Torani Customer Privacy Policy and Procedures

Torani Privacy Policy

Effective date: 9/19/2024

R. Torre and Co. ("us", "we", "our" or "Torani") operates the https://www.torani.com website (the "Service").

This page informs you of our policies regarding the collection, use, and disclosure of Personal Information when you use our Service or otherwise engage with us and the choices you have associated with that data.  This Policy applies to our offline and online data collection practices.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://www.torani.com/terms.

Please note the arbitration provision set forth below, requiring you to arbitrate any claims you may have against TORANI on an individual basis.

Arbitration on an individual basis means that you will not have, and you waive, the right for a judge or jury to decide your claims, and that you may not proceed in a class, consolidated or representative capacity.

U.S. State Privacy Laws 

California state law confers certain rights relating to personal information to its residents. If you are a California resident, please also see our California Consumer Privacy Section in this Policy located at: CA Privacy

Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia state law confer certain rights relating to personal information to its residents. If you are a resident of those states, please also see our Multi-State Consumer Privacy Section. 

1. Consent

By utilizing and interacting with our website, accessing our services, and/or creating an account with us, you are consenting to the collection, use, disclosure, transfer and storage of personal and non-personal information or other information received by us as a result of such use in accordance with this privacy policy.

All personal information may be used for the purposes stated in this Policy.  We may make full use of all information that is de-identified, aggregated, or otherwise not in personally identifiable form. We may also make full use of all user-generated content you submit to us, in accordance with our Terms of Use. 

2. Definitions

Cookies:
Cookies are small pieces of data stored on your device (computer or mobile device).

Data Controller:
Data Controller is any person or organization that, either alone or in combination with others, decides how and why personal data is processed. For purposes of this Privacy Policy, we are a Data Controller of your Personal Information .

Data Processors (or Service Providers):
Data Processor (or Service Provider) is any person or organization apart from the employee of the data controller that processes Personal Information on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User):
Data Subject is any living individual who is using our Service and is the subject of Personal Information.

Personal Information:
Personal Information means any information related to an identified or identifiable natural person.

Usage Data:
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

3. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.  We collect Personal Information using three methods: 1) from you when you choose to voluntarily provide it; 2) using automated technology, including when you visit our Website or interact with our electronic advertisements or communications including through our QR Codes to our mobile-based Website; and 3) using third party sources including but not limited to service providers, entities providing data analysis and analytics, social media and social networking websites and other entities.  To see a complete list of what we collect, how we use this data, please see our Annex 1.

Types of Data Collected

Personal Information. While using our Service, we may ask you to provide us with Personal Information, including certain personal information  that can be used to contact or identify you. This may include, but is not limited to:

Email address
First name and last name
Phone number
Address, City, State/Province, ZIP/Postal Code
Credit card information
Cookies, Web Beacons, and Usage Data
Device ID
We may use your Personal Information to add you to our mailing list so that we may contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by contacting us directly at dpo@torani.com.

Usage Data

We may also collect Usage Data, which may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. Any Usage Data we process is aimed at personalizing the Service to provide you with a more enjoyable user experience, such as via special offers based on your historic purchasing preferences.

Your continued use of the Service indicates your consent to the collection of Usage Data and any other type of automated data processing.

Tracking Cookies Data

We use Cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. We may also use other tracking technologies, such as web beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.
• Marketing, Advertising, and Analytics Cookies. We use marketing, analytics, and advertising cookies to analyze user behavior, tailor advertisements to users based on browsing habits and measure effectiveness of advertisements and marketing efforts.

Use of Data

R. Torre and Co. uses the collected information for various 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.
• 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 and,
• As otherwise specified at the point of Personal Information collection.

4. 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 Messaging Terms and Conditions.

5. Accessing, Correcting and Updating Personal Information

For residents residing in certain states, you have the right to see information we hold about you, with some exceptions which are described in the privacy laws. Residents of those states can review their rights at the CA Privacy section below.

You have the right to see information we hold about you, with some exceptions which are described in the privacy laws. If you would like a copy of your personal information, please contact our privacy officer at dpo@torani.com.

You have the right to review and update your personal details. If for any reason you are concerned that the personal information we hold is not correct, please visit our online services and, after logging into the site using the "Sign In" menu on the home page, your personal information will be made available for review and change in the "My Account" section. Only you or, upon your request, our Customer Care team may access your Personal Information from our online services using your user ID and password. Information may be changed online within “My Account. If you prefer, you may contact us by email at dpo@torani.com and we will amend your personal details.

6. Retention of Personal Information

R. Torre and Co. will retain your Personal Information only for as long as it is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

R. Torre and Co. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

For more information regarding retention of Personal Information see Annex 1.

7. Cross Border Data Transfers 

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside of the United States and choose to provide information to us, please note that we transfer the data, including Personal Information, to the United States and process it there.

Your submission of Personal Information to us indicates your consent to such cross border data transfers.

R. Torre and Co. will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

8. Disclosure to Third Parties

Disclosure of Information for Law Enforcement

Under certain circumstances, R. Torre and Co. may be required to disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Service Providers

We may employ third-party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties will only gain limited access to your Personal Information from us to perform these specific tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Behavioral Remarketing including through Artificial Intelligence

R. Torre and Co. uses remarketing services to advertise on third-party websites to you after you visit our Service. We, and our third-party vendors, may use cookies to inform, optimize and serve ads based on your use of our Service.    

Google AdWords

Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Bing Ads

Remarketing Bing Ads remarketing service is provided by Microsoft Inc. You can opt-out of Bing Ads remarketing by visiting: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads You can learn more about the privacy practices and policies of Microsoft by visiting their Privacy Policy page: https://privacy.microsoft.com/en-us/PrivacyStatement

X (formerly known as  Twitter)

X remarketing service is provided by Twitter Inc. You can opt-out from X's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405 You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy 

Facebook

Facebook remarketing service is provided by Meta Inc. You can learn more about interest-based advertising from Meta by visiting this page: https://www.facebook.com/help/164968693837950 To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217 Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

Pinterest

Pinterest remarketing service is provided by Pinterest Inc. 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: http://help.pinterest.com/en/articles/personalization-and-data You can learn more about the privacy practices and policies of Pinterest by visiting their Privacy Policy page: https://about.pinterest.com/en/privacy-policy 

AdRoll

AdRoll remarketing service is provided by Semantic Sugar, Inc. You can opt-out of AdRoll remarketing by visiting this AdRoll Advertising Preferences web page: http://info.evidon.com/pub_info/573?v=1nt=1nw=false For more information on the privacy practices of AdRoll, please visit the AdRoll Privacy Policy web page: http://www.adroll.com/about/privacy

Links to Other Websites

Our Service may contain links to other third party websites that are not operated by us. If you click on a third-party link, you will be directed to that third-party's site. We strongly advise you to review the privacy policy of every site you visit.

We have no control over, and assume no responsibility for, the content, privacy policies or practices of any third-party sites or services.

Security of Information

We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. No method of transmission over the Internet, or method of electronic storage, is 100% secure. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

9. Children’s Privacy

Our Service does not address anyone under the age of 13.

We do not knowingly collect personal information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children without verification of parental consent, we take steps to remove that information from our servers.

10. Arbitration; Claims Must be Brought on an Individual Basis

By using the Service, you agree that any dispute in any manner arising out of or relating in any way to this Privacy Policy, its enforcement or interpretation, or because of an alleged breach, default, or misrepresentation in connection with any of its provisions, shall be submitted to binding arbitration with Judicial Arbitration and Mediation Services, Inc. ("JAMS") in the San Francisco, California area. ARBITRATION MEANS THAT YOU WILL NOT HAVE AND YOU WAIVE THE RIGHT FOR A JUDGE OR JURY TO DECIDE YOUR CLAIMS. Rights to the prehearing exchange of information and other discovery, as well as appeal rights, are more limited than were you to sue in court.

This arbitration provision is equally binding on claims brought by us as on claims brought by you or others. Arbitrations will be conducted under the applicable JAMS rules. The parties to arbitration will have all the same claims, legal rights, and remedies in arbitration that would be available in court. A single neutral arbitrator shall be selected in accordance with the JAMS Streamlined Arbitration Rules, which shall provide you a reasonable opportunity to participate in the arbitrator selection. It is further agreed that any disputes as to whether the scope of this arbitration provision covers the claim will be submitted to the arbitrator, and not a court, for decision. The parties to arbitration will have full right to use legal counsel at their own expense. All costs of arbitration (including arbitrator fees) shall be paid by us, except if you bring the arbitration, you may be charged an initial filing fee that shall not exceed the filing fees that you would incur for bringing an action in court. You will not be required to pay fees and costs incurred by the opposing parties if you do not prevail in arbitration. In arbitration, the parties may conduct reasonable discovery and shall reasonably exchange non-privileged information relevant to the dispute. The arbitrator's award shall be in writing and provide a written statement of the essential findings and conclusions. The arbitrator will not have the power to commit any error of law or legal reasoning, and the award may be vacated or corrected on appeal to a court of competent jurisdiction for any such error. As an exception to this arbitration provision, no one subject to the provision will be precluded from seeking remedies for disputes or claims less than $10,000 in the aggregate that can be brought in a court of competent jurisdiction.

ANY ARBITRATION SHALL BE CONDUCTED ONLY ON AN INDIVIDUAL BASIS AND NOT IN A CLASS, CONSOLIDATED, OR REPRESENTATIVE CAPACITY. It is expressly understood and agreed that neither you nor we are entitled to arbitrate or bring any dispute covered by this arbitration provision as a class, consolidated, representative, collective, or private attorney general action, and the arbitrator(s) will have no authority to proceed on a class, consolidated, representative, collective, or private attorney general action basis. This means:

You cannot bring a claim as a plaintiff or class member in a class action, consolidated action or representative action.
The arbitrator cannot combine more than one person’s claim into a single case, and cannot preside over any consolidated, class or representative arbitration proceeding (unless we both agree to change this).
The arbitrator's decision or award in one person’s case can only impact the person who brought the claim, not other TORANI customers, and cannot be used to decide other disputes with other customers.
If any part of the agreement to arbitrate in this section is found unenforceable, the unenforceable term will be severed and the remaining arbitration terms will be enforced (but in no case will there be a class, representative or private attorney general arbitration). In the event that any of the class action restrictions are ever deemed illegal or unenforceable, the illegally deemed or unenforceable restriction(s) shall be severed from this arbitration provision, and any class action shall be exempted from this arbitration provision and brought in court. This arbitration provision is subject to the Federal Arbitration Act, and may be enforced in any court of competent jurisdiction.

11.  How to Contact Us

For information and questions about the use of your personal information or this Privacy Policy, you may contact us in the following ways:

Phone: +1 800 775 1925 

Email: dpo@torani.com 

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

12. User Content

As between you and us, you own all content and information you post or share using our website at www.torani.com (“Website”)or tagging Torani, such as posting or sharing comments, photos, and videos (referred to as “User Content”).

You give Torani permission to use your User Content as follows: you grant Torani and its affiliates and its international import partners a license to reproduce, display, perform, distribute, create derivative works from and otherwise use your User Content in connection with the Website and for other Torani marketing purposes, including without limitation in Torani emails, social feeds, website and other communication material. We may display advertisements in connection with your User Content or on pages where your User Content may be viewed by you or others, and we may use your User Content to advertise and promote Torani or the Website. Our license to your User Content is non-exclusive, meaning you may use the User Content for your own purposes or let others use your User Content for their purposes. Our license to your User Content is fully-paid and royalty free, meaning we do not owe you anything else in connection with our use of your User Content. We may exercise our rights under this license anywhere in the world. Finally, our license is perpetual, meaning that our license lasts for an indefinite period of time.

You promise that:

you own all rights to your User Content or, alternatively, that you have the right to give Torani the rights described above;
you have paid and will pay in full any fees or other payments that may be related to the use of your User Content; and
your User Content does not infringe the intellectual property rights, privacy rights, publicity rights, or other legal rights of any third party.
We may refuse to accept or transmit User Content for any reason. We may remove User Content from the Sites for any reason.

If you believe that a user of the Website has infringed on your intellectual property rights, or if we have taken down your materials due to suspicion of copyright infringement, and you would like to dispute the alleged infringement, please click here to notify us.

13. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our website, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

 

CA Privacy

Privacy Notice for California Residents

Last Updated: 09/19/2024

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 by calling 1 800 775 1925 or by sending an email to dpo@torani.com

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 by calling 1 800 775 1925 or by sending an email to dpo@torani.com

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 by calling 1 800 775 1925 or by sending an email to dpo@torani.com

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 by calling 1 800 775 1925 or by sending an email to dpo@torani.com

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://x.com/en/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. 

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.
• 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 

MULTI-STATE (COLORADO, CONNECTICUT, , MONTANA, OREGON, TEXAS, UTAH, VIRGINIA) CONSUMER DATA PROTECTION ACT NOTICE 

This Multi-State Notice (“Multi-State Notice”) provides additional information to Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia residents whose Personal Information is collected by us pursuant to the respective state laws, including the Colorado Privacy Act, Connecticut Data Privacy Act, Montana Consumer Data Privacy Act, Oregon Consumer Privacy Act, Texas Data Privacy and Security Act, Virginia Consumer Data Protection Act, and Utah Consumer Privacy Act.  Please see our Privacy Policy (“Policy”) for more information. Any capitalized terms undefined in this Multi-State Notice have the same definition as the Policy.  This Multi-State Notice is applicable to all the identified states unless there is a state-specific provision identified. 

1. Your Rights and Choices and How to Exercise Them  

RIGHT TO KNOW  

You have the right to request that we disclose to you the following information about Personal Information we collect from you: 

• categories of personal information collected;
• categories of sources of personal information collected;
• to confirm if we are processing personal information; 
• the business or commercial purpose for collecting or selling personal information;
• the categories of third parties with whom we share personal information; and
• the specific pieces of personal information we have collected about you. 

You also have a right to know if we have sold or disclosed your Personal Information for a business purpose 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. 

Information Collected 

We have collected the  categories of Personal Information about Virginia consumers as described in this Notice in Annex 1. To review these categories, click here: Annex 1. 

Sensitive Personal Information

Under applicable laws, consent is required for the processing of certain sensitive personal information.  We do not process, use, or disclose  sensitive personal information under the applicable laws of the Multi-State Notice.  In the advent of any changes, we shall obtain your consent prior to the collection of any sensitive personal information as defined under applicable law.

RIGHT TO OPT-OUT OF SALE OF PERSONAL INFORMATION 

You have the right to opt-out of the sale of your Personal Information. The applicable laws generally define the “sale” of personal data as the exchange of personal data for monetary consideration by a controller to a third party. As explained in Annex 1 of this Policy, we and our third-party partners such as 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 is not considered a “sale” under the applicable laws. If our practices change we will make sure to inform you regarding any sales of your information.  

Cookies 

As explained in our “Cookies“ section, 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 vendors that host our Site, 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. 

RIGHT TO NON-DISCRIMINATION FOR EXERCISING CONSUMER PRIVACY RIGHTS 

You have the right not to receive discriminatory treatment for exercising your privacy rights conferred under Virginia, Colorado, Utah, and Connecticut law, including by exercising the rights specified herein. As the Right to Non-Discrimination is effective across the board, there is no specific “request” that you need to make in order to exercise this right. 

RIGHT TO OPT OUT OF DATA PROCESSING FOR TARGETED ADVERTISING OR PROFILING PURPOSES

You have the right to opt out of the processing of your Personal Information with third parties. To make such a Request, please submit a verifiable consumer request pursuant to the instructions here [link to “How to make a 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 “How To Make A Request” section].    We will attempt to respond substantively within 45-90 days. 

RIGHT TO REQUEST DELETION OF PERSONAL DATA

You have the right to request the deletion of your personal data provided by or obtained about you (“Request to Delete”), subject to certain exceptions permitted by law.  To make such a Request, please submit a verifiable consumer request pursuant to the instructions here [link to “How To Make A Request” section].   

RIGHT TO DATA PORTABILITY 

You can request a copy of your Personal Information in an easily accessible format and information explaining how that information is used.  

To make a request for your personal information, please submit a verifiable consumer request pursuant to the instructions below. We will attempt to respond substantively within 45-90 days. 

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 we use 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.  

2. How to Make a Rights Request 

You can make a Rights Request in the following ways: 

• Enter your request here.   
• 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.

3.  Appeals 

RIGHT TO APPEAL

If you are a Colorado, Connecticut, Montana, Oregon, Texas, or Virginia resident, you have the right to appeal our decision to deny any of your privacy rights requests above. Within 45 days of receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

You can make an appeal in the following ways:

• Enter your request here.  
• 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 reserve the right to deny appeals in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.

• Colorado residents, if your appeal is denied, you may submit a complaint to the Colorado Attorney General at https://coag.gov/office-sections/consumer-protection/.
• Connecticut residents, if your appeal is denied, you may submit a complaint to the Connecticut Attorney General at https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page
• Montana residents, if your appeal is denied, you may submit a complaint to the Connecticut Attorney General at https://dojmt.gov/about/
• Oregon residents, if your appeal is denied, you may submit a complaint to the Connecticut Attorney General at https://www.doj.state.or.us/consumer-protection/contact-us/
• Texas residents, if your appeal is denied, you may submit a complaint to the Connecticut Attorney General at https://oag.my.salesforce-sites.com/CPDOnlineFormVirginia residents, if your appeal is denied, you may submit a complaint to the Virginia Attorney General at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.

3. Retention of Personal Information 

We will retain your Personal Information for as long as it is necessary for the purposes set out in the Privacy Policy 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. 

 

Notice of Collection, Use, and Disclosure  

See our full Privacy Policy here 

See California Privacy Rights here 

See the Multi-State Privacy (including Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia) Rights here