Effective Date: July 1, 2023
This business-to-business policy (this “B2B Policy”) describes how Lactalis Heritage Dairy, Inc. and its subsidiaries and affiliates (collectively referred to as “Lactalis,” “us,” “we,” or “our”) collects, uses, and shares the personal information of California residents who interact with Lactalis as an employee, owner, director, officer, or independent contractor of another company, partnership, sole proprietorship, non-profit, or government agency (collectively, “Entity”). It also explains your rights relating to personal information under the California Consumer Privacy Act, as amended (the “CCPA”).
WHAT PERSONAL INFORMATION WE COLLECT. The types of personal information we obtain about you depends on how you interact with us. When we use the term “personal information,” we are referring to information that identifies, relates to, describes, or can be associated with you or a household. The following are the categories and specific types of personal information that we collect:
Identifiers, including your full name; the Entity you are employed with; your email address; your telephone number; postal or physical address; country; account login information including your username and password.
Personal information described in Cal. Civ. Code § 1798.80(e), including your name, signature, social security number, 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 other financial information.
Commercial and transaction information, including payment/billing information; products purchased; content of and information provided through customer support communications (e.g., recorded customer and technical support calls and stored content of your correspondence with us via our website, chat features, phone calls, and other channels); types of products of interest.
Professional, education or other demographic information, including date of birth; job title; occupation; job function; expertise; the Entity you work for such as, such as the size and industry.
Analytics or other electronic network activity, including IP address; browser; Browser extensions connected to your Adobe accounts.
Internet or other electronic network activity information, including browsing history, search history, and information regarding your interactions with our websites, applications, or advertisements.
Non-precise geolocation data, Non-Precise Geolocation Data: Including information that permits us to determine city and state.
Audio and visual information, including closed-circuit images, and audio recordings as may relate to your job functions.
HOW WE COLLECT YOUR PERSONAL INFORMATION. We collect personal information from various sources, including:
Directly from You: We collect personal information you provide, such as when you make a purchase; contact us; respond to a survey; or sign up to receive emails, text messages, and/or postal mailings.
Automatically by Using Online Tracking and Data Collection Technologies: When you visit our websites, open, or click on emails we send you, or interact with our advertisements, we or third parties we work with (such as Google Analytics) automatically collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third-party libraries, and cookies. This may include the URL of the page you’re visiting and your IP address, which may include details such as your city and state.
For more information, please see Cookies and Similar Online Tracking Technologies section above.
Through Facilities and Other Offline Technologies: We record customer service calls and maintain a transcript of chats for quality assurance and training purposes. We also use Closed Circuit Television or CCTV in our facilities for safety, security, fraud, loss prevention, and operational purposes.
From Our Affiliates: We receive information from other companies within the Lactalis family of companies and affiliates. Our “family of companies” is the group of companies related to us by common control or ownership. Information is disclosed within this “family” as a normal part of business operations.
From our Business Partners: We obtain information from businesses that we have partnered with, such as grocery stores, and other partners we choose to collaborate or work with.
Social Media Platforms and Networks: If you interact with us on social media or use features, such as plugins, widgets, or other tools made available by social media platforms or networks (including Instagram, Facebook, Twitter, Google, YouTube, and Pinterest) in connection with our websites, we collect information that you disclose to us, or that the social media platforms disclose to us. For more information about the privacy practices of those social media platforms, please review the privacy policies and settings of the social media platforms and networks that you use.
Other Sources: We may obtain information about you from other sources, such as data analytics providers, marketing or advertising service providers, fraud prevention service providers, vendors that provide services on our behalf, or publicly available sources. We also create information based on our analysis of the information we have collected from you.
Parties to corporate transactions. As permitted by law, we may receive personal information as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or at transfer, divestiture, or sale of all or a portion of a business or assets.
HOW WE USE YOUR PERSONAL INFORMATION. We collect and use personal information for various purposes, including:
Providing Products and the Services: We use your personal information to provide products you have requested from us on behalf of the Entity, such as to fulfill your orders and/or complete the transactions you request; to process payments on behalf of the Entity; to provide you receipts and order updates; and to send notifications to you concerning purchases, returns, and exchanges.
Communicating With You: To communicate with you, including to obtain feedback from you about products purchased, or to offer products that may be of interest to the Entity.
Onboarding and Maintaining You as a Vendor: To manage our relationship with the Entity you are affiliated with; to arrange business-related travel and manage travel and expense programs; to reimburse you for personal expenses paid (e.g., meals, mileage) for Lactalis business; to manage job duties, evaluate performance, and operate our business; to onboard and enroll you as a vendor or supplier; to provide you with training required pursuant to Lactalis policies; to conduct business with the Entity you are affiliated with.
Marketing and Promotional Purposes: We use personal information for marketing and promotional purposes, such as to send marketing, advertising, and promotional communications by email, text message, or postal mail (such as trend alerts, promotions, and new product launches); to show you advertisements for products and/or services tailored to your interests on social media and other websites; and to administer our sweepstakes, contests, and other similar promotions.
Analytics and Personalization: We use personal information to conduct research and analytics, including to improve our product offerings; to understand how you interact with our websites, advertisements, and communications with you; to determine which of our products are the most popular; to improve our websites, and marketing campaigns; to personalize your experience; to save you time when you visit our Sites; to customize the marketing and advertising that we show you; to understand how you use our Sites; to better understand our customers’ needs; and to provide personalized recommendations about our products.
Security and Fraud Prevention: We use personal information to detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity, including fraudulent transactions; attempts to manipulate or violate our policies, procedures, and terms and conditions; security incidents; and harm to the rights, property, or safety of Lactalis and our users, customers, affiliates, business partners, employees, or others.
Legal Obligations: We use personal information to comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.
Core Business Functions: We use personal information to support core business functions, including to maintain records related to business process management, loss, and fraud prevention; to collect amounts owing to us; and to provide and maintain the functionality of our Sites, including identifying and repairing errors or problems.
HOW WE DISCLOSE YOUR PERSONAL INFORMATION. We disclose personal information to the following categories of recipients and in the following circumstances:
Affiliates: We disclose personal information with our corporate affiliates, including our parent company, sister companies, and subsidiaries. Such corporate affiliates process personal information on our behalf as our service providers, where necessary to provide a product that you have requested on behalf of the Entity, or in other circumstances with your consent as permitted or required by law.
Service Providers: We disclose certain personal information to service providers that perform services to support our core business functions and internal operations including: fulfilling orders; delivering packages; complying with your request for the shipment of products to; sending postal mail, e-mails, and text messages; analyzing customer data; providing marketing assistance; administering our sweepstakes and contests; supporting beacons; processing credit card and debit card payments; investigating fraudulent activity; conducting customer surveys; and providing customer service.
Business Partners: We disclose your personal information with businesses that we have partnered with to jointly create and offer a product or joint promotion. If you decide to obtain a product or service that is offered by these partners, the information you provide will be disclosed to us and them. Their use of your information is not governed by this B2B Policy but by their own respective privacy policies.
Social Media Platforms and Networks: Some of our websites have features such as, plugins, widgets, and/or other tools made available by social media platforms and networks that may result in information being collected or disclosed between us and such parties. Their use of your information is not governed by this Policy.
Public Forums: Some of our websites provide the opportunity to post content in a public forum (such as recipe or product feedback and ratings and recipe exchanges). If you decide to submit information in these public forums, that information will be publicly available.
Legal Process: We may disclose personal information in response to subpoenas, warrants, court orders, government inquiries, or investigations; or to comply with relevant laws and regulations. We may also disclose information to establish, exercise, or protect the rights of our company, employees, agents, and affiliates; to defend against a legal claim; to protect the safety and security of our visitors; to detect and protect against fraud; and to take action regarding possible illegal activities or violations of our policies.
Merger or Acquisition: We may use your personal information in connection with certain corporate events such as a potential merger, sale of company assets, financing, insolvency or acquisition of all or a portion of our business to another company.
HOW LONG WE RETAIN YOUR PERSONAL INFORMATION. Your personal information will be saved only for as long as it is needed for the purposes it was collected. It is difficult to specify the length of time that we will need to keep your personal information, particularly given the many types of personal information that we may hold. In fact, some personal information may be kept for a variety of purposes. We regularly review our need to keep personal information while taking applicable legislation into account. Generally, we save your personal information during our business relationship with you for as long as necessary and for the time needed for tax and book-keeping purposes and other legal requirements. Moreover, we also store personal information to the extent we believe it is necessary to protect our legal rights, interests, and the interests of others. Your personal information may also be stored for a longer period if required by applicable statutory retention periods.
In some circumstances we may de-identify your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Where there are technical limitations that prevent deletion or de-identification, we safeguard personal information and limit active use of it.
HOW WE PROTECT YOUR PERSONAL INFORMATION. Personal Information is maintained on our servers or those of our service providers, and is accessible by authorized employees, representatives, and agents as necessary for the purposes described in this Policy. We maintain reasonable and appropriate physical, electronic, and procedural safeguards designed to help protect your personal information. While we attempt to protect your personal information in our possession, no method of transmission over the internet or security system is perfect, and we cannot promise that information about you will remain secure in all circumstances.
YOUR PRIVACY CHOICES. If you are a resident of California, you also have the right to submit certain requests relating to your personal information as described below.
Right to Know. You have the right to know what personal information we have collected about you, which includes:
- The categories of personal information we have collected about you, including:
- The categories of sources from which the personal information was collected.
- Our business or commercial purposes for collecting personal information.
- The categories of third parties to which we disclose personal information.
- The categories of personal information that we disclosed for a business purpose, and for each category identified, the categories of third parties to which we disclosed that particular category of personal information.
- The specific pieces of personal information we have collected about you.
Right to Delete Your personal information. You have the right to request that we delete personal information we collected from you, subject to certain exceptions.
Right to Correct Inaccurate Information. If you believe that the personal information we maintain about you is inaccurate, you have the right to request that we correct that information.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us.
Right to Opt-Out of the “Sale”. Our use of online tracking technologies may be considered a “sale” / “sharing” under applicable law. Visitors to our Sites can opt out of being tracked by these third parties by clicking on Your Privacy Choices or emailing us at LHD_Privacy@us.lactalis.com with the words “Right to Opt-Out” in the subject line.
Categories of personal information disclosed that may be considered “sale” / “sharing”: Identifiers, Internet or Other Network Activity, Non-Precise Geolocation Data, Commercial Data about the products you have purchased and your use of the Services, Sweepstakes, Promotions & Contests and Inferences.
Categories of third parties to whom personal information was disclosed that may be considered “sale”/ “sharing”: Businesses, Service Providers and Third Parties, such as advertisers and marketing partners, data analytics providers, and social media networks.
The Right to Limit the Use of Sensitive personal information. California residents have the right to limit the use of sensitive personal information. This right is only afforded to individuals if a business uses an individual’s sensitive personal information for purposes not otherwise disclosed and as necessary in order to perform the services or provide products to the individual. We do not use sensitive personal information for purposes other than as disclosed and as necessary to perform services or provide products to you.
Identity Verification. Only you, or an authorized agent may make a verifiable consumer request related to your personal information. The verifiable consumer request must: 1) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of that person; and 2) Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it. We cannot respond to your request to exercise your access, portability, correction and/or deletion rights 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.
Authorized Agent. Residents of California, Colorado, and Connecticut may designate an authorized agent to submit a request on your behalf to access or delete your personal information. To do so, you must: (1) provide that authorized agent written and signed permission to submit such request; and (2) verify your own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf. If you have been designated as an authorized agent to submit a request on behalf of another customer, you must make the appropriate selection when you submit the request.
How to Submit a Request: To exercise any of these rights, please email us at LHD_Privacy@us.lactalis.com, with the words “Exercise My Privacy Rights” in the subject line. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.
Response Timing and Format: We attempt to respond to a verifiable consumer request within 45 days after we receive it. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing within 45 days after we receive your initial request. The response we provide will also provide the reasons we cannot comply with a request, if applicable. For access 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.
Complaints: We commit to resolve complaints about your privacy and our collection or use of your personal information. We ask that you submit your inquiries or complaints to LHD_Privacy@us.lactalis.com.
MANAGING COMMUNICATION PREFERENCES
Email: You can stop receiving promotional emails at any time by clicking on the “unsubscribe” link at the bottom of any promotional email that you receive from us.
Postal Mail: You can stop receiving promotional mail at any time by emailing us at LHD_privacy@us.lactalis.com.
Removing Content from Lactalis’ Public Forums: You can request that we remove content or information that you have posted on a public page on some of our Sites (such as part of a ratings & review by [emailing us at email@example.com.
CHILDREN’S PRIVACY. The Services are intended for a general audience and not directed at children. We do not knowingly collect personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children under the age of 13 If we become aware that a child under the age of 13 has provided us with personal information, we will delete the information from our records. If you are a parent or guardian and believe we have collected personal information of a child under the age of 13, please contact us at LHD_Privacy@us.lactalis.com.
We do not knowingly “sell,” as that term is defined under California law, the personal information of minors under 16 years old.
CHANGES TO THIS POLICY. We may revise this Policy from time to time and will post the date it was last updated at the top of this Policy. We will provide additional notice to you if we make any changes that materially affect your privacy rights.
CONTACT US. If you have any questions or concerns regarding this Policy, please feel free to contact us at the following email or mailing address. We would be happy to answer your questions or hear your concerns.
Lactalis Heritage Dairy
540 W. Madison Street, Suite 300
Chicago, IL 60661
Attention: Data Privacy Team
9 a.m. – 5 p.m. Central Time, Monday through Friday, excluding holidays.