Winland Privacy Notice

Effective Date: March 19, 2025


This privacy notice describes how Winland Foods, Inc., and its affiliates (“Company” or “We”) collect and process your personal information through our websites, products, services, promotions, advertising content, marketing emails, social media properties, and other applications or communications that link to this notice (“Services”).

This notice also provides required disclosures under applicable law (see Additional Legal Disclosures section below) and serves as Winland’s Notice at Collection under the California Privacy Rights Act.

Categories of Personal Information Collected

The Personal Information we collect includes:

• Personal Information, such as name, contact information, address, and phone number, that you provide us through your interactions with our Services. This includes information you provide when you subscribe to our marketing communications, register for a promotion, submit feedback, or request help or other customer services.  
• Personal information that you provide when you place an order for our products so we can take and handle orders, deliver products and services, process payments, and communicate with you about orders, products and services, and promotional offers related to your order.
• Records and copies of your communications with us such as your email address or phone number, when you contact us.
• Your responses to surveys that we or our business partners or service providers ask you to complete for our research purposes.
• Your search queries on our Services.
• Information our business partners may request in order to provide you with special offers.
• As you navigate through and interact with our Services, we use automatic data collection technologies, such as cookies, pixels and beacons, to collect certain Personal Information about your equipment, browsing actions and patterns, including traffic data, IP-based location data, logs, the content that you access and use on the Services, your device identifier, IP address, operating system, and browser type. You can control how we use cookies for these purposes by clicking on Your Privacy Choices in the footer of our websites.

If you do not want us to collect this information, please do not provide us your Personal Information by using our Services. If you would like to exercise your privacy choices after we have collected your Personal Information, please review Your Choices About How We Use and Disclose Personal Information below. Note, however, that opting out of certain data collection may impact our ability to provide you certain Services.

How We Use Personal Information
We use Personal Information that we collect about you or that you provide to us to:

• Present to you, improve, and maintain our Services and their content, and any other information, products, or   services that you request from us.
• Maintain the security of our Services.
• Fulfill any other purpose for which you provide it.
• To personalize your experience such as sending you offers from our business partners or service providers.
• Respond to your inquiries and requests for information.
• Provide you with notices about your subscriptions, including expiration and renewal notices.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• Notify you about changes to our Services including when updates to our Services are available.
• In any other way we describe when you provide the information.
• For other purposes with your consent.

How We Share Personal Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. In addition, we may disclose Personal Information that we collect, or that you provide us as described in this Privacy Policy:

• To our subsidiaries and affiliates.
• To enhance your experience when using our Services through our use of third-party cookies and digital trackers as described in the Third-Party Tracking section above.
• To contractors, service providers, vendors, consultants, and other third parties we use to support our business and   who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes   for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other   sale or transfer of some or all of Winland’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Winland about users of our Services is part of the assets transferred.
• To our business partners to market their products or services to you if you have consented to these disclosures. We   contractually require our business partners to keep Personal Information confidential and to use it only for the   purposes for which we disclose it to them. For more information, see  Your Choices About How We Use and Disclose Personal Information.
• To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “Share This”   feature of our Services, we will transmit the contents of that email and your email address to the recipient.
• For any other purpose disclosed by us when you provide the information to us.
• With your consent.
• To comply with any subpoena, court order, law, or legal process, including to respond to any government or   regulatory request.
• To enforce or apply our Terms of Use and other agreements.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Winland, our business   partners, or others. This includes exchanging information with other companies and organizations for the purposes of fraud prevention.

Your Choices About How We Use and Disclose Personal Information
You have choices about the uses and sharing of Personal Information:

• You can set your browser and device to refuse all or some browser cookies, or to alert you when cookies   are being sent. You can choose whether or not to allow our Services to collect information through other tracking technologies. If you disable or refuse cookies, please note that some parts of our Services may not be accessible or   not function properly. You can also manage your cookie settings for non-essential cookies on our Services by visiting Your Privacy Choices in the Website footer.
• Location Information.You can choose whether or not to allow our Services to collect and use real-time information about your device’s approximate location through your device’s privacy settings. If you block the use of location information, some parts of our Services may become inaccessible or not function properly.
• Disclosure of Personal Information for Promotional Offers from Us and Our Business Partners.If you do not wish to have your email address or other contact information used by us to promote our own or our business partners’ products or services, you can opt-out by contacting us at  privacy@winlandfoods.com. You may also Opt-out by replying STOP to an SMS message, or selecting “unsubscribe” from the footer of any email. This opt out does not apply to Personal Information you provided us related to a customer service request or other transaction.
• Disclosure of Personal Information for Third-Party Advertising.We are not in the business of selling the information we collect about you to others and we do not provide information about you to others in exchange for monetary compensation.  However, certain state laws define “sale” as disclosing or making available personal information to a third party in exchange for monetary or other non-monetary valuable consideration, and “sharing” includes disclosing or making available personal information to a third party for purposes of cross-contextual behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, our use of third-party analytics and advertising cookies may be considered “selling” and “sharing” in certain jurisdictions. Based on these definitions, we may “sell” or “share” the following categories of personal information: identifiers; commercial information; location information; Internet and network activity information. You may opt out of this sharing of your personal information through the Your Privacy Choices link at the footer of our websites or by contacting us at  privacy@winlandfoods.com. You can also opt-out of receiving interest-based ads from third parties who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting    DAA Webchoices Browser Check and  NAI Opt Out of Interest-Based Advertising. You can  download the AppChoices app to opt out in mobile apps. 

 

Exercising Privacy Rights. You may contact us to exercise your privacy rights including:

• Request access to Personal Data.
  
  • Request correction of Personal Data.
  
  • Request erasure of Personal Data.
  
  • Object to processing of Personal Data.
  
  • Request restriction of processing Personal Data.
  
  • Request transfer of Personal Data.
  
  • Right to withdraw consent.
  
  If you wish to exercise any of these rights, please email us at privacy@winlandfoods.com.

If you live in the EU/EEA/UK, you also have the right to make a complaint directly to the EU/EEA/ UK Data Protection Supervisory Authority where you reside.

‍
Security of Personal Information
We have implemented measures designed to secure Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect Personal Information, we cannot guarantee the security of Personal Information transmitted through our Services. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Changes to Our Privacy Policy
It is our policy to post any changes we make to this Privacy Policy on this page with a new effective date at the top of the page. Please review this page periodically and prior to submitting your Personal Information to check for any changes.

Our Contact Information
To ask questions or comment about this Privacy Policy or our privacy practices, please contact us at: 

privacy@winlandfoods.com

OR

Winland Foods, Inc
Attn: Data Privacy Officer
2015 Spring Rd. Suite 400 Oak Brook, IL 60523 USA

Additional Legal Disclosures

Information for EU/EEA/UK/Swiss Residents:

If you are a resident of the European Union, European Economic Area, United Kingdom or Switzerland, this section applies to you.

Please refer to the sections above, for a description of how Winland processes your Personal Data, the legal bases for processing, how to exercise your privacy rights and how your data is shared and protected.

As described above, we share Personal Data within Winland including our subsidiaries and affiliates and with contracted service providers to provide our Services to you. This will involve transferring your data outside the EU/EEA/UK and Switzerland to the United States and other jurisdictions that may not offer the same level of protection to your Personal Data under the law. In these instances, we continue to protect your Personal Data in accordance with your home country’s legislation through the use of Standard Contractual Clauses approved for use in the EU/EEA/UK and Switzerland.

Information for California Residents:

If you are a resident of California, this section applies to you.

We are required to provide you a list of personal information categories collected in the last twelve (12) months in accordance with the CCPA as follows:

• Contact Information and Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, phone number, account name, or other similar identifiers.
• Commercial Information, including records of products and services purchased and purchasing history.
• Usage Data, including internet or other electronic network activity information, such as information about how you interact with our services or advertisements.
• Audio, Electronic, Visual, Thermal, Olfactory or Similar Information, including photographs you may send us or post to our Services or social media properties and voice recordings when you call us.
• Approximate Location, including as inferred from your IP Address.
• Employment History, including professional or employment-related information if you are a job applicant.
• Education Information, including information about education history or background if you are a job applicant.
• Protected Classifications, characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability and citizenship status if you are a job applicant who chooses to voluntarily provide this information for our Equal Employment Opportunity reporting.
• Inferences drawn from any of the information identified above reflecting your preferences and characteristics.

‍
Use of CCPA Personal Information
We may collect, use, share or disclose the Personal Information we collect for the purposes described above in the How We Use Personal Information section.
‍
Sharing CCPA Personal Information

In the past twelve (12) months, we have shared Personal Information about you by disclosing it to a third party for a business purpose as described above in the How We Share Personal Information section.

We do not sell your personal information, so we do not offer a “Do Not Sell” opt out. In some cases, we disclose pseudonymized device and browser information and information about your interactions with our Services with third-party advertising networks to deliver personalized ads to you and measure their performance. To opt out of disclosure of this information, please visit Your Privacy Choices in the footer of our Services and adjust your cookie settings for advertising.

CCPA Personal Information Retention

Please see review the Data Retention section for information regarding how Winland retains personal information. In some circumstances we will anonymize Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

CCPA Rights and Choices

The CCPA provides California residents with specific rights regarding Personal Information. Please see the Privacy Rights section above for information on how to exercise these rights.

CCPA 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 the value of the Personal Information 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. Winland does not currently provide any financial incentives.

Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at  privacy@winlandfoods.com.