Brekki Foods, LLC
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.
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:
- 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;
- 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.
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:
- 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 http://www.allaboutcookies.org/.
MIGHT I ENCOUNTER ANY THIRD-PARTY COOKIES?
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 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.
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
- 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
- Improve 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 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, 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
- 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 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.
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 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 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 firstname.lastname@example.org.
If you want to exercise your rights over your data pursuant to CCPA, GDPR or any similar law, please email us at email@example.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 firstname.lastname@example.org 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 email@example.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 firstname.lastname@example.org.
YOUR CALIFORNIA PRIVACY RIGHTS
Pursuant to CCPA we are providing the following details regarding the categories of personal information about California residents that we have collected (whether online or offline) or disclosed within the preceding 12 months. We may not collect and/or share all of the information listed below from you. What we collect and/or share depends on your relationship with us.
|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|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||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.
|C. Protected classification characteristics under California or federal law.||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, veteran or military status, genetic information (including familial genetic information).||Yes|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes|
|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.||No|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||Yes|
|G. Geolocation data.||Physical location or movements.||Yes|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||No|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||No|
|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)).||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.||No|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||Yes|
We obtain the categories of personal information listed above directly or indirectly from you. For more information see “What Information About Me Do You Collect And How Do You Collect It?”
Personal information as defined in CCPA does not include:
- Publicly available information from government records.
- De-identified 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.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to 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.
- 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.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
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.
Sharing of Personal Information
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.
In the preceding twelve (12) months, we have not disclosed any categories of personal information for a business purpose.
We may disclose your personal information for a business purpose to the following categories of third parties:
- Our affiliates, subsidiaries and affiliated brands.
- Service providers.
- 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.
In the preceding twelve (12) months, we have not sold any personal information for a third party’s commercial purpose or for monetary value however we do disclose personal information for internal business purposes.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see “What Are My Choices?”), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
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. Once we receive and confirm your verifiable consumer we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email us at email@example.com or by reaching us toll-free at (877) 825-9772.
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.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 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 consumer 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.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
California’s “Shine the Light” Law
California law permits customers in California to request certain details about how their personal information is shared with third parties and, in some cases, affiliates, if the personal information is shared for those third parties’ and affiliates’ own direct marketing purposes. We do not share personal information with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. Californians may request and obtain from us once a year, free of charge, information about the personal information (if any) that we disclosed to third parties for direct marketing purposes in the preceding calendar year.
To make a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident, and provide your current California address to which we will send our response. Your inquiry must specify “California Shine the Light Privacy Rights Request” in the subject line of the email or the first line of the letter, and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year.
YOUR NEVADA PRIVACY RIGHTS
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 firstname.lastname@example.org.
HOW CAN I CONTACT YOU?