of a possible or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Brekki’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Brekki about the Website users is among the assets transferred.

DOES THIRD-PARTY CONTENT OR LINKS TO THIRD-PARTY SITES APPEAR ON THE SITE?

The Website may contain content that is supplied by a third party, such as [Instagram], and those third parties may collect usage information and your device identifier when pages from the Website are served to you. In addition, when you are on the Website you may be directed to other services that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you “click” on a link, the “click” may take you off the Website onto a different site. These other sites may associate their Tracking Technologies with you, independently collect data about you or others, including Personal Information, and may or may not have their own published privacy policies. We encourage you to note when you leave our Website and to review the third-party privacy policies of all third-party websites and exercise caution in connection with them.

DOES THIRD-PARTY CONTENT OR LINKS TO THIRD-PARTY SITES APPEAR ON THE SITE?

The Website may contain content that is supplied by a third party, such as [Instagram], and those third parties may collect usage information and your device identifier when pages from the Website are served to you. In addition, when you are on the Website you may be directed to other services that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you “click” on a link, the “click” may take you off the Website onto a different site. These other sites may associate their Tracking Technologies with you, independently collect data about you or others, including Personal Information, and may or may not have their own published privacy policies. We encourage you to note when you leave our Website and to review the third-party privacy policies of all third-party websites and exercise caution in connection with them.

HOW DO YOU USE SITE-USAGE INFORMATION?

Because your site-usage information does not personally identify you, we and our third-party service providers may use such information for any purpose. Brekki may also use or disclose aggregated information that does not identify individual users without restriction.

HOW DO YOU PROTECT MY INFORMATION?

We and our third-party service providers use reasonable organizational, technical and administrative measures in an effort to protect the information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Any transmission of personal information is at your own risk.

Please do not send us sensitive information through email. If you have reason to believe that your interaction with us is not secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us in accordance with the “Contact Us” section below. (Note that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the problem.)

WHAT ARE MY CHOICES?

You can always choose not to provide information, even though it might be needed to take advantage of some offers or features of the Website.

You can decline to accept cookies, set your browser to block cookies, or erase Brekki’s cookies from your computer, though doing so may prevent some aspects of the Website from working properly. As discussed above, third-party cookies may also be active on the Website. If you would like more information about this practice and to learn how to opt out of it on the device on which you are reviewing this Privacy Policy, please visit: http://www.networkadvertising.org/managing/optout.asp and http://www.aboutads.info/

You can also prevent data collection by Google Analytics by clicking on the following link: https://tools.google.com/dlpage/gaoptout. This places an opt-out cookie, which prevents the future collection of your data when visiting this (or other) websites. This opt-out cookie must be stored permanently on your computer. If you delete this cookie or it is deleted automatically via browser settings, you will have to install this cookie again when visiting our website in the future.

If you no longer want to receive email or other mail from Brekki, please press the unsubscribe button on any of our emails or contact us at privacy@brekki.com.

If you want to exercise your rights over your data pursuant to CCPA, GDPR or any similar law, please email us at privacy@brekki.com.

HOW LONG DO WE KEEP YOUR DATA?

Brekki only keeps your personal data for as long as necessary for the purposes for which we collected it unless a longer retention period is required or permitted by law.

CAN I ACCESS OR CORRECT MY INFORMATION?

You may send Brekki an email at privacy@brekki.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change or delete information if it is believed that the change would violate any

law or legal requirement, cause the information to be incorrect, or if we can’t verify your identity.

If you wish to delete your User Contributions, defined below, that you yourself have provided for our Website please email us at privacy@brekki.com but please be aware that copies of this content may remain viewable in cached and archived pages, or might have been copied or stored by other Website users.

CAN I PROVIDE ANY DATA FOR INCLUSION ON THE WEBSITE?

Some parts of the Website allow you to contribute information to us such as questions, comments, suggestions, ideas, feedback, or recipes (“User Contributions”). You acknowledge and agree that any User Contributions provided by you to Brekki are non-confidential and shall become the sole property of Brekki. Brekki shall own exclusive rights, including all intellectual property rights, and shall be entitled to the unrestricted use and dissemination of these User Contributions for any purpose, commercial or otherwise, without acknowledgment or compensation to you.

CHILDREN UNDER THE AGE OF 13

The Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. Brekki does not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Website or on/through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of the Website, or provide any information about yourself to Brekki, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn that we have collected or received personal information from a child under 13 without verification of parental consent, the information will be deleted. If you believe we might have any information from or about a child under 13, please contact us at privacy@brekki.com.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, please see our California Resident Privacy Rights Notice https://brekki.com/california-privacy-policy/

OTHER STATE PRIVACY RIGHTS

Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

  • Confirm whether we process their Personal information.
  • Access and delete certain Personal Information.
  • Correct inaccuracies in their Personal Information, taking into account the information’s nature processing purpose (excluding Iowa and Utah).
  • Data portability.
  • Opt-out of personal data processing for:
    o targeted advertising (excluding Iowa);
    o sales; or
    o profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
  • Either limit (opt-out of) or require consent to process sensitive personal data.

You might not be able to exercise these rights to the extent that you have entered Personal Information into the interface prompt for the application, which we prohibit. The exact scope of these rights may vary by state. To exercise any of these rights please contact us at info@cg3.com. To appeal a decision regarding a consumer rights request email us at info@cg3.com with an explanation about your concerns about our decision.

GDPR

If you are a European Union resident, or are otherwise a data subject covered by the European Union’s General Data Protection Regulation (GDPR) or similar laws in other countries, you may have certain rights in relation to your Personal Information. Such rights may include the right to:

  • Request access to your Personal Information (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You may also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing
    (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request
  • Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also may have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your Personal Information to you or to a third party. This enables you, or a third party you have chosen, to seek to have your Personal Information provided in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You will not have to pay a fee to exercise any of these rights. However, we may charge a reasonable fee if your request is repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests in a timely manner. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. We may also need to contact you about your request to verify your identity, confirm certain information, or clarify the request before we can fulfill the request.

If you are a European Union resident, or are otherwise data subject covered by GDPR or a similar law and would like to exercise these rights or otherwise have questions about your rights please contact us at privacy@brekki.com.

TRANSFER OF INFORMATION TO THE UNITED STATES

Our Website is operated in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Website or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.

CHANGES TO OUR PRIVACY POLICY

It is Brekki’s policy to post any changes it makes to its privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If Brekki makes material changes to how it treats its users’ personal information, we will notify you by email to the primary email address specified in your account and/or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring that we have an up-to-date, active, and deliverable email address for you, and for periodically visiting the Website and this privacy policy to check for any changes. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

HOW CAN I CONTACT YOU?

To ask questions or comment about this privacy policy and Brekki’s privacy practices, contact us at:

privacy@brekki.com
(877) 825-9772

Brekki Foods, LLC
50 Foundation Avenue
Ward Hill, Massachusetts 01835