Effective: [insert], 2020

1. Scope of this Policy
2. Agreement to Terms
3. Effective Date and Changes to this Policy
4. The Information We Collect
5. Cookies
6. Children’s Privacy
7. How We Use Your Personal Information
8. How We Share Your Personal Information
9. Your Privacy Choices
10. How We Store and Safeguard Your Personal Information
11. Additional Disclosures for California Consumers
12. For Residents of Europe (including the United Kingdom)
13. For Our Canadian Customers
14. Third-party Links
15. Contact Us

1. Scope of this Policy
   Thank you for visiting Friendly Grains, owned and operated by Chef Bobo Brands, Inc. (referred to as “Friendly Grains,” “us,” “our,” “we”). We are committed to respecting privacy rights and concerns and have established and implemented this Privacy Policy to inform users of our website and our customers, of what personal information we collect, and how we use, share, and protect such information. If you have any questions regarding this information or our privacy practices, please see the section entitled Contact Us at the end of this Privacy Policy.
2. Agreement to Terms
   If you do not agree with the terms of this Privacy Policy or our Terms of Use, then you should immediately discontinue use of the Friendly Grains website (the “Site”) and/or our services without providing us any personally identifiable information.
3. Effective Date and Changes to this Policy
   This Privacy Policy is effective as of the date above and will remain in effect until a new policy supersedes it. We may choose to update this Privacy Policy at our discretion, so you should check this page periodically as the terms may change from time-to-time. The most recent version of the Policy will be reflected by the “Effective” date noted at the top of the page. In the event of a material change to this Privacy Policy, we will provide a conspicuous message either through the Site or via an email address associated with your account informing you of the change. Your affirmative consent or continued use of the Site and/or our services will constitute your acknowledgment of this Policy in its current version and your understanding of the terms of this Policy.
4. The Information We Collect
   The types of personal information we collect and process about you can include:
   • Personal identifiers, such as your first and last name, email address, phone number, billing and shipping address, online identifier, Internet Protocol address, unique device identifiers, date of birth, account name and password, social media profile name and review, marketing preferences, correspondence, and payment card or other bank account information;
   • Professional or employment-related information;
   • Internet or other electronic network activity information, including browsing history and search history, and information regarding your interaction with a website application;
   • Commercial information, such as your purchase history;
   • Geolocation information;
   • Characteristics of protected classifications, such as age, race/ethnicity, gender, and marital status;
   • Survey information, when you complete any forms, respond to a survey or questionnaire, or participate in a contest, we collect the personal information you provide; and
   • Inferences drawn from any information to create a profile about you reflecting your preferences or behaviour.
   We collect such personal information directly from you when you visit the Site; submit registration forms, feedback forms, or order forms; participate in a survey or contest; or when you otherwise contact us.

   You are not required to provide all personal information identified in this Privacy Policy to use our Site or to interact with us, but certain functionality will not be available if you do not provide certain personal information. For example, if you do not provide certain personal information, we may not be able to respond to your requests, perform a transaction with you, or provide you with marketing that we believe you would find valuable.

   We may also collect some personal information about you from third-parties, including social media networks, when you post reviews or comments on our social media pages, and third-party e-commerce platforms.
   
   

5. Cookies
   A cookie is a small string of information that a website that you visit transfers to your browser for identification purposes. Cookies can be used to follow your activity while using a website or across websites, and that information helps companies understand your preferences and tendencies, as well as improve and personalize your website experience. Some cookies are necessary to operate a website, while others can be functional, analytical, or used for targeted advertising (as discussed in more detail below). More information about cookies and how they work is available at www.allaboutcookies.org

   Cookies on our Site are generally divided into the following categories:

   • Strictly Necessary Cookies: These are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas. These cookies are session cookies that are erased when you close your browser.
   • Analytical/Performance Cookies: These allow us to recognize and count the number of users on the Site and understand how such users navigate through the Site (e.g., when and which pages are visited, in what order the pages are visited, how long a user may stay on a particular page, and where a user is located). This helps to improve how the Site works, for example, by ensuring that users can find what they are looking for easily. These cookies are session cookies which are erased when you close your browser. For example, we use Google Analytics for this process. For more information about Google Analytics, please visit and Google Analytics privacy. You can opt-out of Google Analytics' collection and use of data generated by your use of the Site by going to Google Analytics' collection and use of data generated.
   • Functional Cookies: These improve the functional performance of the Site and make it easier for you to use. For example, cookies are used to remember that you have previously visited the Site and asked to remain logged into it (e.g., saves your username, password, and/or shopping cart). These cookies qualify as persistent cookies, because they remain on your device for us to use during your next visit to the Site. You can delete these cookies as detailed below.
   • Targeting Cookies: These record your visit to the Site and the pages you have visited and the links you have followed, to recognize you as a previous visitor and to track your activity on the Site and other websites you visit. These cookies qualify as persistent cookies, because they remain on your device for us to use during your next visit to the Site. You can delete these cookies as detailed below.

   You can prevent the use of certain cookies by modifying your Internet browser settings, typically under the sections “Help” or “Internet Options.” If you disable or delete certain cookies in your Internet browser settings, you may still access the Site, however, you might not be able to access or use important functions or features of the Site, and you may, for example, be required to re-enter your log-in details.

   To learn more about certain cookies used for interest-based advertising by third-parties, including through cross-device tracking, and to exercise certain choices regarding such cookies, please visit the Digital Advertising Alliance, Network Advertising Initiative, Digital Advertising Alliance-Canada, European Interactive Digital Advertising Alliance or your device settings if you have the DAA or other mobile application.

   Device Information

   Similar to cookies, we may automatically collect certain information about the device you use to access the Site. For example, we may collect and analyze information such as IP addresses, geolocation information, unique device identifiers, browser types, browser language, operating system, the state or country from which you accessed the Site, and other information about your mobile phone or other device(s). In addition to analytical purposes, this information helps us diagnose problems with our server, administer the Site, and display the content according to your preferences.

   Do Not Track

   Friendly Grains respects your privacy, but we do not alter the information we collect or change the Site upon receiving “do-not-track” signals, as the term appears in Cal. Bus. & Prof. Code §§ 22575(b)(5). For more information about DNT signals, visit.
   
   

6. Children’s Privacy
   The Site is not intended for users under the age of 16. We do not knowingly or intentionally gather personal information about visitors who are under the age of 16. If you are aware of, or suspect that, someone under the age of 16 is using the Site without permission, please notify us immediately by contacting us as detailed below. If you have questions or concerns about the Internet and privacy for your child, we encourage you to check out the FTC Guidelines for protecting your child’s privacy online.
7. How We Use Your Personal Information
   We use or otherwise process your personal information to:
   • Manage your relationship with us;
   • Respond to your inquiries or requests, complaints, and request feedback;
   • Provide goods or services requested by, or reasonably anticipated by, you;
   • Provide you with relevant promotional materials or information about the company, its products, its outcomes, and opportunities to get more involved;
   • Deliver targeted advertising to you;
   • Display your reviews of our products;
   • Administer contests, promotions, or surveys;
   • Analyze your use of the Site;
   • Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible; and
   • Comply with legal requirements.
8. How We Share Your Personal Information

   We share your personal information with the following categories of third-parties, where applicable:

   • Brands of Chef Bobo Brands, Inc., including Ava Organics and Wowza;
   • Advisers and financial institutions, including, legal, tax, auditors, risk and compliance, notaries, and business continuity support services;
   • Service providers and suppliers, including, IT outsourcing, marketing, shipment processing, customer management, and payment processors. In some instances, service providers will be directly responsible to you for their use of your personal information. They may be obliged by law to provide you with additional information regarding the personal information that they hold about you and how and why they process that information. Further information may be provided to you in a separate notice or may be obtained from such service providers directly, for example, via their websites;
   • Agency partners.
   • Site visitors, such as when your profile name is chosen for display as part of the social media news feed on the Site;
   • Advertising networks, including Google Ads, to provide you with relevant marketing;
   • Where permitted by applicable laws, with third-parties in connection with a corporate restructuring, sale, transfer or assignment of assets or business, merger, divestiture, or other changes to the company’s control or financial status (or any of our affiliates); and
   • Government bodies and dispute resolution and law enforcement organizations, as applicable.

   If you have questions about the parties with which we share personal information, please contact us as specified below.
   
   

9. Your Privacy Choices
   If you no longer want to receive our newsletter, emails or other marketing communications, you may unsubscribe at any time by following the “unsubscribe” link at the bottom of our emails or by writing to us as detailed below. Please note that you cannot unsubscribe from certain correspondence from us, including messages relating directly to your account or orders.
   
   With exceptions, you may be able to view, amend, or delete your information through your account by logging in with your username and password, or to cancel your account, you can contact us as detailed below. Please note that unless specified otherwise, cancelling your account alone, will not delete your information, and you can re-activate your account at any time.
10. How We Store and Safeguard Your Information
    We maintain reasonable technical and organizational measures to protect personal information from loss, misuse, alteration, or unintentional destruction. Your personal information is only accessible, on a need to know basis, by a limited number of employees who have special permissions. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information as it is transmitted to us. To the extent permitted under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized access by third-parties, or other causes beyond our control.
    
    You play an important role in keeping your information secure. You should not share your username or password for your Friendly Grains account with anyone. If you have reason to believe that your account is no longer secure, please contact us immediately as detailed below.
11. Additional Disclosures for California Consumers
    This section describes how we collect, use, disclose, and/or “sell” (as defined under California law) the personal information of California consumers, and the rights you may have under California law. These disclosures are intended to supplement this Privacy Policy with information required by the California Consumer Privacy Act. We note that the definition of “personal information” in California includes information that identifies, relates to, or could reasonably be linked with a particular person or household.

    To understand what personal information we may have collected about you in the past 12 months, and from where we collected it, please see the section The Information We Collect above.

    We collect this personal information, as further described in the How We Use Your Personal Information section above, to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives.

    We may share such personal information with the third-parties listed in the above section entitled, How We Share Your Personal Information. Below, we have provided more detail regarding the two ways in which we share your personal information: (a) “sales” of information and (b) general disclosures of information for a business purpose.

    “Sales” of Information
    We have marked “sales” with quotation marks because a “sale” under California law broadly includes any disclosure of information in return for any value. This value does not need to be monetary, like in a traditional sale. For example, a “sale” can be when a business provides cookie data that it has collected from its own website to an advertising network that it has hired to promote its own ads—but then the advertising network is able to use the cookie data provided for its own purposes, outside of this particular business relationship.

    In the past 12 months, we may have “sold,” as defined by California law, the following categories of personal information to the following third parties:

    Personal identifiers	· Advertising networks
    Internet or other electronic network activity information	· Advertising networks
    Geolocation	· Advertising networks
    Inferences drawn from any information to create a profile	· Advertising networks

     

    We do not sell, or have actual knowledge of any sale of, the personal information of minors under 16 years of age.

    Disclosures of Information for a Business Purpose

    To manage our business and provide services to you, we sometimes share personal information with third parties. These third parties cannot further collect, sell, or use the personal information we share with them except as necessary to perform our purposes, as instructed by us.

    In the past 12 months, we may have disclosed the following categories of personal information to the following third parties for our operational business purposes:

    Personal Identifiers	· Chef Bobo Brands · Advisors and financial institutions · Suppliers and service providers · Agency Partners
    Professional or employment-related information	· Chef Bobo Brands · Advisors and financial institutions
    Internet or other electronic network activity information	· Suppliers and service providers
    Commercial information	· Suppliers and service providers
    Geolocation information	· Suppliers and service providers
    Characteristics of protected classifications	· Suppliers and service providers
    Survey information	· Chef Bobo Brands · Suppliers and service providers
    Inferences drawn from any information to create a profile	· Suppliers and service providers

     

    Your Rights

    Under California law, you have a right to notice, upon collection, of the categories of personal information collected and the purposes for which the personal information will be used. You have the right to access a copy of the categories and specific pieces of personal information about you that we collect, use, disclose, and/or sell, and the right to ask us to delete/anonymize your personal information, with limited exceptions. You also have the right to opt-out of the sale of your personal information. Finally, you have the right to be free from discrimination for exercising your rights.

    You may exercise your right to opt-out of “sales” by clicking this link and following the instructions: Do Not Sell My Personal Information.

    If you wish to exercise any of these other rights or have any questions or concerns regarding the processing of your personal information, please contact us at info@FriendlyGrains.com with the subject line “Privacy - CA” so that we can get your email to the right team. We will respond to your request consistent with applicable law.

    Please note, however, before we will be able to process your request for access or deletion of personal information, we will need to properly verify your identity for security purposes. If we possess appropriate information about you on file (e.g., name, phone number, email), we will attempt to verify your identity using that information. If it is not reasonably possible to identify you adequately, we may not be able to respond to your request.

    To use an authorized agent to make a request on your behalf, you will need to directly confirm with us that you provided the authorized agent permission to submit the request and provide us with signed permission for the authorized agent to act on your behalf. You will also need to verify your identity, directly with us.
    
    

    12. For Our European Customers (including the United Kingdom)

    International data transfer.

    We take steps to ensure that we handle your personal information subject to appropriate safeguards. As a US company, most of our operations are conducted in the United States and in order to provide the Site, personal information will be processed in the United States, where laws regarding processing of personal information may be less stringent than the laws in your country. We provide appropriate protections for cross-border transfers as required by applicable law for international data transfers. With respect to transfers originating from the European Economic Area, where applicable, the standard contractual clauses approved by the European Commission are implemented. Where required by such laws, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below.

    Retention of your personal information.

    For personal information that we collect and process for the purposes described above, we typically retain such personal information for no longer than the period necessary to fulfill the purposes outlined in this Privacy Policy, and as otherwise needed to address tax, corporate, compliance, employment, litigation, and other legal rights and obligations.

    Lawful bases for handling your data.

    Where required, we have several different legal grounds on which we collect and process your personal information for the purposes set out in the section above, How We Use Your Personal Information, including: (i) as may be necessary to perform a contract (such as when you choose to purchase Friendly Grains products); (ii) as necessary to comply with a legal obligation (such as when we use personal information for recordkeeping to substantiate tax liability); (iii) consent (where you have provided consent as appropriate under applicable law, such as for direct marketing or certain cookies); and (iv) as necessary for our legitimate interests (such as when we act to maintain our business generally, including maintaining the safety and security of the Site).

    Automated decision-making.

    We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or that otherwise significantly affects you.

    Your Rights

    To the extent required under applicable law, you have the right of:

    • Access. You have the right to request a copy of the personal information we are processing about you, which we will provide to you in electronic form.
    • Rectification. You have the right to require that any incomplete or inaccurate personal information that we process about you is amended.
    • Deletion. You have the right to request that we delete personal information that we process about you, unless, for example, we are required to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
    • Restriction. You have the right to request that we restrict our processing of your personal information where: (i) you believe such data to be inaccurate; (ii) our processing is unlawful; or (iii) we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not want us to delete it.
    • Portability. You have the right to request that we transmit the personal information we hold with respect to you to another data controller.
    • Objection. Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your situation (e.g., direct marketing). We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defense of a legal claim.
    • Withdrawing Consent. If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

    Some rights may be limited, and we may need to retain certain personal information, as required or permitted by applicable law. To inquire about or exercise the rights listed above, at any time, contact us at friendlygrains@chefbobo.com with the subject line “Privacy-EU” so that we can get your email to the right team. We will respond to your request consistent with applicable law.

    If you feel that your request or concern was not satisfactorily resolved by us, you have the right to lodge a complaint with your local data protection authority.
    
    

12. For Our Canadian Customers
    We retain Personal Information for as long as you have an account with us in order to meet our contractual obligations to you and for seven years after that and/or purchase of services to identify any issues and resolve any potential legal proceedings.
    Please contact us at friendlygrains@chefbobo.com with the subject line “Privacy-Canada”:
    • If you wish to access, update, and/or correct inaccuracies in your Personal Information or change your consent preferences (note: we may need to collect additional Personal Information for the purposes of verifying your identity before responding to your request);
    • For information about how our foreign-based service providers process your Personal Information; or
    If you have any questions or complaints about the manner in which we treat your Personal Information.

     

13. Third-Party Links
    In an attempt to provide increased value to our visitors, we may choose various third-party websites (e.g., social media networks, e-commerce platforms) to link to within our Site. We have no control over these linked sites, each of which has separate privacy and data collection practices independent from us. As such, we have no responsibility or liability for these independent policies or actions and are not responsible for the privacy practices or the content of any such websites.
14. Contact Us
    If you have questions or comments regarding this Privacy Policy or our privacy practices, or would like to inquire about or exercise your rights, please contact us at:

friendlygrains@chefbobo.com