CA Privacy

Privacy Notice for California Residents

Last Updated: 07/24/2024

1. Introduction

This Privacy Rights Act Notice (“California Notice”) provides additional information to California residents whose Personal Information is collected by us pursuant to California law, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). If you are not a California resident, this California Notice does not apply to you. Please visit our Privacy Policy (“Policy”) at https://www.torani.com/privacy for more information. Any capitalized terms undefined in this California Notice have the same definition as the Policy.  

2. Information We Collect

This Policy applies to our offline and online data collection practices, including when you visit our website at www.torani.com (Website”), inquire about our services, or when you engage or communicate with us via email or other methods both offline and online. Torani 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”). Within the past 12 months, we have collected the categories of Personal Information about California consumers as described in Annex 1 to this Notice. To review these categories click here: Annex 1. 

In particular, our Website has collected the following categories of Personal Information from its consumers within the last twelve (12) months: 

Category
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 (general location of your computer) using geolocation and other technology.
 

Business-to-Business (“B2B”) Information 

If you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship, you have the same rights as other consumers set forth in this Notice with respect to the information we collect from you in that role.  We collect the contact information you provide to us, including name, phone number, address, email address and other contact and relationship information and communications consistent with your role in facilitating that business relationship.  We use that information for internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship.  We do not disclose that information outside our business relationship without your consent.  For more details see Annex 1. 

3. Information Sold or Shared 

As explained in Annex 1 of this Policy, we share your data with third-party partners such as social networking sites and advertising companies in order to serve you with ads tailored to your preferences across various platforms.  This type of sharing may be considered “selling” or “sharing” under the CPRA. You can control the information shared about you and request an opt-out as explained below.   

We have sold or shared the following categories of Personal Information for a business or commercial purpose in the preceding 12 months. 

·         Personal Identifiers  

·         Commercial Information  

·         Internet Activity 

 
We have disclosed the following categories of Personal Information for a business or commercial purpose in the preceding 12 months:   

·         Personal Identifiers  

·         Commercial Information  

·         Internet Activity 

 

We do not knowingly sell the personal information of individuals under 21 years of age without affirmative authorization. 

For details regarding the categories of third parties with whom we have shared, sold, or disclosed Personal Information, please see Annex 1. 

 

4. Your Rights and Choices and How to Exercise Them  

The CCPA provides California consumers 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 to you the following Personal Information we collect about you: 

·         categories of Personal Information collected; 

·         categories of sources of Personal Information collected; 

·         the business or commercial purpose for collecting or selling Personal Information; and 

·         the categories of third parties with whom we share Personal Information; and the specific pieces of Personal Information we have collected about you over the past 12 months.  

 

You also have a right to know if we have sold, shared, or disclosed your Personal Information for a business purpose over the past 12 months and, if so, the categories of Personal Information sold, shared, or disclosed and the categories of third parties to whom the Personal Information  was sold, shared, or disclosed, along with the business or commercial purpose for which the Personal Information was sold, shared, or disclosed. 

To make a request for any of the information set forth above (a “Request to Know”), please submit a verifiable consumer request pursuant to the instructions below. You may only make a Request to Know twice within a 12-month period. To make a Request to Know, please submit a verifiable consumer request pursuant to the instructions here [link to “Making a Rights Request” section].   

RIGHT TO KNOW SENSITIVE PERSONAL INFORMATION COLLECTED 

We do not collect or process sensitive personal information for the purpose of inferring characteristics or for any purposes other than those set forth in Regulations Section 7027(m).

RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION 

You have the right to request the deletion of your Personal Information collected or maintained by us (“Request to Delete”), subject to certain exceptions permitted by law.   To make a Request to Delete, please submit a verifiable consumer request pursuant to the instructions here [link to “Making a Rights Request” section].   

 RIGHT TO CORRECT 

You have the right to request that we rectify inaccurate information about you.  To make a Request to Correct, please submit a verifiable consumer request pursuant to the instructions here [link to “Making a Rights Request” section].   

 

RIGHT TO OPT-OUT OF SALE OR SHARING OF PERSONAL INFORMATION 

You have the right to opt-out of the sale or sharing of your Personal Information by Torani. As explained in Annex 1 of 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 “selling” or “sharing” under the CPRA. You can control the information shared about you and request an opt-out as explained below. We will process your Request to Opt-Out of sale within 15 days.  To make a Opt-Out Request, please submit a verifiable consumer request pursuant to the instructions here [link to Opt – out of sale and sharing]   

Opt-out Preference Signals  

We have implemented technical measures to honor opt-out preference signals that you enable, including a Global Privacy Control. Opt-out preference signals are plug-ins available in certain browsers that signal to websites you visit of your preferences to opt out of the sale and sharing of certain Personal Information. In order to process your request through an opt-out preference signal, you must use a browser supporting the preference signal. If you choose to use an opt-out preference signal, you will need to turn it on for each browser and each device you use. If you have enabled a valid opt-out preference signal device from your browser, we will not sell or share your Personal Information without first seeking your explicit consent.

This California Notice along with the Torani Privacy Policy do not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third-parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third-parties to learn about their privacy practices.

Cookies 

As explained in our Privacy Policy, you can opt out of cookies using your browser.  Please Note: 

·         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 OR SHARING 

In addition to the above options to opt out of the "sale" or “sharing” 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. 

Advertising Opt-Out 

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. 

X formerly known as Twitter. To understand more about X's Personalized Ads and marketing and exercise your privacy options, please visit: https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads. You can learn more about Twitter's privacy practices and policies by visiting their Privacy Policy page at https://twitter.com/privacy. 

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[0]=Instagram%20Help&bc[1]=Managing%20Your%20Account. 

 

Email/Text Marketing

If you no longer wish to receive email marketing communications from us, you may unsubscribe from receiving marketing-related emails by using the unsubscribe method provided in our communications (e.g., by clicking on the “unsubscribe” link in the email to unsubscribe). Please note that unsubscribing from our promotional material will not prevent us from contacting you for other reasons, such as order confirmations, responses to customer service inquiries, or information about an event for which you have registered.

Alternatively, to the extent that applicable law requires your prior opt-in consent to receive marketing and promotional emails, we will ask for your consent and you can choose not to opt-in.

You may also choose to participate in certain text or SMS/MMS marketing. If you opt in to such marketing, we may collect and use certain personal information, including phone number, email, product browsing behavior, purchase behavior, device type, cellular carrier, and location to contact you and provide you marketing communications or promotions. To learn more, please visit Torani’s Terms and Conditions. [link to T&C]

 

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. 

 

RIGHT TO ACCESS INFORMATION ABOUT AUTOMATED DECISION MAKING AND THE RIGHT TO OPT-OUT OF AUTOMATED DECISION MAKING 

You can request access to information about automated decision making processes Torani uses and you may request to opt out of certain automated decision making. To inquire about automated decision making, please email us at DPO@torani.com.

 

5. Making a Rights Request 

You can make a Rights Request in the following ways: 

·         Enter your request here.   [1] 

·         You may make a request here: DPO@torani.com. 

·         You may also make a request by phone by contacting us at +1 800 775 1925. 

 

We will acknowledge your Request within 10 days and will attempt to respond substantively within 45-90 days.

You must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request.  If we cannot verify your identity, we will not be able to respond to your request.

Once we receive your Request, 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.  You will be asked to provide us with two or three pieces of information that will help us to verify your identity.  We will retain correspondence, documents and information related to any Request to Know, Request to Delete, or Request to Opt-Out for 24 months  as required by law.

6. Notice of Financial Incentive

From time to time, Torani may provide financial incentives to consumers who elect to participate in these programs and, in connection with such programs, allow us to collect and retain certain personal information, such as Identifiers (e.g., your name, email address, or phone number) and Commercial Information (e.g., your purchase history).  These incentives may result in differences in the prices of our products offered to consumers (e.g., discounts and other promotions).  For example, the financial incentives we may provide include discounts based upon purchase activity, discounts in exchange for collection of your personal information, or other periodic discounts for promotional purposes.

The material aspects of any financial incentive will be explained and described in its program terms or in the details of the incentive offer.

Participation in any financial incentive program is entirely optional and participants may withdraw from the program at any time. To opt-out of the program and forgo any ongoing incentives, please follow the instructions in the program’s terms and conditions, or contact us at DPO@torani.com.

The value of your personal information that allows us to make these offers and financial incentives is the value of the offer itself.  Each financial incentive or price or service difference related to the collection and use of personal information is calculated based upon our reasonable, good-faith determination of the estimated value of such information to our business, taking into consideration the value of the offer itself, the expense associated with the offer, and the anticipated revenue generation that may be realized by rewarding brand loyalty and repeat purchases.

 

7. Retention of Personal Information 

We will retain your Personal Information for as long as it is necessary for the purposes set out in Annex 1 and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. 

 

8. 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. 

9. 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 

Because there are not yet common, industry-accepted "do not track" standards and systems, the Website does not currently respond to Do Not Track signals.  In addition, we may allow third parties to collect Personal Information from your activity on our Website, as described in this Notice and the Privacy Policy.   

 

9. 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. 

10. 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 

Email: DPO@torani.com 

Postal Address: Torani, 2000 Marina Blvd. San Leandro, CA 94577 

 
 [1]To Torani, we've included a revised webform for your review too.