Privacy Notice for California Residents
Last Updated: 11-16-2020
2. Information We Collect
Our website at www.torani.com ("Website") collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, our Website have collected the following categories of Personal Information from its consumers within the last twelve (12) months:
Personal Identifiers (such as a real name, alias, postal address including zip code, unique personal identifier, online identifier, email, credit card information, date of birth etc.)
Commercial information (such as products and services purchased considered, reviewed or other purchasing or consuming habits, your product preferences).
Internet or other similar network activity (such as IP address, device information, , domain name, browser type and operating system, webpages viewed before and after visiting our Website, time spent on webpages, links clicks, pages viewed within Website, transactions entered into, site-navigation patterns.)
Geolocation data (location of your computer or mobile device using geolocation and other technology such as GPS, Wi-Fi, Bluetooth and cell tower proximity).
Inferences drawn from other personal information.
Torani obtains the categories of Personal Informationlisted above from the following categories of sources:
- Directly from you. For example, when you complete forms or make submissions our Website, sign up for an account on our Website, purchase our products and services; when you contact us in person, by phone or email, or subscribe to our mailing lists or newsletter; or when you access our content or engage with us on social media such as Facebook, Twitter, Instagram, etc.
- Indirectly from you using automated technology such as cookies, web beacons, and pixels. For example, from your mobile or computer device, from observing your online activities, including but not limited to your use of our Website and our social media channels.
3. Use of Personal Information
We may use or disclose the Personal Informationwe collect for one or more of the following business purposes:
- To fulfil 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, process returns, or respond to your feedback regarding our products and services.
- To identify your products, service preferences, and notify you about product recalls or other information regarding the products you have purchased.
- To provide, administer, expand, support, personalize, and develop our Website, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, payments and prevent transactional fraud.
- To provide you with customer service and support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To send promotional communications or special marketing offers about new or additional products, services, and promotions that might be of interest to you (unless you have requested that we not send such communications).
- To enhance, modify, or improve our business, Website, products and services.
- 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 records, testing, research, analysis, and product development, including to develop and improve our business, Website, products, and services and other business purposes.
- To comply with our policies, procedures, and legal obligations, including to respond to law enforcement and government authority requests and as required by applicable law, court order, or governmental regulations, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a change of control of some or all of Torani’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Torani about our Website users is among the assets transferred.
We share your Personal Information with the following categories of third parties:
- Consultants, service providers, and contractors that we use to support our business and operations (e.g. vendors that help with hosting or operating our Website, data-storage vendors, customer service centers, entities that deliver communications on our behalf, and fraud detection service providers) who have agreed to keep the information confidential and use it only to provide the applicable services;
- Data aggregators, marketing affiliates, e-commerce partners including World Pantry.com, and third party companies that assist us with delivery, fulfillment of orders, customer service, communicating with customers regarding products and services that may be of interest to them, data analytics, data research, analyzing website metrics, entities including social networking sites such as Google, Facebook, Instagram, Twitter, Microsoft and Pinterest that assist us with targeted advertising, marketing, and behavioral remarketing;
- Third parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order to respond to governmental and/or law enforcement requests;
- An acquirer or successor-in-interest in the event of a reorganization, merger, sale, change of control, consolidation, joint venture, assignment, transfer or other disposition of all or any part of the business including any negotiation thereof; and
- Third-party advertisers or sponsors of contests, sweepstakes, discounts, and promotions that you enter into on the Website or social networking sites.
5. 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.
Right to Know
You have the right to request that Torani disclose certain information to you about our collection and use of your Personal Information over the past 12 months. The categories of Personal Information we collected about you:
- The categories of personal information we collected about you;
- The categories of sources of personal information collected;
- the business or commercial purpose for collecting or selling that personal information;
- The categories of third parties with whom we share that personal information; and
- The specific pieces of personal information we collected about you over the past 12 months.
You also have a right to know if we have sold or disclosed your Personal Information for a business purpose over the past 12 months and, if so, the categories of Personal Information sold or disclosed and the categories of third parties to whom the Personal Information was sold or disclosed, along with the business or commercial purpose for which the personal information was sold or disclosed.
To learn more about how to exercise your Right to Know, see the section on Exercising Your CCPA Rights.
Personal Information Sold or Disclosed for a Business Purpose
In the preceding twelve (12) months, as described above, Torani has sold the following categories of Personal Information to third parties:
- Commercial information.
- Internet or other similar network activity.
- Geolocation data.
- Inferences drawn from other personal information.
In the preceding twelve (12) months, as described above, Torani has disclosed the following categories of Personal Information to third parties for a business or commercial purpose:
- Commercial information.
- Internet or other similar network activity.
- Geolocation data.
- Inferences drawn from other personal information.
For information regarding the categories of third parties to whom we have sold or disclosed these categories of Personal Information, please review Section 4.
We do not knowingly sell the Personal Information of individuals under 21 years of age.
Right To Delete
You have the right to request that Torani delete any of your Personal Information that we collected from you and retained, subject to certain exceptions permitted by law.
To learn more about how to exercise your Right to Delete, see the section on Exercising Your CCPA Rights.
Right to Opt-Out
You have the right to opt-out of the sale of your Personal Information by Torani. As explained in this Policy, we and our third-party partners, including e-commerce partners such as World Pantry, social networking sites and advertising companies, share your data in order to serve you with ads tailored to your preferences across various platforms. This type of sharing may be considered a "sale" under the CCPA. You can control the information shared about you and request an opt-out.
To learn more about how to exercise your Right to Opt-Out, see the section on Exercising Your CCPA Rights.
Right to Non-Discrimination for Exercising Consumer Privacy Rights
You have the right not to receive discriminatory treatment for exercising your privacy rights conferred by the California Consumer Privacy Act, including by exercising the rights specified herein. Some of the functionality and features available to you may change or no longer be available to you in some instances.
Request to Know and Request to Delete
You can make a Request to Know and/or Request to Delete in the following ways:
- You may make a request here: Right to Delete and/or Right to Know
- You may make a request by calling us at: +1 800 775 1925
- You may make a request by email to DPO@torani.com.
You may only make a verifiable consumer Request to Know twice within a 12-month period.
Once we receive your Request to Know or Request to Delete, we will begin the process to verify that you are the person that is the subject of the request (the "Verification Process"). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. Upon making a request, you should be prepared to provide us with information that will help us to verify your identification. If we cannot verify your identity, we will not be able to respond to your request.
Making a verifiable consumer request does not require you to create an account with us but if you have an account with us, you may make a request through the account. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We will acknowledge your Request to Know and/or Request to Delete within 10 business days and will endeavor to respond substantively to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to additional 45 days), we will inform you of the reason and extension period in writing.
We will retain correspondence, documents and information related to CCPA requests for 24 months as required by law.
Request to Opt-Out
You can make a Request to Opt Out in the following ways:
- You may make a request here – Do Not Sell My Info.
- You may make a request by calling us at: +1 800 775 1925.
We will process your Request to Opt-Out of sale within 15 business days.
- Opt-outs are device and browser based. You must opt out on each device and each browser where you want your choice to apply.
- Opt-outs maybe stored via cookies. If you clear cookies, your opt-out may no longer be valid and you must opt out again where you want your choices to apply.
- We may still share your Personal Information with our service providers that help us perform functions that are necessary for our business such as third party companies that help us with order fulfilment, delivery and shipping, vendors that host our Website, analytics processors, etc. These entities are contractually obligated to keep this information confidential and not use it for any purpose other than for the services they provide to our business.
- You may still receive ads from us that are not tailored to your interests.
ADDITIONAL OPTIONS TO OPT-OUT OF SALE
In addition to the above options to opt out of the "sale" of your Personal Information under the CCPA as described above, you have controls and choices with respect to collection and use of your information by third parties. These are summarized for you below. We do not control or maintain opt-out mechanisms for third party companies and are not responsible for their operation.
You can opt out of sharing your information with third-party companies engaged in targeted advertising including social networking sites such as Google, Microsoft, Instagram, Pinterest and Facebook using the following tools provided through the AdChoices website powered by the Digital Advertising Alliance (DAA): For websites: http://optout.aboutads.info/?c=2&lang=EN. For mobile apps: http://www.aboutads.info/appchoices.
Google. You can opt out of Google Analytics by installing Google's Opt Out browser add on: https://tools.google.com/dlpage/gaoptout and opt out of interest-based Google ads using https://adssettings.google.com/u/0/authenticated.
Facebook. To understand more about Facebook advertising and manage your preferences, please visit https://www.facebook.com/about/ads. Login to Facebook and go to Settings > Ads > Ad Settings (web) or Ad Preferences > Ad Settings (app) for more information.
Pinterest. To understand more about Pinterest’s Personalized Ads, and marketing visit https://policy.pinterest.com/en/privacy-policy#section-choices-you-have-about-your-info. You can opt-out from Pinterest's interest-based ads by enabling the "Do Not Track" functionality of your web browser or by following Pinterest instructions: https://www.pinterest.com/settings/ and updating your "Personalization" preferences. Additional information is available at: https://help.pinterest.com/en/article/edit-personalization-settings.
Microsoft. To learn more about how Microsoft uses your personal information across its products and manage your privacy preferences, please visit: https://account.microsoft.com/account/privacy?refd=account.microsoft.com&ru=https%3A%2F%2Faccount.microsoft.com%2Fprivacy%2F%3Frefd%3Daccount.microsoft.com&destrt=privacy-dashboard. Information on Microsoft Advertising and opt-out choices is available here: https://about.ads.microsoft.com/en-us/resources/policies/personalized-ads.
Instagram. To learn more about Instagram Ads and to exercise your choices please visit: https://help.instagram.com/478880589321969/?helpref=hc_fnav&bc=Instagram%20Help&bc=Managing%20Your%20Account.
7. Authorized Agent
You may designate an authorized agent to make a request on your behalf under the California Consumer Privacy Act. Authorized agents can make requests under the California Consumer Privacy Act by emailing us at: DPO@torani.com. We will require authorized agents to provide proof of the consumer’s consent and designation as an authorized agent for purpose of making the request, and will require authorized agents to provide information necessary to verify the identity of the consumer who is the subject of the request. We may also require that a consumer verify his or her own identity directly with us before we respond to an authorized agent’s request.
We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.
8. Other California Privacy Rights
California Shine The Light Law
Under California Law, California residents have the right to request in writing from businesses with which they have an established business relationship, (1) a list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties' direct marketing purposes, and (2) the names and addresses of all such third parties. To request the above information, please e-mail us at: DPO@torani.com or write to us at: Torani, 2000 Marina Blvd, San Leandro, CA 94577 with a reference to California Disclosure Information.
We will respond to such written requests within 30 days following receipt at the e-mail or mailing address stated above. If we receive your request at a different e-mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are required to respond to each customer only once per calendar year.
California Do Not Track Notice
10. Changes to Our Privacy Notice
Torani reserves the right to amend this privacy Notice at our discretion and at any time. When we make changes to this privacy Notice, we will post the updated Notice on the Website and update the Notice’s last updated date.
11. Contact Information
If you have any questions or comments about this Notice, the ways in which Torani collects and uses your Personal Information described above, 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: +1 800 775 1925
Postal Address: Torani, 2000 Marina Blvd. San Leandro, CA 94577