VENCHI Privacy Policy for California Residents

Effective Date: [10/04/2023]

Last Updated on: [10/04/2023]

This Privacy Policy for California Residents supplements the information contained in Venchi’s Privacy Policy [https://us.venchi.com/privacy-policy] and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.

This Policy does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

Information We Collect

We collect 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 ("personal information"). Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA's scope, like:

personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples	Collected
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.	[YES]
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).	[NO]
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.	[NO]
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.	[NO]

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

Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, from observing your actions on our website.
Third-party sources, For example, from fraud prevention providers, advertising and marketing partners, and data analytics providers.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following purposes:

Provide, maintain, and improve the Services and our products and services.
Process transactions and send you related information, including confirmations, receipts, invoices, surveys, and recall notices.
Personalize and improve your experience on our Services.
Send you security alerts related to your online account and support and administrative messages.

Respond to your comments and questions and provide customer service.
Communicate with you about products, services, and events offered by Venchi and others and provide news and information that we think will interest yo .
Provide and administer our loyalty programs.
Monitor and analyze trends, usage, and activities in connection with the Services and our products and services.
Personalize the advertisements you see on third-party platforms and websites.

Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards.
Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Venchi and others.
Debug to identify and repair errors in our Services.
Comply with our legal and financial obligations.
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 consumers 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 Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company [has] disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

We do not sell personal information. In the preceding twelve (12) months, Company has not sold personal information to the categories of third parties indicated in the chart below.

Personal Information Category	Category of Third-Party Recipients
Personal Information Category	Business Purpose Disclosures	Sales
A: Identifiers.	Service Provider	None
B: California Customer Records personal information categories.	Service Provider	None
C: Protected classification characteristics under California or federal law.	None	None
D: Commercial information.	Service Provider	None
E: Biometric information.	None	None
F: Internet or other similar network activity.	Service Provider	None
G: Geolocation data.	None	None
H: Sensory data.	None	None
I: Professional or employment-related information.	None	None
J: Non-public education information.	None	None
K: Inferences drawn from other personal information.	None	None

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 and Data Portability

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 (the "right to know"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), 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.
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.

The specific pieces of personal information we collected about you (also called a data portability request).

We do not provide a right to know or data portability disclosure for B2B personal information.

Right to Delete

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 (the "right to delete"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information 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.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

We do not provide these deletion rights for B2B personal information.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

Emailing us at venchi-usa@venchi.com
Visiting at https://us.venchi.com/contact-us

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
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.

You do not need to create an account with us to submit a request to know or delete.

However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact venchi-usa@venchi.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (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.

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 our receipt of your request. 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.

Non-Discrimination

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.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

CCPA Rights Request Metrics

Metrics regarding the consumer rights requests we received from California residents from January 1, 2023, to August 31, 2023, appear in the following chart:

Request Type

Received

Granted (in whole or in part)

Denied

Median Days to Respond

Requests to Know

N/A

Requests to Delete

N/A

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on our website and update the notice's effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Venchi collects and uses your information described here and in its Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: us.venchi.com

Email: venchi-usa@venchi.com

Postal Address:

16 W 36th Street, New York, 10018, Suite 901

Attn: Privacy Department

Physical Address:

16 W 36th Street, New York, 10018, Suite 901

If you need to access this Policy in an alternative format due to having a disability, please contact venchi-usa@venchi.com and +1 201 719 5171.

This Privacy Policy explains how Venchi US Inc. and its subsidiaries (“Venchi,” “we,” or “us”) collect, use, and disclose information about you. This Privacy Policy applies when you use our website and mobile application (collectively, our “Services”), shop in our stores, contact our customer service team, engage with us on social media, or otherwise interact with us.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

CONTENTS

Collection of Information

Use of Information

Sharing of Information

Advertising and Analytics

Transfer of Information to the United States and Other Countries

Your Choices

Contact Us

COLLECTION OF INFORMATION

Information You Provide to Us

We collect information you provide directly to us, such as when you create an account, fill out a form, submit a review, make a purchase, communicate with us via third-party platforms, participate in a contest or promotion, request customer support, sign up for our loyalty program, or otherwise communicate with us. The types of personal information we may collect include your name, email address, postal address, phone number, credit card and other payment information, and any other information you choose to provide.

Information We Collect Automatically When You Interact with Us

When you access or use our Services or otherwise transact business with us, we automatically collect certain information, including:

Transactional Information: When you make a purchase or return, we collect information about the transaction, such as product details, purchase price, and the date and location of the transaction.
In-Store Activity: When you shop in our stores, we collect information about your activity through closed circuit TVs for security monitoring.
Device and Usage Information: We collect information about how you access and use our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, search terms entered, and the page you visited before navigating to our Services.
Location Information: In accordance with your device permissions, we may collect information about the precise location of your device. You may stop the collection of precise location information at any time (see the Your Choices section below for details).
Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see our Cookie Policy and the Your Choices section below.

Information We Collect from Other Sources

We obtain information from third-party sources. For example, we may collect information about you from fraud prevention providers, advertising and marketing partners, and data analytics providers.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer that you are looking to purchase certain products based on your browsing behavior and past purchases.

USE OF INFORMATION

We use the information we collect to:

Provide, maintain, and improve the Services and our products and services;
Process transactions and send you related information, including confirmations, receipts, invoices, surveys, and recall notices;
Personalize and improve your experience on our Services;

Send you security alerts related to your online account and support and administrative messages;
Respond to your comments and questions and provide customer service;
Communicate with you about products, services, and events offered by Venchi and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
Provide and administer our loyalty programs;
Monitor and analyze trends, usage, and activities in connection with the Services and our products and services;

Personalize the advertisements you see on third-party platforms and websites (for more information, see the Advertising and Analytics section below);
Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Venchi and others;
Debug to identify and repair errors in our Services;
Comply with our legal and financial obligations; and

Carry out any other purpose described to you at the time the information was collected.

SHARING OF INFORMATION

We share personal information in the following circumstances or as otherwise described in this policy:

We share personal information with vendors, service providers, and consultants that perform services for us, such as companies that assist us with web hosting, shipping and delivery, payment processing, fraud prevention, customer service, and marketing and advertising.
If you post user-generated content on the Services, such as a product review, we share this information publicly on our Services.
We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
We may share personal information if we believe that your actions are inconsistent with our Terms of Service or other policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Venchi, our users, the public, or others.
We may share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
Personal information is shared between and among Venchi and our current and future subsidiaries.
We may share personal information with your consent or at your direction.

We may also share aggregated or de-identified information that cannot reasonably be used to identify you.

ADVERTISING AND ANALYTICS

We engage third parties to provide analytics services and serve advertisements on our behalf. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by Venchi and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising targeted to your interests on other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes.

We also work with third parties to serve ads to you as part of customized campaigns on third-party platforms (such as Facebook and Instagram). As part of these ad campaigns, we or the third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.

TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

Venchi is headquartered in the United States, and we have operations and service providers in the United States and other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

YOUR CHOICES

Account Information

You may update and correct certain account information at any time by logging into your account. If you wish to deactivate your online account, please contact us at venchi-usa@venchi.com.Note that we may retain certain information as required by law or for our legitimate business purposes. We may also retain cached or archived copies of personal information about you for a certain period of time.

Location Information

When you first launch the section of our mobile app that collects precise location information, you will be asked to consent to the app’s collection of this information. If you initially consent to our collection of such location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. You may also stop our collection of this location information by following the standard uninstall process to remove our mobile app from your device. If you stop our collection of this location information, some features of our Services will no longer function properly.

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services. For more information about cookies and how to disable them, see our Cookie Policy.

Communications Preferences

You may opt out of receiving promotional emails from Venchi by following the instructions in those communications or by e-mailing a request to venchi-usa@venchi.com. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

If you sign up to receive text messages from Venchi and later want to opt out of receiving these messages, you can reply “STOP” to any text message you receive from us.

Mobile Push Notifications

With your consent, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

If you have any questions about this Privacy Policy, please contact us at venchi-usa@venchi.com.

VENCHI Privacy Policy for California Residents

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