Brekki California Residents Privacy Policy

Effective Date: July 17, 2025

INTRODUCTION

This California Residents Privacy Policy describes how Brekki and its affiliates (collectively, “Brekki,” “Company,” “we,” or “us”) collect and process personal information about our consumers who reside in California. The California Consumer Privacy Act (“CCPA”) requires us to provide our California consumers with a privacy policy that contains a comprehensive description of our online and offline practices regarding our collection, use, sale, sharing, and retention of their personal information, along with a description of the rights they have regarding their personal information. This Privacy Policy provides the information the CCPA requires, together with other useful information regarding our collection and use of personal information. Any terms defined in the CCPA have the same meaning when used in this policy.

This Privacy Policy does not apply to our collection and use of personal information from residents outside of California. Consumers residing in other locations should see our general privacy notice at: www.brekki.com/privacy-policy/.

Personal Information Collected

We collect and use 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 or household (“personal information”). Personal information does not include:

Publicly available information, including from government records, through widely distributed media, or that the consumer made publicly available without restricting it to a specific audience.
Lawfully obtained, truthful information that is a matter of public concern.
Deidentified or aggregated consumer information.

Personal Information Categories Chart

The chart below identifies which categories of personal information we collected from our consumers within the last 12 months and the expected retention period.

Category	Examples	Collected	Retention Period
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	[YES/NO]	[RETENTION PERIOD]
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (“California Customer Records“).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	[YES/NO]	[RETENTION PERIOD]
C. Protected classification characteristics under California or federal law (“Protected Classes“).	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, reproductive health decisionmaking, military and veteran status, or genetic information (including familial genetic information).	[YES/NO]	[RETENTION PERIOD]
D. Commercial information.	Records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	[YES/NO]	[RETENTION PERIOD]
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	[YES/NO]	[RETENTION PERIOD]
F. Internet or other similar network activity.	Activity on our websites, mobile apps, or other digital systems, such as internet browsing history, search history, system usage, electronic communications with us, postings on our social media sites.	[YES/NO]	[RETENTION PERIOD]
G. Geolocation data.	Physical location or movements, such as the time and physical location related to use of our internet website, application, or device, and GPS location data from mobile devices of consumers who visit our website.	[YES/NO]	[RETENTION PERIOD]
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information, including customer service call monitoring and store video surveillance.	[YES/NO]	[RETENTION PERIOD]
I. Professional or employment- related information.	Current or past job history.	[YES/NO]	[RETENTION PERIOD]
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) (“FERPA Information“).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	[YES/NO]	[RETENTION PERIOD]
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	[YES/NO]	[RETENTION PERIOD]
L. Sensitive personal information.	As defined under applicable California law.	[YES/NO]	[RETENTION PERIOD]

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you, such as from the forms or other information you provide to the Company.
Indirectly from you, such as from your interactions with the Company’s website or social media platforms.
From our service providers, such as data analytics providers.

How We Use Personal Information
Personal Information Collection, Use, and Disclosure Purposes

We may use and disclose the personal information we collect to advance the Company’s business and commercial purposes, specifically to:

Develop, offer, and provide you with our products and services, including providing information about our food offerings.
Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or to comply with legal requirements.
Fulfil the purposes for which you provided your personal information or that were described to you at collection, and as the CCPA otherwise permits.
Improve our products or services, marketing, or customer relationships and experiences.
Notify you about changes to our products or services.
Administer our systems and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
Enable your participation in our website, social media, or other similar features.
Protect our Company, employees, or operations.
Measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
Make suggestions and recommendations to you and other consumers about our goods or services that may interest you or them[, including developing profiles.
Perform data analytics and benchmarking.
Administer and maintain the Company’s systems and operations, including for safety purposes.
Engage in corporate transactions requiring review of consumer records, such as for evaluating potential Company mergers and acquisitions.
Comply with all applicable laws and regulations.
Exercise or defend the legal rights of the Company and its employees, affiliates and customers.
Respond to law enforcement requests and as required by applicable law or court order.

Additional Categories or Other Purposes

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. If required by law, we will also seek your consent before using your personal information for a new or unrelated purpose.

We may collect, process, and disclose aggregated or deidentified consumer information for any purpose, without restriction. When we collect, process, or disclose aggregated or deidentified consumer information, we will maintain and use it in deidentified form and will not to attempt to reidentify the information, except to determine whether our deidentification processes satisfies any applicable legal requirements.

Disclosing, Selling, or Sharing Personal Information

Business Purpose Disclosures

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We have not disclosed consumers’ personal information to third parties for a business purpose in the preceding 12 months.

Selling or Sharing Personal Information

We do not sell your personal information to third parties and have not sold it in the preceding 12 months. We do not share your personal information with third parties for cross-context behavioral advertising purposes and have not shared your personal information in the preceding 12 months.

Your Rights and Choices

If you are a California resident, the CCPA grants you the following rights regarding your personal information:

Right to Know and Data Portability Requests

You have the right to request that we disclose certain information to you about our collection and use of your personal information (the “right to know“), including the specific pieces of personal information we have collected about you (a “data portability request“). Our response will cover the 12-month period preceding the request, although we will honor requests to cover a longer period that do not extend past January 1, 2022, unless doing so would be impossible or involves disproportionate effort. You may make exercise your right to know twice within in any 12-month period. Once we receive your request and confirm your identity, we will disclose to you:

The categories of:
· personal information we collected about you; and
· sources from which we collected your personal information.
The business or commercial purpose for collecting your personal information and, if applicable, selling or sharing your personal information.
If applicable, the categories of persons, including third parties, to whom we disclosed your personal information, including separate disclosures identifying the categories of your personal information that we:
· disclosed for a business purpose to each category of persons; and
· sold or shared to each category of third parties.
When your right to know submission includes a data portability request, a copy of your personal information subject to any permitted redactions.

Right to Delete and Right to Correct

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 and limitations (the “right to delete“). Once we receive your request and confirm your identity, we will delete your personal information from our systems unless an exception allows us to retain it and notify our service providers, contractors, and other recipients to take appropriate action.

You also have the right to request correction of personal information we maintain about you that you believe is inaccurate (the “right to correct“). We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct personal information that our review determines is inaccurate and notify our service providers, contractors, and other recipients to take appropriate action.

Personal Information Sales or Sharing Opt-Out and Opt-In Rights

You have the right to request that businesses stop selling or sharing your personal information at any time (the “right to opt-out“), including through a user-enabled opt-out preference signal. Similarly, the CCPA prohibits businesses from selling or sharing the personal information of consumers it actually knows are under 16 years old without first obtaining consent from consumers who are between 13 and 15 years old or the consumer’s parent or guardian for consumers under age 13 (the “right to opt-in“).

As we do not sell or share consumers’ personal data, we do not currently provide these consumer rights.

Right to Non-Discrimination

You have the right not to be discriminated or retaliated against for exercising any of your privacy rights under the CCPA.

How to Exercise Your Rights

Exercising the Rights to Know, Delete, or Correct

To exercise the right to know, data portability, delete, or correct described above, please submit a verifiable request to us by either:

Calling us at (877) 825-9772.
Emailing us at privacy@brekki.com.
Visiting https://brekki.com/contact/.

Please describe your request with sufficient detail so we can properly understand, evaluate, and respond to it. You or your authorized agent may only submit a request to know, including for data portability, twice within a 12-month period.

Verification Process and Authorized Agents

Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or correct related to your personal information. If your minor child is our consumer, you may also make a verifiable request on their behalf. We may request specific information from you or your authorized representative to confirm your or their identity before we can process your right to know, delete, or correct your personal information.

We cannot respond to your request to know, delete, or correct if we cannot verify your identity or authority to make the request and confirm the personal information relating to you. We will only use personal information provided in the request to verify the requestor’s identity or authority to make the request.

For requests to limit or opt-out, we ask for the information necessary to complete the request, which may include, for example, the consumer’s name, email address, or account username.

Responding to Your Requests to Know, Delete, or Correct

We will confirm receipt of your request within ten business days. If you do not receive confirmation within the ten-day timeframe, please contact us at privacy@brekki.com.

We endeavor to substantively respond to a verifiable request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response to your verified email address. Our substantive response will tell you whether or not we have complied with your request. If we cannot comply with your request in whole or in part, we will explain the reason, subject to any legal or regulatory restrictions. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, deleted, or made your personal information anonymous in compliance with our record retention policies and obligations.

Any disclosures we provide will cover information for the 12-month period preceding the request’s receipt date. We will consider requests to provide a longer disclosure period that do not extend past January 1, 2022, unless providing the longer timeframe would be impossible or involves disproportionate effort.

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.

We do not charge a fee to process or respond to your verifiable 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.

Response and Timing on Rights to Limit or Opt-Out

In response to your request to limit or opt-out, we will process your request, as soon as feasibly possible, but no later than 15 business days from the date we receive the request. We will only use personal information provided from your request to comply with the request.

We may deny opt-out requests if we have a good-faith, reasonable, and documented belief that the request is fraudulent and will clearly explain our denial decision to the requestor.

Once you make a request to limit or opt-out, we will wait at least 12 months before asking you to reauthorize personal information sales or sharing. However, you may change your mind and opt back in at any time by:

Privacy Policy Changes

We reserve the right to update this Privacy Policy at any time. If we make any material changes to this Privacy Policy, we will update the policy’s effective date and post the updated policy on our website at www.brekki.com/privacy-policy/. We encourage you to check our www.brekki.com/privacy-policy/ to review the current Privacy Policy in effect.

Contact Information

If you have any questions or comments about this policy, the ways in which we collect and use your information described here, or 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: (877) 825-9772
Website: www.brekki.com
Email: privacy@brekki.com

Postal Address:
Attn: Privacy Officer
Brekki Foods, LLC
50 Foundation Avenue
Ward Hill, Massachusetts 01835

If you need to access this Privacy Policy in an alternative format due to a disability, please contact privacy@brekki.com